In the last ten years, Parliament and the federal government have passed a series of laws and regulations designed to standardise higher education and training in Australia. While they do establish national quality benchmarks, they also have made legal operation of a college, university, or training institute more difficult.
Registered Training Organisations, known better as RTOs, are the main institutions providing vocational education training (VET) courses and programmes. All of the nearly 5,000 registered RTOs provide training that meets national quality standards. Only registered providers can deliver nationally recognised courses and accredited Australian Qualifications Framework qualifications. Most RTOs break down into one of two categories: private colleges or Technical and Further Education institutes, also called TAFEs.
Also, providers must successfully register before receiving federal, state, or territory funding.
Registration serves as a huge challenge to higher education and skills training providers. Providers must meet a number of administrative, academic, and governance benchmarks, then provide sufficient evidence that they meet each mandate. Not getting registered is not an option. Registration opens the door to federal assistance to institutions as well as study assist programmes for students.
Few education providers can exist without access to these revenue sources.
Registered Training Organisations have special challenges to face. In most states, they operate primarily under the Australian Skills Quality Authority (AQSA), but many must also adhere to guidelines established by the Tertiary Education Quality and Standards Agency. While Parliament has considered merging the agencies, under the current structure, they comprise dual bureaucracies that have authority over education.
RTOs should not underestimate the challenges and potential problems faced in getting legally registered. When they do, they commonly make mistakes.
Provider institutions looking at registration, especially from overseas, may find distinctions between HEP, VET, TAFE, and RTO confusing. First of all, VET refers to the courses, not the institutions. Any higher education or skills training provider can offer VET courses. All have to make sure that the VET courses have proper registration and meet federal and state standards for skills education.
VET courses cover the following areas
- Basic life skills including, for some, reading and mathematics
- Vocational skills for particular occupations, such as for auto mechanics or carpenters
- Business and office setting training
- Training in other job specific areas with a practical focus, such as hospitality
VET courses can benefit those doing first time training for a skills based career, those upgrading current job skills, or those who want a new career path.
The term Higher Education Providers, known as HEP for short, refers to what most commonly would call a university or college. They offer bachelors and sometimes also graduate degrees. HEPs must comply with TEQSA decisions and guidelines when applying to be on that agency’s national register.
Overseas institutions trying to take advantage of the benefits of national registration may get confused by the distinctions in the system. Acronyms, multiple bureaucracies, state and federal agency authority, and a profusion of regulations make understanding the system intimidating to those unfamiliar with the process.
Even from the very start, institutions can find the process of registration overwhelming.
Getting a VET on the RTO register presents many challenges. First and foremost, AQSA only directly regulates RTOs in Australian Capital Territory, New South Wales, the Northern Territory, Queensland, South Australia and Tasmania. Victoria and Western Australia have direct authority over RTOs in their states, except when they offer online or face-to-face courses in other states or territories. AQSA also has direct authority when RTOs in Victoria and Western Australia train overseas students using student visas.
Victoria’s RTOs adhere to guidance from the Victorian Registration and Qualifications Authority. The body in Western Australia regulating RTOs is the Training Accreditation Council in Western Australia.
Even before applying for registration, the federal government urges institutions to do an honest self-assessment. Institutions need to develop a thorough understanding of the requirements to ensure that they will meet ASQA guidelines. They must also demonstrate financial viability as part of the process.
To register successfully, a provider must meet a number of requirements. First, it must comply with all aspects of the Vocational Education and Training (VET) Quality Framework which, according to the government, include:
- Standards for Registered Training Organisations (RTOs) 2015
- Australian Qualifications Framework
- Fit and Proper Person Requirements that prevent certain disqualified individuals from assuming leading or influential roles in provider administration or faculty
- Financial Viability Risk Assessment Requirements 2011
- Data Provision Requirements 2012.
Other required mandates include:
- Compliance with ASQA standards and cooperation with monitoring authorities
- Payment of registration fees and charges
- Placing courses on the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) when offering courses to those on student visas
- Meet any additional VET related requirements for licensing
- Wait for two years after registration before applying to deliver qualifications or assessor skill sets associated with the Training and Education Training Package
Unfortunately, those looking to get their skills training provider onto the ASQA register will find this list very general. Within most listed requirements come a plethora of other regulations and specific reporting requirements. Institutions unprepared for this reality will most likely falter or fail during the process.
The registration process follows multiple stages, each of which the institution must clear before it moves on to the next. This can take up to nine months.
Many times, institutions fail to follow through with some aspect of the registration process. Often, this involves staff mishandling of the initial application materials. The multitude of requirements combined with the precision reporting necessary can overwhelm administrations unprepared for the process.
Because the application process goes through several steps over a long period of time, unprepared institutions can get lost in the process.
The first step lies in an application completeness check. ASQA will determine if the institution has submitted all proper materials. If not, ASQA notifies the institution and gives it ten days to submit materials properly.
Next comes a risk assessment of administrative leadership and other influential personnel for fitness.
Stage three brings an auditor to campus to ensure that the institution complies with all relevant standards. The audit specifically checks
- functionality of administrative management systems, educational delivery, and other resources
- suitability of facilities and equipment
- credentials of nominated faculty and staff
Any dispute with audit findings must get submitted within 20 days.
Finally, ASQA renders a decision.
With multiple deadlines and stages of examination, unprepared institutions can easily get lost in the process and fail to complete it. Administrators also need to understand their rights in the case of a denial and prepare for that possibility. These rights include:
- Review of the reasons for the decision and right to resubmit.
- Application to ASQA for a reconsideration.
- Apply for an appeal from the Administrative Appeals Tribunal.
Some providers aspiring to get proper ASQA registration have experienced staff who can successfully guide them through the process. Most of these schools have larger student bodies, experienced human capital, and deep resources. Some US or UK-based large scale providers could possibly research and perform the job in house.
While ASQA does have a self registration portal, wise providers seek assistance with the process. Even the government website concerning registration describes it as “a complex process.” Most institutions that have never experienced this process lack the resources and necessary knowledge for proper navigation. Registration requires a team of experienced experts who have done the job before and can guide a provider to success.
Preparing for registration and following through with the entire process require a mighty and costly commitment of personnel and effort. Provider administrations can avoid mistakes that can run up heavy costs by engaging a team of registration experts to prepare them and then guide the school through the process.
Additionally, ASQA does not provide all Australian Administrative Tribunal decisions on its website. A team of experts knows how to search for precedent among AAT cases involving registration issues. Knowledge of case law and its interpretations can help institutions prepare for adverse situations during and after registration.
A team of experts bring a game plan to the registration process. They will evaluate the provider prior to starting the process and recommend changes. Then, the team put together a plan of attack that combines the best possible application, analysis of strengths and weaknesses, and preparation for adverse responses.
Most importantly, seeking registration assistance keeps the administrators free to continue concentrating on the best interests of the students.
Even when schools survive the complex and difficult process, many make the mistake of letting standards go lax and losing their hard won registration. Staff may also lose track of crucial deadlines, such as the requirements to pay fees on time and also to submit for registration renewal.
RTO registration renewal resembles the original application process. It includes a risk assessment that examines high level personnel. The examination could include an assessment of the institution’s finances through the Australian Securities and Investments Commission. If the renewal passes this stage, ASQA may opt to put the RTO through another audit. Audits usually get assigned if examiners find issues in the renewal application.
Findings of non-compliance can lead to revocation of registration and its privileges. The institution has 20 days to prove compliance.
Falling into non-compliance once on the register is no joke. Just last January, Study Group Australia Pty Limited had its registration cancelled for a variety of reasons, including low qualification rate completion.
RTOs should not consider the registration process done when they get approved by ASQA. In some ways, administrators should look at it as an ongoing process. Unfortunately, the view from the inside may not always provide the necessary objective perspective. Administrators may miss negative trends and developments or not appreciate their seriousness in the eyes of ASQA.
Failing to maintain standards and compliance after registration may serve as the most serious mistake RTOs make. Losing a registration means that the institution and its leadership has let down students, faculty, and staff who relied upon the school for a quality education and employment. Registration with ASQA is a permanent and ongoing process that administrators need to take seriously.
Earning and maintaining registration for your RTO is a task worthy of Hercules. You will need to know the strengths and weaknesses of your own institution in the eyes of federal or state regulators. Standards for everything from administrator fitness to academics, to financial viability govern the process and can make or break your school.
Most schools cannot do it alone. That is why Darlo Higher Education exists.
Darlo Higher Education shares a fundamental belief that the Australian Higher education system needs diversity. Private colleges, institutions from overseas, and other forms of skills based education create more competition that pushes everyone to higher standards. We here at Darlo do not want to see good education programmes fail because the staff does not have the expertise to understand how to comply with bureaucratic reporting mandates.
RTOs cannot succeed without proper registration. Let Darlo handle the process from start to finish. Our team of policy, financial, and academic experts can help you prepare for each stage of the registration process. We can advise what changes must be made and work on how to implement them.
Once registered, Darlo Higher Education can continue to advise and assist your administration. Our outside perspective can provide honest and unbiased advice on how to maintain levels of quality that satisfy federal and state standards.
Registration costs providers a great deal in time, effort, and money. Failing to get registered or losing that status will cost even more. Make sure that your skills based education provider can get registered and obtain all the benefits associated. Then, make sure that you are not caught off guard at renewal. Talk to Darlo Higher Education today for more information on how we can help. Email us at firstname.lastname@example.org
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