Navigating New Standards: First Audit Experiences

Ever wondered what your first audit under Australia's new RTO standards might look like? In this revealing conversation, Angela Connell-Richards and Lauren Hollows share candid insights from their recent experiences guiding RTOs through audits under the updated regulatory framework.

The landscape has shifted noticeably. Auditors now place substantial emphasis on governance structures, risk management processes, and inclusivity practices. Both initial registrations and re-registrations reveal a regulatory approach that's evolving but increasingly data-driven. Lauren describes how auditors are spending significant time explaining their quality assurance processes to RTOs, creating greater transparency about how compliance determinations are made.

One striking development is the focus on RTO leadership taking genuine ownership of compliance rather than outsourcing responsibility to consultants. Auditors are directly questioning how providers select their consultants and whether they verify consultants' qualifications – a clear signal that the "RTO in a box" approach is under scrutiny. Meanwhile, for CRICOS providers, PRISMS data management has become a critical audit focus, with regulators examining everything from the timing of non-commencement notifications to deferral processing timeframes.

The good news? RTOs who come prepared can still expect reasonable outcomes. Both Angela and Lauren share examples where providers who could quickly furnish additional documentation when requested demonstrated their readiness to operate compliantly. The key differentiator appears to be responsiveness and preparedness – having compliant assessment tools, well-developed policies, and competent staff already in place before the audit begins.

Whether you're facing initial registration, re-registration, or simply maintaining ongoing compliance, this episode offers valuable perspective on what to expect and how to prepare. Listen now and discover how to position your RTO for succes

 Join host Angela Connell-Richards as she opens each episode with a burst of insight and inspiration. Discover why compliance is your launchpad to success, not a limitation. 

Wrap up with gratitude and guidance. Subscribe, leave a review, and join our community as we continue supporting your compliance journey in vocational education. 

Chapters

• 0:00 Podcast Introduction and Audit Numbers
• 2:01 Initial Registration Experiences
• 4:36 Focus on Governance and Inclusivity
• 6:40 CRICOS and PRISMS Data Management
• 12:23 Comparing Auditor Approaches
• 16:06 Re-registration Process and Audit Readiness
• 18:36 Compliance Red Flags and Closing Thoughts

Transcript

Speaker 1: 0:28

Welcome to the RTO Superhero Podcast. With me, angela Connell-Richards and Lauren Hollows. Welcome back, lauren. Great to have you back on board again. It's been a little while.

Speaker 2: 0:41

Yeah, it's like getting back on a bike with friends, that's right. It's all good, yeah, as long as I'm getting back on a bike with friends. That's right.

Speaker 1: 0:47

It's all good. So in today's episode, Lauren and I thought we would follow on from the theme that Maycheck and I had in our last podcast and discuss our first audit under the new standards. So, Lauren, how many audits have you done so far under the new standards? Yeah, so we've had three. We've had two initial registrations. Um, uh you, how many audits have you done so far under the new standards?

Speaker 2: 1:06

Yeah, so, um, we've had three. We've had two initial registrations um and then also a CRICOS, uh slash, rto, uh uh renewal um re-registration, and then we've just had a couple of interactions um from like compliance monitoring activities that we're continuing on from from, you know, before the financial year.

Speaker 1: 1:28

Yeah, yeah, okay, so we've had one. So we had an initial registration for RTO and CRICOS and it went really well. We provided some additional documentation prior to the audit and we had the opening meeting on a Friday, closing meeting on the Monday and we had registration by the Friday. So I was pretty happy with that. But we've also heard some stories about people who are still waiting to get even called up about an audit because of the training products that they're putting on their scope. But we can talk about that a bit more later. Let's start with what was your experience, because I've already discussed this my case. I'd like to know what your experience has been with the three audits that you've had so far, in particular, any differences between those as well, or consistency. So go for it.

Speaker 2: 2:27

So I mean, look, in terms of registration or re-registration, I think obviously those are always going to be very different experiences, regardless of, you know, the standards that we operate under. The two initial registrations were really. One of the things that I did see was there was a lot of focus on outlining the quality practices that the auditors had to go through. So they spent a lot of time speaking to the CEOs and basically saying this is the process that we're going to go through. I've already reviewed your documentation. Now we're going to have a discussion, then I'm going to take that back, I'm going to write up my final report, then I'm going to sit with another assessor. We're going to go through that report together. If we both come to the same conclusion, we're going to make a referral, then that referral is going to be reviewed and then a decision will be made. So they were really good about communicating the different steps in the process and what would happen, you know, if there was a non-compliance found. Obviously, there was a very strong focus, so they did allow me to participate in all of the audits. However, they were very clear at the very beginning to say we are happy for your consultant to participate in these things. However, you as the CEO, you as the people in the meeting, are actually the ones who are going to be running the RTO. So we want to hear what you say, we want to hear how you are going to run the organization, and I think that was really important.

Speaker 2: 3:58

One of the questions that they got was how did you come to a decision about who you used as a consultant? So that I thought was very interesting, because they basically said like, what process did you go through to determine, you know, who you would use as a consultant? Were they sufficiently qualified? They asked whether or not they checked my qualifications. So I think that's a great practice to see happening, because obviously there are RTO consultants out there that go and kind of sell like RTO in a box. They don't want the client to be really involved in the process. I think you and I operate quite differently from that, where it's like, no, you're going to be the one answering these questions. My role here is to prepare you in how to run your RTO, so watching a lot of those sorts of things come to fruition was really good to see.

Speaker 2: 4:51

Obviously much stronger focus on governance, on risk management, on how they ensured inclusion. So questions like you know, what practices do you have so that you are inclusive? What are your reasonable adjustment processes? You know, do you have processes in place to support your First Nations students and staff? How do you respond to things like sorry business, all of those sorts of things that came more under the new standards, that weren't really covered under our old standards? I thought that there was, I mean, in our ones. There was a lot of focus on that. Again, I think part of that process was because they literally came to us and went your TASs are fine, your trainer matrices are fine and your assessment tools are compliant. Had we had non-compliant assessment tools that we'd submitted, I think the whole audit process would have gone very differently.

Speaker 2: 5:47

In the CRICOS re-registration space, there was a huge focus on PRISMS data, on the management of PRISMS data, on pulling out a lot of different reports and things like that in relationship to you know when your non-commencements were lodged, when your deferrals were lodged, you know if you notified a commencement, you know a week after you were supposed to lodge the commencement. So there's definitely a lot more use of data in terms of the PRISM system happening and I think that we're going to continue to see that focus. So you know, we got a list of, I think about four different types of PRISM breaches and so it was things like you know, you processed a non-commencement. You did it, you know, three days after it was due. You processed a deferral application six weeks after and so we had to go back and demonstrate that, you know a communication process had been put in place, that there was, you know, comms happening to the student In certain circumstances. It was the fact that the student had notified us that they needed a deferral. But getting the actual evidence of the compelling and compassionate circumstances you know, in one case there was a parent that had passed away. Trying to get a death certificate from another country is not an easy process and it took the RTL a while to get that documentation. So we had to provide the evidence of all the emails going back and forth between the students and things like that.

Speaker 2: 7:29

So that has progressively increased in all of my Prisms interactions. When we talk about you know anything in the CRICOS space with Asqua, they're using that data a lot more and I'm actually finding we're having to do more and more training and create more and more like procedures on how we manage Prisms. The Prisms user guide is great, but like really having those checks of you know, like every six months going and checking that the students' addresses are up to date. You know being massively pedantic on noting the commencements and the non-commencements. You know when you're processing the refunds, making sure you're going through all four stages in Prisms of you know when that refund was made, the amount that it was made, the rationale for it and all of that sort of thing you know. Or having all of that data and you know you've got to train admin really well to understand it, which is one of the things that we don't see happening great in the PRISM space.

Speaker 2: 8:32

And in the CRICOS space.

Speaker 1: 8:34

We've seen quite a big focus on PRISMs, more so in the last year, not necessarily under the new standards, but that's very interesting because we're in the process right now of rewriting all of our CRICOS documentation to ensure that it aligns with the standards for RTOs. So we're just going through all of that now. But it was accepted in the last audit that we hadn't mapped those yet, so they were fine. The auditor was fine with that. But, yes, I'm definitely seeing that there's more of an emphasis on how you're implementing PRISMS and they're wanting to see it more in your policies, in your policies and procedures and your handbooks and things like that. So, yeah, yeah. So what was the main differences that you found between? So you had two initial registrations. Was there any differences that you had?

Speaker 2: 9:40

So one was an external auditor and one was an internal auditor, so there was some slight differences in terms of the approval process between one and the other. Um, however, I will say, outside of that, not really um, you know both of the, you know the, the questions that we got. They obviously have like a list of questions against every standard, you know, and they're kind of going okay, ask, ask this question, ask this question. So I'm just, you know, very diligently going every question that ask what asks. I'm writing it down into my big old checklist, um, and you know it's. It's one of those interesting things like do you want to release that list so that you can make sure your clients are prepared? But also, you know, it's probably good for them to not, because you know, if you know your policies and you know the standards, whatever question you get asked you should be able to respond to right. So I'm going to be a bit too minds on that one. I think we're going to. I mean, like in all of the interactions we've had so far under the new standards, the asper assessor has been very clear and kind of going this is all new for us as well. We're still working our way through all of this. We're still, you know, testing and trialing and figuring out what the best way is to approach this because, again, asper didn't write the standards, diwa wrote the standards. Um, asper was then just responsible for interpreting them. So I think that spirit of everything was very good. That's a completely separate process from everything that you know. These teams that are going out and shutting down RTOs and cancelling qualifications are going through those two things. Those two activities are chalk and cheese and different departments too. Yeah, we'll just continue to see. We'll continue to see that.

Speaker 2: 11:40

You know that, depending on how ASQA initially approaches you, you know, and the mechanism through which they approach you, if your first interaction with ASQA is them coming to do a site visit on you and you're supposed to have 62 students on site and you've got three, you know you're going to, you should expect a different process. I'm just going to be honest. Yes, back to my pride and I look, I mean I do like I said. We had a CRICOS registration and I'd actually said to the client I'm like you're in for a rough ride Like this is not going to be easy, and we had three or four interactions with the regulator pre and post the new standards getting logged, with the regulator pre and post the new standards getting logged.

Speaker 2: 12:33

And then one day I got an email notification going traininggov has been updated and your application's been approved, or your application's been approved and traininggov will be updated. I got my notification through AspenNet and I called up a client and I went you've been re-registered, and he goes what? And I went you've got re-registration. He goes what. I was like I'm looking at the email now and he goes cry, cost two. And I was like hold on. And I was like yep, you've got it all. And he was like oh my God. And I was like yeah, yeah, me too. And he was like, oh, that wasn't as hard as you made it sound like it was going to be. I was like, yeah, I know. Like I'm like genuinely shocked dude. I was like look, we gave them more information than they asked for at every step.

Speaker 1: 13:16

Yeah, and I think that really does help. That's what we did with our initial is it said they said if they got any. So they had a list of what they wanted and the units that they wanted to go through and any do you have any other additional documents? So we just did it straight away and we got provided them with all the new policies and procedures, and I think that's the thing is if you can demonstrate that you're prepared and ready you can, you're going to have a much smoother audit, yeah.

Speaker 2: 13:47

And like being able to turn around, like you know, if somebody asks you for, if ASQA comes back. I know, in one of our audits our initials we submitted four assessment tools. They came back to us and they asked us for three additional assessment tools and they were sent through within, you know, 72 hours or something like that. I think little things like that where the regulator tests you and go have you just purchased the four units that you submitted to us or are you actually ready to rock and roll? Yeah, I think little things like that. Maytech had the same.

Speaker 1: 14:23

Yeah, maytech had the same where the auditor asked for other assessment tools. Yeah, yeah, and very interesting that you had that one as well, and also what I found with the auditor we had. She definitely did have a list and she actually said I've got these questions, I've got to ask. So she went back down through the list and just asked all those questions. So, uh, so that was good because it was, um, because she wasn't, uh, focused on just the new standards, but they had actually specifically had a list of things that needed to be covered under the new standards. So, yeah, so it'll be interesting to see.

Speaker 1: 15:06

We've've got about another three that are in for initial and we've got about five who are up for re-reg over the next six to 12 months. So, yeah, it's going to be interesting to see how it goes. Some of the other things that we've seen is re-regs just going through and because they're more focused on other areas, particularly if you've got a low-risk RTO. However, they can just do a pop audit at any time in the next, you know, two years. So just because you get through on your re-reg with no audit doesn't mean it's not going to happen. So I would always be prepared.

Speaker 2: 15:53

Like for me personally, I would prefer to see no registration go through without a desktop, even if the desktop is limited, to send me these five assessment tools, these three TAS and two trainer matrices of your choosing within the next 72 hours, right, or within the next week.

Speaker 2: 16:18

you know, a really little test like that for most RTOs is a really good indicator of whether or not they have their shit together, because you can go and look at their event list and go well, you delivered this assessment tool last, like you delivered that unit in November last year, right. And if they turn around and go, oh well, we don't have that, we don't deliver it. You can turn around and go, you're, you're full of shit. What you don't have is a compliant assessment tool that you want to provide to us, like to me. I would rather see that on every single registration, even if even if it means you're only getting checked once every seven years. Having a person dedicated to doing that would provide a higher level of quality assurance in the sector, and I think that should be part of the ASQANET process.

Speaker 1: 17:11

So when you're submitting your re-reach, you should have to submit your TASAs with it. So and then and I would think then the auditors would have a good idea of whether you'd be ready or not auditors would have a good idea of whether you'd be ready or not.

Speaker 2: 17:31

Yeah, well, I mean you do. I mean you submit that. You submit that spreadsheet which says the units you've deemed competent in the last six months. Yeah, right, so you know, pick, pick three units that they've delivered in the last three months, pick two student files, have them submit that. That'll tell you everything you need. Like I mean, that's how you and I do our audits, I'm sure, like that's what I ask for. And from that you know, like I've just done an audit on a provider.

Speaker 2: 17:54

It took me four times going back to them, like you know, going this is everything I expect you to upload. And from the first day I was like you need to upload your mapping guides, you need to upload your evidence of your assessor competency and currency. But he took a further three emails of me going mate, these are the units I'm auditing. You've given me a mapping guide but no assessment tool. Or you've given me assessment tool but no mapping guide. You've given me a trainer registration but you haven't given me any of their actual documentation for me to see that they've actually got a freaking TAE. Freaking TAE like I should like if I go to any compliance person and say I'm auditing you, put up the documents that I need to audit it. Yeah, and the RTO doesn't know that they need to give me a corresponding mapping guide to the assessment tool and the certificates for their trainers and assessors.

Speaker 1: 18:47

It's a red flag yeah, yeah, yeah, yeah, and it definitely can show where, whether they're ready or not and whether they um. So what I find, when someone uh comes to us for an audit, they know they're non-compliant. They just don't know how non-compliant they are. They don't come to us because they think they're non-compliant. They just don't know how non-compliant they are. They don't come to us because they think they're compliant. So it's very interesting and you can tell by the conversation and by your initial list of documents that you request whether they're going to be ready or not. Yeah, yeah, definitely, all right, so my time has gone up. So thank you very much, lauren, for being here today and sharing with us your valuable insights into what you've experienced so far under the new standards in audit. And, as per usual, it's always a pleasure to have you join me on the RTO Superhero Podcast. Thank you, thanks, angela, have a great day. Thank you, usual, it's always a pleasure to have you join me on the rto superhero podcast thank you, thanks, angela.

Speaker 1: 19:48

Have a great day thank you, there we go awesome.