Quality Reforms Phase 2 ‘RTO Quality‘ Consultation Feedback

Quality Reforms Phase 2 ‘RTO Quality‘ Consultation Feedback

Skills Ministers have committed to strengthening the quality of training delivered within the Vocational Education and Training (VET) sector including through reforms which seek to create a shared understanding of quality across the sector and ensure the Standards for Registered Training Organisations (RTOs) 2015 (the Standards) are more strongly focussed on quality outcomes.

The second phase of consultation on RTO quality was undertaken in August/September 2021. It was targeted at RTOs and focussed on exploring and identifying possible solutions from an RTO perspective to key issues identified in the first phase, which took place between December 2020 and March 2021. These issues included:

  • Industry engagement
  • Student support and wellbeing
  • Learner safeguards
  • Assessment
  • Validation of assessment
  • Recognition of prior learning (RPL)
  • Managing superseded training products
  • Industry currency and professional development
  • Working under supervision
  • Continuous improvement
  • Governance and leadership

Note that consultation was also undertaken around the VET Workforce Quality Strategy separately to the broader feedback on RTO quality. Feedback on the Strategy will be published separately on skillsreform.gov.au.

Key Findings

Industry engagement

Many stakeholders noted that regular and ongoing engagement with employers is more meaningful and effective than ad hoc engagement. From an organisational level, RTOs noted that engagement needs to be strategic and coordinated across the organisation. The increasing use of online platforms for engagement is seen as beneficial as it decreases the time commitment required. However, the 'language of VET' is seen as a barrier in some cases, as employers often do not have a solid understanding of the VET system or how training package requirements are turned into training, or how the regulatory framework operates.

Some RTOs commented that the Standards lack clarity on expectations in terms of employer engagement. However, flexibility needs to be retained, and the Standards need to strike the right balance to ensure that any extra detail is applicable to all RTOs.

Student support and wellbeing

Feedback from RTOs was that they consider supporting students to be central to their role and purpose. It was also noted that there is a strong link between student support and positive student outcomes and completion rates. Stakeholders identified a range of best practice student support strategies, as well as areas that RTOs find challenging.

A key theme was the importance of early identification of support needs, and early intervention when a need for additional support is identified. Many RTOs reported significant benefits with formal pre-training interviews, where learners identify support needs up-front. Another common theme was the need to proactively check in with students and track attendance and learning in an online training environment, as this mode could make student support more difficult.

It was also seen as important to communicate the types of support available to students. Some RTOs suggested that rather than just providing this information to students on enrolment, students should be reminded about the support available at key points throughout their learning journey. Seeking feedback from students, and trainers and assessors, was also seen as important to ensure the support provided was helpful.

Learner safeguards

Most RTOs indicated that accurate student record keeping is imperative, and that there are a range of associated challenges. Many RTOs indicated the Standards could be improved to provide more clarity around minimum requirements for maintaining student records, including guidance on the creation, retention, and destruction of records. It was also noted that some RTOs must comply with various sets of requirements in addition to the Standards, and that these can be inconsistent in terms of record keeping.


As with the first phase of consultation, many RTOs reiterated that the centralised development or quality assurance of assessment tools which could then be contextualised by RTOs could be helpful and enable RTOs to focus more on training delivery and student support. Many RTOs noted that purchasing independently developed resources is costly and that the quality is variable, with some noting that they purchase resources for use as a benchmark, to compare with the ones they have developed.

Stakeholders also noted that the Principles of Assessment and Rules of Evidence in the Standards could be clarified with the use of more precise and clear language.

Validation of assessment

The importance of pre-validation emerged as a key finding with many RTOs noting that it is critical to validate assessment tools before they are used. It was suggested that pre-validation and post-validation could be better differentiated in the Standards.

Some stakeholders suggested the Standards are too prescriptive in relation to validation and that they should be more principles-based or risk-based, while others noted it is important to have a clear minimum requirement. RTOs reported that the 5-year validation cycle is broadly appropriate in terms of a minimum expectation, and that most RTOs would go beyond this. However issues were raised with the 5-year validation cycle including those related to the frequency of change to training products and how that impacts on a 5 year validation schedule.

It was also suggested that the Standards should be clearer about whether a sampling approach is permissible, and many RTOs were of the view that the sampling requirements can be excessive and difficult to understand.

Recognition of prior learning

A key challenge for many RTOs is that RPL is seen as an evidence-driven process. Some RTOs reported that they often gather more evidence than what may be necessary, due to a desire to have sufficient evidence about each RPL assessment and to ensure with absolute certainty that the RPL candidate was competent. To overcome this, it was suggested that guidance could be provided in relation to the evidence expectations, such as templates or clear checklists of evidence required by RPL candidates.

It was also noted that often RPL candidates do not understand the process and that RTOs need to guide RPL candidates through the process. However, despite the time taken, it was strongly believed that closely guiding candidates through the process is best practice, rather than simply providing a list of evidence requirements.

Quality of training

Many RTOs expressed that their main focus is on delivering quality training, which they feel does not have a clear focus in the Standards, nor did they feel the importance of training was necessarily reflected in the Standards. However, there was no broad support for additional regulation of training delivery, a common suggestion was that principles for training delivery be developed.

Some RTOs also suggested the Standards could be updated to be more contemporary in relation to blended and online learning, with some noting that the Standards can be difficult to interpret for RTOs that do not deliver face-to-face training.

Managing superseded training products

Many RTOs reported that the current transition arrangements are administratively burdensome due to the frequency of change in training packages, and that the standard 12-month transition period has, in particular, significant impacts on students already enrolled.

A common suggestion was that the transition period should be varied depending on the industry and the amount of change to the product. However, some RTOs did indicate a preference for a consistent timeframe for transition across training packages, for simplicity.

Industry currency and professional development

The challenge of striking the right balance between clarity of requirements and flexibility for RTOs was evident in the feedback from the sector. Many RTOs consider it appropriate for the Standards to be broad in relation to what counts as professional development and "current" industry skills, with some suggesting even more flexibility should be provided. However, other RTOs suggested more clarity could be provided, particularly around the intersections between vocational competency, industry currency, and professional development.

Working under supervision

Working under supervision arrangements were perceived by some RTOs as being high-risk (both from a quality perspective and a compliance perspective). There were mixed views around whether the requirements in the Standards were clear, however many RTOs suggested more clarity could be provided.

A common view among RTOs was that there is a need to enable industry experts to more easily work in the VET sector, without having to have the full Certificate IV in Training and Assessment, which is seen as too high a barrier. Some RTOs reported only using working under supervision arrangements where the trainer and assessor was currently undertaking their TAE Cert IV. Many RTOs suggested that there needs to be improved options for skill sets for those undertaking different roles within the RTO such as training, assessing or designing.

Continuous improvement

Many RTOs reported using feedback from a range of sources to inform continuous improvement within their organisation. The importance of being strategic in gaining feedback from students to ensure that they are not limited by survey fatigue was also highlighted.

RTOs saw many benefits from sharing information and collaborating with other RTOs. Many RTOs reported cooperating with other RTOs to add significant value through the sharing of best practices, and through working together to find solutions to common challenges. However, for some cooperating with other RTOs was not feasible for various reasons, such as being a niche RTO or due to the competitive nature of the sector.

Governance and leadership

A range of qualities were identified as being important to be an effective RTO leader. There was general agreement that a good leader in an RTO context has a combination of:

  1. A focus on the students
  2. An understanding of the VET sector
  3. Business acumen and leadership skills

Governance and leadership were identified as important elements that contribute to the overall quality of an RTO. However, care needs to be taken in adding requirements into the Standards around governance as it risks duplicating other existing requirements. Active risk management emerged as an area that could be covered more explicitly in the Standards, as well as possibly adopting the requirements in place from other standards or obligations, such as state funding contracts or from VET Student Loan guidelines.

Training packages

The impact of training packages on the delivery of training was noted throughout the consultation process. In particular, the amount of prescriptive detail within some training packages, and the frequency of change of training packages, was identified as having a significant impact on RTOs and students. This feedback will be considered through the qualifications reforms which are currently underway.

Next steps

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