Public consultation on the draft Standards for RTOs concluded on 31 January 2023. We would like to thank everyone who engaged in the consultation process.
- Date opened
- Date closed
Information about the proposed changes to the Standards for Registered Training Organisations (RTOs) and other reforms to support high-quality training delivery can be found on the Quality Reforms page.
Consultation on the draft Standards for RTOs was undertaken from November 2022 – January 2023. Approximately 900 people participated in online and face-to-face forums, and over 250 online submissions were received. A summary of consultation findings is available below.
Consultation feedback on the draft revised Standards
There was strong support for the structure of the draft Standards, with a general view that the requirements are clearer, more logical, and more user-friendly. Stakeholders were supportive of the move to outcome-based Standards, and the benefits of this approach in enabling diverse RTO types to deliver more flexibly and innovatively.
Stakeholders raised the importance of ensuring the Standards enable a consistent approach to regulation by auditors and provide clear expectations to the sector. Stakeholders also provided constructive feedback around areas in which further guidance could be beneficial and where the draft Standards could be further refined to improve clarity and better reflect the diversity of the sector.
There were some concerns raised about the importance of sufficient time for RTOs and regulators to be prepared to transition to the revised Standards.
Quality Area One – Training and Assessment
There was general support for the increased focus on the quality of training. Many in the sector thought this area could be further strengthened, possibly through the inclusion of principles for good training.
The inclusion of pre-validation of assessment tools was positively received. However, many stakeholders suggested that an alternative word to ‘pre-validation’ be used for greater clarity. Stakeholder also sought more clarification around how validation of assessment was to be undertaken.
There were also mixed views around the wording in the draft Standards around credit transfer. While many RTOs, especially those that saw themselves as delivering high-risk training products, considered RTO discretion in granting credit to be important, others saw additional discretion as a potential burden on RTOs and a disadvantage for learners.
Quality Area Two – Learner Support
There was general support for the requirements around learner wellbeing. Some RTOs were concerned that the way the draft requirements were written could make RTOs liable for ensuring all learners receive appropriate wellbeing support. There were diverse views about the extent to which RTOs should be responsible for delivering, or referring learners to, wellbeing support services.
While there was general support for the requirement around reasonable adjustments for learners with disability, there was less support for the separate requirement around adjustments for personal circumstances. Some suggested these requirements could be brought together, however noted that in doing so it is important to not dilute the term ‘reasonable adjustments’ which has an established meaning in the context of the Disability Standards for Education.
There were mixed views on the extent to which existing learner competencies (including language, literacy, numeracy and digital (LLND) skills) should be reviewed prior to enrolment or commencement of training. While many RTOs saw this as integral to ensuring learners have the ability to complete the training they are engaged in, others suggested that conducting LLND assessments ahead of time may be unnecessary depending on the training and the timing needs to be carefully considered for some less engaged learners.
There was general support for the need to ensure training delivery is culturally safe. Some stakeholders suggested a more expansive requirement.
Quality Area Three - Workforce
Stakeholders were generally positive about options for broadening the pool of people who can train and assess, including those working under direction and working towards a relevant TAE credential.
There was general support from both larger and smaller RTOs for greater flexibility to enable RTOs to engage industry experts, balanced with caution that there needs to be clear quality controls in place to prevent exploitation or a potential deskilling of the VET workforce. Others suggested that the Standards could provide more definition around industry experts and around the responsibilities of the person providing direction.
There was strong agreement that only those with appropriate qualifications and skills, and qualifications in training and assessment, should be able to make assessment judgements (i.e. determine competency).
Quality Area Four - Engagement
There were mixed views around the need for community engagement. Some in the sector were strongly in favour of this requirement, particularly where their learner cohort requires strong engagement with community. Some suggested an option may be to merge the requirements in this area so that RTOs engage with industry and/or community as relevant to the training product and cohort.
Quality Area Five – Governance
RTOs were generally highly supportive of the inclusion of new requirements relating to leadership and governance and continual improvement. However, stakeholders raised that requirements should not duplicate matters otherwise addressed in other laws (such as work health and safety), that consideration be given to whether ‘management’ is the appropriate term or whether an alternative term should be used (noting the diversity of governance arrangements within RTOs), and that greater clarity is needed regarding what constitutes third parties.
While agreeing that culture is important, some stakeholders queried how this could be evidenced.
Other issues raised
Feedback was also provided by the sector around the burden on RTOs imposed through the transition of superseded training products and the frequency of training product updates. However, there were diverse views around how current arrangements should be amended, with some RTOs seeking the ability to fully teach out existing learners, while others thought the priority should be that learners have the most up-to-date training product.
Stakeholders also raised issues around fee protection arrangements, with many stating the existing $1,500 threshold may not be appropriate, and can be burdensome especially where RTOs are delivering short courses.
The feedback received though public consultation is currently being used to refine the draft Standards.