How can we improve RTO / CRICOS initial applications?

In a recent article on our website, I discussed how ASQA has this year made some genuine improvements to its audit processes (although there’s still a long way to go with auditor consistency).

However, the initial registration process and the approach being taken by ASQA remains problematic. Establishing an RTO and/or CRICOS provider is an enormous and expensive undertaking, and I feel that the processes and requirements in place often only serve to make initial applications harder.

Self-assessments and evidence

For a start, the self-assessment that applicants must initially submit is broad. This means that while some documentation is specifically requested, there’s a lack of clarity about how much information applicants should provide.?

This becomes a problem at the validation component of the audit, which is – as per ASQA’s own communications – “not an opportunity to provide new or revised evidence”. Most auditors at this meeting do ask for additional evidence, based on their document review. However, I’ve attended initial audits where the auditor has been clear that they will not accept any new or revised evidence.?

Where is the clarity and consistency? Where does this leave the concept of further evidence?

Evidence revisions

Applicants are barred from making any revisions to submitted documents, which they may have improved while waiting (a long time) for their application to be processed.?

Sometimes applicants find small mistakes or make minor improvements during this waiting period. I understand that allowing full-scale changes is unrealistic, but why can they not address small issues to better their registration??

I also find it arbitrary that applicants cannot discuss the findings from the desk component or audit. They only find out about alleged non-compliances when they receive their report. This is particularly unfair since the performance assessment process is quite different. Issues are discussed throughout the assessment process, with the opportunity for minor revision.

Timeframes for evidence and application waiting times

ASQA now only gives applicants 24 hours to provide their learning and assessment resources. Why such a short timeline? It leaves no allowance for those who may be on holiday, sick or experiencing difficulty accessing documents – for example, because of lockdowns.?

While I appreciate that RTOs are expected to be adequately resourced, the “race against time” mentality doesn’t seem fair. The registration phase is a stressful and busy time for an RTO. ASQA has given a 2-day turnaround in the past – which is much more reasonable. However, I still think that it should be extended to, say, a week.

Further, applicants can wait several months for the regulator to process their application, audit them and finally provide a report and outcome. Because they’re expected to submit their lease and occupancy certificates at the time of application, they may be stuck paying large rents, while unable to operate their business.

From my own experience, applicants often don’t receive their report for at least 2 months after their audit.

So what can be done?

ASQA needs to consider a better way of handling initial applications. While there has been rorting in the past, there are also plenty of genuine applicants who are being disadvantaged by the current process.?

ASQA could start by:

1. Making the self-assessment clearer – defining a minimum number of documents;
2. Allowing all applicants to supply additional supporting evidence during the audit and ensuring that all auditors allow this;
3. Giving applicants more time to submit their evidence to the auditor before their audit;?
4. Incorporating feedback into the process, so that applicants understand non-compliances and can discuss them – possibly having them overturned before the report; and
5. Allowing applicants to make minor revisions to their evidence before the report is processed.

I’d love to hear your thoughts on how ASQA can make the registration process smoother for RTOs.