Ross Woods, 2007. Rev. Nov. '19
The Australian Quality Training Framework (AQTF) was the quality standard for the Australian vocational education sector. It was eventually replaced with the Standards for National Recognition and then the Standards for Registered Trainng Organisations.
The underlying philosophy of the Australian training sector has not changed since then. Some changes in the standards are conspicuous and probably beneficial, but it is uncanny how many of the problems of the mid 2000s have persisted to 2020 with no solution in sight. To some extent, the problems are not totally within the Standards themselves, but in how Registered Training Organizations and auditors interpret them and use them as a basis for program compliance and audits.
This document was first produced in stages with the previous version dated 2007. At that time, auditors' decisions were wildly inconsistent and the training sector had no interpretive document. This document sought to fill the gap and was a collation of audit experiences, professional development sessions, and feedback from reviews, especially Review of the Implementation of the AQTF Standards: Final Report (KPA Consulting, July 2004).
This new version is generally the same and I have made no attempt to update the content. However, the presentation is quite different and some language edits have hopefully made the contents more palatable to the reader.
It is split into two volumes to reduce file sizes. Volume 1 refers to the broader issues of interpretation, while Volume 2 refers to the specific interpretation of individual sections.
Ross Woods
newversion
A new version of the AQTF came into effect on 1 July, 2007 and has been in revision ever since.
The AQTF for RTOs now has only three standards and generally fewer points in each one, but RTOs must continuously improve their performance on all of them. They are:
Besides the three standards, the AQTF also has an expanded section on the conditions of registration, which defines the legal relationship with the state training authority. By their nature, the criteria in this section are generally not subject to continual improvement. They are static and only require compliance.
Three indicators
State Registration Authorities use three indicators to gauge the continuous improvement of RTO performance and establish risk profiles. They are:
According to one auditor, they should be interpreted in context, because they are meaningless on their own. For example, a very high completion rate might mean that the RTO:
Similarly, a very low completion rate might mean that the RTO:
Under the old versions of the AQTF, a site that had no students could be AQTF compliant in that there was nothing to be non-compliant. But now, it can be deemed to be non-compliant in all three standards because it has no outcomes and no improvements.
If an RTO complies with the AQTF this year it will be noncompliant if it just does exactly the same next year. It should have improved across the board. In other words, criteria are now dynamic.
The Australian Quality Training Framework (AQTF) is the Australian national training standard for institutions in the training sector. It comprises two parts: one for the accreditors themselves in each state, and one for Registered Training Organisations (RTOs), e.g. ACAS. This AQTF for Beginners only deals with the section for RTOs.
There are twelve standards for RTOs, each of which is spelt out in many points and (often) sub-points. Depending on how one counts, they come to about 130 rules in all, not including the "evidence guide".
On the whole, the requirements are well-intentioned. In paraphrase, these twelve standards are:
Accreditors are very tough on points 7, 8, 9, which are those most affecting teaching staff: their competence, assessments, and appropriate learning and assessment strategies.
Most organizations have the same basic systems and processes simply to exist, to get things done well, and to be legal:
The AQTF covers almost all these in one way or another. That is, it is a quality system for an organization (or the RTO section of an organization), and most of it equally applies to any organization.
This has several implications: First, AQTF compliance is intended to be a quality measure for how you run the organization. Second, it shouldn't take extra work specifically to comply with the AQTF. Rather, the standard at which an RTO does its business should comply with the AQTF.
This sounds obvious, but one unnamed RTO kept two entirely separate sets of paperwork: one for how it actually ran its business, and the other to demonstrate to auditors how it complied with the AQTF. Auditors saw only the AQTF documents, and never the "real" documents. Ironically, the cause of this unfortunate mess was AQTF auditors who wanted much more paperwork and who could not see how the "real" documents related to AQTF requirements. For the RTO, the extra paperwork (and general angst) related to the AQTF was very burdensome.
In fact, this dual system would almost certainly be non-compliant, because it is hardly "effective" (Standard 4).
However, the AQTF was not meant to be interpreted in this way. It is a quality standard for all the kinds of things a well-managed organization should do anyway.
The AQTF works on several main assumptions:
First, each RTO may be unique. The standards are designed to be flexible enough so that RTOs don't all have to be the same.
Second, quality depends on consultation and consensus. The AQTF often refers to working with particular groups and getting their input and approval. In this sense, quality is what people agree on.
Third, quality depends on explicit standards, especially relating to competency and assessment. In this sense, quality is what can be written down clearly.
Fourth, one pursues quality by seeking to do better. Quality isn't somewhere you finally arrive at. Quality is about trying to improve.
Fifth, the purpose of training is employment in industry. This is especially reflected in the training packages.
Sixth, training has a compliance environment. Many other laws and sets of standards affect training, so the AQTF is seldom an isolated document.
Seventh, education and training is a commodity provided to consumers. This is reflected in the rules relating to student rights, open access, and fee-for-service. However, commodification is not relevant in some contexts.
Eighth, the AQTF is quite internally consistent. It's easy to make one mistake and be non-compliant on two points of the AQTF. But it's hard to argue that one part of the AQTF contradicts another.
AQTF compliance is a huge undertaking if you're starting from scratch. To help an organization trying to comply, I offer the suggestions below.
I keep full records of what we do to comply with each aspect of the AQTF. By working on it myself, I can see exactly how compliant we are. Having the file alone meets some of the requirements (i.e. review AQTF compliance). For any auditor question, I have a full log of what we do to comply.
Control them by compiling many small policies into a book and give it an edition number or year. That reduces the number of documents and makes it much easier to keep track of them. When the document is changed, just give it a new edition number or year. (By the way, it may be an electronic on your website so you don't drown in paper.)
Although procedures are different from policies, it may be that many of them are also appropriate to put somewhere in the larger document.
I also have a set of staff induction readings. Some procedures might need to be changed much more often, so you might need to keep them separate.
People read the necessary information, download the form, and sign it.
This meets the AQTF requirement and gives us the freedom and timeframe to do the other things we need. I found that people still need to digest it through group discussion.
It's amazing how much will fit on a simple one-page form if you do it right. In some cases, "The form is the procedure."
The AQTF has many disassociated bits, so it's very easy to miss things. But now I can tell my member colleges "Fill in everything and I know you're compliant." They need to have a full staff meeting, for which they need to do some preparation. It works so well that I treat the centre as a branch: the consultant and I fill in the form too.
They are all asking: "What's a problem or potential problem? How can we fix or improve something to avoid the problem?" Perhaps assessment validation is almost the same, just more specialized; it's handling potential problems of inconsistent assessment.
There is so much information that you must provide students that it is difficult to put it efficiently on paper. Although some people really need a piece of paper, the website is an excellent way to provide information and it is possible to put the entire application process on the website.
Some auditors in the past have specified that you must specify that you will provide information in another way for those who do not have Internet access. However, the AQTF review has now said that provision of website information is adequate.
Your application form should specify that applicants have been given that information and understand it to their satisfaction.
My concern is that you'd want to monitor staff, because some people are naturally slack about record-keeping, and really need someone to push them along.
Here are two options:
It's much better for the toughest questions to be asked beforehand than later when you get a validator doing an external audit. That way, you know where you stand — it's better for any weaknesses to be found by your own people than by an auditor.
Besides, good auditors are much more pleasant if they can see that you're doing a good job and are basically on top of it.
The AQTF requires RTOs to review it all only annually, but it is too easy for small non-compliances to creep in and then be hard to fix. Twice yearly will keep you on top of it, although it might be sensible not to commit yourself in policy to twice yearly.
First, annual consultation of assessment procedures doesn't have to be of the same rigor as that specified for developing training packages. The point is that you know your assessment systems work in real situations in industry. So you might not need to consult too widely. Check that you are fitting in with current workplace requirements.
Some people say that the training packages are consulted, so why do it again? But the packages are written to be too generic to deal with detailed changes that occur in real workplaces. Besides, specific requirements can change quite rapidly, and not be reflected in the package. (In fact, many packages have a "find out the current requirements" section, and the competency to do so is included in the Cert IV AWT.)
Second, consultation should fit the shape of the industry, which is most difficult when every member is a free agent and there is no association.
If possible, a small number of key people will make the process much simpler. The almost ideal scenario is when the industry association or representative panel is functionally part of your RTO, or when key industry leaders are staff members of your RTO. The trap then is that they have a role conflict; your consultation must include people what aren't part of your RTO.
You need to be able to move very efficiently through the compliance evidence when the auditor comes, so you're not flustered or unable to find things easily. The website helps greatly, but some documents must be hard copies (e.g. insurance certificates, staff qualifications, CV's), and it's easy to get muddled with lots of paper. It's your job to find each item quickly and go through it with the auditor.
You can't assume that the auditor has already carefully read everything with which they've been provided before they arrive. Some deliberately don't because they first want you to explain how the RTO works. The documents might not make much sense until they know that.
Allow time for questions and comments. All staff attending should sign an attendance list, which should then be attached to a record of what was discussed (agenda, policy, minutes, etc.). You’ll get good input for the revision and everybody will understand the factors involved in the policy change. In some cases, it can work as Professional Development as well.
The reason is that it is difficult to get the details right when making major changes. But the external auditor will want to see that those details are right.
Have a page deep in your website with links to all items of evidence on the website (e.g. information to students, policies, staff information, etc.) This can make up to about 40% of all compliance.
That extra information is necessary; that's why you asked for it. Some shortfalls will be non-compliances and some are simply errors for which you will be noted as a need for improvement.
Make sure assessors fill in forms correctly and sign them. (Sounds silly, but easy to get wrong.) The administrator should check assessment forms right through when they are handed in.
What you write in a form needs to be clear someone who can't ask you personally about it. It should not allow other possible interpretations. E.g. If you omitted something, why? If you crossed out something, why?
If an assessor writes a negative comment on an assessment form for a student assessed as competent, will it be interpreted to mean that the student is not yet competent? However, it is quite legitimate to suggest ways that the student could still improve, or give comments on things that would be necessary in a different context.
Your continual improvement and validation systems must ensure that changes are actually made. Planning them alone isn't actually enough.
Have a favorite on the browser that goes directly to your industry's current practice website so you can quickly update. (A html page in the area that you back up might be even better, so it's not lost if your hard-drive crashes.)
You wrote it, and it might not be included in your regular AQTF commitments. But an AQTF auditor should check that you police your own policies and comply with them.
Write in what you can comply with and what you will actually do. Don't strive for the unattainable ideal so that you can't comply with your own policies.
This will make your life a lot easier, saving you having many bits of paper and lots of confusion. Having it all in one book will save you a lot of pain a little way down the track for several reasons:
Compile all the instructions to students and forms into a program handbook. The point is to provide students with useful information all in one place, and meet most of the accountability provisions for accreditation at the same time.
Here's a list of the kinds of things that must be in it:
You can put other kinds of things in it too:
Even though it's not actually an AQTF requirement, auditors look for good instruments. It is basically impossible to comply with Standard 8 without them.
Ideally, instruments should include a set of written instructions, written especially for each unit (or cluster) on how the assessment should be conducted, test papers, questionnaires, etc.
Auditors want to eliminate the judgment call in assessment, so that tools can be assured of being reliable. The criterion is, "Would it be adequate for another assessor to use? And would they independently get the same assessment result?" Consequently, they want to see the idiot-proofing on paper in the assessment tools.
Several possible ways:
Auditors don't really like large clusters, generic tools, or checklists based on the elements. They don't like them even when they are perfectly adequate, as is the case of very well-written packages or sophisticated generic tools.
Auditors are getting pickier and pickier. (Or should I say "less tolerant of slackness"?)
It is good practice to have someone else check your assessment tools for compliance with package requirements before you start to use them.
The AQTF does not actually require you to write a separate compliance document, but WA auditors will generally demand it. The package requirements are so detailed that it's the best way to demonstrate that you meet all requirements. If you don't have it, you are considered unable to demonstrate that you meet all requirements.
There are different ways of demonstrating compliance, but they all ways of showing where and how you have included each requirement.
Where a student must be assessed on more than one occasion for the same thing, you need to be able to see clearly in the form that all were done and whether or not the student has successfully completed the unit.
Cutting down paperwork is tricky. For example you might need separate forms for each observation and a separate form for assessment outcome? Hmmm. But you'd want to combine them into one form wherever possible.
The assessment forms should include:
This worked well:
Simple and very effective.
If you are very effective, then you will naturally meet most of the requirements.
Records should have a useful purpose. Don't just try to prove that you comply with the requirements by keep lots of extra paperwork only for the auditor to see. Ironically, organizations that might actually be non-compliant; standard 4 requires the records system to be effective.
The only document that has no purpose other than to show an auditor is compliance mapping of assessment tools to units. And it's debatable whether the AQTF actually requires them.
Involve all stakeholders, and least by asking for their expectations.
Develop your system at the beginning. It is easier to modify a good system as your needs change, but difficult to modify a shambles.
Develop a good system to start with, so you won't have to rebuild it from scratch when you get bigger. If the basic system is wrong, you have to start from scratch every time you expand.
If it isn't helpful to you, why do you keep it? There aren't many records that have no purpose other than to show an auditor.
Oddly enough, many RTOs swamp themselves in paperwork in order to show that they comply with the AQTF, but are susceptible to being non-compliant with Standard 4 because their records system is ineffective.
The notes below refer to general principles that affect much of the AQTF.
You might change what you do so you need to have a compliant system in place.
Example 1: "We don't charge fees, so why do we need a refund policy? The AQTF says that the RTO must have a refund policy. Some enterprise RTOs ague that a refund policy is not required as they do not charge fees. (Getting the training is part of their employees' normal work duties.) But the RTO could change its approach and start charging fees. They should say " At present the RTO does not charge fees, but if it does then the refund policy is .... "
Example 2: Why should we keep a register of organizations offering training on our RTO's behalf? Nobody else provides training on our behalf. You must maintain a register of organizations offering training on the RTO's behalf, even if it is empty and there are no organizations listed in it.
There are some exceptions:
The "have it in place in case you change" principle works when policy is adequate evidence. It doesn't work if the evidence must comprise concrete applications e.g. forms that are filled in and signed indicating what students or staff have done. In that case, you can only specify "not applicable."
If an official letter is not on letterhead, it will need to be verified by a telephone call.
In the review, people complained about the burden of documentation required, in particular for small not-for-profit organisations and RTOs delivering a single course.*
The revised evidence guide might have different examples for different kinds of RTOs, (TAFEs, schools, enterprise RTOs, and small and medium RTOs.)
The Evidence Guide was not intended to be mandatory in its range of evidence, recognising that each RTO and audit event has unique aspects and challenges.*
Interpreting standards is the same in assessment. It is possible to stretch them either so far upwards or downwards that they mean something other than what is intended. You might want to be extra rigorous, or believe that a lower performance still meets the standard. Some of the problems are with over-enthusiastic validators who stretch the standard upward to say things that aren't really there.
According to Russel Docking (No. 04), the tendency is to stretch upwards to "offer an excellent program". But that is non-compliant with the AQF and denies students the right to study at the level they can handle and that they enrolled for.
Some AQTF standards only mention having a policy. Consequently:
This can particularly affect multi-site operations:
_____________
*Review of the Implementation of the AQTF Standards: Final Report KPA Consulting, July 2004.
One of the most efficient ways of complying with the AQTF is by having one activity or process that meets more than one criteria. The whole process of compliance and auditing becomes far more holistic. It is also the most effective and efficient way to run an RTO.
As there are so many "two-for-one's", there is no one best way to manage compliance, and some won't work for some situations.
Anyway, we are nearly at a stage where a website could carry most of an RTO's requirements.
Continual improvement (1.10) | can be the same process as: |
Self-assessment and review (1.2.iii, 1.4b) Internal and external audits (1.4a) Processing complaints and appeals (1.5, 8.1.ix) Management of partnerships (1.6) Revision of business plans (1.7) Risk management (1.8) Client and student feedback (1.9) Staff development (7.1) Industry consultation (9.1b) Assessment validation (9.2) Revision of information given to students (including updating website) Trap: You must actually implement changes as a result of these processes for it to become continuous improvement. |
The website | can contain: |
the marketing tool the logo compliance pre-enrolment information the application procedure training and assessment plans feedback system the policy and procedure statement staff duty statements the staff induction system information to staff staff development materials staff development records the document register, with links to all non-confidential documents evidence of review and improvement (with subsequent editions and update messages to staff) student feedback section (through student pages). staff meeting minutes (see below) the forms (see below) the textbook for online learning (see also below under writing a textbook) AQTF compliance record |
Writing a textbook | can be the same process as: |
providing training and assessment information to students teaching materials developing assessment instruments and procedures industry endorsement of training and assessment plans (having their input into the draft and their approval of the final draft) evidence of continual improvement (with subsequent editions of textbook) the forms for recording information moderation with industry validation tool (if instructions are detailed enough to ensure consistent assessment) |
Developing training and assessment plans | can be the same process as: |
industry endorsement of training and assessment plans (having their input into the draft and their approval of the final draft) evidence of continual improvement (with subsequent editions) moderation with industry |
Assessment plans | can be: | a large part of the assessment tool if they tell students how they will be assessed |
Keeping minutes of board or staff meetings | can be a record of: |
Moderation Program monitoring Risk management Review and continual improvement Self-assessment Staff review Evidence that staff have been in discussion on updated policies Evidence that people received documents (e.g. policies) |
The forms | can contain: |
information to students the procedure the policy |
Assessment forms | can contain: | review notes student feedback notes |
Industry validation | can include: | Feedback from work experience in industry. That is, after students in classroom-based courses have have done practicum in industry, you ask them "Is what we taught you what you really needed to know?" You can also ask the workplace supervisor "Is what we taught the student what he/she really needed to know?" Either way, check their comments against their expectations. Were expectations realistic for both parties? To idealistic. Too low? |
Grievance policy | can be the same as: | Appeals policy (except in WA due to a state framework) |
Teaching under supervision | can be the same as: |
Gaining the Cert IV in Training and Assessment Validation (by having two assessors check evidence, tools, and standards against each other) |
Email records | can contain: |
Information to students information to staff moderation notes program monitoring risk management review and continual improvement industry consultation self-assessment staff review |
Student's Job Description and procedures handbook | can be: |
training materials assessment guidelines |
Professional Development | can be: |
Moderation, if you take training courses that are designed for keeping staff up to date with current standards in their field. Policy review Staff review Program and compliance review |
Carefully-written staff instructions | can be: |
De facto job description De facto policy |
Outside co-assessor | can be: | Both assessment and moderation |
Workplace supervisor | can be: | mentor/trainer |
Staff review | can be: |
formal assessment (for a qualification or admission to a course) professional development, if it includes development goals and strategies |
Stakeholder feedback | can include: |
internal audit client feedback Board meeting minutes (if they record board feedback) Staff meeting minutes (if they record staff feedback) Industry consultation |
Internal audit | can be: |
identifying and documenting assessment improvements staff review stakeholder review client feedback CEO annual review, if the CEO is listed as present at the exit meeting of the annual audit. |
AQTF compliance record | can be the same process as: |
compliance review instrument audit instrument |
A business plan | can be: | mapped to AQTF requirements other than business plans (e.g. industry consultation) |
A funding application proposal | can be: | A business plan for a particular project |
Professional Development | can be: |
Your industry consultation (because you find out the current industry requirements) Part of assessment validation, because you can compare your assessments to current interpretations of requirements and discuss critical items of evidence. |
Staff induction materials | can be: | Providing staff with information of Competency Based Training and Assessment |
Compliance mapping that shows how you addressed all unit requirements | should be: |
part of validation (comparing standards with tools) demonstration that you meet package requirements Sufficiency of evidence (enough assessments according to package requirements) |
Fair assessment (8.1.iii) | is the same as: | equitable for all persons (8.1.viii) |
Staff competence | can be evidenced in or through: |
Program review (at either unit or course level) Stakeholder review Audit of activities Writing training and assessment materials Website as webmaster or author of website materials or systems PD given |
Getting industry people to rewrite the elements and performance criteria in their own language. | can also be part of: |
Industry consultation (9.1.b) validation (9.2) and language requirements (9.3.v). Reliability of assessment tools (because you have made them unlikely to be interpreted in different ways). |
Ross Woods, 2019
Pay special attention to the elements that are easiest to get wrong. These were the most commonly occurring non-compliances in WA during 2004:
1.8.i
1.10.i
4.3.i, ii*
5.2
5.3
6.3.i, iv, v, vii
7.4.i
8.1.i, iii*, v, vi
9.1.a*, b*, c*, d
9.2.i*, ii
9.3.ii
10.2.i
The highest risks are asterisked above. They are:
4.3.ii Version control
8.1.iii Valid, reliable, fair and flexible assessments
9.1.a Training and assessment strategies for each course
9.1.b Strategies developed in consultation with industry
9.1.c Strategies identify target groups delivery and assessment modes, assessment validation processes.
9.2.i Validate assessment strategies
10.2.i Qualification and statements of attainment
Source: Quality Training in Western Australia 04 Activities Report (Training Accreditation Council 2004) pp. 15, 16.
At a Professional Development for AQTF internal Auditors in April 2006, Claire Werner identified the largest problem area as a whole to be training and assessment, with validation and staff qualifications being the most common specific problems. After that, records and systems tended to often pose problems.
She also reported that the most common non-compliances are:
Risk factors also include lots of students, high staff turnover, and new training packages.
The text of the AQTF doesn't actually require as much documentation as it might seem. In many cases it really talks about what an RTO does, not about what it writes. And, often, if an RTO has a piece of paper but doesn't do what is required, the paper doesn't count as compliance.
The AQTF generally differentiates policies from procedures.
The AQTF uses the word "process" several times, apparently to indicate a consistent, systematic way of doing something, even if it is not a set of steps.
Policies should almost always written down, the possible exception being a small one-person RTO.
In many cases, the normal or preferred evidence may be written, but it is not actually compulsory. There may have been better non-documentary ways to comply with the requirement (e.g. give a question and answer orientation to new students rather than a provide an induction handbook.)
Some "required" documents are required only under certain circumstances. For example, if an RTO has no Trainees or Apprentices, then it does not need Training Plan Outlines for them. In this view, if an RTO has no auspicing agreements, then it doesn't need a register of partnered organisations at all, not even an empty one.
On the other hand, it may be that an RTO really needs some things to be in writing for other reasons. This most likely applies particularly to policies and procedures. Reasons for needing things to be in writing are:
The text of the AQTF itself specifies very little documentation, and it is a worthwhile exercise to go though and check. The AQTF allows a wide variation documentary and interview (non-documentary) evidence in many cases.
However, the AQTF evidence guide (especially at 1.1) specifies some compulsory documents. That is, the main requirement is simply to have the document. 1.1 states that "as a minimum, these policies and procedures must cover the following:" and lists many standards and sections.
Standard 1.1 does not clearly differentiate between a policy and a procedure; it might be impractical to have both a policy and a separate procedure for each case listed, especially when it includes whole standards. And it would be unreasonable for an auditor to require it. The point is that the RTO has written down what they will do. The text of the standards themselves is generally more specific about whether they must be policies and/or procedures.
In a couple of locations, (e.g. 1.9, 2.2), policies and procedures are mentioned not as separate documents but as a review or compliance requirement.
The sections requiring obligatory specified documents are highlighted below in white blocks.
Boxes are not highlighted in cases where any one of a range of documents would meet the requirement, even if evidence must be documentary.
Many thanks to Claire Werner for her advice.
Not only does an RTO have to do all the right things, but it should also have a workable system of documenting them. This often involves making forms that standardize procedures for getting everything into writing. In the worst cases, auditors wanted to see a separate piece of signed dated paper that addressed each AQTF requirement.
There is an argument that compliance is not the same as an extra layer of paperwork. The only written evidence actually required is that which is stated as a requirement. However, at least in WA, TAC has said that validators are permitted to require the extra layer of evidence. The rationale is that an RTO doesn't just have to comply with the AQTF, but that it have to be able to demonstrate how it complied.
Auditors need evidence, but it doesn't doesn't have to all be written. It can be oral, for example, through an interview. The point is to get enough evidence to corroborate findings. It's actually the same principle as using documentary evidence to corroborate interviews. Either an in-depth interview with a convincing interviewee or a look at documents alone might not be sufficient corroboration. People say and write all sorts of fairy tales for auditors.
And the "one size fits all" approach doesn't work; there are no ideal forms that work equally well for everybody.
This might sound like an easy question but it's not. How the records are formulated is up to the RTO, and many of them in the list below can be combined in different ways. There is no problem having them electronic, as long as they are securely backed up and safe for privacy reasons.
So far, the list is this long for an instructor teaching a unit, not including any other administrative records.
You must also have an RPL system and an appeals system (and OHS, if students would be reporting hazards during the course of the unit) all of which the the RTO might provide on its website.
Here's a test, with thanks to Sally Lumsden in the department:
Your planning documentation should be clear enough for another competent instructor or assessor to take over at any time, understand it, and do it for you.
Two points. First, if you don't get there for some reason (you're sick) and somebody else teaches or assesses for you, will it still work?
Second, you need to ensure reliability. An assessment tool is reliable if different people use it the same way and it still collects the same evidence each time and produces the same assessment outcome. If it's not written down, the assessment is unreliable. This also applies to you: you'll forget the details of what you did during a long break, and you won't want to figure it all out from scratch again.
Compliance is quite difficult for the following reasons.
The document is quite long and it is very easy to overlook details. Having the contents in a difficult to follow order exacerbates the problem.
The AQTF has sub-strata of compliance. For example, standards 1.1 and 1.4 require the RTO to comply not only with the AQTF, but also its own policies. On a trickier note, the RTO must have a code of practice (6.2a). But does the RTO police it to ensure that people actually follow it? In this case, the AQTF does not explicitly require that you do so because it is not a policy or procedure (cf. 1.1, 1.4). Nevertheless, the functional view of the AQTF is consistent with the idea of policing this substratum.
In the 2005 edition, the Standards include definitions, but the Evidence Guide doesn't. Consequently, you must have both documents on hand to be able to use either. Both the definitions and the evidence requirements are integral to applying the standards. Even so, key words like "valid", "current", "reliable", "flexible" and "fair" are not defined in the AQTF, and often have more than one meaning elsewhere.
The AQTF is not completely consistent with several other influential standards:
The AQTF assumes that compliance is a yes/no decision, but in practice, there are often shades of grey. Compliance systems are not bullet-proof, and nobody is perfectly compliant at every point all the time.*
RTOs could generate unworkable extra paperwork to make compliance documentation much more watertight. But in reality, RTOs must choose effective, streamlined documentation systems that work in practice.
As a point of interpretation, RTOs are not required to create a full extra layer of paperwork except where the AQTF requires those items be documented (e.g. policies). However, some extra documentation is required, not by the AQTF, but to protect the RTO from possible litigation.
Compliance is not just a simple state that one attains, it is a process for handling the way that non-compliances naturally tend to arise. There will always some forms filled in incorrectly or "still on the way", students who didn't provide feedback, incoming staff who are still organizing their documents, and procedures that could be improved. An RTO is technically noncompliant in the period between the departure of a CEO or the leading compliance officer and the employment of a replacement, or when moving offices. A nit-picker could argue that any one of these is evidence of noncompliance, but the point is that all of them are fairly normal and usually need to be managed as risks rather than non-compliances.
The AQTF requirements are generally well-intentioned, but the intent is never actually stated and the purposes of many AQTF points are left to the reader's imagination. For example, RTOs are required to have a functional document versioning system. But why? The purpose of versioning is so that organizations can keep track of their documents and don't have two different current versions of the same thing.
The main difficulty in interpreting the AQTF is whether it is primarily about achieving organizational goals with a good quality program, or about complying exactly with what auditors think RTOs need? In other words, is it:
The AQTF is open to either interpretation. Good compliance auditors (called "validators") tend to the former, and weaker auditors tend to the latter.
As a system that will actually help RTOs do better, it may be likened to a pipeline. If the pipe leaks, it's no good. That is, non-compliances are like inefficiencies in the system. But when the pipe is in good order, you can efficiently pump anything through it. You are then free to be as creative as you can in choosing what you'll send through it.
Here's a similar aspect that parallels assessment. Auditors collect holistic evidence but judge it according to specific criteria. That is, they should look at a system as a functioning whole and collect evidence holistically, but they still need to record compliance with each of the criteria.
Auditees might not arrange evidence in the most effective way to demonstrate compliance, but that doesn't mean they are non-compliant. It just means that they are difficult to audit, and that evidence may be more difficult to locate.
If the auditor is given a good picture of the whole range of evidence, he/she will sometimes be able to list more evidence items for a particular standard than the auditee.
Auditees might not have mastered the jargon, but could still be compliant. For example, most program managers provide students with a clear, well-written description to on how the program will work. But they might not call it a training plan.
These programs are difficult to audit, and evidence may be more difficult to locate. But they could still be compliant.
The AQTF has many layers of meaning:
Access and equity is clearly directly governed by the AQTF (6.2.b), but most are not (e.g. evidence guide for 2.1).
There are various interpretations of many points of the AQTF, and there is no published, transparent system for consistent interpretation. Setting up such a system was one of the main recommendations of the AQTF review, but possibly won't happen with the abolition of ANTA.
Training authorities have a national moderation system in place, but its findings are not publicly available. The extent to which the moderation system is effective is not known, although there is evidence both of improvement and of continuing inconsistencies.
Public servants generally cannot take it upon themselves to produce specific interpretations.
A good auditors' best advice is their interpretation of the AQTF; they see lots of different training packages and many different kinds of RTOs, and get a broader knowledge base than is available to any particular RTO.
However, some auditors simply get their AQTF interpretations wrong and make them up on the run. That is very frustrating, especially when dealing with someone who is incompetent or legalistic. For the RTO, it feels like you're blindfolded in a boxing ring, not knowing what to expect but very vulnerable. Besides, there are sometimes changes in interpretation that aren't publicly announced.
Consequently, the AQTF looks like it can mean whatever someone wants it to mean at the time, and the recommendations of auditors can sometimes appear inconsistent or at variance with the regulations. This is even more frustrating when dealing with possible auditor mistakes. It's a case of "You interpret it for yourself and we'll catch you if we think you're wrong."
The AQTF also looks like it can be interpreted forever, but there is bedrock, that is, when one knows what it means and how it fits together.
Auditors have a right to investigate apparent or suspected non-compliances, but some have not primarily been concerned with compliance but with perfection.
The assessment analogy is helpful. Assessors who simply assess to a competent/not yet competent result are like auditors who determine compliant / non-compliant. If 100% is perfect performance, the system is designed so that nobody gets 100%. Consequently, percentage-based assessment systems have a "pass mark" of, say 50%, 60%, or 70%. If auditors take the approach that defines fully compliant as 100%, the standard is defined in a way that nobody will can attain it and everyone is non-compliant, and consequently subject to unreasonable levels of investigation.
A frightening possibility raised by an e-zine: Could an RTO be required to recall all qualifications from the date when they were found to be non-compliant with the AQTF? Recalling certificates from students really is a long shot and so far I've never heard of it happening. But here's an answer anyway.
Answer 1. It would depend on different laws in different states.
Answer 2. Probably not, if the issuer was still operating as an RTO. As a rule of thumb, when a qualification is issued, it's issued. Under consumer law, students generally have a right to keep their qualifications, and even some dodgy "drive-through" qualifications in the 1990's were not withdrawn.
In cases of deliberate dishonesty or gross negligence, training authorities can withdraw registration effective forthwith. In most cases, however, they simply decide that the RTO must get its act together, require evidence of compliance through changes made, perhaps do another follow-up audit, and only then restrict scope or de-register if necessary. But this isn't the same as recalling qualifications from students.
Answer 3. Perhaps yes, if other factors came into play. For example:
In any case, recalling qualifications would probably require a court order unless legislation specifically empowered the State Training Authority to do so.
__________
* This is analogous to the argument for graded assessment and the notion that assessment is a judgment call. There is a significant difference between a written set of standards and an assessment decision in a real situation. I call it the "assessment gap." Considerable research seems to have gone into taking the guesswork out of the decision, usually by adding systems of objectifying information.
The political factors are most interesting and extremely frustrating to work with.
1. Known risk factors are, justifiably, a matter of priority.
2. Public service structures affect the way things are done. The officers must comply with a wide range of protocols. They are usually limited in what they can put in writing, because they can't compromise their department, e.g. be interpreted as making a promise or committing to a particular policy interpretation. Their job is to get RTOs to comply with government policies, and only a few will honestly tell you when a policy simply doesn't work. Not only that, a lot of back-covering goes on, often for quite justifiable reasons.
3. The government has adopted such a stringent standard so that they can close down smaller, weaker RTOs and cowboy operations. Some RTOs try to cheat the system to make more money with less effort. These are sometimes called the "drive through" qualifications.
4. Some people have complained that the complaints and appeals processes might not work as well as intended. For example:
There is a difference between:
All these things can look like non-compliance, but only the last one really is. Both validators and RTO administrators need to be able to differentiate, and will respect the ability in others to clearly differentiate them. Inability to differentiate these four categories is a serious weakness in any auditor.
What about this: What's the difference between these two?
Unless the AQTF calls for documentation (which it usually does), the RTO would be considered compliant. The issue for auditors is often about the extent to which they may depend on interview evidence.
Here's another one. What's the difference between these two?
An auditor is unfair if he/she requires something better or more rigorous that the AQTF to be considered compliant. In assessment, it would be classified as a problem of validity. The correct path is that, if something is compliant, it should be recorded as such. Improvements should be identified as a separate issue, not as non-compliances.
A few standards comprise separate items lumped together in one sentence. This makes audit records harder to keep, because an RTO might be compliant on one part of the paragraph, but non-compliant on another part.
Standard 9 is of special concern as it includes so many lumped-together standards. These make compliance more difficult as it is easy to overlook particular parts. Yet Standard 9 is a high priority to get right.
The points in square brackets are additions to identify separate items:
6. [a] The RTO applies access and equity principles and [b] provides timely and appropriate information, advice and support services which assist clients to identify and achieve their desired outcomes.
"7.1 The RTO must [a] develop and implement written procedures for the recruitment, induction, and ongoing development of each member of its staff who is involved in training, assessment or client service; [b] encourage and provide relevant opportunities for their professional development; [c] and monitor their performance."
"8.1.v where relevant, [a] focus on the application of knowledge and skill to the standard of performance required in the workplace and [b] cover all aspects of workplace performance, including task skills, task management skills, contingency management skills and job role environment skills;
9.1.c The delivery and assessment strategies referred to in Standard 9.1 a should identify [a] proposed target groups, [b] delivery and assessment modes and strategies, [c] assessment validation processes and pathways.
9.2.i reviewing, comparing and evaluating the [a] assessment processes, [b] tools and [c] evidence contributing to judgements made by a range of assessors against the same competency standards, at least annually: and
9.3.i methods used to [a] identify learning needs, and [b] methods for designing training and assessment, are documented;
9.3.vii where assessment or training is conducted in the workplace, the RTO [a] negotiates the delivery and assessment strategy with the employer and [b] learners; [c] works with the employer to integrate any on-the-job training and assessment; and [d] schedules workplace visits to monitor/review the training and assessment;
9.1.viii where an Apprenticeship/ Traineeship Training Contract is in place or being negotiated, individual Training Plans are [a] developed, [and] documented, [b] implemented and [c] monitored for each apprentice or trainee, encompassing all relevant off-the-job training and structured workplace training; and ...
Besides those mentioned elsewhere, here are some more:
The assessment procedures do not easily integrate into Western Australia's Skills Recognition Framework to make a step-by-step procedure that one takes students through.
The procedure also needs to be clear enough on how to offer RPL to overseas students, for whom pre-enrolment requirements for RPL become quite messy in practice.
How autonomous can local branches be? How centralized must the RTO be? This is not difficult, but, for example, each location may need to maintain its own document register, insurance, business plan, etc.
Some government TAFE schools feel that they have a monopoly of all qualifications issued when a new package is introduced. They suggest that all private RTOs may only run that course when the staff of the private RTO have received the TAFE qualification.
Procedures for introduction of new qualifications could be made more explicit when no one person has all required competencies and most RTO staff need to become formally qualified.
Two approaches have been suggested:
Some validators can interpret the AQTF on the run; this is usually not too difficult and things can run well.
The problem is the shades of gray, when a single application can reasonable be argued either for or against. The decision could go either way and this should be handled in the validator moderation process; however, validator moderation interpretations are not made public. The last section of this e-book contains different interpretations on the kinds of issues that have been raised so far. Even when the AQTF seems to be clear, the issues still come up.
The AQTF Review suggested that state registration authorities should jointly establish a web-based interpretation system similar to ATO Tax Rulings.
Documentation levels are sometimes ambiguous. Validators can make up extra rules on the run as evidence for documentation of compliance.
For example, the RTO is required to provide students with an assessment plan. Is the written assessment plan sufficient evidence of compliance? The evidence guide would suggest so.
But an auditor might ask for proof that it was given to students. One RTO required all students to sign the Assessment Plan and return it so the RTO had documentary evidence that students received it. But then students didn't have it any more and couldn't use it.
Similarly, some auditors ask for documentary evidence that students received and understood assessment plans. (Discussed further in standard 8.) Or received and understood course admission information before enrolment.
Despite the lists of examples, the AQTF itself does not contain a ruling on how much extra documentation validators can require to prove compliance.
The basic view so far has been to interpret units according to AQF levels at which they are offered. Consequently, the same unit can be offered at different levels with varying degrees of sophistication. Note kkkkkkkkkkk kkkkkkkkkkk
Presently an RTO may be required to accept the same unit that was done at a much lower level.
For example, a simple composition would suffice for a unit "Conduct research activities" done at Certificate II level. It would also be quite appropriate for a Graduate Diploma to include a unit "Conduct research activities". But the Cert II student might ask for recognition of his/her Cert II unit in the Graduate Diploma. According to one interpretation of the letter of the law, the student should be able to credit that Cert II unit in a Grad Dip. because they have exactly the same unit code.
This is an oversight in the AQTF. One way to fix it easily is to specify no more than one AQF level lower (giving one AQF level for flexibility's sake). The alternative is to fix package units at AQF levels, which is the current trend, but saddening because the ability to offer the same unit at different levels is one of the strengths of training packages.
It is compliance with sets of regulations regarding logos.
There is a trend to disallow scope for qualifications that are primarily for the RTO's own teaching staff, as this is seen as a role conflict. This is not actually a contravention of the AQTF in its present form but it should perhaps be considered. It particularly affects qualifications in training and assessment.
Accepting transfer credit other than by mutual recognition should be explicitly permitted, and the conditions for doing so should be made clear. Some interpretative work has gone some way to resolving this.
Standard 9.3.vii requires a wide range range of students to be catered for, while standard 9.1 requires specification of specific target groups. Probably the point is that 9.3.vii should mean appropriacy for all members of the target group.
Theoretically, and practically, the assessment gap remains the largest single problem in the AQTF. Training accreditors perceive a gap between written standards on one hand and making specific assessment decisions with real students.
They are concerned about assessment decisions being judgment calls made by assessors. For example, if a student appeals, can you prove your assessment was correct? How can you show that the assessment was valid, fair, reliable, and flexible?
A great deal has been done to objectify the judgment and narrow the gap:
While some of this is helpful, the level of irrational angst is still fairly high, and the gap is often not as wide as the theorists admit.
Moderation is the usual "too hard" basket for all kinds of assessment problems, and it often doesn't carry the load well. It should be simply a means for clarifying expectations so that assessment are consistent.
The parallel and sometimes equivalent use of the word "validation" adds confusion rather than clarity to the issue, especially as "review" is not necessarily much different.
Access and equity is a separate issue from information to students. I'd probably move access and equity principles to institutional policy compliance and put the rest in training and assessment strategies.
Standard 9.1.b and 9.1.c clarify the "What" of industry consultation but don't really give a purpose. "The delivery and assessment strategies referred to in Standard 9.1 a should identify proposed target groups, delivery and assessment modes and strategies, assessment validation processes and pathways."
So it doesn't actually say very much and is fairly easy to comply with. Under the present requirements, the requirements would be met by a simple list of:
While it's clear that RTOs have to do the consultation, it's not really clear what they must achieve by it. The emerging consensus seems to be that the purpose is to:
Increasingly, "assessment strategy" is interpreted to refer specifically to instruments, not just to a strategy. One very good explanation of what auditors are looking for in an assessment strategy is a set of written instructions on how the assessment should be conducted. The criterion is, "Would it be adequate for another assessor to use?"
Whatever consultation is supposed to achieve, it needs to be spelled out better.
I'd bring the two together. Industry consultation is usually the first one to come up. The AQTF requires the RTO to do it, while the Cert IV requires the instructor to do it. But you wouldn't do it twice. The best answer so far is that staff should do it as part of their responsibilities in preparing for teaching, and hand in the documentation.
Review is another example. The Cert IV requires teaching staff to be actively involved in reviewing their instruction and assessment. This includes reporting what went well and what didn't, and making recommendations for improvements.
The AQTF (e.g. 1.10, 9.2) requires the RTO (not necessarily teaching staff) to conduct review and improvement. Consequently, an RTO can meet the AQTF requirement without meeting the Cert IV requirement, for example, by having a separate committee review student feedback or conduct student surveys.
Accredited | Refers to courses developed by Registered Training Organisations and approved by the accreditor. They are nationally recognised. |
ANTA | Australian National Training Authority. Now abolished and its tasks transferred to the Department of Education Science and Training, which is now the Department of Education, Employment and Workplace Relations (DEEWR) |
AQF | The Australian Qualifications Framework (AQF), a system of qualifications that ranges from certificates for the simplest menial skill up to postgraduate research qualifications |
AQTF | Australian Quality Training Framework, predecessor to the Standards for NVR Registered Training Organisations, which is part of the ASQA quality framework. |
ASQA | Australian Skills Quality Authority, the ACAS accreditation agency |
ARF | Australian Recognition Framework, the predecessor to the AQTF |
ASQA | Australian Skills Quality Authority. ACAS's national accreditor since its accreditation was moved from the state-based Training Accreditation Council of WA. |
Assessment | Examination by any valid means. It does not mean only a written test, but can also be observation, interview, portfolio, references, etc. |
Assessor | Examiner |
CBA | Competency Based Assessment |
CBT | Competency Based Training |
CBTA | Competency Based Training and Assessment |
Endorsed | Refers to courses developed by industry in consultation with government and nationally approved. |
DEST | Department of Education Science and Training, the federal department that oversaw training at national level and was renamed DEEWR. |
DEEWR | Department of Education, Employment and Workplace Relations. |
Evidence | Documentation (or sometimes artifacts) that support or demonstrate that the student has the required skills or abilities. It is often based on observed performance. |
Mapping | A comparison of two sets of requirements, normally written. The most common forms are to (1) lay out lists side by side and (2) embed references within one document to the other document. Other forms of mapping are (3) colour coding on one document to refer to the other, (4) diagrams, and (5) narratives show how one document was developed to produce the other. |
Moderation | Checking to ensure that assessments of the same outcomes are consistent between assessors and between different groups of students. |
Module | A module is laid out quite differently from a unit of competency. The module represents a fairly inflexible, one-dimensional slab of knowledge. (Contrast "Unit".) Modules seem to have beocome obsolete. |
NRT | Nationally Recognised Training (the ANTA logo which RTOs may use on recognized courses) |
Outcome | Goal, aim or objective. The trend is now to use the rather unwieldy term Element of competency (abbreviated to become Element). |
Qualification | One of the award levels of the Australian Qualifications Framework (AQF ) |
RCC | Recognition of Current Competencies. It once meant the same as RPL, but now sometimes means confirming whether or not certified competencies are still current. |
Registered | The institutional approval given to an RTO (contr. "accredited" and "endorsed") |
Registered Training Organisation (RTO) | An approved institution, which can be anything from a large college to a lone person who has contracted to comply with registration requirements. |
RTO | Registered Training Organisation |
Required Knowledge | Also often called "Essential knowledge" It is knowledge that you are required to assess. |
Report or Project | Essay, practical report, or thesis | RPL | Recognition of Prior Learning. This is assessment of skills regardless of how they were acquired. It does not refer to transfer credit, although unrecognized credit from other insitutions may be assessed using RPL procedures. |
Scope | The range of courses that an RTO is approved to offer. |
Standards for National Recognition | ASQA's quality standard. The content is almost exactly the same as the AQTF, but it has the status of legislative instrument. Besides, ASQA can add any rules they like to it at any time, also with the status of legislative instrument. |
Stakeholders | People who depend in some way on the success of the program, so have a right to some kinds of information or a say in how it is run |
Statement of Attainment | A kind of transcript of transferable credit. |
TAC | Training Accreditation Council of WA, ACAS's accreditor before it moved to ASQA. |
Trainer | Lecturer, teacher |
Unit of Competency | A layout for describing a skill area that might apply to a number of different occupations, making it very flexible. Hence the name Unit of Competency. It is more usually just called a unit, but some hard-core jargonists call it a UoC (pronounced "you-okk"). It is the smallest unit for which a statement of attainment may be issued. Contrast Module. |
Validation | This term has several distinct meanings:
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These definitions were quoted in the AQTF review* and are usually very good. They derive from three sources: Those with no reference were written by the authors of the review. Some are referenced directly to the AQTF, and these are authoritative. Some are referenced to a range of quasi-authoritative publications, but are not necessarily consistent with the AQTF itself and might not be a reliable guide it its interpretation. Some seem to have competing definitions in other quasi-authoritative publications.
Assessment | "the evaluation of sufficient evidence to enable judgements to be made about whether competency has been attained" (AQTF 8.1.vi) |
Assessment guidelines | "Assessment Guidelines included in the applicable nationally endorsed Training Packages or the assessment requirements specified in accredited courses." (8.1.i) |
Assessment materials | Assessment materials are any resources that assist in any part of the assessment process. They may include information for the candidate or assessor, assessment tools or resources for the quality assurance arrangements of the assessment system. (From Guide 4 Training Package Assessment (DEST) |
Assessment method | The particular technique used to gather different types of evidence. This may include methods or techniques such as questioning, observation, third party reports, interviews, simulations and portfolios. (From Guide 4 Training Package Assessment (DEST.) |
Assessment mode | See "assessment method". |
Assessment process | The assessment process is the agreed series of steps that the candidate undertakes within the enrolment, assessment, recording and reporting cycle. The process must best suit the needs of all stakeholders and be both efficient and cost-effective. The agreed assessment process is often expressed as a flow chart. From Guide 4 Training Package Assessment Guides (Department of Education, Science and Training, Commonwealth of Australia {DEST}) |
Assessment products | See assessment materials. |
Assessment services | Assessment services are those services provided by an RTO to enable the assessment of individuals to determine their achievement of the outcomes defined in national Training Packages and/or Australian Qualifications Framework accredited courses, in accordance with the RTO’s defined scope of operations. |
Assessment strategy | Assessment strategy means the approach to assessment and evidence gathering used by the assessor or Registered Training Organisation. It encompasses the assessment process, methods and assessment tools. (From Guide 4 Training Package Assessment Guides, DEST). |
Assessment system | An assessment system is a controlled and ordered process designed to ensure that assessment decisions made in relation to many individuals, by many assessors, in many situations are consistent, fair, valid and reliable. (From Training Package for Assessment and Workplace Training.) |
Assessment tool | An assessment tool contains both the instrument and the instructions for gathering and interpreting evidence. |
Assessment validation | Validation involves reviewing, comparing and evaluating assessment processes, tools and evidence contributing to judgements made by a range of assessors against the same standards. Validation strategies may be internal processes with stakeholder involvement or external validations with other providers and/or stakeholders. [Note: This definition does not specify what is to be achieved by validation i.e. consistency between assessments (i.e. moderation) or suitable match of assessments to workplace requirements. In fact, the literature uses the terms with both meanings.] (From Guide 4 Training Package Assessment Guides, DEST.) |
Evidence and ‘quality’ evidence | Evidence is information gathered which, when matched against the performance criteria, provides proof of competency. Evidence can take many forms and be gathered from a number of sources. Assessors often categorise evidence in different ways, for example:
Quality evidence is valid, authentic, sufficient and current evidence that enables the assessor to make the assessment judgement. (From Guide 4 Training Package Assessment Guides, DEST.) |
Fair assessment | Fair assessment should not disadvantage particular learners. If an assessment is fair, all learners will be treated equally, will understand clearly what is expected of them and what form the assessment will take. A fair assessment procedure should also support learning – e.g. by providing feedback on assessment performance. (From Key Aspects of Competency Based Assessment. National Centre of Vocational Education Research (NCVER) 1995.) |
Flexible learning (and assessment) | Flexible learning and assessment means an approach to vocational education and training which allows for the adoption of a range of learning strategies in a variety of learning environments to cater for differences in learning styles, learning interests and needs, and variations in learning opportunities (including online). |
Instrument(s) | The specific questions or activity developed from the selected assessment method(s) to be used for the assessment. (A profile of acceptable performance and the decision making rules for the assessor may also be included.) |
Procedures | The information/instructions given to the candidate and/or the assessor regarding conditions under which the assessment should be conducted and recorded. (From Guide 4 Training Package Assessment Guides, DEST) |
Reliable assessment | Reliable assessment uses methods and procedures which make sure as far as possible that competency standards are interpreted and applied consistently to all learners and in a variety of situations. Ideally, a reliable assessment should be reproducible, that is, it should be able to produce the same result for learners of equal competence at different times and/or places. (From Key Aspects of Competency Based Assessment. National Centre of Vocational Education Research (NCVER) 1995.) |
Valid assessment | A valid assessment assesses what it claims to assess; evidence collected is relevant to the activity and demonstrates that the performance criteria have been met. (From Training Package for Assessment and Workplace Training.) |
* Review of the Implementation of the AQTF Standards: Final Report KPA Consulting, July 2004.