Ross Woods, 2010, rev. 2022
This history covers the period from the Australian Recognition Framework (c. 2000) to 2010.
This history refers to Western Australia, where the auditing of the Australian Quality Training Framework (AQTF) is overseen by the Training Accreditation Council (TAC). Each state in Australia has its own system, although there is now interstate moderation. I take the viewpoint of a Registered Training Organization (RTO).
Under the previous framework, the Australian Recognition Framework, TAC's auditing procedure was fairly lax. There was a checklist and a fairly brief on-site visit, but it was not particularly difficult to meet the requirements. The system then allowed whole training packages to be put in scope at once.
The first version of the AQTF was a nightmare. It contained detailed requirements that governed many organizational processes. Although the rules were good, they were difficult to interpret and took auditors and RTOs alike several years to figure out what they meant. This was exacerbated by the absence of any authoritative interpretation, either as an interpretive moderation system in TAC or as a public document. In fact, one of the Executive Officers of TAC did not even know what such a document might look like.
To make matters worse, auditors interpreted evidence-based auditing to mean that documents were the only permissible kind of evidence. Consequently, compliance was mainly about generating more paperwork that did not add value to RTOs’ business; they were forced to generate pieces of paper for everything and compliance costs were forced upward. Compliance was not really about doing a good job of training.
TAC thought of the AQTF as a quality system, and this view has tended to persist. It was considered good practice for all staff to intentionally comply with the AQTF as if the AQTF were a quality system. This implied that all staff should not only be knowledgeable about AQTF requirements, but also be able to interpret them accurately.
It would have been better for the AQTF to be seen as a quality standard against which procedures and their implementation were measured. Each RTO would then design procedures that suited its particular needs, and staff would simply follow procedures.
The main benefit of this version of the AQTF was that it did what it was secretly designed to do: de-register many weak RTOs that should not have been in business. However, some could have slipped through the net, and, unfortunately, some good RTOs probably lost their registration in silent frustration.
Eventually, the obsessive-compulsive view of compliance was relaxed. RTOs reportedly lodged complaints about many auditors and TAC deliberately weeded out some of them. Besides, RTOs created more efficient compliance systems and auditors began to allow them.
After a long review by a private consultant, the second version of the AQTF was released in 2005. The greatest value of the consultant's report was that it was a very good interpretive document.
The changes were generally insignificant. The thinking was that it was probably better to change as little as possible than to suffer the pain of great change for a better version of the AQTF. But this version of the AQTF was relatively short lived.
Oddly, RTOs were required to comply with the following version six months before it was released in July 2007. It had several significant innovations:
compliesor
;does not comply.
implementation guide,which generally explained it. This reduced much of the confusion, and greatly reduced the amount of work for consultants and freelance AQTF auditors.
This version of the AQTF also had some oddities. The standards were poorly written and tended to overlap in practice. They were also quite brief, mainly because many items from the old AQTF were transferred to the implementation guide. In general, compliance was relatively easy.
A new edition of the AQTF was released in late 2009, but the changes were generally minor.
Under the ARF in WA, when training packages were very new, TAC allowed RTOs to put whole training packages in scope at once.
TAC later defined scope more tightly as an industry area. For example, youth work was defined as AQF levels 0-6
, meaning the Community Services Training Package, the generic Certificates I and II, and the qualifications in youth work from Certificate III to Diploma. This system was quite different from other states.
Although the definition of scope on the STARS website was still the same, TAC later added registered delivery
, which meant that each qualification was individually put in scope, along with the address of the location of delivery when first offered. This met the AQTF requirement of defining scope as the list of qualifications that appeared on the National Training Information Service (NTIS) website.
Although delivery of elective units was audited, WA still did not keep a unit-specific definition of scope, although some other states did.
TAC has had a policy of auditing according to risk.
Risk factors. TAC kept a list of factors that indicate that a program is high risk and reviewed the list quite often. It included factors such as delivery to students under 18 years old, overseas delivery, higher qualifications, etc.
Strategic industry audits. Some industries were considered higher risk than others, and TAC announced audits of all RTOs delivering qualifications within that industry. For example, when a death occurred in an outdoor recreation activity, TAC assigned a high risk rating to the outdoor recreation qualifications and audited them. When the security services RTOs were subject to a strategic audit, most RTOs in that industry either closed down or dropped their security services scope. In a later strategic audit, RTOs were surveyed to identify risk factors. Presumably those with lower risks would not be audited.
Samples in large RTOs. It wasn’t feasible for TAC auditors to audit every qualification offered in a large RTO, so they selected a sample of the qualifications offered, and tried to include higher risk qualifications. Those were then properly audited.
Large RTOs sometimes cheated this system. If TAC audited a program, it was likely that they would select the same program in the next audit to check on improvements. Consequently, some other qualifications could go many years without being externally audited, so lax practices could proliferate.