Evidence in ASQA audits

Ross Woods, 2021

The nature of acceptable evidence in ASQA audits came up when ASQA personnel expressed the following views:

• RTOs must document every action that is subject to compliance.
• Only documents can be used as evidence of compliance.
• RTOs must authenticate every document that they use as evidence of compliance.
• The compliance standard for third party auspicees is higher than the standard for the auspicing RTO.

The audit standards, however, do not support these views.

Audits are done under the Standards for Registered Training Organisations 2015 (the SRTO). The other relevant standards are:

• The BSB competency standards for auditors. The previous version was BSBAUD402 Participate in a quality audit (Release 1) issued in August 2001. Its replacement isBSBAUD411 Participate in quality audits, (Ver. 1), issued in October 2020. See appendices 1 and 2 for quotes from the relevant sections.
• Code of practice: ASQA Auditors and course accreditation assessors (ASQA).

The question is What is required for compliance? It is not What is required for best practice? In part one, the SRTO defines itself as a compliance standard: To comply with a Standard, the RTO must meet each of the Clauses. As a compliance-driven system, it promotes mediocrity; the intent is that RTOs achieve the minimum requirement, not that they seek excellence and best practice.

The question of evidence

1. What is evidence in the standards?
   
   None of the standards define evidence, although BSBAUD411 mentions a range of sources of information, documentation, and Communicate with relevant parties. BSBAUD402 specifically mentions interviews, as opposed to the vague communicate in the newer version.
    
2. What corroboration of evidence is required under the SRTO?
   
   None.
    
3. What corroboration of evidence is required in auditing good practice?
   
   From an auditor’s viewpoint, interviews and documents are both evidence. A document alone is not usually adequate evidence that something was done. It is just as easy to manufacture paperwork as to tell an untruth in an interview. Best practice in auditing was once to require corroboration, for example, the auditor would ask people about the documents, how they were generated, who had appproved them, who had read them, and where they were kept. This seems to be reflected in both BSB standards, but not in the ASQA guide.
   
   Exclusive reliance on interviews for information in not banned, but carries risks for both auditor and auditee. For example, a key interviewee might leave the organization, and different interviewees might have different versions of the information.
   
   (A document alone is only adequate evidence if the SRTO requires RTOs to have that particular document e.g., an insurance certificate).
    
4. Should compliance requirements be addressed in documentation?
   
   The SRTO mentions only a limited number of items that must be documented. (See Appendix 2.) None of the relevant standards (SRTO, ASQA or BSB) makes a general requirement that RTOs must have documentary evidence of compliance.
    
5. Should all activities subject to compliance be documented?
   
   This is not the same question. For example, what is all? Consider the example of an RTO that auspices to a school. Do all visits to the school need to be documented?
    
6. Do all activities and source documents need to be authenticated?
   
   No. The SRTO requires requires only authentication of incoming transfer credit and even then, only if there are no AQF certification documents. On the basis of reasonable, a caveat could be deemed that the RTO must be confident that documentation is not fraudulent. Other than that, the standards don’t require any authentication.
   
   As the standards don’t require general authentication of documents, they also do not specify who must do it.
    
7. What about providing information to students, such as pre-enrolment information and assessment results? Do the Standards require that the staff member record that it has been done or do students have to sign a form that “I have received information XYZ”?)
   
   The RTO needs a way to confirm that it has been done. Interview evidence is satisfactory according to audit standards, although risky. The Standards do not indicate any particular means of recording what or even that it was done.
    
8. What about providing information to students of an ausicee, such as pre-enrolment information and assessment results? Do the Standards require that the Centre rather than RTO staff in the auspicee attend and record somehow what was done?
   
   No.
    
9. Do the standards require that staff qualifications be verified, e.g. certified true copy or checked with original issuer?
   
   No.
   
   
10. Do the standards set a higher compliance standard for auspicees?
    
    No. Standard 2 makes RTOs responsible to ensure that auspicees comply with the Standards. That probably means that the same scrutiny applies to auspicees as to its own programs; it doesn’t necessarily require greater scrutiny for auspicee programs.
    
    However, risk factors might apply, especially if the RTO suspects fraudulent behavior.

Appendix 1: Excerpt from “BSBAUD402 Participate in a quality audit (Release 1)”

• 3. Gather and analyse information
• 3.1 Access a range of potential sources of information
• 3.2 Collect and make an initial assessment of sample documentation
• 3.3 Interview appropriate persons in relation to relevant documentation
• 3.4 Identify and report patterns, trends, interrelationships and areas of risk
• 3.5 Identify aspects of the audit that require the use of specialists and request appropriate assistance
•  
• 4 Evaluate information
• 4.1 Evaluate information against prescribed benchmarks
• 4.2 Form a defensible opinion as to the meeting of these benchmarks by the auditee
• 4.3 Ensure opinions are formed from and supported by available information

Appendix 2: Excerpt from “BSBAUD411 Participate in quality audits (Ver.1)”

• 3. Gather and analyse information
• 3.1 Access a range of sources of information relevant to task
• 3.2 Collect, and make an initial assessment of, documentation
• 3.3 Communicate with relevant parties in relation to documentation
• 3.4 Analyse patterns, trends, interrelationships and areas of risk, and communicate to team according to own role and responsibilities
•  
• 4. Evaluate information
• 4.1 Evaluate information against prescribed benchmarks
• 4.2 Form an objective decision regarding the level of compliance found
• 4.3 Check decision is formed from and supported by available information

Appendix 2: SRTO documentation requirements

The SRTO requires or clearly implies that the following items be documented.

1. Glossary. AQF certification documentation (i.e. graduation documents) [term also used elsewhere]
2. Glossary. Assessment system …
3. 1.3.c) learning resources
4. 1.9. The RTO implements a plan for ongoing systematic validation of assessment practices and judgements ...
5. 1.9.d) how the outcomes of these activities will be documented and acted upon.
6. 2.3. The RTO ensures that where services are provided on its behalf by a third party the provision of those services is the subject of a written agreement.
7. Standard 3. The RTO … provides access to learner records.
8. 3.4. Records of learner AQF certification documentation
9. 3.4.b) authenticated VET transcripts issued by the Registrar.
10. 3.6.d) ensuring the security of Student Identifiers and all related documentation under its control, including information stored in its student management systems.
11. 4.1. Information, whether disseminated directly by the RTO or on its behalf, ...
12. 5.2. ... the RTO provides, in print or through referral to an electronic copy, current and accurate information
13. 5.3. Where the RTO collects fees from the individual learner, ... the RTO provides or directs the learner to information
14. 6. Complaints and appeals are recorded …
15. 6.1, 2. The RTO has a complaints policy … an appeals policy
16. 6.4. ... the RTO: a) informs the complainant or appellant in writing,
17. 6.5. The RTO: a) securely maintains records of all complaints and appeals and their outcomes; and
18. 7.4. The RTO holds public liability insurance
19. 8.1. The RTO cooperates with the VET Regulator: ... f) in the retention, archiving, retrieval and transfer of records.
20. 8.4. The RTO provides an annual declaration on compliance with these Standards …
21. Schedule 4. Conditions of Use of NRT Logo
22. Schedule 5.
23. 8. a) ... registers of all statements of attainments issued;
24. 8. b) ... records of statements of attainment issued for a period of 30 years;
25. 8. c) provide reports of its records of statements of attainment issued to its VET Regulator on a regular basis, as determined by the VET Regulator.