Weaknesses of the SRTO
Ignores actual learning
The SRTO is preoccupied with administrative requirements and generally ignores what instructors actually teach and what students actually learn.
Documentation
The SRTO generally refers to what RTOs must do, and doesn’t mention the amount of required documentation. Some auditors require everything to be written, but the SRTO doesn’t actually require it. Explicitly required documentation is listed below:
- Graduation documents
- Assessment system
- Validations of assessment
- 3.4. Graduation records
- 2.3, 8.2. Agreements with third party providers.
- 6.3. d) acknowledgement of complaints and requests for an appeal
- 6.4. a) Informing complainants and appellants if processing will take more than 60 calendar days
- 6.5. a) records of all complaints and appeals
- 8.4. Annual RTO declaration
The SRTO does not require other items, especially policy, to be documented although it would be normal. However, ASQA's desktop audit procedure requires that RTOs document all compliance.
Trainer and assessment qualifications
Schedule 1 mentions some Diplomas, but it is unclear whether it includes any listed iDploma or any diploma in adult education. Persons holding Diploma are not qualified to validate assessments.
Requiring the two extra units for the TAE Cert IV was probably a mistake. Qualifications in Training and Assessment become obsolete very quickly, even though the competencies change relatively little.
Interpretation
Although not a fault of the document itself, it is subject to various interpretations. For example, auditors can easily decide that their task is only about checking documents, and ignore all practices, including teaching and learning. In other words, the SRTO emphasises what RTOs must do, and some auditors only view what is written.
A collection of patches
The SRTO contains several sections that specifically address particular problems in the not-too-distant past. They are best understood in terms of the problem that they are intended to resolve. The most obvious examples are:
- Determines the amount of training (I.e. An RTO may not give students a book and say, "Show up in four month's time for the exam.")
- Does not guarantee that students will successfully complete a training product.
- Does not guarantee that a training product can be completed in a manner that does not meet the requirements.
- Does not guarantee that students will obtain a particular employment outcome if it is outside the control of the RTO.