Angela Connell-Richards: 0:31

Welcome to the RTO Superhero Podcast with my special guest host, lauren Boone-Hollows, who today we're going to be discussing a very hot topic of what's happening in the education sector right now, in particular, with international education and the pressures of government. Welcome, lauren. Let's get started with Boxing gloves are off. Yeah, get the boxing gloves off. Yeah, I think let's get started with the big picture of how would you describe the current state of international education in Australia right now.

Lauren Boon-Hollows: 1:10

So, look, unfortunately, we've been in this position before. Angela, you've been around for a while. I know I have too. We felt this way in 2016. We have felt this way in 2009 and we feel this way again. And look, I'm sure that in seven or eight years, we will feel this way again. And look, I'm sure that in seven or eight years we will feel this way again.

Lauren Boon-Hollows: 1:29

But there does seem to be a concerted effort at the moment to significantly reduce the, you know, the VET workforce and the international cohort. There are some legitimate and genuine reasons for that, which we can all understand. International students are vulnerable students. There have been and there will always be issues such as we see in ghost colleges, where you've got, you know, really bad practices from education agents who are making false promises, and you've got RTOs who are willing to support them in that, and you've got some even worse issues where you know there's some real human abuse that's occurring as well.

Lauren Boon-Hollows: 2:13

However, unfortunately, when we go to address those issues, there's often this kind of massive course correction over course correction that happens, and what we generally see around about every seven to nine years is a concerted effort to, I guess, regulate international RTOs in such a way that it has a massive business impact and I would say you know, if it was happening from anyone other than the government, would basically be anti-competitive practices that are put in place on a lot of these RTOs to effectively throttle the RTOs, to significantly reduce the, to change the regulatory environment so much that there is no security from a business perspective, there is a severe limiting of any potential to grow or develop business and even a limit to be able to operate within fiscally responsible categories. So we're looking at international RTOs who have to have massive premises, much higher rates of students to staff, you know, additional requirements in terms of making sure that everything is 9B compliant. The costs that are associated with that are huge international education agencies take massive advantage.

Lauren Boon-Hollows: 3:34

Um and and. When times get tighter, that's when the education agents really smash rto. So some education agents expect, you know, upwards of 40, which is effectively all of the profit that any potential RTO can make, and generally then some, you know, in order to get a visa across the line. And so what we're seeing at the moment is we're just seeing huge amounts of cryocross RTOs exiting the sector. Some are exiting by way of just selling out, some are exiting by way of the fact that they're financially strangled and many, almost all, are being limited from entering the market. So look, unfortunately, it's really sad, and I guess the bigger problem that I have with it is that I'm a huge advocate of the regulator. I always have been. I believe that strong regulation and I know you feel the same strong regulation in our sector is really important Improves our quality of our education.

Lauren Boon-Hollows: 4:36

Absolutely. But trust in the regulator to evenly audit across everyone is also incredibly important as part of that. Across everyone is also incredibly important as part of that. And at the moment I'm seeing TAE RTOs getting their re-registration without a look-in and you know international RTOs of 70 students being dragged through a 24, 36-month renewal process. You know whereby we're demonstrating to them that we're doing weekly QA meetings which are logged in Accelerate's quality register. You know all of the assessment tools contextualised for international students, all the validations up to schedule, all the trainers' trainer matrices in place. Think like I've got assessment tools that have passed an international like past a domestic audit in the last three months. That exact same assessment tool right is now um being told that it's non-compliant for an international student. And I'm kind of going.

Angela Connell-Richards: 5:41

I literally have an audit report where you've said that this is compliant, where you've, where you've looked at this assessment tool and said this is compliant and now you're telling me six months later it's not, and you're saying um, also when we were chatting earlier, that um, they're making some massive changes when it comes to international students and what are the requirements, so it's putting more burden on the rto because they've got to contextualize it.

Lauren Boon-Hollows: 6:08

Yes, you should always contextualize your assessment tools anyway to the learner cohort, but I think from what I'm hearing is it's going overboard yeah, and I look, I think I think one of the challenges is is that, um, I know that there are a lot of new regulators coming through asqua and I know that there's a lot of them that coming through ASQA and I know that there's a lot of them that haven't worked in RTOs before, which is always challenging. Rtos are a beast and our industry is so diverse, but there's a lot of practical things that occur in terms of you know understanding how an RTO works and you know practical observations is a great example of that. When you have, you know 10, 15, 20 students that are undertaking a practical assessment. You've got. You know 12 students 20 students in a kitchen, you know, you've got. You know you've got students running a group presentation or you've got you know six groups of four students that are all working and you know, as a trainer and assessor, you're moving around and you're looking at what each of those students are doing and you're making sure that everything happens safely and you're you know you're documenting all of those interactions and you know, like I'm always scribbling, you know massive notes and kind of going so-and-so is doing this really well, right? Pull this person aside, give them that live feedback to you know tweak and make sure that they're meeting that competency standard. Those are the focuses and that's the really beautiful stuff that happens when you've got like these big group training things, like you've got the ability to kind of you know really kind of get that atmosphere happening where it's kind of buzzing and everyone's creating stuff and you know like there's so much good learning and so much good assessment and so much competency being demonstrated in those scenarios.

Lauren Boon-Hollows: 7:55

But the practical realities of them is is that you don't have a trainer and assessor sitting there with 20 ipads going through and you know the focus is not on ticking a box. The focus at that point is on determining competency. And determining competency is an iterative process and every so off, every so many years and and there's, I think, over the last really 10 years we've seen this degrade more and more. When an assessor who has their TAE, who has their industry qualifications, who has currency in TAE, who has currency in their industry, turns around and ticks a box to say they can do this, more and more and more, we are saying not good enough, yeah. And if that is the point, like if we're ultimately going to turn around and say, unless I as the auditor or I as the validator? See it with my own eyes. You, as a qualified industry trainer and assessor, you telling me that you ticking a box and signing a declaration to say that they are competent is not enough.

Angela Connell-Richards: 9:04

Sufficient.

Lauren Boon-Hollows: 9:06

Right, say that they are competent is not enough, right?

Lauren Boon-Hollows: 9:11

I don't know how else our industry, so I don't know how our industry survives that short of having a camera on every student in which case we take away like we're taking away from the educative experience, the training experience, the assessment experience, every and and the other thing is is why would I want to be a trainer, like our industry? Is the educative experience, the training experience, the assessment experience. And the other thing is is why would I want to be a trainer? Like our industry is so short of trainers? But why would I want to be a trainer If nothing, I say nothing, I do no comment, that I write is good enough for you to believe that I know that that student can do it.

Lauren Boon-Hollows: 9:43

Yeah, without a video or an observation, that's right and competency isn't determined on that one observation Certainly not. It's taken over a period. It's taken from me working with that student over time and, yes, they'll have bad days but, like, I've seen them do the planning and do the communication and do the skills over that period of time. So when I, as the assessor, say they can communicate, they know the safety policy, they know how to do this safely, they know how to do it within industry time frames. But if I it doesn't matter how often I say that, doesn't matter what declarations I sign, it doesn't matter how many boxes I tick I'm consistently being told it's not sufficient. It hurts our industry Like it just seriously hurts our industry.

Angela Connell-Richards: 10:30

So there are other issues that are coming into the reason why international education like when we think about pre-pandemic international education was vying for first and second position as the biggest export out of Australia and the pandemic absolutely crashed that. But we've never got back. We've never got back to that level and now we've got two governments that are vying for the political station right now when it comes to the election and the big focus is on accommodation and that there is a lack of accommodation. So, yes, I can understand this. We need to put Australians first, but we also need to, we need the workers. So what are your thoughts on the government trying to squash the international education market because of lack of accommodation?

Lauren Boon-Hollows: 11:52

I think it's just a political handball. I think it's short-sighted. I think that both are both major parties. In fact, I think the majority of the parties within Australia have such a fundamental lack of understanding of the benefits that international education brings in. So international education has been in a top four export, just under coal, iron ore, for the last, I think, 10 years, some years, contributing $50 billion on the top line right to the Australian economy. Now, what then flows from that is a significant amount of workers that are open to doing jobs that potentially not a lot of Australians want to do. There is also, you know, a huge amount of work that flows for Australians our RTO administrators, our university administrators, our trainers and assessors, our university lecturers, you know, particularly within our university sector. Without the international money to prop up those universities, those universities would actually fall over. Without, you know, the international students to support our sector, you know there would not be the money flowing in from international education to support a lot of the important initiatives that we run for job seekers, for asylum seekers, for, you know, trainees and for apprentices, and all of the government funding programs that we do, which are so incredibly important and vital.

Lauren Boon-Hollows: 13:32

The only reason I got into this industry was because I was literally I was. I came from an abusive relationship. I became a trainer. I was working with moms who had come from abusive relationships as well, and I was getting them into jobs and getting them trained and getting them skilled up, and it was the most life-changing experience of my life. It was life-changing for them, and that is what that does it's.

Lauren Boon-Hollows: 13:52

It's an incredibly beautiful thing, but all of that requires money to support it. There's huge education initiatives that happen for Aboriginal and Torres Strait Islanders and our First Nations, and the money that we get the $50 billion that we get from international education goes to support a lot of those initiatives and all of the other money that then flows in from it. Accommodation is an issue. Right, I'm not going to lie, accommodation is an issue, but we can deal with that by deregulating the ability to build houses and also, in order to build more houses, guess what we need to do. We can deal with that by deregulating the ability to build houses and also, in order to build more houses, guess what we need. We need electricians, we need brickies, we need carpenters, we need plumbers, and all four of these areas are supported by international education providers yeah, right, they're supported by that.

Lauren Boon-Hollows: 14:43

So if we need more of those people and there are people willing to come in and spend, you know, 15 to 20 000 a year in order to become a brickie and then want to, you know, be you know and you can, you can organize legislation so that you can say right, well, if you're an international student and you're going to come in and you're going to study being a brickie, then you've got to work as a brickie. We're going to limit your work visa to you being a brickie. Right? That's a really simple solution. People have been talking about it for ages. I've put it forward. I know multiple other people in understreet has put it forward and gone. If you're going to come over and study something, be it electrical, be it, you know, brickie, be it.

Lauren Boon-Hollows: 15:23

Um, aged care, right, be it electrical, be it, you know, bricky be it aged care, be it nursing right, be it hospitality, whatever you're studying, that's the industry that you can work in and that's what you're limited to, right so effectively. International kind of becomes like a, like a traineeship, apprenticeship style as well. Right Increases the quality of the training and assessment increases the competency. You can do. All of those sorts of things, those sorts of initiatives would be great. The initiative to turn around and go. Well, we just need less international students as a blanket, but we're going to continue to allow higher education because you know what. We need more postdocs, or we need more people studying a master's in business administration or a master's in you know, I don't know postgraduate dance theory or something like I don't. We don't need those. We don't need any of that in Australia. Limit the visas to what we need, no problems. We need builders, we need nurses, we need aged carers. Need you know plumbers? Let's.

Lauren Boon-Hollows: 16:26

Let's use the vocational education system to support building australian skills and fill our skills gaps in australia yeah, not target it and tick like, tick a box and say that if we think that we limit the number of international students, there is magically going to be more houses. That's just. I mean, it's just such a short-sighted, you know view for both major governments to be taken. It's really, really disappointing.

Angela Connell-Richards: 16:54

My thought on this is also what about, like the regional areas, there are regional RTOs and CRICOS providers that don't have accommodation issues. Maybe they should push more funding to go, or visas to go, to regional areas, where they can then also build those skills that we need in Australia.

Lauren Boon-Hollows: 17:20

Yep, and I mean, like the 88-day visa is a great example of that. You know, quite often, like I obviously live in regional Queensland and far north and so we get a lot of people through here. We're actually coming into our winter season, which is, you know, our busy season for the year, so we've got a huge amount of providers that are putting out there and going, hey, we will take on people for their 88 days of, you know, regional work. We'll provide you with accommodation, um, you know, and all of that, like there's, there's that opportunity when you're coming out regionally and again, I know that there's a couple of places up here that do similar things from, like a study perspective, like come here, study here, you know, and like build out the economy of rural and regional Australia because, again, like that's a fantastic thing, we need more people to come out country, in, you know, in Australia.

Angela Connell-Richards: 18:16

Yeah, and I'm in Newcastle, which Newcastle also has, like, we've got the University of Newcastle and there is student-specific housing that is now empty because we don't have sufficient students here to fill that accommodation. So, yeah, my thought is why, you know, if we could solve the world and the issues of international education, my thoughts would be let's throw it into regional areas where they need that tourism, where they need that support of people living in the accommodation and working in those areas as well. I think there's many opportunities for where we could redirect international students.

Lauren Boon-Hollows: 19:03

Yeah, and I mean, look, it does form a part of our tourism economy as well. We get a lot of people who come through here and you know, like international students will. You know, they might start here on a holiday visa, you know, study a little bit of English, then go onto an Helicos visa, then jump into a VET visa and they do stay for a long period of time and I'm not going to lie that. You know there are people that overstay and there are people that take advantage of our system. And look, if you have lost your visa and you've gone through the ART process and they've said no, you're not. You know you didn't meet your obligations, you weren't a good international student, you didn't meet your requirements, then you need to go home now and that's absolutely fine. Like I want people to operate within the legal bounds and confines of our system, in the same way, I want every RTO to operate within the legal. But I want you to provide good training, I want you to provide contextualized training, I want you to provide those support services. But if we're going to hold RTOs to, you know, the legal standard, then hold everyone to the legal standard right, and we need to have faith that our regulator is going to apply that. And it's, you know, the education team at ASQA is so brilliant. They, you know, they're putting out all of these practice guides, they're attending every conference, they're sitting and they're talking to intern like they're talking to RTOs, they're actively trying to solve problems and it's like it's a little bit heartbreaking to know that there's like all of this beautiful work that the regulator is undertaking. But then, when we get to the regulation side, you know, if we don't, then you know, even handily apply it.

Lauren Boon-Hollows: 20:49

Like I just I get providers coming to me more and more going it honestly, doesn't matter what we do. Like the intent is very clear that they've made a decision that we're not going to get through. And we're not going to get through. And you've got like smaller providers that will turn around and go. I'm just not willing to like run my, my personal and my business into the ground. Um, we're just going to give up, you know. And then you've got other providers that are fighting for it and you know, like that's that's a really hard thing to see.

Lauren Boon-Hollows: 21:21

Like I've talked to several providers in the last couple of weeks who, you know, want to start up an RTO or they're going into their re-registration this year and I've literally I sat down with a provider last week and I was like you know, you guys are really good, we've updated all your assessment tools, we've got all these quality notes. I said, but you're an international RTO and they're like, well, what do you mean? I'm like I don't see you. I don't see this is not going to be an easy ride. You're going to get delays. You're going to be told things are non-compliant, when my professional perspective is that it's probably not. Um, you probably are compliant, but regardless, you're in for a fight Like this is not going to go through easily.

Lauren Boon-Hollows: 22:01

You're going to be in for a fight for the next 12, 18 months until we get through this next rough patch. And they're sitting there kind of going but like we've done everything right, Like we've been engaged with them for like 18 months now, setting up new business processes for them, you know, refining all of their trainer matrices, updating their assessment tools, doing all the validation. You know recording all the quality meeting minutes and everything like that, recording all the quality meeting minutes and everything like that. It's heartbreaking to see that work going into an rto of somebody who genuinely wants to do the right thing and not have any of it recognized when they go into an audit, because there there is a validation component of like we're like, we're trying real hard, guys, we're trying real hard, and when you see the regulator going it's just not good enough.

Angela Connell-Richards: 22:42

Like yeah, yeah, this is a good segue into the ASQA pressures at the moment and, in particular, around assessment tools and compliance and what you've been experiencing. We've been experiencing that pre-assessment validation is usually focusing especially on the learner cohort, contextualisation and industry specifics for the provider. So, yes, I do agree that we do need to contextualise for the international market, but can you see what it will actually the future will be if we continue this way in particular? But you've mentioned that ASQA is now requesting this pre-validation of assessment tools. We've seen it as well at Vivacity. Can you walk us through what this actually looks like in practice for a CRICOS RTO?

Lauren Boon-Hollows: 24:03

Yeah. So I guess, first and foremost, I get a lot of RTOs that come to me and go oh, but we purchased our tools pre-validated, so under the current standards, the responsibility is on the RTO to, you know, ensure that their assessment system is compliant at all times, and part of that assessment system is having compliant assessment tools. So, believing without actually validating, um, even under the old, under the old rto standard, under the current rto standards of 2015, not really enough, guys, like you know, like it's just you know you've got to do these things yourself. Um, so that's I guess that's point number one um, under the old system, what I would say is is like there was probably a lot more lenience for, oh well, we've, you know, we've done a pre-validation on a couple of the units. We've checked with the, you know. We've checked on the provider. We've done a pre-validation on a couple of the units. We've checked on the provider when we've built them into the system.

Lauren Boon-Hollows: 25:11

We've been cross-checking the mapping and we're pretty happy with that and we've got a little bit of evidence, maybe some emails or maybe a validation form or something like that, under the new standards, when the new standards take over on 1-7-25, it's so black and white. It's so clear within this Every single assessment tool needs to be pre-validated before use. Now what that will actually look like when the audits come in of the formal new standards, I think we will see two versions of it, unfortunately, I think within the domestic market. I think there'll be a kind of a grandfathering in of like okay, well, we've got a validation schedule in place that includes pre-validation and it includes the post-validation. So the pre-validation of, like, the assessment tool structures and the trialing and the testing, and the post-validation of the assessment judgment itself, right? So when I use the term pre and post-validation, that's what I mean.

Lauren Boon-Hollows: 26:13

I know everyone's got their own you know, testing, moderation, validation we won't get into that today. I think for internationals they are going to be held to a very strong line of show me the pre-validation form that has been done for every single assessment tool that you have. Um that you've delivered in the last year. Um, and it's very easy for me to pull that report because I can go and I can pull your last um, avs, avet, mislodgement, and I can filter all of the units of competency that you've delivered in the last 12 months and I can pick six or seven of those at random and you need to be able to show me that you've done pre-validation on them. And I wouldn't hazard a guess that there is maybe two percent of RTOs out there that would be able to meet that requirement. Um, I agree, you know, yeah, like the vast majority of rtos do validation poorly. Um, there's some great pro like there's, there's, you know there's tools out there. Now you know like obviously you know, we both know vanessa at prickly sweet, her whole thing is validation, produces that automated report and everything like that. Um, you know ai is getting better and better at kind of starting to review and I think that we're going to continue to see that that technology flesh out.

Lauren Boon-Hollows: 27:37

Um, but you know how RTOs document and again, even with some RTOs, they may be doing it but not documenting it. Doing and not documenting is a big problem for RTOs. So I think we're going to see a really strong adherence to like no, you're delivering this tool. Demonstrate to me that you've actually done some sort of a check yourself, as the RTO, that the assessment tool is compliant. Like, show me that you actually, you know, know that what you're delivering is compliant. To be fair, like, yeah, you should be like, as an RTO, if you aren't delivering an assessment tool, you should have checked that that assessment tool can actually, you know, take on, you know demonstrate competency meet all of the requirements, gather all the required evidence.

Lauren Boon-Hollows: 28:34

That's fair and reasonable. And there's kind of something with that. Rtos have been like bucking a little bit, like they've been passing the ball a little bit on that one with the whole. We purchase compliant, you know, like we purchase compliant assessment tools or you know, I mean even people who purchase from us like our assessment tools are contextualized for the state and the cohort and the delivery model. But even our assessment tools come with like a little pre-validation in the mapping guide to say, hey, as the RTO, I've actually checked this, so now I know that you know, for us we're actually fleshing out that process and kind of going okay, we're no longer actually just going to build the tool for you in your system, we're actually going to need to start having some meetings with you and actually like documenting that pre-validation process with you which is super like, super easy to do.

Lauren Boon-Hollows: 29:27

Guys, honestly, get an ai note taker, jump onto a team's meeting, spend half an hour reviewing the assessment tool. Get your ai notes, chuck them into your quality register. Bob's your uncle. You're done like it's not rocket science, but it's time, you know, and there's a lot of jobs that have to be done in our land so, and it's not as much time as it used to be, thanks to ai, so we we can do it much quicker.

Angela Connell-Richards: 29:54

But a bigger thing that we already have discussed, uh, before we got online, was when you're looking at these requests that we're receiving from ASQA with regards to pre-validation, is there consistency across providers or are you seeing targeted behaviour, especially towards international providers?

Lauren Boon-Hollows: 30:18

Yeah, unfortunately and look, this is just my experience, and so there may be consultants out there or there may be RTOs out there who have a completely different experience um, my experience at the moment is very different and I and unfortunately it's come to a point now where I'm advising clients differently based on whether or not they're domestic or whether they're international. Um, I've got international, I've got domestic clients that are going to go through registration this year. Um, they're very solid and I've said to them look, I don't, I don't think, I think we'll be okay, I think we'll. You know, I will make sure that we can robustly defend this and we can robustly defend that um, but I'm confident that we'll get through. Um, I wouldn't say that to an international rto at the moment.

Lauren Boon-Hollows: 31:03

I've already outright told RTOs that are looking at registering, as Cryocast have said don't do it. I've said wait 18 months, because you're not going to get through in the next 18 months anyway. It's going to drag all of your resources and you're likely just going to be spending money for nothing. So let's not do it now, let's wait 18 months. I've got, you know, clients that are going through. They're going to be putting in registration, re-registration this year and I've said to them we're in for a hell of a fight. You know my our, you know. I think our best case scenario is that we can drag the re-registration out for 18 months to a point that the regulator calms down, that the election is over, that things settle, that they realize the importance of international education, that we start losing that many students and we start losing that many rtos. The government feels they can tick a box and say they've had a win and they can return to normal auditing. Um, and this is what's happened every other time.

Lauren Boon-Hollows: 32:01

Like you, know yeah everything swings and roundabouts in international education, but I've been very clear, like my advice, the road forward and the standard that the clients are being held to is, for me, for the experiences that I've seen, very different across RTOs and I will continue to provide advice to clients very differently based on whether or not they're international or domestic. And again, I understand some of the reasons for that. I get the regulators' reasons for wanting to apply pressure. I know some of it is external to them. They're getting advice from ministers, they're getting ministerial ministers, they're getting ministerial directions and border protection Exactly.

Lauren Boon-Hollows: 32:50

But it's just, it is heartbreaking. It's heartbreaking because there's a lot of good things that international education does and every time we go through one of these processes it hurts the Australian reputation it has. I mean, as a small business provider myself, I feel and I feel it a lot more this time round, having run a business for five years than I did last time, where I didn't really have that concept of how much you sacrifice to start up a business and watching people like sacrifice and sacrifice and give up their own wages to pay their staff, or you know, to make sure that they can meet to pay their staff, or you know, to make sure that they can meet ASPA's requirements or, you know, dole out more money to lawyers and things like that, when they are genuinely trying to do the right thing for their students and for themselves and, you know, for their staff, is really disappointing.

Angela Connell-Richards: 33:42

Yeah, we're seeing that in particular for initial registration with CRICOS. It's taking a long time before they actually get to an audit and then when we do, there's very much a focus on the learner cohort and secondary language. This is the big thing, and having clear and detailed instructions for the international student market when it comes to the assessment tools. But one of the things and we've raised this already is there's a very big difference between when assessment tools are validated by the auditors for domestic compared to international. They seem to be a lot harder on the international. It seems to have increased compared to what it was in the past. You were talking earlier about this exact example of the same assessment tools, but for domestic and international. What was the main differences that they were targeting? What was the evidence that they were looking for?

Lauren Boon-Hollows: 34:51

So I think there's two areas with internationals that there's a much stronger focus on. I think the first is authenticity. So obviously all students are getting more adept at using ChatGPT we all are and being able to identify authentic submissions is becoming more challenging. I know at AnnaWire we balance that by like any submission, like if there's a presentation or if there's a report that's due or a paper that's due, we always do written questions, but the written questions and then the you know, the paper and the report are generally then, you know, finalised with a presentation whereby the assessor has an opportunity to kind of go right. Well, I know you've written all of this and you've probably written it with ChatGPT, but let's actually find out that you know what you're talking about right, so it gives them a really good opportunity and to us that's the best authenticity mechanism that we can build in right. And I know universities are going very much the same way. I had a chat just last week with a couple of university lecturers who are saying you know, they're moving to a lot more verbal assessments and things like that in light of chat GPT. So I think that's a big focus is like, and things like that in light of chat, gpt. So I think that's a big focus is like calling you know, like questioning whether or not the assessments are actually authentic to the students. And that issue exists with every student, like I mean, apprentices and trainees know it as well as you know, any other international student, so I don't see why that should be regulated differently across one or the other, but it's being it's, it's being brought up in internationals and it's not being brought up with domestics at the moment. Yeah, um. Then the other issue is is the issue in and around observations being undertaken by our trainers and assessors? Um, and again, you know, at the end of the day, uh, yes, we have tick boxes. Okay, almost every RTO has to utilize observation checklists.

Lauren Boon-Hollows: 36:50

A good observation checklist is not a copy and paste of the performance criteria, it's a. You know, this is the skill that we're looking at and then this is what it looks like. So it's built out with a lot of benchmarks of like okay, well, if we're talking about good communication, we're talking about thinking about the tone and pace, and we're thinking about the body language and we're making sure that they're utilizing industry terminology correctly, right, we've got all those benchmarks that then sit underneath it and what we're seeing from the regulator at the moment is a questioning of like saying, well, you've got a checklist, but that's not sufficient. And I'm like, okay, well, I agree with you that a checklist is not sufficient, but we don't have a checklist. We've got a checklist backed up by you know, very detailed benchmarks, backed up by generally a form. So like if a student is creating a recipe or you know building a recipe, they'll fill out a recipe card on like what the recipe was and you know how they had to, you know, adapt it for a customer request, or what techniques they used and what ingredients they used. So they fill something out that kind of supports what was actually done. Same with job cards. You know, like if somebody is building, building a wall, we put the take five with it, right, or we put the swims with it, or something like that. So no matter what skill we have, um, that we're assessing generally, there's like a supporting you know document. Behind it, there's an observation checklist and there's robust benchmarks. Those three things together are the foundations of a strong assessment tool, and what we're starting to see come out again is this thing saying that that's still not sufficient.

Lauren Boon-Hollows: 38:31

You know, and I'm kind of going well. You've got a qualified trainer and assessor. You guys have agreed that they are industry current. You guys have agreed that we're providing professional development for them. So they're they're a qualified trainer. You agree, they're a qualified trainer. They're saying that they've seen this being done. We've got supporting evidence from the students. We can't upload videos to asquire portals, right, so we don't have like, if you want us to, we'll take videos and we'll upload the videos there, but you won't actually allow our squad uploads of videos. So we've got pictures of the final dish. We've got a form signed by the student to say all the steps that they took. We've got observations by a trainer and you're still calling bullshit as to whether or not it was done.

Lauren Boon-Hollows: 39:20

I don't know how else we can demonstrate authenticity short of recording every single student, uploading it into the student portal and just having assessors sit there and mark.

Lauren Boon-Hollows: 39:34

And the practical business reality of a decision like that is going to be a reduction in the quality of training, a reduction in the quality of assessment and an offshoring of a sugar load of trainer and assessor jobs to countries where it is more financially viable, because I can get a TAE qualified trainer in Philippines to sit there and mark.

Lauren Boon-Hollows: 40:05

But you know, I would much rather have a trainer on the ground in Australia. And if our governments are as they say they are, for more jobs in Australia, for building the Australian economy, right then we want to focus on having our trainers training and assessing live in person with our students and that's what we want them to be focused on. But if we want really good trainers and we set some pretty high benchmarks for trainers and assessors in australia, if we're going to set those high benchmarks for them, then when they say and when they sign a declaration that the student is competent and that they've seen them do that skill and we've got supporting evidence that they've done that skill we have to believe them. We have to say, okay, you've seen them do it. You've signed to say them do it. You've got some additional evidence from what they've been doing. I'm not going to put a camera in every classroom and make an assumption that you're going to lie to me every time you fill out an observation checklist.

Lauren Boon-Hollows: 41:26

We just we can't do it. We're going to lose all of our trainers and assessors.

Angela Connell-Richards: 41:31

Yeah, yeah, yeah, and I can see this issue and like they're trying to get more trainers back in but they're causing more issues when assessors need to do more more of this type of work. I'm just going to change track a little bit. Have you seen evidence of ASQA using minor non-compliances as justification to question someone's fit and proper person status, and what procedures does this set or precedent does this set?

Lauren Boon-Hollows: 42:05

yeah. So look, I mean obviously ask who's been going after fit and proper person for a while now. New fit and proper person um came out last year and I think you and I had a chat about this and we were both like, absolutely like, I don't want, I don't if someone is has had their rto shut down before you know if they've been that quiet, shadowy figure that operated during the vet fee help scandal. Like we need to understand who is operating RTOs and I think that's fair. I you know. I think there's probably a few tweaks that I would like to make to the fit and proper form Like. At the moment you've got to like I have clients even disclosing like all of their speeding tickets and stuff like that. Like so like they're getting pretty big um. You know my fit and proper person is now huge um, like it's like 40 pages or something like that. It's big um, you know so. So I understand the rationale for it and I think the intent is very good.

Lauren Boon-Hollows: 43:05

Unfortunately, I think the road to hell is paved with good intentions and in this particular case, what I've seen now in the last three audit reports that have come through is kind of a statement to the effect of you didn't address. You know it's taken you to audit reports or it's taken you. We had to identify the noncompliance. You didn't pick it up in the first place. So therefore you're unable to effectively manage a quality system right. Effectively manage a quality system right and therefore that makes you like not a fit and proper person, right, and I think that this is a.

Lauren Boon-Hollows: 43:49

I think we've got to be really careful with this, because no RTO is compliant 100% of the time. Every single one of our major TAFEs have received an intent to cancel at some point. You know, and we're not about to turn around to TAFE Directors Australia and say it's full of, you know, unfit and proper persons, right, yeah, um, half those people then go into work within governments and become regulators. So you know, like, all of us have worked in RTOs and and there is no RTO in Australia that is 100% compliant, 100% of the time. God knows we try, right, god knows we try, but it's full of people, it's full of students, it's full of human beings that are going to make mistakes, right, 100%. So what I want to determine at an audit and you know what I try and determine when I'm working with clients and I mean to some extent like price point plays a role in this.

Lauren Boon-Hollows: 44:45

Right, I'm like, well, unless you're like really willing to invest in, like getting your RTO right, and where you're willing to put in systems, and you're willing to like put your money where your mouth is, I'm not willing to work with you. Right, and there's been several clients where, like, I've gone in, I've taken a look at it all and I'm like it doesn't matter what I tell you, you're not going to listen to me, you're not going to make the changes. At the end of the day, you're chasing dollars, and I don't want to be associated with somebody that chases dollars, because, as consultants, we've got to protect our reputations pretty fiercely, pretty fiercely. Otherwise we end up with more problems for ourselves than anyone else. Right, and there's bad consultants out there that like-.

Angela Connell-Richards: 45:27

We'll take anybody.

Lauren Boon-Hollows: 45:29

So I think the intent of the fit and proper person is good. I think that every RTO is going to have non-compliances that the regulator is going to pick up on. I think this is particularly the case when regulator expectations change over time and the interpretations of standards change over time and we can't like. That is always going to be a thing. You know. It happens in WHS, it happens in quality management and ISO systems, it happens within education systems. The interpretation of how we need to evidence standards is going to continue to change over time. But as a result of that, as a regulator we have to give a little bit of grace and in the past there's been statements made by regulators as to like we're coming out to regulate you. This is not an improvement process that you're going through, but to some extent it is because when an RTO hasn't had a regulatory interaction for 7, 8, 9, 10, 15 years right, they're going off of ASQA practice guides and they're going off of, you know, professional development that gets put out there, of which there is a wide variety. If this was like the Singaporean government, right, in Singapore there's one TAE provider, right, that's the Singaporean government, right. They're very restrictive on who actually gets to get put through their TAE process or they're like the equivalent of their RTO process. And if ASKWA is going to become the TAE delivery person, right, like only ASQA can teach people how to do it, then that's fine. You can hold them to a higher standard. But like there's so much PD in our market, there's so many conflicting opinions. If an RTO has got evidence that they're demonstrating, that they're trying, but they haven't quite met the mark, like the regulator has been really good in the past at understanding and kind of going. Like I've gone through audits where the RTO has, let's say, 120 units on scope. They've got a timeline for getting all of them updated. They've identified, you know previously and maybe they're you know I think I did one early last year they had spent the last two years developing new assessment tools. They were about 45 of the way through. They were still using the old, non-compliant assessment tools and they were kind of like, yeah, we know these aren't good enough, but we know our training practices are good, we know the kids are coming out compliant. We just know that like the way we documented is not strong enough. Right, they and we were very upfront with the regulator that, like this is the new process. We've you know all like the we we've developed the schedule in line with, like what we deliver the most of so like we've so like we risk rated and we risk reviewed all of this. And like the high risk stuff we've updated and the ones with the most vulnerable cohorts, we've updated those. But we've got these ones which are like workplace trainees. We've got a plan to update those assessment tools and get them compliant over the next six months. But we're not there yet.

Lauren Boon-Hollows: 48:41

And the regulator was so great they were like we understand, we can see you're trying, we can see you're investing. We love this process that you're doing and it was such a wonderful experience, like the audits I had, you know, up to like August of last year with the regulator. They were so wonderful. There was so much listening happening, there were so many good communications happening and then, like come like August time, the communications just dropped off and all of a sudden it was like, yes, you'd have a quick closing meeting or a quick opening meeting, but that engagement and dialogue of like understanding how the RTO operates and, you know, digging into, like those tools, no, it all went to like. I'm just going to review the documents that you submit.

Lauren Boon-Hollows: 49:29

What do you think happened at that time? Look, I don't know whether or not it was. I think part of it was probably a resourcing issue, like obviously all regulators have to deal with like do I have enough staff? And I don't know whether or not it was kind of like that just the numbers, the numbers of applications or the numbers of issues were going up so much and so they didn't have the time like they don't have the time to spend working and talking to the clients and understanding how they operate. But a lot of the last ones have literally like we did have one with a course accreditation last year and we were working and talking with Asper and they were explaining to us like the little tweaks that we needed to make.

Lauren Boon-Hollows: 50:08

And it was again. That was just a wonderful interaction. Like anytime the regulator comes to a provider and genuinely seeks to like understand what they're doing and they can see that there's like such a good intent that sits behind it, I find there's a positive outcome right. But when all of the regulation is like very limited meetings and majority of is just reviewing documentation, I think as a regulator, you fall into a habit of making negative assumptions about providers and I get why they have a risk-based approach, so they deal with the worst of the worst. And when you deal with the worst of the worst like I know it's the same for some ART consultants you know they deal with the worst of the worst, so it's so easy to kind of get that in your head that like everyone's dodgy.

Lauren Boon-Hollows: 50:59

All of these are ghost colleges.

Angela Connell-Richards: 51:01

There's no genuine from one to another, to another. Yeah, yeah, it would be really hard like.

Lauren Boon-Hollows: 51:06

I mean, like that I I try and stay out of art for that reason, right, like that's why I love working with providers, you know, on an ongoing basis, because I get to see all the good stuff that happens. I get to see the graduations, I get to see, you know, like, the students being like, oh, you're seeing more stuff, amazing, or a staff kind of going, oh my God, I've learned so much. That's the really good stuff. But as a regulator, the education team sees a lot of that and I think that's why the education team is such a positive force for ASQA, right, because they go out and they have those talks, they go to conferences where, like you've got all of these, you know rtos that are like super pumped, like do the right thing and engage in and you know like, but the education team and the regulations teams experiences are chalk and sheets.

Lauren Boon-Hollows: 51:51

Yeah right one gets to see the best of industry, the other one sees the worst of our industry and, like, our industry is amazing and 90 of providers are trying to do the right thing, like I genuinely believe that in my heart.

Lauren Boon-Hollows: 52:05

But, holy cow, you and I have seen what the 10 do and it's heartbreaking and it's horrific I trust the name of all the good rtos that are out there so much bad work and they, they, you know, and, and, and it's all of it's the good rtos, it's the 90 of the good rtos that have to pay for what that 10 of rtos do, because it's that 10 that makes the headlines right. Yes, and it's that 10 that has led to the government now turning around both governments turning around and saying, uh, you know, international education doesn't provide anything for this country, it's just taking up our housing, right? It? It's just not true. Like I've sat through so many, like so many graduations where, you know, the parents have flown over from the country and they've been, like you know, my child achieved a diploma. You know, like this is so amazing. You know like we've our entire family is, like you, you know, given everything for this kid to come and get this experience from australia and they have such beautiful beliefs about, like, the australian people and the australian system. And like there's an exporting of our values that happens and there's so much goodwill exported with international education.

Lauren Boon-Hollows: 53:18

Um, but we're losing, we, we will lose all of that again and we've gone through this before and I am sure that we will again. We'll get to 2028 and we'll start to build it back, but we don't need to Like. This is all unnecessary. And so for those of you that are going to the polls or talking to your local members or are part of the vocational education and training system, guys, you all need to become bigger advocates of it. Like, become an advocate of our international education system, become an advocate of the vocational education and training system. Because if you want houses, if you want a plumber, if you want an electrician, if you want someone to take care of you when you go into a retirement community, if you want an electrician, if you want someone to take care of you when you go into a you know retirement community, if you want a nurse, right, you need to be advocates of our system.

Angela Connell-Richards: 54:07

Yeah, and the big thing is is and it's not just focused on the international, it's and you touched on this earlier what the benefits are of international students in Australia. They actually support the financially support the RTOs to be able to deliver more to the domestic market as well, so, and it also gives the domestic market a good opportunity to learn from other cultures. So there are so many benefits of international education for both domestic and international, and I think it's something that we're going to lose and I hope it's not 2028 before we build back up our international education market again. So let's now focus on. You know, if we could provide the solutions to ASQA and to the government, what changes would you like to see from ASQA to make the compliance process more transparent and supportive, especially for quality focused CRICOS RTOs?

Lauren Boon-Hollows: 55:10

So, like, look within the CRICOS space. I think the regulatory framework is there and I do believe that you know ASQAqua, the guys that they've created, are a great start. I think it would be good for the regulatory team to understand that part of their role is is educated, is educative, right, um, every audit, um is educative, and I think an initial determination gets made okay, are you going to be willing? Are you going to be willing to? Are you going to be willing to listen and improve? Okay, and obviously there's going to be some circumstances where the breaches are so bad that we can't give you another opportunity. However, I think, when the breaches are minor, as to like know, we can see, like let, we're going to come out and we're going to observe, we're going to, we're going to see what your training looks like and we're going to see what your practical training looks like and if we can see that the students are showing up and we can see that the training is actually occurring and we can see that the assessment process is authentic in that practical skills, be they business, practical skills of communicating and presenting and negotiating, or you know what we would typically call old-fashioned hard skills of you know building homes connecting.

Lauren Boon-Hollows: 56:37

You know wires. Um, you know physically creating a. You know wires. You know physically creating a. You know a dish. You know caring for a person. You know caring for a simulated person, changing a diaper right. Any of those things are being done and you've got the resources to do them and you've got the trainers to deliver them and the students are showing up and they're everyone's giving a genuine most people are giving a genuine face effort to try and do the right thing. We're going to give you that leeway and that grace right to improve and we're going to explain to you in very clear terms where you're not meeting the standards and we're going to provide you with how you need to then go about addressing that.

Angela Connell-Richards: 57:22

Okay, and that could be or what is the evidence we're looking for?

Lauren Boon-Hollows: 57:26

that's right. We're going to give you, we're going to give you an idea of what we're looking for and we're going to operate in good faith, that you are operating in good faith. And where we find providers that are not operating in good faith, all right. Even then, we are going to be very clear where they are not meeting the standard and that standard is going to be consistent, because faith in the regulator, faith in our government, is an incredibly important part of being able to continue to see our industry grow.

Lauren Boon-Hollows: 58:03

And when RTOs lose faith in the regulator, they go rogue. Quite often it then becomes how can I get past the regulator as opposed to how can I meet the quality standard, work with them, and we've seen that happen before in the past. We saw it in the wake of 2009. We saw it in the wake of 2009. We saw it in the wake of 2016. That that the strategy was well. Effort, let's just take him to art, right like there will be people who will be willing to blow that money and we'll take the rent. We'll waste the regulators time along with it. There are people. The other strategy was all right. Fine, I'm going to call in my favors. I'm going to go to the ministers and you know like none of those strategies are good for the regulator or good for our industry.

Angela Connell-Richards: 58:49

And good for Australia. It's not. We need to have that quality education and we need like, when I talk about transparency, we need transparency of what is sufficient evidence, like I remember when we used to have the guide, the evidence guide, or that would have been 2015,. I suppose they had that evidence guide and in that evidence guide, they actually showed you this is the evidence that we're looking for. Yeah, I think we need to go back to that.

Lauren Boon-Hollows: 59:24

Look to be honest, there are that many RTOs that like, for example, okay, asqa does go and audit RTOs and they pass their assessment tools. Yeah, talk to the RTO and say hey guys, are you open to your assessment tool being put up there as an example? Because I don't know many RTOs that wouldn't do that. Like, I've put my hand up as a resource provider that literally sells my resources. I've said to the regulator on that many occasions I've gone like dude, take my assessment tools, I'll give you, like, I'll give you an assessment tool from every training package. I will let your auditors go to town on them, we will get them so that every single auditor thinks they're compliant. And then I will happily sign over that ip to you and you can put them up on the ask for website as an example of a compliant assessment tool. Like I, I will.

Lauren Boon-Hollows: 1:00:18

I honestly, if that's, if that would help our industry, I've got no problems with that. I have no issues with that whatsoever. Right, there are so many people that want to help and want to, but those sorts of like a concrete example of what a good checklist looks like. Right, pick a unit BSB TWK 201, bsb SUS 211, right, which, like tens of thousands of those units are issued a year HLT AID 009, right, which, like tens of thousands of those units are issued a year HLT AID 009, right those hundreds of thousands of that unit is issued a year. Take a unit, show us what a compliant assessment tool looks like and I can guarantee that you will have RTOs adopting that style of an assessment tool. Rtos want to do the right thing.

Angela Connell-Richards: 1:01:05

And what type of evidence do they need to demonstrate to contextualise as well, because, of course, we're always going to fall back on ASK. We're always going to fall back on. Well, you need to contextualise it for your individual RTO. What does that look like? How do we do that?

Lauren Boon-Hollows: 1:01:21

That's right, but but like that's it, like it's you know, okay, so that's in the instructions or that's in the benchmarks for the observations, right, or that's you know.

Lauren Boon-Hollows: 1:01:30

Like again, like you know, that's in the exemplar responses you know for the written questions, like it's there, give us some, give RTOs some tangible examples, because if you've given them a whole bunch of really tangible examples of like what a good policy procedure looks like, what a good TAS template, I've been, I've been begging them for years to go produce a TAS template, produce a trainer matrix template, like, seriously, guys, give RTOs those two documents. Guys, give out those two documents. Every RTO will adopt it. They will adopt it, I promise you, and it means it means less sales for you and me. But honestly, you and me would be like the first people to put our hands up and go I don't care, I'm willing to lose the revenue on those particular products to see our industry be more consistent and to see our regulator you know support even the previous standards, so I think it was in the 2011, 2012 they actually had the actual areas that they wanted within the TAS, which they haven't.

Angela Connell-Richards: 1:02:33

They haven't even got anything like that now, but at least then you, you knew what. We wrote our TAS around those exact standards and we did it in order of the standards as well, and that made it much easier. Now, when you've been in the industry for as long as we have, we've seen what works, what doesn't work, and I mean not only what works and what doesn't work for ASQA, I mean for the trainer, for the RTO as well, and making sure that we've got that framework, and I do agree with that. I've seen so many people going why don't they just provide us, like the government, just provide us with all the documents and all the policies and procedures and things like that? And I'm going well, how do they do that when there's so many different?

Lauren Boon-Hollows: 1:03:19

Because what works for a mom-and-pop business versus what works for a TAFE is not going to be the same thing yeah, yeah.

Angela Connell-Richards: 1:03:24

So you do need to have it so that it's contextualized for your industry sector, for your learner cohorts, for so your RTO what makes? You unique? Yeah, yeah, yeah. Safe funding, yes, yes, definitely as well. All right, so we've talked a lot today. It's been a very, very big topic for us to talk on. If there's one thing you want policymakers and ASQA to understand about the cryocross sector right now, what would that be?

Lauren Boon-Hollows: 1:03:57

I want the government to know that they're missing an opportunity. Removing international education is not going to get us the houses that we need. Deregulation and supporting more strategically directing our visas to the qualifications that we need is what is going to get us more houses, because in order to get more houses, we need more builders, more brickies, more carpenters, more electricians and more plumbers, and that's what we need in Australia, and we are not going to get that through trainees and apprentices only. I would love it if we could. My son's just starting an electrical apprenticeship. I'm so proud of him. I have another son coming up and I'm sure he will go into an apprenticeship as well. Both my boys have been massive recipients of the vocational education sector and they both know that that's kind of that's where we're going to be directing them, because skills are crucial.

Lauren Boon-Hollows: 1:04:56

But a better way to address the international crisis would be to link employment of your visa with the qualification that you are studying. So if you are studying to be an engineer, you need to be working as an engineer. If you are studying as a nurse, you need to be doing work in that field of nursing right. Not as an actual nurse, but, like you know, working in a hospital to some extent or working, you know, like if you're studying to be a chef, you need to be working in a restaurant.

Lauren Boon-Hollows: 1:05:28

If you are studying to work in you know, studying aged care or community services, you need to be working in that industry. Right? Link it to that. That will naturally probably shrink the vocational market, but what it will also do is it will also ensure that the international market is actually supporting the areas and the skill shortages that need it, because we are always going to have a skill shortage in Australia and the international students that come in to lose a $50 billion industry in Australia. At this particular point in time, with the international market as it is, I think we are being silly. I think our politicians are being very silly and I think that it's okay for every normal person to be talking to their government and to be saying hey, guys, I get that this is the issue that you're saying, but maybe it's not the win that you think it is.

Angela Connell-Richards: 1:06:27

Yeah, yeah, yep, totally agree with those. And finally, what gives you hope right now for the future of international education in Australia, and hopefully it's before 2028.

Lauren Boon-Hollows: 1:06:40

What gives me hope is the fact that we've weathered these storms before and we still have a thriving. We still have a thriving vocational education market. We still have brilliant providers in the public and the private sector. We still have passionate consultants, ceos, rto trainers that are still willing to fight for our industry. And those people change over time because I get, you can only fight for so long. I just genuinely I see, I get to see so many trainers and developers and RTOs investing in just creating these beautiful programs and changing people's lives that I can't be anything other than positive, like I can't be anything other than a passionate, positive advocate for our sector. Because what, what, what we do in this industry? We can. They don't do it. And it doesn't happen in um, it doesn't happen in the schools, it doesn't happen in the universities, it happens in the rto colleges.

Angela Connell-Richards: 1:07:49

So I think that's something we're fighting for, yeah, and I I've experienced this personally myself, and it's it's something I've spoken about many, many times education changes lives, and it's something I've spoken about many, many times. Education changes lives, and it's not just the student, it's the lives around the student as well. And you do see a big impact with vet sector, because there are applicable skills that they can apply and also not only apply them, grow through that as well. So not only apply them, grow through that as well. Well, thank you once again, lauren, for today, on a very hot topic, we changed the subject of what we were going to talk about, because sometimes this is what we need to do.

Angela Connell-Richards: 1:08:34

We just need to discuss what's actually happening right now, and I thank you for being very open and honest, lauren, with your thoughts of where we're at, in particular, with international education. Let's hope that we get the change, we get international students back into Australia and we get back to that number one position of the biggest export out of Australia, because it was something I've always been proud of and, I think, proud of this sector as well, and I think it could make a massive change. Thank you very much Until next time. We'll see you at our next RTO Superhero Podcast.

Lauren Boon-Hollows: 1:09:11

Thanks guys.

Angela Connell-Richards: 1:09:17

Right.