Speaker 1: 0:22

Welcome to the RTO Superhero with me Angela Connell-Richards, and today I'm joined with Maychek. Hello, and we're still in Darwin. How?

Speaker 2: 0:32

beautiful, is it though?

Speaker 1: 0:33

Oh, it's been beautiful, so 32 degrees.

Speaker 2: 0:36

Yeah, beautiful weather.

Speaker 1: 0:36

And it was 12 degrees back home, yep, okay, so today we're going to be talking about re-registration and preparing yourself for re-reg under the new standards and what you need to know. Very interestingly, what we're hearing is maybe you may not go to an audit, but you may go to an audit, so let's see what happens. Okay, so let's start. I've got a couple of clients who are up for re-reg this year and one had asked me the question when can I submit my application for re-registration? And you can submit up to 12 months before, so you don't have to wait for the three months before you can do the 12 months before, 12 months before. And then the next question I got asked was well, will I go to audit? Then I said, well, possibly, but you don't know. So they might actually see you being proactive with submitting your application early and might just go. Okay, we're busy right now, let's just push you through.

Speaker 2: 1:40

Correct and I think a lot of that is happening at the moment is that they're pushing the applications that are low risk. They're doing, obviously, their risk assessment based on scope, complaints, et cetera, and, I guess, picking the organisations or the RTOs that are seen as a high risk to audit and the ones that are, let's call it, flying under the radar, no issues, et cetera. Or what's the point of auditing them if our resources are stretched at the moment and we need to look at other things?

Speaker 1: 2:10

Yeah, yeah.

Speaker 2: 2:11

Although it's really interesting, I will say. One of my clients lost their CRICOS registration because they submitted for their CRICOS renewal two days late and even though they got told that's fine, put it through. But because they had no students at the time and two days late, they said, well, we're cancelling your registration.

Speaker 2: 2:30

And the reason was because it was lodged two days late and it wouldn't be fair on existing Cryocross providers, so that didn't sit well with me. The client wasn't too fussed because whatever, but it was still a significant investment because two days. So the lesson there is do not leave your re-registration.

Speaker 1: 2:51

Yeah, I say that all the time, and if anybody comes to us for re-registration, we want at least six months 100% before.

Speaker 2: 3:00

So you've got nine months before.

Speaker 1: 3:02

Yeah, to prepare them because they need to know. They often come to us because they know they're non-compliant. They just don't know how non-compliant they are.

Speaker 2: 3:11

I mean the re-registration application itself is about a 15-minute ASQA job, right? So the lodgement is. There's no excuse not to lodge, even at 11.45 pm the day before the cutoff. Yeah, because you can lodge it, you can submit it and then at least prepare for it. But yeah, do not miss the deadline.

Speaker 1: 3:29

Yeah, yeah, and I wouldn't wait until the three months before you know, submit it before then. The three months is a guideline Correct so that ASQA are prepared. So you need to understand what is happening in your RTO and if you think it's non-compliant, do something about it. You know, and this is something that I really identified in the standards is being proactive.

Speaker 2: 3:56

As opposed to reactive.

Speaker 1: 3:57

As opposed to being reactive and really identifying what are the risks that you have currently within your RTO. So that's, under the governance requirements, is making sure you have a risk register, but it's making sure that you don't just have the policies and procedures, it's that you have the understanding.

Speaker 2: 4:17

The understanding and the demonstrated practices of those things. I think the critical thing to remember is, if you plead ignorant, asca is going to come down harder than being proactive and demonstrate look, these are the things that we've identified, this is how we fixed it or how we are fixing it at the moment, the moment you can demonstrate that you've got. Yep, you've identified an issue with an assessment tool or whatever it was, but you've actually put down a process to fix it. Asqa will look at that and go good on you. Well, done.

Speaker 1: 4:50

No, rto is going to be 100% compliant.

Speaker 2: 4:53

Except ours. All the ones that we work with you know, you included, right.

Speaker 1: 4:59

Yes, but ASQA aren't there to go. We're looking for non-compliances, we're looking for evidence of compliance and if you are non-compliant, what is your process for rectifying that? And one thing I say be honest with your annual declaration of compliance, because if you do go to an audit following and ASQA have said this they will be looking back at your annual declaration and what you submitted.

Speaker 2: 5:30

Yeah, it's one of those things that I always say to anyone that asks me. You know it's a balancing act between self-incrimination versus declaration about the truth, because at the end of the day, you're signing a stat dec. I think it's a stat dec, isn't it? Or just a declaration? And yeah, you don't really want to be turning around and saying yeah, to the best of my knowledge, we're compliant. Yet, knowingly, deep down inside you know that there's flaws. We all know that there's issues, identify them, put in a redress process and then fix it.

Speaker 1: 5:59

Yeah, and I think your annual declaration of compliance should be closely tied with your risk register, identifying what those risks are and then action plan.

Speaker 2: 6:10

And, hopefully, your monthly ongoing compliance practices that you're implementing to go okay, let's not like this concept. I know we've always spoken about this annual internal audit, etc. No-transcript Right. Constantly reviewing things, constantly seeking feedback, constantly doing our continuous improvement and actually implementing what the concept of the standards is about, then you're going to be far less inclined to have issues at audit. Firstly, because you're going to know the standards and the auditors are going to or the performances, are going to see that you understand the standards and you're going to understand your practices a much, you know much deeper level and ensure that you're complying with them.

Speaker 1: 7:08

Yeah, what we implement with our clients is we have a poster with a continuous improvement cycle and every month we could look at a couple of standards, so breaking it down instead of having to do it all in one go. So each month you're focusing on one area.

Speaker 2: 7:23

We don't have a poster. We've got a compliance schedule which goes over the 12 months, picking out the various areas.

Speaker 1: 7:27

Yeah, yeah, and then we tie that with our vet PD, so the vet PD will focus on that, and then the idea is for our clients to then watch that webinar, then review what their practices are and what they're doing. Yeah, yeah, what else would you recommend for re-registration?

Speaker 2: 7:48

Again, similar to initial don't fear People that fear audit don't understand the concept of the environment that we live in. Audit is just part of what we do. It's part of your registration. It is and it's running a business. You can be audited by the ATO, you can be audited by ASQA. So don't fear it. Don't live in fear of an audit. Focus on your practices. Focus on that culture of compliance that we always talk about. Focus on that operational requirements across your whole business, not just a compliance person. Across your whole of business, not just a compliance person. Don't rely on a consultant to fix you six months before re-reg. We can perform miracles sometimes, but we can't make stuff up.

Speaker 1: 8:36

And we don't know who your auditor or assessor is going to be.

Speaker 2: 8:39

And so, yeah, just don't don't look at the negatives. Look at the positives and don't be scared to identify potential issues that you can fix, but also implement a process to start fixing them, as opposed to oh well, let's just wait for audit, because the auditor is going to identify them anyway. That's not a good look.

Speaker 1: 9:00

No, because once again, they're going to be looking for evidence of compliance and that you are implementing your policies and procedures. So part of that should be your risk management and your continuous improvement. So how are you implementing that? One of the things that I also recommend is you know, don't leave it to the last minute. Definitely don't do that. We can not wave a magic wand and tell you that you're going to have the best audit, because we don't know who's going to be audited. We also don't know what skeletons are hiding in the closet. We need plenty of time, and that's what we were talking about earlier. You need about nine months to prepare, or a year. That's ideal.

Speaker 2: 9:48

It depends on how bad your housekeeping is.

Speaker 1: 9:51

But with the change of standards.

Speaker 2: 9:53

Yeah, yeah, look for me the change of standards. Yes, they are, I mean, the biggest. They've moved the date from the end of the standards for RTOs to the beginning. So, instead of being standards for RTOs 2015, it's now the 2025 standards for RTOs to the beginning. So, instead of being standards for RTOs 2015, it's now the 2025 standards for RTOs. But, look, I would probably say 70 to 80% is still somewhat comparably aligned from the old standards to the new standards. From an in-principle perspective, the wording has changed a little bit, yes, but a lot of the things, like I said, your TASs are still your TASs. There's tweaks that you need to put in there about student support and so forth, but overall, if your TAS was compliant pre-July 1, there's not really that much that you need to do with it.

Speaker 1: 10:40

As long as you're updating it.

Speaker 2: 10:41

As long as you're updating it, correct. But that's not a difference between the standards that should be your operations as it is anyway, whether it's the old standards or the new standards. So from my perspective, it's really just.

Speaker 1: 10:54

Again, it goes back to that simple word what do you think are the biggest differences that people will need to be aware of and make sure that they have implemented that?

Speaker 2: 11:13

I think if we break down the outcome standards the outcome standards, really, that student support focus on. Outcome standard two that's probably been the biggest area that we need to focus on and demonstrating how those support mechanisms are in place within your organisation, suitable for the client and demographic and course type that you've got. The whole of workforce management is probably a big one. And then outcome standard 4.2, around that risk and conflict of interest. They're the main ones that sort of jump out at me. A lot of the other ones in some respects have been simplified a little bit. But then, forgetting the outcome standards, if we have a look at the compliance requirements slash compliance standards, as they're now called according to DUR a lot of them are mapped across to areas of the 2015 standards, whether it was the USI, whether it was the issuance of qualification policy. So a lot of them will still map across.

Speaker 2: 12:21

The only funny part between the two things for RTOs that are operating at the moment is that the compliance requirements have got their pre-enrollment information at the beginning about the incentives and all that, but also we have 2.1, which talks about providing information to ensure suitability of product. So I made the decision to effectively move marketing out of compliance requirements and bunch it together with the outcome standards under 2.1 to make it part of that student's journey being that information. So because I think in the compliance requirements it's talking about marketing and information, versus in 2.1, it's just information, and so to me that makes sense to have the two bunched up together because it then means marketing. Then we talk about that student support and enrollment aspect and we move on.

Speaker 1: 13:13

And I think information makes sense because, in particular, if you're like, different RTOs don't all have fee for service, they don't have marketing, they have internal information that they need to provide. So, when it comes to information, it's ensuring that the student has a clear understanding of what are the requirements to complete this training and be successful in it.

Speaker 2: 13:36

And it's not rocket science, is it?

Speaker 1: 13:37

No.

Speaker 2: 13:38

It's just be honest with what you ensure that the students know what they're studying.

Speaker 1: 13:41

Yeah, yeah, yeah, and they know if they've got work placement. How is that conducted? Do they need to find the work placement? Does the RTO find the work placement? And you need to make that clear in your information that you provide prior to course commencement. The other one so I'm up in Darwin because I delivered a workshop on support services. On support services, one of the questions I got asked is by one of the audience was around. We've got we deliver qualifications and training in health services, and is it a breaking the standards with regards to diversity and inclusion if we say that students need to be physically fit? And I went no, because part of the requirements is they need to do first aid and they've got to be able to get themselves up and down off the floor.

Speaker 2: 14:35

Anywhere where we're doing a first aid, we always make it that as part of the entry or the course requirements is that they have to be physically fit to perform two minutes at least two minutes of continuous CPR on the floor.

Speaker 1: 14:46

Yeah, and anything in health. If you're working as a nurse or there's so many things, you can't go in with a bad back.

Speaker 2: 14:52

No, a hundred percent. We always talk about physical fitness when it comes to any type of physical activity, and one of the requirements that we always put on our marketing flyers is also that if you are under the influence of anything that may, or under stress, or any mental health issues, et cetera, that could impact on your ability to participate in the course or be a safety concern to you and others in the class, then you will be excluded from the class until that's resolved, and so we make that as a standard statement within all our clients' marketing information, because it's about protecting them.

Speaker 1: 15:26

Yeah, yeah, I just remembered a very interesting conversation I had with an RTO where they had a student who came in for working at Heights and they did all of the theory side and then they had to go up on.

Speaker 2: 15:42

And they were scared of Heights.

Speaker 1: 15:43

They were scared of Heights and they said no, I can't go up there because I'm scared of heights. And they're like this is working at heights. But can't you just give me the certificate?

Speaker 2: 15:55

No, and again, you know we assume, and we know what assume means, right, yep. And so one could argue that, okay, that's an opportunity for improvement. Maybe in our marketing flies we have to put you will be required to work on a platform at least of three meters or higher. So if you're scared of heights, yeah but, um, I had a?

Speaker 2: 16:18

um diving client and we had to make sure that they were physically fit for diving purposes. Had to make sure that they were physically fit for diving purposes. Cpr is another good one. So, yeah, we often assume and we laugh, but at the end of the day we have to make sure that everyone understands.

Speaker 1: 16:36

I call it idiot. Proof our documents yes, that's right and that information you're providing prior, not on your induction day, not after they've enrolled. Prior to enrollment, because what I see with the support standards, so quality. Area two it's all about successful completion and we should all be looking at how can we ensure successful completion and one of the things-.

Speaker 2: 17:01

And that includes starting before they enroll.

Speaker 1: 17:03

That's right. That's right, and you should work back from successful completion to prior to enrolment. So what that information is and what I highly recommend all RTOs do right now, is have a look at your completion ratings now and set a KPI for in 12 months' time.

Speaker 2: 17:22

What you're, that's a great statistic to provide, not only internally for your team and others within the industry, but then ultimately ASCA as well.

Speaker 1: 17:31

Yeah, yeah, yeah. So I think when it comes back to the topic of re-registration, we were talking earlier off audio. You were saying you haven't experienced any.

Speaker 2: 17:46

Going to audit following re-reg, so no existing client of mine. I've had people approach me about re-reg and we've gone through that and, similar to you, we've worked with them leading up to it. We've taken them through, we've made sure that everything was in line and they had all the evidence. But what I find is that a lot of clients that have what would be seen as a lower risk, they lodge their application, application's approved, but they may get an audit 12 months after.

Speaker 1: 18:16

That's right.

Speaker 2: 18:16

Now, being the pessimist, sometimes I sort of wonder if that's a bit of a wonder, if that's a bit of a. What's a cost recovery methodology? Yes, because I don't know whether the cost of the audit is included in the initial reg, in the re-registration fee anymore, because it used to be. It used to be seven thousand dollars for re-registration and it's a lot cheaper now to apply for re-reg so so your re-reg fee is just the fee.

Speaker 1: 18:45

And if you go to audit, you pay per hour, correct?

Speaker 2: 18:48

Yeah, so I don't know. Look, I generally think ASQA is taking on their risk approach properly and you hear a lot of RTOs that have been closed down, qualifications being cancelled. So I think there's the larger players at the moment, the smaller RTOs that are just focusing on the niche industries. I think there's a bit of well. There are lower risks compared to what the issues that we've got to look at at the moment.

Speaker 1: 19:19

Yeah, yeah, and I think. So we've had a mix. We've had some who just went straight through, submitted their re-reg and got their re-registration and then, but as you said, it was more the high risk. So if you've got childcare on your scope, disability, community services, any of those ones, they tend to be the higher risk and anything that involves equipment is more high risk because they want to be the higher risk and anything that involves equipment is more higher risk because they want to see the equipment. So I think that's where you're looking at, but you don't know.

Speaker 2: 19:53

It's a hit and miss. But again, if you're going into the post-initial registration renewal so it's two years after with a fear of audit, you need to change your mindset because you need to be operating in a way to basically say Asqua, come on in, have a look, we're proud of what we do, yeah, and see it as an opportunity for improvement. Yep, absolutely. So yeah, I think don't fear audit. Focus on running your business, running your RTO in a compliant manner, and learn the standards and you'll be right yeah, I think so too.

Speaker 1: 20:29

Great advice, thanks, may check. That's uh another wrap up of the rto superhero podcast.

Speaker 2: 20:36

So good from darwin, from darwin live good to see you in person.

Speaker 1: 20:40

Likewise, and uh, may check's off on the road again today doing his second lap around Australia. Yep, we've been. I've been, because this is my plan is to also do the lap around Australia. So I've been learning lots from Maycheck over the last couple of years. Off to Kakadu, yes, yes, awesome. So thank you very much. Thank you, maycheck.

Speaker 2: 21:01

Thank you.

Speaker 1: 21:02

And we look forward to catching up with you again soon on the next podcast.