cricos - neas · my goals •to encourage you to have confidence that you have the know-how to...
TRANSCRIPT
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CRICOS
Audit Preparation
Meeting compliance need not be a burden
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My goals
• To encourage you to have confidence that you have the
know-how to achieve a successful result at audit
• To encourage you to view an audit as a continuous
improvement opportunity
• To provide you with some tips to assist you
• To give you the opportunity to share your experiences
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Contents
1. CRICOS and the Regulators
2. Preparing for the big day
3. The day arrives
4. The aftermath
5. Common areas of non-compliance
6. It’s all about quality
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1. CRICOS and the Regulators
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What if
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Your Regulators
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ASQA
TEQSA
State/territory
regulators
CRICOS
RTOs
ELICOS providers (except when delivered in
schools, higher education or a
pathway arrangements to
higher education)
CRICOS
Higher Education
providers
ELICOS providers (where ELICOS is delivered in
pathway arrangement to
higher education)
CRICOS
Schools
ELICOS (where delivered in schools)
Non-award courses (i.e. aviation and religion)
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The Regulators
ASQA
o ~4,000 RTOs
o ~600 CRICOS providers
(Stand-alone, VET)
o ~145 providers offering non AQF-award ELICOS
(of which ~80 stand-alone)
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TEQSA
o 172 providers
o 40 universities
o 129 HEPs/HEIs
o 1 specialist + 2 foreign universities
o 45 HEP/ELICOS
o 1.27 million students (26% international)
o 1.19 in the university sector
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TEQSA regulatory activities 1/2-30/6/2014
• 3 initial registrations
• 13 renewals of registration
• 59 initial course accreditations
• 102 renewals of course accreditation
• 36 renewals of CRICOS registrations
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22 Multi-sector providers
• If both VET and HEd courses are delivered, must comply
with ASQA and TEQSA requirements
– 13 with ASQA
– 9 with TEQSA
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The CRICOS regulatory audit
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• Approve CRICOS initial registration
• Approve CRICOS renewal of registration
• Approve amendments to CRICOS scope of registration
• Monitor under the ESOS Act
• Enforce under the ESOS Act
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The Regulatory Framework
• ESOS Act
• ESOS Regulations
• National Code 2007
• National Code Explanatory Guide
• ELICOS Standards*
• Other legislation**
Legislation is vital, but you can draft the best
legislation in the world and it will not work unless the
implementation works. VC ACU Greg Craven, Campus Review Dec. 2013
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Main features of the ESOS Act
Obligations on providers that offer courses to overseas students
beyond domestic delivery quality requirements
• To provide tuition assurance and refunds for courses for which
students have paid
• To protect and enhance Australia’s educational and training
reputation
• To complement Australia’s migration laws – collecting and
reporting information regarding the law governing student
visas
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Main features of the National Code
For the Regulator:
• Outlines the responsibilities of the registering body in
approving a provider to deliver a course at a particular location
to overseas students
For the Provider:
• Sets out standards which details specific obligations that must
be met at point of registration and throughout the registration
period.
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The Regulators’ approach
• Evidence-based and risk-based approach to regulation.
• Providers need to provide the evidence that
demonstrates they comply with the legislative
requirements, and how they comply.
• Evidence to demonstrate compliance is not prescribed –
to allow for flexibility and innovation in the way education
and training is delivered.
• Ensure that regulatory assessments take a risk-based
and proportionate approach.
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TEQSA
• Application Guides o Application Submission
o Preliminary Assessment
o Substantive Assessment
o Site visits
• Evidence of o Policy and procedures
o Implementation of these policies and procedures
o Learning outcomes
• Analysis of qualitative and quantitative data o Feedback from students, destination higher education institutions
o Attrition and completion rates
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ASQA
• Submission of documents with application
o Evidence must be complete and clearly referenced on the
relevant sections of the application form.
o Email or post
o If incomplete will be returned
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ASQA
• Assessment of application may be followed by an onsite
audit
o Initial registrations
o Renewal of registration or change of scope
o assessed for risk
o higher risk applications may be referred to site audit
o if significant management changes
o if there are sector wide compliance issues
o to follow up on previously identified compliance issues
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2. Preparing for the big day
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Tackling compliance
• Part of your operational procedures
• Build being compliant into quality
• Opportunity for continuous improvement
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Be prepared • Self assessment
o Conduct an internal audit
• Prepare evidence o Everything should be well organised
• Organise personnel o Management - Make sure calendars are free for the day(s)
o Ensure staff are across what they do and which policies apply to
them
• Premises o You want to sell your school but your school should sell itself
o Prepare a space for the auditors
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Your approach
• Be prompt
• Be willing to impress in all interactions o From first email
• Be nice to yourself o Make sure you are ready and free for the day
o Prepare a team
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Staff
• The team o Not alone
o Professionally presented
o Experienced, knowledgeable
o Identify roles and responsibilities
o Briefed and prepared
o Confident
o Have documents and information to hand if required
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Documentation and Evidence
• Organise documents o Big picture, long term view
o Allow for growth
• Document management systems o NOVACore
o Sharepoint
o Intranet
o Wiki
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• Preparation of evidence
o Quality documents
o Be organised, be prepared
o Be able to find evidence quickly
• Know where everything is
• Ready to access documents when asked
o Computer based presentation?
• Laptop
• Data projector
• Own the mouse
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o What evidence might you need to produce? • Policies and Procedures
• Student files
• Learning resources
• Assessment resources
• Course materials
• Forms, letter templates
• Promotional material
• Websites
• Internet/intranet
• Agent list - Up-to-date!
o Where are they? • Quickly accessible
• Ensure infrastructure (IT, folders) to easily find and access documents
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P&Ps
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• Policies and procedures o Effective
o Target audience
o Common template
o Style guide/styles feature in word
o Future-proof
o Communicate to staff, students, others
o Must follow your own
o Living documents
o Allow to live beyond the audit
o Annual review
o Amendments made to each iteration
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• Implementation of policies & procedures
o Need to prepare evidence that you have implemented your policy
o For every policy think about how you can demonstrate this
o Records
o Documented actions
o Templates – letters, forms
• Qualitative and Quantitative data
o Feedback from students and receiving institutions
o Attrition and completion rates
o Assessment validation and moderation
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• Appropriate version control o Size of organisation
o Allocate document owners
o Keep it simple
o Soft and hard copies
o No multiple version of the same document
o Archiving to show continuous improvement and so that you have
retained out-dated documents that agents might still be using
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3. The day arrives
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Steps in a site audit
• Brief opening meeting
o senior staff and key staff – 15 mins – overview of audit process
and timetable
• Business operations explained to audit team – brief
• Assessing evidence provided by your organisation to
demonstrate compliance
• Evidence readily available o documents – electronic – photos – student records – verbal
• Interviews with staff and students
• May do tour of premises – make take photos
• May ask to take documented evidence away
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Premises
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• First impressions count o Premises
o Signage
o Staff
• Site tour o Orientation
o Opportunity to impress
• Meeting room o Designated room
o Comfortable, clean, tidy
o Appropriately equipped
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• Be nice to your auditor too!
o Make their life easy
o Anticipate their needs
o Give them a guide (person)
• Understanding your auditor
o Personal connection
o Professional
o Courteous
o Never angry or defensive
o Who’s nervous? Not just you!
o What does your auditor need?
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Interactions with the auditor(s)
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o Who is the auditor
o Perception of auditor
o CI experience
o Issues • Push back but know when to stop
• Take notes, ask questions
• Understand the issue(s)
o Listen
o Answer concisely then be quiet
o Only expand if requested
o Silences do not mean dissatisfaction
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• Goal o Low risk rating
o Minimise rectification
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4. The aftermath
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Managing non-compliances
• If a non-compliance is identified
o Try to switch to a continuous improvement (CI) process
• If CI unsuccessful
o Attempt to fix on the day
• If immediate rectification unsuccessful
o Attempt to get rectification to auditor before draft report
(2-3 days)
• Start rectification as soon as possible
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Rectification
• Good to submit electronically – but other options
available – check with the auditor
• Use a unique folder for each non-compliance, include: o Cover letter identifying
• Non-compliance
• Rectification required
• Rectification you have undertaken
o Supporting evidence of actual rectifications undertaken
• Zip folder(s) and submit as email
• May also be posted
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A few final words
• Script your audit
• Don’t shoot from the hip
• Nominate evidence of compliance for each standard (file
location, document name, page numbers)
• Be demonstrably compliant in each area
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Don’t forget
• Student files
• PRISMS
• Policies and Procedures
• Version control
• Evidence of procedures
• Website – including agents
• Marketing material
• Letter of Offer and Written Agreement
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Don’t forget
• Education Agent agreements
• Partnership and other agreements
• Correct Regulator and Legislation names
• Tuition Protection Service
• PRISMS
• Accurate enrolments – e.g. under 18s
• Staff know about legislation
• Correct terminology
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5. Common areas of non-compliance
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Common areas of non-compliance
• Standard 1: Marketing information and practices
• Standard 2: Student engagement before enrolment
• Standard 3: Formalisation of enrolment
• Standard 6: Student support services
• Standard 14: Staff capability, educational
resources & premises
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Common areas of non-compliance with the
National Code: May 2013 – May 2014
National Code Standard % of non-compliance at audit
Standard 1.1 25 %
Standard 1.2 23 %
Standard 2.1 35 %
Standard 3.1 27 %
Standard 3.2 22 %
Standard 6.1 20 %
Standard 14.1 35 %
Standard 14.2 40 %
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See the National Code of Practice 2007 Explanatory Guide on www.aei.gov.au
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Possible consequences of serious non-
compliances
• Directions
• Shortening period of registration (1-5/7 years)
• Conditions
• Amending scope
• Suspension
• Cancellation
• Infringement notices
• Civil penalties and offences
BUT – we do not expect ANY of the above in your case!
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6. It’s all about quality
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The Self-Assessment
• Not just regulation
• Build it in to your quality systems
• Annual self-assessment
• Independent, knowledgeable, experienced opinion
• Guidance notes for evidence
• Internal reviews
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Some best practice
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• Tracking student progress with receiving institution, place
of employment
• Learning outcomes and assessment validation &
moderation
• Other examples?
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Beyond the audit
• Recognise your goal; you are aiming for:
o Not waving drowning
o In the boat
o On the super yacht
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The role of NEAS
• Working in partnership with providers to attain excellence
in ELT delivery
• Quality Assurance Framework o Quality Principles
o Quality Practice Guide
o Mapping against ENS & National Code
o Account Managers
• Working with the Regulatory authorities
• Quality assurance supports compliance o over 200 centres
o 146 “UHEs”
o Quality Learning Series
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