Enrolment Processes at Technical and Further Education Institutes

Tabled: 11 September 2019

4 TAFEs' compliance with the VET funding contract

TAFEs are eligible for funding only if they meet the department's contractual requirements, including those relating to enrolment. TAFEs must demonstrate that they have enrolled only eligible students, correctly applied student fees and charges, and assessed course suitability for individual students.

In this Part, we examine how TAFEs' enrolment processes comply with the contract's requirements, focusing on whether:

  • enrolment processes are clearly documented and compliant
  • the department effectively supports and monitors TAFE compliance
  • TAFEs effectively monitor their own compliance.

4.1 Conclusion

TAFEs are committed to meeting the contract's enrolment requirements, however, they are unable to do this consistently.

Despite departmental efforts to clarify requirements, inconsistencies between the contract and the department's monitoring frameworks prevent a common understanding of how to comply. Gaps in TAFEs' documented enrolment processes further limit their ability to consistently comply, and increase the risk of ineligible or unsuitable enrolments.

4.2 Documenting TAFE enrolment processes

Under the contract, TAFEs must have a clear and documented business process for:

  • assessing student eligibility for enrolling in a subsidised course or qualification under Skills First
  • conducting the pre-training review to determine the most suitable training for an individual.

There are gaps both in the detail and currency of TAFEs' documented processes for assessing eligibility and conducting the pre-training review. This means TAFEs rely on other undocumented measures to help achieve consistency in these two areas. For example:

  • Box Hill uses staff training presentations on how to complete the pre‑training review and eligibility assessment to augment their documented business processes.
  • TAFE enrolment systems and forms often prevent enrolments from progressing without TAFEs entering specific information or completing checks.

Assessing student eligibility

Prospective students must meet the Skills First eligibility criteria, including the two‑course rule. TAFEs can exempt individuals from eligibility requirements under special initiatives, such as for retrenched workers, and exclude ineligible individuals, such as students enrolled in secondary schools.

To satisfy themselves about student eligibility, TAFEs must document their business processes for the key contractual requirements—assessing eligibility criteria, exemptions and exclusions, retaining evidence of eligibility, and completing the Skills First declaration form.

Figure 4A summarises whether each TAFE's documented business processes provide sufficiently detailed information about the eligibility requirements and whether they reflect the 2018–19 contract for each TAFE.

Figure 4A
TAFEs' documented business processes for assessing student eligibility

TAFE

Detailed information(a)

Meets current contract(b)

Box Hill

Melbourne Polytechnic

SuniTAFE

Swinburne

William Angliss

(a) The process provides detailed information on how to meet eligibility requirements.
(b) The process reflects the 2018–19 contract.
Source: VAGO.

In accordance with the contract, four TAFEs—Box Hill, Melbourne Polytechnic, Swinburne and William Angliss—have documented business processes that provide detailed information about eligibility criteria, exemptions, exclusions and how to apply these requirements. For example, William Angliss's business process includes a summary of common eligibility exemption scenarios and identifies the specific criteria that individuals are exempted from under each special initiative.

SuniTAFE's documented business processes for assessing eligibility do not have enough detail. For example, they identify that staff must assess individuals against Skills First eligibility criteria, but do not provide detailed information about the criteria themselves or how to apply the criteria.

Changes in the 2018–19 contract

The department updated the contract for 2018–19 to reflect government decisions about exemptions for specific cohorts of students from certain aspects of the Skills First eligibility criteria. It introduced specific exemptions to the two‑course rule, eligibility exemptions for new initiatives, increased the proportion of exemptions allowed, and introduced new formats for TAFEs to sight and retain evidence of eligibility. Four of the five TAFEs do not reflect all these changes in their documented business processes for assessing eligibility.

The department also made some key improvements to enrolment requirements in the 2018–19 contract. We discuss these in detail in Section 4.3. The improvements allow TAFEs to use a document verification service to sight and retain evidence of eligibility and allow individuals to use electronic signatures to endorse the Skills First declaration form. Box Hill, Swinburne and SuniTAFE use a document verification service to check evidence of eligibility and have updated their business processes to reflect this change. Swinburne and Melbourne Polytechnic use electronic signatures to complete the eligibility declaration form, but have not updated their business processes to reflect this change.

Pre-training review

The contract requires TAFEs to determine the most suitable course for an individual prior to enrolment. TAFEs do this through the pre-training review, which must have a documented business that considers an individual's:

  • aspirations and interests
  • educational attainment and capabilities
  • literacy and numeracy skills
  • prior learning or competencies
  • digital capability (when training is delivered online)
  • capacity to undertake the course learning strategies and materials.

Each TAFE must document how it assessed course suitability for each individual and retain evidence of conducting the pre-training review.

Figure 4B summarises our assessment of each TAFE's business process for conducting the pre-training review.

Figure 4B
TAFEs' documented business processes for the pre-training review

TAFE

Detailed information(a)

Meets current contract(b)

Box Hill

Melbourne Polytechnic

SuniTAFE

Swinburne

William Angliss

(a) The process provides detailed information on how to assess suitability.
(b) The process reflects the 2018–19 contract.
Source: VAGO.

None of the five TAFEs' documented business processes provide detailed information about the thresholds they use to determine the suitability of an individual's aspirations, capabilities, prior learning, or digital capability, or if course learning strategies are appropriate. For example, a pre-training review should include defined learning supports and reasonable adjustments for individuals with identified learning disabilities, to ensure that staff consistently assess if individuals have the capabilities to undertake the training.

TAFEs' business processes do include thresholds for minimum literacy and numeracy levels, using the ACSF. While the pre-training review is a qualitative assessment, clearly documenting suitability thresholds for each pre‑training review component will reduce the risk of inconsistent assessments.

Changes to the 2017 contract

In the 2017 contract, the department introduced a new pre-training review requirement for TAFEs to identify an individual's digital capability and access to technology when portions of the course are delivered online. Three of the five TAFEs—Box Hill, Swinburne, and William Angliss—have documented business processes that include this requirement, but do not include detail about how to assess it. Melbourne Polytechnic and SuniTAFE have not updated their documented business processes to reflect this change.

4.3 Department monitoring and support

The department must make the contract's compliance requirements as easy to understand as possible. It should also have mechanisms to monitor TAFEs' contractual compliance, and to identify opportunities for improvement.

The department provides wide-ranging advice and support that helps clarify TAFEs' enrolment obligations under the contract. It has also made several key contract improvements that make it easier for TAFEs to comply. However, the department's compliance monitoring of TAFEs is sometimes inconsistent with the contract's enrolment-related clauses.

Communicating the contract's enrolment requirements

The department has effectively communicated the contract's enrolment requirements to TAFEs by:

  • running TAFE workshops during 2018 to clarify the contract's enrolment requirements—all 16 TAFEs attended one of these workshops, which were highly rated in participants' evaluations
  • supplying various guidelines and tools to clarify enrolment obligations regarding student eligibility, data collection, record keeping, and tuition fees
  • issuing notifications when it amends contractual requirements relating to enrolment, and supplying a curated version of the contract in October 2018 that incorporates prior amendments
  • responding to 36 enrolment-related TAFE enquiries submitted through the SVTS during 2018, with 32 of these resolved within one month.

However, as noted in Section 2.4, the department needs to more clearly communicate the contract's requirements for considering an individual's literacy and numeracy skills.

Departmental monitoring of contract compliance

The department monitors TAFEs' compliance with the contract through its Skills First Audit and Assurance Program. This aims to:

  • confirm that TAFEs spend Skills First funding appropriately
  • confirm that TAFEs provide students with quality training services
  • gain assurance that TAFEs have capacity to comply with the contract
  • identify opportunities for improvement in TAFE business processes and controls.

The department outsources the delivery of its annual audit program to a provider panel consisting of four contractors. The program includes eight audit types that may examine enrolment activities.

The department's audit and assurance program provides a sound, high-level framework for assessing whether TAFEs enrol students in accordance with the contract. The annual audit program:

  • is risk-based and includes both planned audits and off-cycle audits that respond to matters that have come to the department's attention
  • enables examination of TAFEs' enrolment-related business processes, controls and detailed transactions
  • enables targeted assessments of key enrolment requirements in line with the contract, including evidence of eligibility, granting of fee concessions and completion of the pre-training review
  • requires that the auditor and TAFE agree on a rectification plan to address audit findings within a set time frame. The TAFE must then report to the department on its progress within six months.
Departmental audits of TAFEs against the 2017 contract

Despite having a range of audit types available, the department has used only one in the TAFE sector since October 2017—the Quality Review. Compared with other audit types that examine contractual compliance from a transactional perspective, the Quality Review has a broader, more qualitative focus. Despite this, Quality Reviews also have some focus on how TAFEs' enrolment processes comply with the contract in relation to the students' pre-training review.

The department advised that it took this narrow approach to TAFE compliance auditing because it had previously focused on auditing TAFEs' business process and transactional compliance with the contract, and it decided to shift to the qualitative aspects of TAFE performance.

We reviewed four of the eight TAFE Quality Reviews scheduled across 2017 and 2018, two of which examined a TAFE included in our audit. The department advised that the remaining four Quality Reviews are still in progress, despite all being scheduled for completion in either 2017 or 2018.

Each of the four completed Quality Reviews found that the audited TAFE had not complied with the contract's requirements for completing the pre‑training review. Figure 4C summarises these non-compliances.

Figure 4C
Pre-training review non-compliances from 2017–18 TAFE Quality Reviews

Non-compliance

TAFE 1

TAFE 2

TAFE 3

TAFE 4

Not completed prior to a student's enrolment

 

Did not adequately assess student's suitability for the qualification

Did not adequately assess student's appropriateness for the qualification

 

 

Proposed learning strategies and materials not appropriate for students

 

 

Note: Non-compliances may be based on single or multiple occurrences across the sampled student files, student data, and relevant business process documentation.
Source: VAGO.

However, we found examples where Quality Reviews reported that a TAFE's pre‑training reviews were non-compliant based on requirements that are not clear in the contract. Two reviews identified non-compliant pre-training reviews on the basis that the literacy and numeracy test did not ascertain the individual's literacy and numeracy levels in line with the ACSF's five core skills of learning, reading, writing, oral communication and numeracy. However, the contract does not require TAFEs to assess a prospective student's literacy and numeracy skills using the ACSF.

The reviews' focus on the ACSF's five core skills reflects the audit worksheets that the department provides to its auditors. These worksheets ask auditors to 'consider the ACSF levels described in the training and assessment strategy for the program(s)' when reviewing TAFE literacy and numeracy assessments.

TAFEs developed action plans to address the identified non-compliances in the four Quality Reviews we examined. Under clause 11.3(b) of the contract, an audited TAFE must write to the department within six months of the audit's finalisation on its progress in implementing the rectification plan and provide supporting evidence. While all four TAFEs did write to the department within this time frame, they provided varying amounts of supporting evidence:

  • Two TAFEs submitted revised pre-training review templates and guidance showing how they had addressed each action.
  • A third TAFE wrote to the department claiming that it had addressed all enrolment-related actions, but did not submit any further evidence or commentary.
  • A fourth TAFE provided detailed commentary showing progress against each action but did not submit any supporting evidence.

The department plans to review TAFE progress against their action plans during its 2019 audit program, commencing in September 2019. These audits will examine enrolments as far back as 2017 and include assessments of TAFEs' business processes and transactional compliance.

Managing external audits

The department engages the VET Development Centre to deliver professional learning to VET providers and its auditors.

The department manages its contract audit providers by delivering induction sessions, providing templates and guidance, holding quarterly meetings to identify emerging issues, and mandating attendance at VET Development Centre professional development workshops.

This helps to clarify the department's audit methods and areas of focus. However, in some cases this approach has driven inconsistent interpretations of enrolment-related contractual requirements between TAFEs and audit providers. The department's audit worksheets for the Quality Review require audit providers to answer specific questions that are tied to relevant contract clauses. However, some audit questions misrepresent their corresponding clauses. Figure 4D shows these inconsistencies.

Figure 4D
Inconsistencies between 2018–19 contract requirements and audit worksheets

Contract clause

Audit question

VAGO assessment

Schedule 1, clause 5.1 (a)

'Do the student's interests and aspirations (as documented in the pre-training reviews) align with the training package and programs the individual has enrolled in?'

Contract clause only requires that the pre-training reviews 'ascertain the individual's aspirations and interests with due consideration of the likely job outcomes from the development of new competencies and skills'.

Schedule 1, clause 5.1(b)

'Do the student's capabilities align with the learner characteristics, course entry requirements and course pre-requisites documented in the training and assessment strategy for the program the student has enrolled in?'

Contract clause only requires that the pre-training reviews 'consider the individual's educational attainment and capabilities'.

Schedule 1, clause 5.1(c)

'Was the nature and scope of the literacy and numeracy assessment sufficient to indicate whether the student possesses the minimum literacy & numeracy skills to successfully complete the training they are enrolled in?

Consider:

  • the AQF (Australian Qualifications Framework) level of the qualification the student is enrolled in
  • the ACSF levels described in the training and assessment strategy for the program(s).'

Contract clause only requires that the pre-training reviews 'include consideration of literacy and numeracy skills'.

Source: VAGO.

The department advised that the above audit questions also incorporate clause 5.4 of Schedule 1. This clause requires TAFEs to document how they determine the course or qualification an individual enrolled in was the most suitable. However, this connection is not evident in the department's audit worksheets and remains unclear for audited TAFEs.

Departmental improvements to enrolment requirements

The department reviewed the 2017 contract and TAFE enquiries submitted through the SVTS to identify areas where it could clarify or improve the 2018–19 contract. In late 2018, the department reviewed the 2018–19 contract as part of developing a curated version for TAFEs.

Figure 4E shows that the department has made several key improvements to enrolment requirements in the 2018–19 contract following these reviews.

Figure 4E
Key improvements to enrolment requirements in the 2018–19 contract

Change

Rationale/benefit

Sighting and retaining evidence of eligibility

The contract no longer requires TAFEs to sight and retain an original or non-certified copy of evidence of eligibility where it uses an online document verification service. Instead, TAFEs have to retain the prospective student's unique verification number, as well as secure access to the document verification service.

The contract now allows TAFEs to rely on previous eligibility checks of citizenship and age for subsequent enrolments, provided that this information remains valid.

Reduces the administration burden for TAFEs and prospective students.

Timing of the pre-training reviews and provision of statement of fees

TAFEs are now required to provide individuals with a statement of fees prior to the commencement of training, rather than prior to enrolment.

TAFEs no longer have to undertake a pre-training review prior to enrolment. Instead, it can now occur either as part of enrolment or prior to training commencement.

Reduces the administration burden for TAFEs.

Recognises the significant time needed for TAFEs to complete these activities for prospective students who may not end up enrolling.

Checking evidence of concession

The Guidelines about Fees—Skills First Program removed the reference to one week as a reasonable grace period in which TAFEs can accept evidence of concession if it is not provided before beginning training. Where a grace period applies, TAFEs must still ensure the concession that is eventually presented was valid at the time of commencement of training.

Recognises that it can take a longer time for Centrelink to process applications for concession entitlement.

Training to be provided in Victoria

The wording of clause 5.3 was amended to clarify that its intent is not that a prospective student must be a 'resident' of Victoria to undertake training, but that the TAFE must deliver training within Victoria.

Minimises the risk of TAFEs misinterpreting the contract and unnecessarily excluding prospective students from enrolling.

Electronic signatures

The 2018–19 contract clarifies instances where the department will accept an electronic signature.

Minimises the risk of TAFEs misinterpreting the contract and unnecessarily seeking physical signatures as part of enrolment.

Customising the training plan for individual needs

The second version of the 2018–19 contract clarifies the requirement that a student's training plan be customised to reflect the outcomes of the pre-training reviews. It details that where the pre-training review identifies the need for particular support, and the support to be provided is documented separately, this may be referred to, rather than included, in the training plan.

Reduces the administration burden for TAFEs.

Source: VAGO.

The department's reviews of the 2017 and 2018–19 contracts sought to address enrolment requirements that are inefficient or unclear based on TAFEs' feedback. While this is positive, there remains a need for clearer requirements for assessing a prospective student's literacy and numeracy skills.

4.4 TAFEs' internal audits of contract compliance

Under contract clause 11.4, each TAFE must conduct an annual internal audit of their compliance with the contract, including enrolment requirements. Where an internal audit reveals non-compliance, the TAFE must:

  • promptly notify the department
  • develop a rectification plan to address the non-compliance within a reasonable time
  • provide the department, or its auditors, with a copy of the rectification plan on request.

All five TAFEs internally audit their compliance with the contract's enrolment requirements and act on any non-compliances. In contrast, separate TAFE compliance assessments that follow the department's internal audit checklist produce conflicting results that show full compliance. The non-prescriptive design of the department's checklist is driving this inconsistency.

The department's internal audit checklist

The department provides TAFEs with an optional internal audit checklist template to help them assess their contractual compliance. The department expects TAFEs to supplement this checklist with other forms of ongoing compliance monitoring.

The checklist is of limited value because it does not specify any compliance criteria or testing methods other than referencing the contract's clauses. It includes some 'key audit considerations' for different groups of clauses, but these are general in nature and focused on eliciting details about TAFEs' processes, rather than their level of compliance. The audit findings produced by using the checklist are therefore unlikely to be reliable or comparable between TAFEs.

The checklist's open-ended design is also at odds with the audit worksheets used by the department's external auditors, which have more prescriptive criteria. This inconsistency further encourages conflicting interpretations of contractual requirements between external auditors and TAFEs.

Internal audit checklist results from 2018

All audited TAFEs except SuniTAFE supplied us with evidence showing their completion of contractual compliance audits during 2018 using the department's checklist. SuniTAFE completed a 2018 internal audit of contractual compliance using its own audit tool, which is more prescriptive than the department's checklist.

The four TAFEs that did use the department's internal audit checklist in 2018 all reported full compliance with the enrolment-related aspects of the contract.

Using its own audit tool, SuniTAFE identified instances of non-compliance with the contract in relation to:

  • the pre-training reviews
  • eligibility
  • fees—concessions, waivers and exemptions.

Findings from other TAFE internal audits

In addition to completing the department's internal audit checklist, Box Hill, Melbourne Polytechnic and William Angliss undertook further internal audits that examine the enrolment process in greater detail than the department's internal audit checklist. Three of these TAFEs' internal audits identified enrolment-related contract non-compliances that conflict with the full compliance reported in their completed checklists:

  • Box Hill performed three separate internal audits that examined, among other areas, the enrolment process. These identified multiple instances where the TAFE had left parts of the pre-training reviews incomplete.
  • Melbourne Polytechnic undertook an internal audit of its compliance with the contract during 2018. This revealed common instances where students had not signed and/or dated their training plan, and where the TAFE had not adequately documented outcomes of an individual's pre-training reviews in relation to course suitability. The audit also found one instance where there was no record of the TAFE performing the pre-training review.
  • William Angliss undertook an internal audit of its compliance with the contract during 2018. It found separate instances where the TAFE did not fully complete the pre-training reviews or the eligibility assessment. It also found cases where the TAFE had not satisfied the evidence requirements for assessing eligibility and applying fee concessions.

As these three TAFEs did not consider the above issues when completing the department's internal audit checklist, the department would not be aware of them unless they were identified through an external audit. However, it is the high-level, process-focused design of the department's internal audit checklist that is at the root cause of the TAFEs' inconsistent internal audit results.

For example, the department's checklist asks the TAFE questions about its processes and controls for completing the pre-training reviews and eligibility assessment, while TAFEs' own internal audit activities focus on whether they have enrolled students in accordance with the contract.

All five TAFEs developed rectification plans that show that they either have addressed, or are addressing, the enrolment issues identified in their supplementary 2018 internal audits. These typically focus on:

  • reminding staff of their compliance obligations
  • revising templates, guidelines and processes
  • committing to follow established processes more consistently
  • further investigating non-compliances to determine their root causes.

It is positive that through their internal audit activities, each TAFE is actively working to achieve ongoing compliance with the enrolment requirements under the contract.

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