PQS Compliance Audit Audit Report (User Choice & )

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1 PQS Compliance Audit Audit Report (User Choice & ) SUPPLIER ATTACHMENT 1 Registration Code 2437 RTO Legal and Trading Name Address Axial Training Pty Ltd Unit 10/10A Portal Central, Portal Office Park, 2994 Logan Road, Underwood PARTICIPANTS Lead Auditor Brad Timms Auditor(s) Auditor Phone Alena Smith General Manager Supplier Michael Smart Head of Administration and Resources Drew Clark AUDIT DETAILS Date(s) March 2017 Location PQS Agreement(s) Underwood PS Type Monitoring Re-audit Outcome Compliant Not Compliant Notes Qualification Code Qualification Certificate III in Engineering - Mechanical Trade (Maintenance - Diesel Fitting) Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning) Certificate III in Engineering - Mechanical Trade (Refrigeration and Air Conditioning) Number of Students Sampled MEM30305 Certificate III in Engineering - Fabrication Trade (Boilermaking/Welding) 5 MTM30813 Certificate III in Meat Processing (Retail Butcher) 5

2 ASSESSMENT Compliant Not Compliant Not Examined For each competency for each student the supplier has: Non-compliances gathered sufficient evidence that competency has been achieved, as expressed by the relevant endorsed industry/enterprise competency standards of a Training Package or by the learning outcome of an accredited course to support the outcome of the assessment (AVETMISS Outcome identifier 20) (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.4 (Table 3)) retained sufficient evidence to support that students have attempted all assessments and failed in at least one method (AVETMISS Outcome identifier 30) (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.4 (Table 3)) retained sufficient evidence to support recognition of prior learning (AVETMISS Outcome identifier 51) (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.4 (Table 3)) retained sufficient evidence to support transition of student to a superseding qualification and similar units of competency are deemed to be non-equivalent (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.3.3) (User Choice Policy, Clause and 2.4 (Table 3)) not been funded for delivery of a unit of competency/module through RPL in any instance where this leads to the entire qualification being achieved through RPL (User Choice Policy, Table 5) AVETMISS Outcome identifier 20 The evidence provided by the supplier did not contain the full range of assessment evidence to support AVETMISS Outcome identifier 20 claims for payment for the following students: MTM30813 Certificate III in Meat Processing Student Competency Detail Jake Bayliss CPPCLO3038A, MTMCOR203B, MTMR107C, MTMR202C, MTMR203C MTMR204C, Insufficient retention of assessment evidence - Observation assessment incomplete. Tyson Varley MTMCOR205A, MTMCOR206A Insufficient retention of assessment evidence - Student responses to verbal questions not retained. The supplier is advised the non-compliance relating to the insufficient retention of assessment evidence as outlined above, and detailed within Attachment 2, constitute Overpayments as defined in Clause 8.1 of the Pre-qualified Supplier Agreement. The department will seek recovery for the overpayments. AVETMISS Outcome Identifier 51 Recognition of Prior Learning (RPL) The evidence provided by the supplier did not contain the full range of assessment evidence to support AVETMISS Outcome identifier 51 claims for payment for the following students: Certificate III in Engineering - Mechanical Trade (Maintenance - Diesel Fitting) Lennard Thompson MEM18030B, MEM18006C, MEM18035B, MEM18003C, MEM18005B, MEM18032B, MEM18055B, MEM05050B, MEM17003A, MEM18024B, MEM18028B Insufficient evidence to validate RPL involved the assessment of the previously obtained skills and knowledge an individual has achieved outside the formal education and training system of their apprenticeship or traineeship. This student achieved competence in 16 units in 2015 and 2016 prior to being granted RPL in these 11 units of competency in October Training plan signed by all parties in September In addition, the lead auditor identified the insufficient retention of observation of practical skills to support RPL process. Record of conversation makes reference to the assessor observing ; however, no evidence of any observation evidence had been retained. 2 Department of Education and Training

3 Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning) Aaron Calderbank MEM18006C, MEM12006C, MEM18003C, MEM18004B, MEM18005B, MEM18007B, MEM18009B, MEM18055B, MEM05005B, MEM18011C, MEM18012B Insufficient evidence to validate RPL involved the assessment of the previously obtained skills and knowledge an individual has achieved outside the formal education and training system of their apprenticeship or traineeship. This student achieved competence in 15 units in 2015 and 2016 prior to being granted RPL in these 11 units of competency in January In addition, the lead auditor identified the insufficient retention of observation of practical skills to support RPL process. Record of conversation makes reference to the assessor observing ; however, no evidence of any observation evidence had been retained. The supplier is advised the non-compliance relating to the insufficient retention of assessment evidence as outlined above, and detailed within Attachment 2, constitute Overpayments as defined in Clause 8.1 of the Pre-qualified Supplier Agreement. The department will seek recovery for the overpayments. AVETMISS Outcome identifier 20 The supplier must implement a process to ensure the full range of assessment evidence for each competency, which addresses critical aspects of evidence, required skills and required knowledge, is validated and retained prior to the submission of any claim for payment. The supplier must ensure all assessments are marked, signed and dated by the assessor to support the assessment outcome. AVETMISS Outcome identifier 51 The supplier must implement a process to ensure, when making a claim for AVETMISS Outcome identifier 51; it retains sufficient evidence of the student s competence as outlined in the Evidence Guide for Pre-qualified Suppliers. been sufficiently addressed. However, rectification action must be immediately undertaken (unless otherwise advised by the lead auditor) to address all identified non-compliances and will be examined as part of future TRAINING Compliant Not Compliant Not Examined The supplier retained information and material necessary to provide a complete record of training and assessment, including: records of each student s participation in training for each unit of competency, including records of the commencement of educational content, attendance and progression. (PQS Agreement, Clause 9) The supplier has retained evidence: to support the student s participation in the learning activity prior to withdrawing (AVETMISS Outcome identifier 40). (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.4 (Table 3)) Training Plans and Training Records Where training is required to be delivered by the employer or the SRTO, the employer or the SRTO has at intervals of not more than 3 months: required the apprentice or trainee to produce the training record to have the particulars of the training completed by the apprentice or trainee during the interval entered and has kept the record complete, accurate and up-to-date by entering the particulars in it. (FET Regulations r. 4(6)) 3 Department of Education and Training

4 Non-compliances Training records The evidence provided by the supplier confirmed there was no process to retain evidence the training record was reviewed and updated at intervals of no greater than every three months. This non-compliance relates to the following students: Certificate III in Engineering - Mechanical Trade (Maintenance - Diesel Fitting) Dominic Bayntun, Levi Parsons, Lennard Thompson, and Jefferson Wheeler. Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning) Ashneel Dutt, and Daniel Pukallus. Certificate III in Engineering - Mechanical Trade (Refrigeration and Air Conditioning) Braeden Best, and Calvin Prossliner. MEM30305 Certificate III in Engineering - Fabrication Trade (Boilermaking/Welding) Mark Beilby, Dane Colley, Harrison Douglas, and Lachlan Kemp. MTM30813 Certificate III in Meat Processing (Retail Butcher) Jake Bayliss, Tyson Varley, and Desley Lowrie. Training records The supplier must implement a process to ensure evidence of the reviewing and updating of training records is retained at intervals of no greater than every three months. ADMINISTRATIVE Compliant Not Compliant Not Examined Induction information The supplier provided, for each unit of competency: Records rate of student contribution fees partial tuition fee exemption categories full exemption tuition fee categories full refunds for units not commenced and proportionate refunds for units commenced but not completed any additional fees to be charged to the employer/industry (User Choice Policy, Clause 2.6) The supplier retained information and material necessary to provide a complete record of training and assessment, including: a copy of the qualification(s) and statement(s) of attainment issued to each student. (PQS Agreement, Clause 9) The supplier provided, for each unit of competency: Training Plans a completed and accurate assessor s marking guide, criteria and observation checklists for the unit of competency. (PQS Agreement, Clause 9) signatures of all parties (student, employer and SRTO) sighted for all training plans FET Act s. 74(1) The SRTO has taken reasonable steps to ensure each training plan is signed: (a) if the training plan is the initial training plan for the apprentice or trainee within 3 months of the start of the apprenticeship or traineeship FET Act s. 74(2)(a); or 4 Department of Education and Training

5 (b) if a training plan for an apprentice or trainee ends because the SRTO registered training organisation has been replaced within 28 days after the replacement day (FET Act s. 74(2)(b)); or (c) if a training plan for an apprentice or trainee ends because the registered training contract has been permanently, temporarily or a statutory transfer within 28 days after the transfer of the contract (FET Act s. 74(2)(c)) The SRTO ensured a copy of the signed training plan is given to each apprentice or trainee, and the employer, within 14 days after the parties sign it (FET Act s. 75) Requirements of a Training Plan for an Apprentice or Trainee Training Records The training plan format implemented by the organisation contains the minimum requirements as outlined within Guide to Training Plans and Training Records and the nationally approved training plan template (released 11 September 2014) (PQS Agreement, Clause 9.1(c)) (Evidence Guide (User Choice ) for FET Act 2014, Training Plans) Individual training plans within student files have been fully developed (PQS Agreement, Clause 9.1(c)) (Evidence Guide (User Choice ) for FET Act 2014, Training Plans) Training plans address training package requirements in relation to the selection and sequencing of units of competency (PQS Agreement, Clause 9.1(c)) (Evidence Guide (User Choice ) for FET Act 2014, Training Plans) The SRTO has provided the apprentice or trainee with the appropriate training record to be kept for the apprenticeship or traineeship within 14 days after a training plan is signed by the parties to the training plan (FET Regulations r. 4(1)) AVETMISS Reporting Requirements The supplier has: Non-compliances Induction information retained sufficient evidence to support credit transfers (AVETMISS Outcome identifier 60) (PQS Agreement, Clause 9) (User Choice Policy, Clause 2.4 (Table 3)) retained sufficient evidence that an induction was conducted and training plan developed prior to the student s training contract being cancelled or the student changing suppliers (SRTO1 Administration Payment) (User Choice Policy, Clause 2.4.7) In reviewing the supplier s student handbook, the lead auditor identified the supplier was charging a 15% fee for withdrawn and not commenced units. Assessor marking guides In review of the marking guides, for two units of competency MTMCOR205 and MTMCOR206 within the qualification MTM30813 the marking guide is silent on range of assessment responses. Training plans Individual training plans within student files have not been fully developed: Student Qualification Non-compliance detail Dominic Bayntun Levi Parsons Lennard Thompson Ashneel Dutt Daniel Pukallus Braeden Best Mark Beilby (Diesel Fitting) (Diesel Fitting) (Diesel Fitting) (Fitting and/or Turning) (Fitting and/or Turning) (Refrigeration and Air Conditioning) (Boilermaking/Welding) Credit transfers not complete; Section 3 regarding student support not complete 5 Department of Education and Training

6 Dane Colley (Boilermaking/Welding) Jake Bayliss MTM30813 Tyson Varley MTM30813 Range of assessment nominated does not consistently align with assessment evidence retained; Section 3 regarding student support not complete Desley Lowrie MTM30813 For all student files examined, the supplier was unable to provide clear evidence to support when the signed copy of the training plan was issued to the apprentice or trainee and employer. This non-compliance relates to the following students: Jake Bayliss, Dominic Bayntun, Mark Beilby, Braeden Best, Dane Colley, Ashneel Dutt, Harrison Douglas, Lachlan Kemp, Desley Lowrie, Levi Parsons, Daniel Pukallus, Calvin Prossliner, Lennard Thompson, Tyson Varley, and Jefferson Wheeler. Training record The supplier was unable to provide evidence to support the training record was issued within 14 days of the training plan being signed by the parties as per legislative requirements for the following five students: MEM30305 Certificate III in Engineering - Fabrication Trade (Boilermaking/Welding) Mark Beilby Dane Colley Harrison Douglas Lachlan Kemp Certificate III in Engineering - Mechanical Trade (Refrigeration and Air Conditioning) Braeden Best Induction information: The supplier must review and amend its induction material to ensure all information regarding the charging, collection and refunding of full or partially exempted student contribution fees accurately reflect the requirements of the current User Choice Policy. Assessor marking guides: The supplier must develop and retain detailed and accurate assessor s marking guides, criteria and observation checklists for each unit of competency. Training plans The supplier must review and revise its planning and administrative processes to ensure evidence is retained to verify a copy of the signed training plan has been given to the apprentice/trainee and the employer, within 14 days after it is signed by the parties. The supplier must ensure training plans are fully developed to include accurate and relevant information. Training records The supplier must review and revise its planning and administrative processes to ensure it provides the appropriate training record to the apprentice or trainee, to be kept for the duration of the apprenticeship or traineeship, within 14 days after the training plan is signed by all parties. EMPLOYER RESOURCE ASSESSMENT Compliant Not Compliant Not Examined The supplier provided evidence it: assessed employment arrangements of each student to ensure the employer provides adequate facilities, range of work supervision and the on-the-job training required by the Act. (User Choice Policy, Clause 1.2) sourced or developed an employer resource assessment document which addresses the employment and training arrangements required under the Act for traineeships and apprenticeships (PQS Agreement, Clause 9.1(c)) (Evidence Guide (User Choice ) for FET Act 2014, Employment Arrangements) 6 Department of Education and Training

7 Non-compliances has taken appropriate action when the employment arrangements do not meet the requirements of the Act, the Agreement and/or the qualification (User Choice Policy, Clause 1.2) A review of Employer Resource Assessments (ERAs) identified the supplier had not captured all necessary information. The following issues were identified: the supervisory arrangements listed within the ERAs; o Student Levi Parsons (Certificate III in Engineering - Mechanical Trade (Maintenance - Diesel fitting)) recorded an excess ratio without the supplier justifying this decision and recording details within the ERA. details regarding appropriateness of qualified supervisor had not been completed. This non-compliance relates to the following students: o Mark Beilby (Certificate III in Engineering - Fabrication Trade (Boilermaking/Welding)) o Ashneel Dutt (Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning)) o Daniel Pukallus (Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning)) o Braeden Best (Certificate III in Engineering - Mechanical Trade (Refrigeration and Air Conditioning)) The supplier must revise its processes to ensure a thorough and accurate assessment of the employment arrangements is conducted for all future students, capturing the required facilities, range of work and supervisory arrangements available in the student s workplace, prior to signing the training plan and the commencement of any training and assessment. FEES Compliant Not Compliant Not Examined The supplier has: charged student contribution fees for all students (excluding school-based apprentices and trainees (SATs) and appropriately approved exemptions) and retained evidence of fees collected (User Choice Policy, Clause 2.6.1) calculated individual student contribution fees at the correct rate taking into consideration any partial or full exemptions (User Choice Policy, Clause 2.6.1) retained sufficient evidence to support the granting of student contribution fee exemptions (User Choice Policy, Clause and Clause 2.6.3) not charge a student contribution fee for any SAT (User Choice Policy, Clause 2.6.3) not charged student contribution fees for units of competency/modules granted, or which should have been granted, through credit transfer/national recognition (User Choice Policy, Clause 2.6.3) not charged student contribution fees for units of competency/modules when the student has transferred to a superseding qualification and the unit of competency/module is deemed to be non-equivalent (User Choice Policy, Clause 2.6.3) not charged student contribution fees for students undertaking a qualification as part of a Skilling Queenslanders for Work Work Skills Traineeship (User Choice Policy, Clause 2.6.3) not charged Queensland Year 12 graduates who have commenced a High Priority qualification within 12 months of completing Year 12 (User Choice Policy, Clause 2.6.4) retained sufficient evidence that additional charges to the employer have been negotiated (User Choice Policy, Clause 2.6.5) not charged a fee for: (a) the provision of materials essential to achieving competence (b) the development and supply of a training plan (c) the development and supply of the initial training record (User Choice Policy, Clause 2.6.7) not withheld the issuance of a qualification or statement of attainment due to non-payment of fees (User Choice Policy, Clause 2.6.9) 7 Department of Education and Training

8 Refunds The supplier has: Non-compliances provision for full refunds to students for Student Contribution Fees charged for training delivery that had not commenced at the time of cancellation of the enrolment. (User Choice Policy, Clause 2.6.6) provision for proportionate refunds where the student has withdrawn from a Unit of Competency/Module. (User Choice Policy, Clause 2.6.6) provision for refunds for employers/industry for additional charges paid beyond the student and government contributions. (User Choice Policy, Clause 2.6.6) Year 12 Graduate Fee-Free Training Strategy The supplier failed to identify student Dominic Bayntun as having graduated Year 12 and converted to an apprenticeship within a high priority qualification. These apprentices retain entitlement to the 100% co-contribution fee exempt. Refunds The lead auditor identified the supplier was charging a 15% fee for units which the student did not commence. This specifically applies to students Jake Bayliss and Desley Lowrie. The supplier was referred to User Choice Policy, Clause regarding the requirement to provide a full refund for individual unit of competency where no participation in training has been undertaken at the time of cancellation of enrolment. Year 12 Graduate Fee-Free Training Strategy The supplier must implement a process to ensure a full exemption of student contribution fees for the entire qualification is granted where an apprentice/trainee commences an apprenticeship/traineeship in a high priority qualification within 12 months of graduating Year 12. Refunds When a student contribution fee has been charged and collected, the supplier must retain evidence to support a full refund has been issued for each individual unit of competency where no participation in training has been undertaken at the time of cancellation of enrolment. ON THE JOB VERIFICATION Compliant Not Compliant Not Examined The supplier retained information and material necessary to provide a complete record of training and assessment: Non-compliances including evidence that the supplier has a process in place to capture confirmation from the employer that the student has consistently demonstrated competent performance in workplace tasks relevant to the unit of competency/module. User Choice Policy including evidence the supplier has consistently retained evidence that confirmation has been obtained from the employer that the student has consistently demonstrated competent performance in workplace tasks relevant to each unit of competency for each student prior to submission of claims for payment User Choice Policy (Evidence Guide (User Choice ) for FET Act 2014, Assessment) The supplier did not provide the full evidence to support the on-the-job verification had been captured and retained to validate claims for payment for the following students: Certificate III in Engineering - Mechanical Trade (Maintenance - Diesel Fitting) Dominic Bayntun MEM09002B, MEM18003C, MEM14005A, MEM18028B, MEM18006C, MEM18055B 8 Department of Education and Training

9 Levi Parsons MEM15002A, MEM14005A, MEM16006A, MEM16008A, MEM16007A*, MEM15024A*, MEM13014A*, MEM14004A* Lennard Thompson MEM18026C, MEM18029B Jefferson Wheeler MEM12024A, MSAENV272B, MEM15002A MEM12024A, MSAENV272B, MEM15002A, MEM09002B, MEM16006A, MEM16008A, MEM18003C Certificate III in Engineering - Mechanical Trade (Maintenance - Fitting and/or Turning) Ashneel Dutt Daniel Pukallus MEM11011B, MEM15002A, MEM14005A, MEM16008A, MEM16006A, MEM13014A*, MEM15024A*, MEM16007A*, MEM14004A* MSAENV272B, MEM12006C, MEM14005A, MEM16006A MEM12006C, MEM14005A, MEM16006A Certificate III in Engineering - Mechanical Trade (Refrigeration and Air Conditioning) Braeden Best MEM12023A, MEM14005A, MSAENV272B, MEM15002A, MEM16006A, MEM16008A, MEM13014A*, MEM14004A*, MEM15024A*, MEM16007A* 9 Department of Education and Training

10 Calvin Prossliner MEM14005A, MEM16008A, MEM16006A, MEM15002A, MEM18001C, MEM18002B, MEM14004A*, MEM15024A*, MEM13014A*, MEM16007A* MEM30305 Certificate III in Engineering - Fabrication Trade (Boilermaking/Welding) Mark Beilby Dane Colley Harrison Douglas MEM14005A, MEM16006A, MEM16008A, MEM14004A* MEM05011D, MEM05015D, MEM05036C, MEM12007D, MEM05010C, MEM05037C MEM11011B, MEM15002A, MEM16006A, MEM16008A, MEM14005A, MSAENV272B, MEM13014A*, MEM15024A*, MEM16007A*, MEM14004A*, Lachlan Kemp MEM05015D MTM30813 Certificate III in Meat Processing (Retail Butcher) Jake Bayliss CPPCLO3038A, MTMCOR203B, MTMR203C, MTMSR201C, MTMR202C, MTMR204C, MTMSR202C MTMR202C, MTMR204C, MTMSR202C perform tasks to industry standards not evident - Workplace Referee s Report incomplete The supplier is advised the non-compliance relating to insufficient retention of on-the-job verification evidence as outlined above, and detailed within Attachment 2, constitute Overpayments as defined in Clause 8.1 of the Prequalified Supplier Agreement. As a result of the department moderating the audit findings, recovery of overpayments will not be pursued in this instance, however, the department may examine rectification evidence of these noncompliances as part of any further audit activity. In relation to student Braeden Best, the lead auditor was unable to clearly identify the person signing the On-the-Job verification for seven units was the person listed on the ERA. The supplier must ensure information regarding the name of the nominated qualified person and details regarding any industry specific qualifications currently held must be clearly captured within the ERA. 10 Department of Education and Training

11 The supplier must ensure the evidence of workplace validation confirms the apprentice/trainee demonstrated the required range of skills in the workplace and that the validation evidence is signed and dated by the employer. This validation must be reviewed by the supplier prior to making a final judgement as to whether the apprentice/trainee is competent and prior to the submission of any future claim for payment. The supplier must ensure a suitable qualified supervisor is signing off on the on-the-job component for each unit of competency. The supervisors must also be listed on the ERA as a suitably qualified supervisor, with information on qualifications held and years of experience. AVETMISS DATA Compliant Not Compliant Not Examined The supplier has: Non-compliances reported the Delivery mode identifier specified in AVETMISS for the relevant delivery mode. (User Choice Policy, Clause 2.4.3) reported the Outcome code identifier specified in AVETMISS for the relevant outcome. (User Choice Policy, Clause 2.4.3) reported accurate AVETMISS activity start and activity end dates for each student for each unit of competency (PQS Agreement, Clause 9.1) submitted AVETMISS postcodes that accurately reflect the location in which the majority of training has been undertaken (User Choice Policy, Clause 2.4.3) not submitted claims for payment for units in excess of the competency count for the qualification (User Choice Policy, Clause 2.4 Table 5)) not submitted claims for payment for units of competency previously assessed as competent (User Choice Policy, Clause 2.4 Table 5)) Previously assessed competencies On the first day of the audit the supplier was provided with a list of 179 units of competency which had previously been claimed as competent indicating the supplier had failed to apply eligible credit transfers. Prior to the completion of the audit site visit, the supplier provided the lead auditor with information regarding the supplier s justification as to why eligible credit transfers hadn t been identified and acknowledged. On review of this evidence, the lead auditor accepted evidence only for student Jake Freeman. The supplier is advised claims made where the supplier has claimed payment for a competency previously assessed as outlined above, and detailed within Attachment 2, constitute Overpayments as defined in Clause 8.1 of the Prequalified Supplier Agreement. The department will seek recovery for the overpayments. Previously assessed competencies The supplier must implement a process to ensure competencies which have already been previously assessed as competent are not claimed. The supplier must ensure it reports all units of competency available for credit transfer, as a credit transfer. It is the responsibility of the supplier to check and retain a student s statement of attainment when they have previously undertaken training, to determine whether any completed unit of competency can be counted towards the qualification in which the student intends to enrol. All documents are available online at: 11 Department of Education and Training