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CRICOS
Audit Preparation
Meeting compliance need not be a burden
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
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
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
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
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
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
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?
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
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
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
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
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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