Training Compliance Unit
January 2014
Version 5
PRE-QUALIFIED SUPPLIER DETAILS
RTO number
Address
Audit venue
0427 PQS number QS100125
Sarina Russo Centre, 82 Ann Street, Brisbane City
Level 10, 100 Eagle Street, Brisbane City
Contact person
Phone number
Tracey Silcox
0437 704 310
Web site
E-mail www.sri.edu.au
TSilcox@sri.edu.au
Student numbers
AUDIT TEAM
Lead Auditor
Phone
Email
Phoebe Turk
(07) 3225 2400 phoebe.turk@dete.qld.gov.au
Auditor/s
Auditor/s
AUDIT DETAILS
Audit date/s
Audit outcome on day of audit
Other audit notes
25 th and 26 th February 2014.
Compliant
FOCUS OF AUDIT
Qualification code
BSB30112 Certificate II in Business
Qualifications
BSB30412 Certificate III in Business Administration
SIR30212 Certificate III in Retail Operations
SIT20212 Certificate II in Hospitality
SIT30712 Certificate III in Hospitality
TLI31610 Certificate III in Warehousing Operations
INTERVIEWEE/S
Kathleen Newcombe, Nadine Neave, Tracey Silcox and Cecilia Sorensen.
Rex Tom
Drew Clark
Non-compliant
Total
Students
5
Delivery site
QLD state-wide
10 QLD state-wide
7
1
QLD state-wide
QLD state-wide
5
7
QLD state-wide
QLD state-wide

Clause 26 Good faith
In performing its obligations under this Agreement and seeking to become entitled to public funding under this Agreement the Supplier has acted:
Y N
in good faith in all matters pertaining to the Agreement;
consistently with the spirit of this Agreement and the Funding Program;
in a way that best achieves the objectives of the Funding program.
At time of audit:
Compliant
Not Compliant
The audit of Sarina Russo Institute identified non-compliances relating to the assessment of participant eligibility and retention of supporting evidence – matters which underpin the aims of the funding program. The lead auditor notes the organisation did not appear to be deliberately acting in a way which contravenes the intent of the Agreement or program aims.
The organisation is advised, however, the types and scope of non-compliances identified have the potential, if found at future audit, to result in a reassessment of the organisation’s compliance with this “Good Faith” provision and could result in the imposition of significant sanction, including termination of the Agreement.
Clause 3 Supplier’s obligations
The supplier must:
Y N
give students information specified by the Department.
Clause 3.2.d
At time of audit:
Compliant
Not Compliant
Clause 9 Records
The following information and material, necessary to provide a complete record of training and assessment, was sighted at audit:
Y N
records of each student’s participation in training and assessment for each unit of competency, including records of the commencement of educational content, attendance and progression;
accurate AVETMISS start and end dates for each student for each unit of competency;
copy of the qualifications and statements of attainment issued to each student;
For each unit of competency for each student, the auditor sighted:
Y N N/A completed and accurate assessor’s marking guide, criteria and observation checklists for the unit of competency; and the completed assessment items for the unit of competency:
a) completed digital assessment items
b) completed paper-based assessment items.
At time of audit:
Compliant
Not Compliant
NON-COMPLIANCES:
AVETMISS end dates
The auditor identified the organisation had not consistently reported accurate AVETMISS end dates for each student for each unit of competency. This issue relates specifically to students who undertook SIR30212 Certificate III in Retail
Operations. It was identified claims had been submitted up to one month prior to the observation assessment being conducted. In some instances the observation cover sheet had not been retained and the auditor was unable to verify the date practical assessment occurred and validate the AVETMISS end date.
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Completed observation checklists and digital assessment items
TLI31610 Certificate III in Warehousing Operations
The auditor identified the organisation had not retained evidence of the practical assessment for students undertaking
TLI31610 Certificate III in Warehousing Operations. The context of and specific resources for assessment for each TLI unit of competency state ‘performance is demonstrated consistently over a period of time.’ In discussion with the auditor, the organisation advised it had self-identified this issue prior to audit and had already taken action to amend its processes for future students enrolling in the qualification. For those units for which no evidence of practical assessment was retained, the auditor was unable to validate practical assessment had occurred.
SIR30212 Certificate III in Retail Operations
The auditor identified the organisation had not retained the completed observation checklist for each unit of competency for each student undertaking SIR30212 Certificate III in Retail Operations. On some student files reviewed at audit, the auditor sighted a completed assessment cover sheet, however, did not sight the completed observation checklist to support the assessor’s determination of competence. For those units for which an observation checklist was not retained, the auditor was unable to validate practical assessment had occurred.
On some student files reviewed at audit, the auditor sighted a ‘work experience log book’ and no assessment cover sheet. The ‘work experience log book’ includes an observation checklist which lists the unit of competency code and performance criteria, against which the assessor provides his/her initials. The observation checklist did not cover every unit delivered to the student and did not capture the date of assessment. For those units on the observation checklist, the auditor was satisfied assessment had occurred. For those units not on the observation checklist, the auditor was unable to validate practical assessment had occurred.
SIT30712 Certificate III in Hospitality
The auditor identified the organisation had not retained evidence of the practical assessment for some units of competency for students undertaking SIT30712 Certificate III in Hospitality. In some instances the organisation had not retained any evidence of practical assessment. Where no evidence was sighted, the auditor was unable to validate practical assessment had occurred. In some instances the organisation had not retained sufficient evidence to support the full range of assessment, as required by the training package rules, had occurred.
SITHFAB204 Prepare and serve espresso coffee
It was identified the organisation had not retained evidence the student had been assessed preparing the full range of coffee styles required.
SITHIND301 Work effectively in hospitality service
It was identified the organisation had not retained evidence the student had undertaken all 36 required service periods.
SIT20212 Certificate II in Hospitality
The auditor identified the organisation had not retained evidence of the observation checklist for one student for one unit of competency. A completed assessment cover sheet was sighted, however, the auditor did not sight the completed observation checklist to support the assessor’s determination of competence.
BSB30412 Certificate III in Business Administration
The auditor identified the organisation had not retained evidence of the digital assessment items for some units of competency for one student. Specifically, the written assessment items for some units were not on the organisation’s online student management system, Catapult, however the student had been marked competent and the assessor had written notes referencing a practical assessment. For those units for which the completed digital assessment items were not retained, the auditor was unable to validate assessment had occurred.
Details of specific students and units of competency to which these issues apply are outlined in Attachment 2.
Where the RTO claims for and receives payment and there is insufficient evidence of assessment an “Overpayment”, as defined within Clause 8.1 of the Agreement, has occurred.
Pre-requisite requirements
The auditor identified the organisation had not retained evidence to support the delivery of pre-requisite units in the order specified by the training package rules. This issue relates to units of competency within SIT30712 Certificate III in
Hospitality and SIT20212 Certificate II in Hospitality. It was identified the organisation had co-assessed pre-requisite units and in some instances assessed them on dates subsequent to assessing the unit/s of competency for which they are a pre-requisite.
The organisation provided the auditor a document which showed it had identified the pre-requisite requirements and structured its training and assessment schedule to meet them. However, the conduct of training and assessment did not
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follow the schedule provided.
Entry requirements
The auditor identified the organisation had not retained evidence the entry requirements for Na-Chu Yen, SIR30212
Certificate III in Retail Operations, had been assessed. A resume was identified on the student file, however it was a one page document listing the student’s contact details only, with no further supporting information related to employment history etc.
RECTIFICATION REQUIRED:
AVETMISS end dates
The organisation must develop and implement a process to consistently report accurate AVETMISS end dates for each student for each unit of competency.
Completed observation checklists and digital assessment items
The organisation must review its current processes and develop and implement new processes to retain, for each student for each unit of competency, the completed observation checklist and digital assessment items.
The organisation must review its assessment items for SITHFAB204 Prepare and serve espresso coffee and
SITHIND301 Work effectively in hospitality service and ensure it retains evidence it has assessed the full range of assessments required by the training package rules.
Pre-requisite requirements
The organisation must review and amend its processes to ensure the delivery of pre-requisite units occurs as required by the training package rules for each unit of competency.
Entry requirements
The organisation must develop and implement a process to retain evidence of student’s retail experience to support entry to SIR30212 Certificate III in Retail Operations, as required by the training package rules for the qualification.
The organisation is advised a number of the above non-compliances constitute “Overpayment” as defined in Clause 8.1 of the Agreement and the Department will seek recovery in this regard (see Attachment 2). The organisation is required to co-operate with the Department by prompt payment of Departmental invoices raised.
Sarina Russo Institute will not be required to submit further evidence to the Department to demonstrate noncompliances have been sufficiently addressed. However, the organisation is advised rectification action undertaken to address all identified non-compliances will be examined as part of future audit or monitoring activity.
Clause 10 Access to premises and records
The RTO gave the Department access to its premises:
Y N
to inspect and copy information and material related to the Agreement or kept by the
Supplier under clause 9.1; and
to monitor the provision of training and assessment and other VET Services and performance of the RTO’s obligations under the Agreement.
employees and contractors provided full and accurate answers to questions asked by the Department in connection with training and assessment, other VET Services and
Supplier obligations under the Agreement.
At time of audit:
Compliant
Not Compliant
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Clause 11 Publicity
In making any public statements in relation to the training and assessment funded under this
Agreement the RTO:
Y N N/A
has referenced the Department as the funding source within any public statement
has not made any misleading public statements including statements to students, employers or other organisations relating to the Agreement or the Department
has correctly referenced the Funding Program as “Certificate 3 Guarantee
Program” or such other name as specified by the Department
has not used the logo of the State of Queensland or the Department.
Clause 12 Conflicts of interest and inducements
The organisation provided evidence that for the term of its agreement with the Department it:
Y N N/A
immediately gave notice to the Department of a conflict or risk of conflict of interest
has not offered any gift or other benefit to a prospective student as an inducement to influence a prospective student or a student to choose the
Supplier to provided training.
Clause 13 Insurance
The organisation provided evidence that for the term of its agreement with the Department it:
Y N N/A maintained public liability insurance for a minimum of $10 million arising out of any one event in respect of death, injury, loss, or damage howsoever sustained to or by any person or property;
maintained professional indemnity insurance
maintained workers compensation insurance.
3.1.1 – Training covered
At time of audit:
Compliant
Not Compliant
Not Applicable
At time of audit:
Compliant
Not Compliant
At time of audit:
Compliant
Not Compliant
The RTO has:
Y N N/A
retained evidence to support the delivery of lower-level training to eligible
participants
retained evidence to support the delivery of foundation skills training (i.e. language, literacy and numeracy)
At time of audit:
Compliant
Not Compliant
Not Applicable delivered lower-level qualification(s) which are a mandated pre-requisite for a funded certificate III level qualification.
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Clause 3.2 Eligibility Requirements
Participant Eligibility
The RTO has assessed prospective participant eligibility and retained evidence each participant is:
Y N
aged 15 years or above
no longer at school
a Queensland resident (Australian Citizen, Australian permanent resident or New
Zealand citizen permanently residing in Queensland)
The RTO has assessed prospective participant eligibility and retained evidence that, from 1
July 2013, each participant:
Y N
did not already hold a post-school certificate III qualification or higher
was not already enrolled in a post-school certificate III qualification or higher
The RTO has retained evidence it has:
Y N
used the Apprenticeships Info Self Service (AISS) to verify eligibility for each participant
implemented and used other supporting processes of integrity to verify eligibility for each participant.
PQS Obligations
The RTO has:
Y N N/A disclosed upfront and published/advertised all Student Contribution Fees
(inclusive of all essential training costs) for both concessional and nonconcessional participants for each qualification it is approved to deliver under the
Certificate 3 Guarantee
not advertised fee free training published a summary of its latest audit information in a prominent position on its website provided staff continuous professional learning on Inclusive Practice
implemented the mandated Training and Employment Survey
administered the Training and Employment Survey to each participant within three (3) months of finishing or discontinuing their training
obtained or taken reasonable steps to obtain, from each participant, a completed
Training and Employment Survey
reported to the Department the Training and Employment Survey responses by participants who have finished training (submitted by 31 March each year)
validated whether a participant is a concessional participant confirmed with the participant that they understand they will no longer be eligible for a subsidised training place under the Program once they complete the certificate III qualification
Training and Assessment Plan
The RTO has:
Y N N/A
developed a Training and Assessment Plan for the qualification which includes: a breakdown of all training costs (including Student Contribution Fees, how and when fees will be charged and collected at the unit of competency level) timelines for training delivery
At time of audit:
Compliant
Not Compliant
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delivery mode and location
vocational placement support services available to assist the participant to successfully complete their qualification.
NON-COMPLIANCES:
Participant Eligibility
The auditor identified the organisation had not retained a sufficient range of evidence to support student eligibility. In some instances the organisation had not retained any evidence and in other instances the organisation had retained only one or two forms of evidence, which were not sufficient to demonstrate the student’s eligibility against each criterion.
In some instances the student had identified on their enrolment form they were born overseas, however the organisation had not retained evidence to support the student is an Australian Citizen or permanent resident.
In some instances the organisation had retained a copy of the front of a drivers licence only, failing to capture the address on the back to support Queensland residency.
In some instances the organisation had recorded the student’s health care and Medicare card numbers, but not retained a copy of either card.
The auditor identified instances where students had previously completed a certificate III or higher level qualification. In these instances, the students were ineligible to receive funding under the Certificate 3 Guarantee Program. Details of specific students for whom this issue applies are outlined in Attachment 2.
It was identified the organisation’s enrolment form included a question which asked the student if they had previously completed tertiary study, but did not ask the student if they had partially completed a qualification or were currently enrolled in a qualification. In discussion with the organisation, the auditor advised the enrolment form should be expanded to include a range of questions to better assess student eligibility.
The auditor identified the organisation had not conducted a search of AISS for each participant. In discussion with the auditor, the organisation advised it had begun using AISS after receiving notification it had become a mandatory requirement.
Claims for payment made and received for students ineligible to receive funding under the Certificate 3 Guarantee
Program are identified as “Overpayments” as defined within Clause 8.1 of the Agreement.
PQS Obligations
The auditor identified the organisation had not retained evidence to support Merinda McDonald’s eligibility for concession. Prior to the completion of the audit, the organisation provided the auditor additional evidence to verify the student’s eligibility for concession.
The auditor identified the organisation has included a check box on a document titled ‘Appendix 2’ which captures the students’ acknowledgement they understand they will no longer be eligible for a subsidised training place under the
Program once they complete the certificate III qualification. However, it was identified the organisation had not consistently retained a copy of this document on each student file.
Training and Assessment Plan
The auditor identified the organisation had not developed and implemented a training and assessment plan. As a result, the requirements of the training and assessment plan had not been met. In discussion with the auditor, the organisation advised it has captured the required information in other documents provided to student’s and had misunderstood the term training and assessment plan to refer to a training and assessment strategy.
RECTIFICATION REQUIRED:
Participant Eligibility
The organisation must develop and implement a process of rigour and integrity to capture a range of current, sufficient evidence to support student eligibility against each criterion, prior to enrolment.
The organisation must develop and implement a process to check AISS for each participant and retain evidence of this.
It is important to note the absence of a student’s name from AISS does not guarantee his/her eligibility under this criterion. The organisation is required to evidence other actions/processes undertaken to ensure prospective students do not already hold or are not already enrolled in a Certificate III or higher qualification.
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The organisation is advised a number of the above non-compliances constitute “Overpayment” as defined in Clause 8.1 of the Agreement and the Department will seek recovery (see Attachment 2). The organisation is required to cooperate with the Department by prompt payment of departmental invoices raised or by promptly amending AVETMISS data, where specified.
PQS Obligations
The organisation must develop and implement processes to:
• consistently retain evidence to support each student’s eligibility for concession
• retain a copy of ‘Appendix 2’ to support the student’s acknowledgement regarding funding.
Training and Assessment Plan
The organisation must develop and implement a training and assessment plan which captures:
• a breakdown of all training costs (including Student Contribution Fees, how and when fees will be charged and collected at the unit of competency level)
• timelines for training delivery
• delivery mode and location
• vocational placement (where applicable) and
• support services available to assist the participant to successfully complete their qualification.
Sarina Russo Institute will not be required to submit further evidence to the Department to demonstrate noncompliances have been sufficiently addressed. However, the organisation is advised rectification action taken to address all identified non-compliances will be examined as part of future audit or monitoring activity.
OPPORTUNITY FOR IMPROVEMENT
In discussion with the organisation, the auditor advised the quality of some eligibility evidence retained made it difficult to verify the information it intended to captured. Specifically, scanned copies of documents were not legible. The organisation should investigate implementation of a process to capture high-quality records to support each student’s eligibility against each criterion.
Clause 3.4.2 AVETMISS Reporting Requirements.
The RTO has correctly reported:
Y N NA the Delivery Identifier Code specified in AVETMISS for the relevant mode of delivery the Outcome Identifier code specified in AVETMISS the participant is eligible to receive the qualification by ticking the Qualification
Issued Flag
participant’s eligibility for concession the amount of Student Contribution Fees collected per unit of competency
AVETMISS postcodes that accurately reflect the location in which the majority of training has been undertaken.
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 Code 20);
retained sufficient evidence to support that students have attempted all assessments and failed in at least one method (AVETMISS Outcome Identifier
Code 30);
retained sufficient evidence to support the student’s participation in the learning
At time of audit:
Compliant
Not Compliant
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activity prior to withdrawing (AVETMISS Outcome Identifier Code 40);
retained sufficient evidence to support recognition of prior learning (AVETMISS
Outcome Identifier Code 51);
retained sufficient evidence to support credit transfers (AVETMISS Outcome
Identifier Code 60);
any unit of competency available for credit transfer has been reported by the RTO as a credit transfer (AVETMISS Outcome Identifier Code 60);
retained sufficient evidence to support gap training for non-equivalent units within a transition from a superseded qualification (AVETMISS Outcome Identifier Code
65).
NON-COMPLIANCES:
Delivery identifier code
It was identified the organisation had reported delivery identifier code ‘10’ (classroom). In discussion with the auditor, the organisation advised training occurs via Catapult, an online system. Students attend a classroom and access learning resources using a laptop. During this time students are supervised and have access to trainers via telephone. This method of delivery was moderated by the audit team and it was determined where this type of delivery occurs it is deemed to be electronic and delivery identifier code ‘20’ must be used.
Outcome identifier code
It was identified the organisation had submitted claims for training and assessment, using AVETMISS outcome identifier code ‘20’, for which the student should have received credit transfer. In these instances, the organisation had reported the incorrect outcome identifier code.
AVETMISS post codes
As a result of the incorrect delivery identifier code being used, the organisation had also submitted incorrect AVETMISS post codes. In the case of delivery identifier code ‘20’ (electronic) the organisation must report the location from which the learning resources originate. In discussion with the organisation it was identified this would be its head office.
AVETMISS outcome identifier code ‘20’
As outlined in Clause 9 Records, the audit identified issues relating to retention of assessment records. Please refer to that section of the audit report for details of non-compliance.
AVETMISS outcome identifier code ‘60’
The auditor identified a number of instances where available credit transfer had not been given to some students for some units of competency. In some cases, the organisation had retained a copy of the student’s statement of attainment, indicating the eligible unit/s of competency, however no action had been taken in this regard. Details of students to whom this issue relates are outlined in Attachment 2.
Claims for payment for units previously assessed as competent, constitute “Overpayments” as defined within Clause 8.1 of the Agreement.
RECTIFICATION REQUIRED:
Delivery identifier code
Where appropriate, the organisation must report delivery identifier code ‘20’ (electronic). This use of this code will be appropriate when students undertake learning in the situation described above.
AVETMISS post codes
When using delivery identifier code ‘20’ (electronic), the organisation must report the post code from which the learning resources originate. As outlined above, this would be organisation’s head office.
AVETMISS outcome identifier code ‘20’
Please refer to the section of the audit report titled ‘Clause 9 Records’ for details of rectification required.
AVETMISS outcome identifier code ‘60’ and outcome identifier code
The organisation must develop and implement a process to identify each student eligible for credit transfer. It must undertake a process to capture evidence to support credit transfer and award it in each instance the student is deemed eligible.
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The organisation is advised a number of these non-compliances constitute “Overpayment” as defined in Clause 8.1 of the Agreement and the Department will seek recovery (see Attachment 2). The organisation is required to cooperate with the Department by prompt payment of Departmental invoices raised and by promptly amending AVETMISS data, where specified.
Sarina Russo Institute will not be required to submit further evidence to the Department to demonstrate noncompliances have been sufficiently addressed. However, the organisation is advised rectification action taken to address all identified non-compliances will be examined as part of future audit or monitoring activity.
Table 4 – Service provision not funded
The RTO has:
Y N
not submitted claims for payment for units in excess of the competency count for the qualification;
not submitted claims for payment for units of competency previously assessed as competent.
At time of audit:
Compliant
Not Compliant
NON-COMPLIANCES:
Please refer to the section of the report titled ‘3.4.2 AVETMISS reporting requirements’ for details of non-compliance relating to the submission of claims for payment for units of competency previously assessed as competent.
RECTIFICATION REQUIRED:
Please refer to the section of the report titled ‘3.4.2 AVETMISS reporting requirements’ for details of rectification required, relating to the submission of claims for payment for units of competency previously assessed as competent.
Sarina Russo Institute will not be required to submit further evidence to the Department to demonstrate noncompliances have been sufficiently addressed. However, the organisation is advised rectification action taken to address all identified non-compliances will be examined as part of future audit or monitoring activity.
Clause 3.5 – Fees and charges
The RTO has:
Y N N/A
charged a Student Contribution Fee disclosed and advertised Student Contribution Fees upfront supplied participants with its Fees and Charges Policy prior to enrolment
retained evidence of Student Contribution Fees collected
charged and collected Student Contribution Fees at the unit of competency level
not charged Student Contribution Fees for Outcome 60 (Credit Transfers) or
Outcome 65. developed a refund policy provided prospective participants with a copy of, or access to, its refund policy prior to enrolment
issued refunds as per its refund policy and retained supporting evidence.
At time of audit:
Compliant
Not Compliant
NON-COMPLIANCES:
The auditor identified the organisation had not charged and collected fees at the unit of competency level.
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RECTIFICATION REQUIRED:
The organisation must develop and implement a process to charge and collect fees at the unit of competency level. As discussed during the audit, amendment of the organisation’s invoice to include specific wording detailing the breakdown of cost at the unit of competency level would be sufficient to address this issue.
Sarina Russo Institute will not be required to submit further evidence to the Department to demonstrate noncompliances have been sufficiently addressed. However, the organisation is advised rectification action taken to address all identified non-compliances will be examined as part of future audit or monitoring activity.
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