PQS Compliance Audit ReportPQS Compliance Audit Report Queensland VET Quality Framework RTO code RTO...

PQS Compliance Audit Report Queensland VET Quality Framework

RTO code

RTO legal name

RTO trading name

RTO address

Funding program(s) audited

PQS agreement(s) audited

Audit location

Type of audit

Compliance assessment

Lead auditors

Issue date

HPE ref

AUDIT-IN-CONFIDENCE

Contents Contents .............................................................................................................. ii 1 Executive summary .................................................................................... 1

1.1 Background ................................................................................................ 1 1.2 Objective and scope ................................................................................... 1 1.3 Summary of results ..................................................................................... 1

1.3.1 Noteworthy initiatives ......................................................................... 1 1.3.2 Internal control improvement opportunities ........................................ 2 1.3.3 Audit overview ................................................................................... 2 1.3.4 Root causes and risk issues .............................................................. 3

1.4 PQS acknowledgement and feedback ........................................................ 3 1.4.1 Acknowledgement ............................................................................. 3 1.4.2 Feedback ........................................................................................... 4

2 PQS development areas ............................................................................ 5

Appendix 1 Priority focus area ratings ............................................................ 7

Appendix 2 Audit scope detail ........................................................................ 8 1 Quality and Compliance audit team ............................................................ 8 2 Qualifications included in the audit .............................................................. 8

QS agreement code .................................................................................... 8 PS agreement code .................................................................................... 8

3 Audit focus .................................................................................................. 8

Appendix 3 Non-compliance detail – VET Investment .................................... 9 1 Administration ............................................................................................. 9 2 Eligibility ................................................................................................... 10 3 Lower-level training and foundation skills training ..................................... 10 4 Fees ......................................................................................................... 11 5 Training .................................................................................................... 12 6 Assessment .............................................................................................. 13 7 AVETMISS reporting ................................................................................ 14

Appendix 4 Non-compliance detail – User Choice ....................................... 16 1 Administration ........................................................................................... 16 2 Employer resource assessment ................................................................ 17 3 On-the-job verification ............................................................................... 17 4 Fees ......................................................................................................... 17 5 Training .................................................................................................... 18 6 Assessment .............................................................................................. 19 7 AVETMISS reporting ................................................................................ 20

Appendix 5 Summary of key non-compliances – VET Investment ............... 21

Appendix 6 Summary of key non-compliances – User Choice ..................... 22

PQS Compliance Audit Report - ii -

1 Executive summary 1.1 Background A pre-qualified supplier (PQS) audit has been performed in accordance with the approved 2018–19 Department of Employment, Small Business and Training (DESBT) PQS Audit Plan. Your registered training organisation (RTO) provides services that underpin the delivery of VET Investment Plan program outcomes to Queensland students.

This report summarises the department’s assessment of PQS operations within the audit scope conducted by the Quality and Compliance Unit, including maturity rating for the areas reviewed; and focus areas identified during the audit impacting the sustainment of compliance.

Please note that Appendix 5 and Appendix 6 contain the summary of key non-compliances, within the audit report for the purposes of identification and provision of details. Any action regarding the recovery of any identified ‘overpayments’, as detailed within Clause 8 of your PQS Agreement, may be progressed separately by Contract Management.

1.2 Objective and scope The objective of the audit is to assess the design and operational effectiveness of PQS controls and compliance with the requirements of PQS agreements.

The scope for the audit includes a review of:

PQS governance, planning and risk management in relation to PQS agreements PQS agreement delivery i.e. evidence of operating in accordance with the terms of

the PQS agreement/s, including relevant policies and evidence requirements documentation.

Qualifications included:

[Qualification code and title] [Qualification code and title]

For further detail regarding the scope and the qualifications, refer to Appendix 2.

1.3 Summary of results 1.3.1 Noteworthy initiatives

The audit has identified the following good practices already in place:

Table 1 Noteworthy initiatives

Noteworthy initiatives Key benefits of initiatives [Where identified, these will be outlined here with the key benefits of the initiative]

PQS Compliance Audit Report - 1 -

1.3.2 Internal control improvement opportunities

The audit has identified the following opportunities for internal control improvement:

Table 2 Internal control improvement opportunities

Internal control improvement opportunities Key benefits of improvements [Where identified, these will be outlined here with the key benefits of the initiative]

1.3.3 Audit overview

The design and operational effectiveness of PQS controls and compliance as per departmental requirements require strengthening:

The focus areas identified in Table 3 below, together with their assessed priority rating for actioning (refer to Appendix 1 for an explanation of priority ratings)

Findings and proposed management actions for each focus area as provided in Section 2

The detail regarding non-compliances (by agreement) as provided in appendices 3 and D

An overview of key non-compliances (by agreement) as provided in appendices 5 and 6.

Table 3 PQS audit overview

Ref Focus area Priority focus area 2.1 Governance, planning and risk management 2.1.1 Assurance framework

2.1.2 Policies and procedures 2.1.3 Information management 2.2 Agreement delivery – VET Investment 2.2.1 Administration 2.2.2 Eligibility

2.2.3 Lower-level training and foundation skills training

2.2.4 Fees 2.2.5 Training

2.2.6 Assessment

2.2.7 AVETMISS reporting 2.3 Agreement delivery – User Choice 2.3.1 Administration

2.3.2 Employer resource assessment 2.3.3 On-the-job verification

2.3.4 Fees

2.3.5 Training 2.3.6 Assessment

2.3.7 AVETMISS reporting


Table 4 PQS maturity ratings

PQS maturity ratings Maturity rating Governance, planning and risk management

Agreement delivery – VET Investment

Agreement delivery – User Choice

Refer to Table 5 for the maturity rating key.

Table 5 Maturity rating key

Maturity rating Rating definition Achieving / enhancing

Good governance structures; strong policies and procedures; routine performance management; sound internal controls that are ‘embedded’ and ‘understood’. Unmitigated risks of ‘low’ priority only.

Developing / emerging

Improvements required – governance, policies and procedures, performance management; internal controls that ‘exist’ but are not ‘embedded’ or ‘understood’. Unmitigated risks of ‘medium’ or ‘high’ priority.

Learning / beginning

Significant weaknesses – governance, policies and procedures setting, performance management; weak internal controls that do not ‘exist’ or are not ‘defined’. Several unmitigated risks of ‘medium’, ‘high’ or ’extreme’ priority.

1.3.4 Root causes and risk issues

[If non-compliance or risk of non-compliance is identified, root causes and risk issues will be outlined here.]

1.4 PQS acknowledgement and feedback 1.4.1 Acknowledgement

Thank you to your management and staff for the assistance provided during the course of this audit, specifically:

Name Position


1.4.2 Feedback

We value your feedback, which will contribute to the continuous improvement of Quality and Compliance processes. It would be appreciated if you could complete and return the PQS audit evaluation form provided via email with this audit report.


2 PQS development areas Rectification of all non-compliances as well as processes identified as contributing to non-compliance must be undertaken immediately; however, there is no requirement to submit rectification evidence to the department unless specifically requested.

More information regarding non-compliances specific to individual students, qualifications and/or units of competency is provided in Appendix 3 and Appendix 4.

[Focus areas for PQS development as well as areas of non-compliance will be provided where relevant]

Ref Focus area Risk / impact Recommended management action

Priority focus area

2.1 Governance, planning and risk management

2.1.1 Assurance framework

2.1.2 Policies and procedures

2.1.3 Information management systems

Ref Focus area % of compliance

Recommended management action

Priority focus area

2.2 Agreement delivery – VET Investment 2.2.1 Administration

[Focus areas listed as required]

2.2.2 Eligibility

[Focus areas listed as required] 2.2.3 Lower-level training and foundation skills training


2.2.4 Fees [Focus areas listed as required]

2.2.5 Training

[Focus areas listed as required] 2.2.6 Assessment


2.2.7 AVETMISS reporting [Focus areas listed as required]

Ref Focus area % of compliance

Recommended management action

Priority focus area

2.3 Agreement delivery – User Choice 2.3.1 Administration

[Focus areas listed as required] 2.3.2 Employer resource assessment (ERA)



2.3.3 On-the-job verification e

[Focus areas listed as required] 2.3.4 Fees


2.3.5 Training [Focus areas listed as required]

2.3.6 Assessment

[Focus areas listed as required] 2.3.7 AVETMISS reporting



Appendix 1 Priority focus area ratings Priority focus area ratings have been assigned to the findings raised in this report as outlined below. They are assigned in order to provide assistance to PQS in relation to focusing the action that needs to be taken based on the audit finding. They are not a departmental rating of importance.

Priority focus area Attributes

Extreme priority An extreme weakness in the PQS control environment. The department’s findings point to serious ongoing risk of not meeting the requirements of the PQS agreement.

High priority A significant weakness in the PQS control environment. Findings indicate an unacceptable level of ongoing risk of not meeting the requirements of the PQS agreement.

Medium priority A moderate weakness in the PQS control environment. Findings point to ongoing risk of not meeting the requirements of the PQS agreement.

Low priority A minor weakness in the PQS control environment. Findings point to minimal or no ongoing risk to meeting the requirements of the PQS agreement.

Business improvement opportunity

The department finds there is an opportunity to improve efficiency and effectiveness of current processes which, if not actioned, may result in not meeting the requirements of the PQS agreement.

Priority levels at the medium level and higher may be escalated to executive management via the PQS Review Panel to consider an appropriate response, if required.

For further information email [email protected].


mailto:[email protected]

Appendix 2 Audit scope detail

1 Quality and Compliance audit team Name Role Lead Auditor Auditor Auditor

2 Qualifications included in the audit QS agreement code

Qualification code and title Number of students sampled

Number of units of competency sampled

TOTAL

PS agreement code Qualification code and title Number of

students sampled Number of units of competency sampled

Total

For the programs audited, not every student included in the audit sample would have been sampled across every audit focus area.

3 Audit focus This was conducted as a monitoring audit to evaluate PQS compliance with the

agreement/s. The audit incorporated the review of AVETMISS data submitted by the PQS within

the [specified] time period. The audit activity commenced with an initial desk audit review of controls and

assurances the PQS has implemented to support service delivery against its agreements and department policy.

This was followed by site audit fieldwork conducted over [specified time period] to analyse the sufficiency and accuracy of evidence retained by the PQS to support funding payments received from the department. The site audit fieldwork component also allowed the audit team to validate the effectiveness of internal controls implemented by the PQS to address its compliance responsibilities.


Appendix 3 Non-compliance detail – VET Investment

Rectification of all non-compliances as well as processes contributing to non-compliance must be undertaken immediately; however, there is no requirement to submit rectification evidence to the department unless specifically requested.

[Detail regarding non-compliance will be provided where non-compliance has been identified.]

1 Administration Refer to PQS Agreement, Clause 9; Certificate 3 Guarantee Program Policy 17–18; Certificate 3 Guarantee Program Policy 18–19; PQS Policy 17–18 Performance Standard 1, Performance Standard 2G and Appendix 3E – Credit Transfer; PQS Policy 18–19 Performance Standard 1, Performance Standard 2G and Appendix 3E – Credit Transfer; Higher Level Skills Program Policy 17–18; Higher Level Skills Program Policy 18–19; PQS Audit Evidence Requirements.

Focus area – 2.2.1 Agreement delivery – VET Investment Priority focus area

Records – certification documentation

Student name/s Qualification Detail regarding insufficient evidence

Records – completed and accurate benchmark materials

Qualification Detail regarding insufficient evidence

Evidence to support credit transfer

[Qualification code and Title] Student name/s Unit of

competency Detail regarding insufficient evidence

PQS Obligation


Government subsidised training place under the Certificate 3 Guarantee


Government subsidised training place under Higher Level Skills


Refund Policy



Complaints


2 Eligibility Refer to Certificate 3 Guarantee Program Policy 17–18; Certificate 3 Guarantee Program Policy 18–19; PQS Policy 17–18 Performance Standard 3C; PQS Policy 18–19 Performance Standard 3C; Higher Level Skills Program Policy 17–18; Higher Level Skills Program Policy 18–19; PQS Audit Evidence Requirements.


Process of integrity to verify eligibility


Eligibility


Subsidy availability – Concession status

Student name/s Unit of competency / qualification

Detail regarding insufficient evidence

Subsidy availability – Free training for Year 12 graduates

Student name/s Unit of competency / qualification


3 Lower-level training and foundation skills training Refer to PQS Agreement, Clause 9; Certificate 3 Guarantee Program Policy 17–18; Certificate 3 Guarantee Program Policy 18–19; PQS Policy 17–18 Performance Standard 4; PQS Policy 18–19 Performance Standard 4; PQS Audit Evidence Requirements.


Foundation Skills The evidence provided by the supplier did not confirm it had adequately assessed eligibility to undertake foundation skills.



Training and support plan (Foundation skills) The evidence provided by the supplier did not confirm it had developed a training and support plan or one which met the minimum requirements outlined in the PQS Audit Evidence Requirements (VET Investment).


Lower-level qualifications – Individual pathway The evidence provided by the supplier did not confirm it had adequately assessed eligibility to undertake a lower-level qualification via the individual pathway.


Training and support plan (Individual pathway) The evidence provided by the supplier did not confirm it had developed a training and support plan or one which met the minimum requirements outlined in the PQS Audit Evidence Requirements (VET Investment).


Lower-level qualifications – Pre-apprenticeship pathway The evidence provided by the supplier did not confirm the delivery of training and assessment was mandated as a prerequisite for the related Certificate III level qualification under the training package rules.


Lower-level qualifications – Cohort specific The evidence provided by the supplier did not confirm the delivery of training and assessment is [enter detail].


4 Fees Refer to PQS Policy 17–18 Performance Standard 1A, 2D and 3B, and appendices 1F, 1E, 1G, 1H and 1L; PQS Policy 18–19 Performance Standard 1A, 2D and 3B, and appendices 1F, 1E, 1G, 1H and 1L; PQS Audit Evidence Requirements.


Fees published on website


Co-contribution fees charged and collected



Co-contribution fees at unit of competency level


Fee-free training not advertised


Not charged for qualification and/or offering in addition to co-contribution fee


Co-contribution fees for credit transfers

Student name/s Unit of competency


Co-contribution fees charged and collected from exempt students


5 Training Refer to PQS Agreement, Clause 9; PQS Policy 17–18 Appendix 5 – Table 4; PQS Policy 18–19 Appendix 5 – Table 4; PQS Audit Evidence Requirements.


Record of participation in training

[Qualification code and title] Student name/s Unit of


AVETMISS Outcome identifier 40



Vocational placement




6 Assessment Refer to PQS Agreement, Clause 9; PQS Policy 17–18 Appendix 5 – Table 4 and Performance Standard 5B; PQS Policy 18–19 Appendix 5 – Table 4 and Performance Standard 5B; PQS Audit Evidence Requirements.


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 – Competency achieved/pass’ claims for payment.



AVETMISS Outcome identifier 30 The evidence provided by the supplier did not contain the full range of assessment evidence to support ‘AVETMISS Outcome identifier 30 – Competency not achieved/fail’ claims for payment.

[Qualification Code and Title] Student name/s Unit of


AVETMISS Outcome identifier 51 The evidence provided by the supplier did not contain the full range of assessment evidence to support ‘AVETMISS Outcome identifier 51 – Recognition of prior learning granted’ claims for payment.



AVETMISS Outcome identifier 65 The evidence provided by the supplier did not contain the full range of mapping and assessment evidence to support ‘AVETMISS Outcome identifier 65 – Transitional gap training’ claims for payment.




7 AVETMISS reporting Refer to PQS Agreement, Clauses 5 and 9; PQS Policy 17–18 Appendix 1I, 3D and 3E; PQS Policy 18–19 Appendix 1I, 3D and 3E; PQS Audit Evidence Requirements.


AVETMISS end dates



Delivery mode identifier



Outcome code identifier



Concession status



Co-contribution fees



Postcode



Competencies previously assessed as competent



Eligible credit transfer



Fund source code




Highest level of school



Qualification issued flag




Appendix 4 Non-compliance detail – User Choice

Rectification of all non-compliances as well as processes contributing to non-compliance must be undertaken immediately; however, there is no requirement to submit rectification evidence to the department unless specifically requested.

[Detail regarding non-compliance will be provided where non-compliance has been identified.]

1 Administration Refer to PQS Agreement, Clause 9; User Choice 2017–20 Policy, Clause 2.6; Further Education and Training Act 2014, Sections 74 and 75; Further Education and Training Regulation, Section 4; PQS Audit Evidence Requirements.

Focus area – 2.3.1 Administration Priority focus area

Information provided prior to enrolment


Records – certification documentation


Records – completed and accurate benchmark materials

Qualification Detail regarding insufficient evidence

Training plans


Requirements of the training plan


Training records


Evidence to support credit transfer



SRTO1 Administration payment



2 Employer resource assessment Refer to PQS Agreement, Clause 9; User Choice 2017–20 Policy, Clause 1.2; PQS Audit Evidence Requirements.

Focus area – 2.3.2 Employer resource assessment Priority focus area

Sufficient evidence indicating employer resources fully assessed


Student to qualified workplace supervisor ratio


Review at intervals of no greater than three months


3 On-the-job verification Refer to User Choice 2017–20 Policy, Clause 2.6; PQS Audit Evidence Requirements.

Focus area – 2.3.3 On-the-job verification Priority focus area

On-the-job verification



4 Fees Refer to User Choice 2017–20 Policy, Clause 2.6; PQS Audit Evidence Requirements.

Focus area – 2.3.4 Fees Priority focus area

Student contribution fees charged and collected


Student contribution fee exemptions



School based apprentices and trainees


Credit transfers / Transitional gap training / Skilling Queenslanders for Work


Year 12 Graduate


Employer contribution fees


Additional changes


Issuances of qualifications / statements of attainment


Refund of student contribution fees


5 Training Refer to PQS Agreement, Clause 9; User Choice 2017–20 Policy, Clause 2.4; Further Education and Training Regulation, Section 4; PQS Audit Evidence Requirements.

Focus area – 2.3.5 Training Priority focus area

Record of participation in training



AVETMISS Outcome identifier 40



Training records




6 Assessment Refer to PQS Agreement, Clause 9; User Choice 2017–20 Policy, Clauses 2.3 and 2.4; PQS Audit Evidence Requirements.

Focus area – 2.3.6 Assessment Priority focus area

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 – Competency achieved/pass’ claims for payment for the following:



AVETMISS Outcome identifier 30 The evidence provided by the supplier did not contain the full range of assessment evidence to support ‘AVETMISS Outcome identifier 30 – Competency not achieved/fail’ claims for payment for the following:



AVETMISS Outcome identifier 51 The evidence provided by the supplier did not contain the full range of assessment evidence to support ‘AVETMISS Outcome identifier 51 – Recognition of prior learning granted’ claims for payment for the following:



AVETMISS Outcome identifier 65 The evidence provided by the supplier did not contain the full range of mapping and assessment evidence to support ‘AVETMISS Outcome identifier 65 – Transitional gap training’ claims for payment for the following:



Entire qualification via RPL pathway


The evidence provided by the supplier indicated that all units of competency needed to achieve the qualification had been attained via the supplier’s RPL process for the following students:


7 AVETMISS reporting Refer to PQS Agreement, Clause 9; User Choice 2017–20 Policy, Clause 2.4; PQS Audit Evidence Requirements.

Focus area – 2.3.7 AVETMISS Data Priority focus area

Delivery mode identifier



Outcome code identifier



AVETMISS start and/or end dates



Postcode



Competencies previously assessed as competent



Eligible credit transfer




Appendix 5 Summary of key non-compliances – VET Investment

Non-compliances where recovery may be sought by the department

[A table identifying non-compliances where recovery may occur if relevant]


Appendix 6 Summary of key non-compliances – User Choice

Non-compliances where recovery may be sought by the department

[A table identifying non-compliances where recovery may occur if relevant]


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