With so many RTOs being determined as Non-Compliant against clause 1.2 of the standards for RTOs, I feel it necessary to provide some guidance on how RTOs can ensure they are compliant with this requirement.
Common Misunderstanding
First of all, it is important to understand that there is a difference between Amount of Training and Volume of Learning. The volume of learning requirements detailed in the AQF is much broader and relate to ALL teaching and learning activities such as guided learning (classes, lectures, tutorials, online or self-paced study), individual study, research, learning activities in the workplace. Volume of learning also includes assessment activities. According to ASQA the amount of training requirement is part of the overall Volume of Learning, however, relates primarily to formal activities including classes and other activities as well as workplace learning. It does not relate to assessment activities. So to summarise, the volume of learning includes all training and assessment activities, whilst the amount of training refers to the formal (supervised) training activities.
Meeting Amount of Training Requirements
Many RTOs, particularly those delivering distance or online courses are unable to demonstrate how they have met the amount of training requirements because they haven’t documented the hours for formal Training Activities comprehensively in their Training and Assessment Strategy. The other big problem RTOs face at audit, is not being able to support the volume of learning hours they have documented for the delivery of a qualification where the number of hours deviates from the guide provided in the AQF.
Another factor for amount of training is the mode of delivery. In their amount of training fact sheet, ASQA defines the modes of delivery as including:
- face-to-face learning
- online learning
- self-paced distance delivery
- workplace training, or
- a mixture of modes
Different modes of delivery require more or less training. For instance, a completely online course with little or no face to face training time would likely require a greater duration to allow learners to gain the knowledge and skills. Of course, it would also need to have enough formal learning activities to meet the amount of training requirements. Your RTO is required to show how it has taken the delivery mode into account when determining the amount of training and volume of learning. This should be documented in your TAS or supporting documents.
Volume of Learning
Let’s look at volume of learning a little closer. The AQF stipulates 600-1200 hours for a Certificate IV Qualification. This does not mean that your RTO can simply choose any duration between 600 and 1200 hours for their course. Your RTO must have evidence of having analysed the qualification complexity, including the number of units and the requirements of those units to determine the number of hours for their course. ASQA defines the qualification complexity as:
- the breadth and depth of the knowledge
- skills required
- application of knowledge and skills, and
- the AQF volume of learning
This analysis should include consultation with industry experts to support your judgement. If your RTO can not provide evidence of having completed this analysis, it is likely you will have a non-compliance recorded at audit.
Understanding How Much Training Your Learners Require
Lastly, your RTO will need to provide evidence of having analysed their learner cohorts existing skills and knowledge to inform course duration and amount of training. It is important to note that ASQA has advised “If your RTO intends to deliver to learners who are new to the industry area and/or who do not have any workplace experience, the amount of training required that is described in the training and assessment strategy would closely match the time frame listed with the AQF volume of learning.” If the course duration is less than the AQF set 1200 hours (Cert IV), ASQA wants to see evidence of how your RTO has determined this. They would expect that either the number or complexity of the units is less, the mode of delivery supports the reduction OR the learner cohort has existing skills and knowledge to substantiate a reduction in the volume of learning. All this must be clearly documented in your TAS.
As always with ASQA, it is all about the evidence and RTO’s must be able to support their amount of training and volume of learning hours set out in their TAS. ASQA won’t accept a number of hours without a clear justification of how that number was determined. The RTO must be able to show evidence of:
- How your RTO has analysed their learner cohort to determine existing knowledge and skills?
- How your RTO has applied the existing knowledge and skills of their learner cohort determine the amount of training/volume of learning?
- How your RTO has engaged with industry to determine to volume of learning?
- How your RTO has analysed the qualification and unit requirements to determine the volume of learning that aligns to the AQF?
- How your RTO has engaged with industry to determine how much formal training is necessary to meet the amount of training requirements?
- How your RTO has taken the mode of delivery into account when determining the amount of training
Could your RTO provide evidence of all of the above to support your TAS at audit? Does your TAS have a clearly laid out schedule that details the hours for all formal and informal training as well as assessment activities? Is this schedule aligned to the AQF volume of learning requirements? If you can answer is yes to these questions, then you should have no issues with clause 1.1 at audit. If not, you may have some work to do, and now is the time to do it. ASQA is clamping down hard on the volume of learning and no RTO can risk non-compliances in the current regulatory environment.
There is likely to be some better clarification on the minimum amount of training and volume of learning in the near future. ASQA is pushing for changes to better lay out the amount of training for each unit which will really help RTOs to have a clear standard to work to. The current standards for amount of training are completely ambiguous and creating massive problems for RTOs and Auditors. You can read about the recommendations by clicking HERE
