First-Hand Experience: RTO Initial Registration in the 2025 Standards Era

Welcome to the RTO Superhero podcast with me Angela Connell Richards. Each week we break down the standards for RTO's 2025 and turn them into clear actions you can use. You get real examples, compliance tips and straight answers for running a quality RTO. Let's get started. Welcome to the RTO Superhero podcast with Angela and Maycheck. Maycheck and I are meeting up in person today in Darwin. So I just happen to be up here speaking at an event and Maycheck just happened to be in town. Still stuck here for three weeks, three and a half weeks now. And he's looking forward to getting back on the road. Indeed. Yeah, yeah. So Maycheck and I thought, well, for this in person, let's talk about audits and the first, our very first, as well, audit under the new standards. So Maycheck, your first audit was initial registration. It was just RTO. Just RTO about a week into the new standards. Yeah. And what was your experience compared to pre 2025? I think the biggest difference between these audits other than obviously the standards and really focusing on the difference of the approach. The main thing was the implementation. How are you going to implement the actual standards? Again, what we've spoken about in the past. It's not just about documents, policies and procedures, but also about tell me how you're going to do things. And making sure that the applicant had a solid understanding of what they actually needed to do based on becoming an RTO, for example, tomorrow, as opposed to ticking off a bunch of documents and then saying, "You're good to go." So there was a bigger focus on that understanding and tell me how you're going to do things. Yeah, because it's there in the practice guys, they're talking about outcome focused. Yeah. So where are, how are you going to do this and what are the outcomes? Yeah, so they really, all the auditors so far have really been speaking the whole concept of tell and show. So tell us what you're going to be doing and they already know what's in the documents because they've got in front of them on their screens, but often they're comparing to what the applicant is saying versus what's on their documents. And if there's discrepancies, that's where they, they start to become issues. So I think for anyone that's going down that path, it's really important to know your documents. If you're buying them off the shelf, if you're getting them from another consultant, making sure that you've got that understanding of those documents. And you know where to find things and you have a good understanding of your policies. And because the important part, if you don't know as a CEO or a senior management position, if you don't know, how was everyone else going to know? And Asquit just wants to be confident that the order to the assessor wants to be confident that when they walk away, they're not relying on the consultant, that you're not relying on someone else to do this job for you. So I've had one audit since the news ended. I know you've had a few more than me. I feel like I'm a veteran, I'm ready. And my experience was they, my assessor had a list of things that she had to ask for. So my assessor was an external auditor, not a Asquit employee. So she basically went through her checklist of do you have this, do you have this? So we submitted, and I'm assuming your client did as well, but we submitted before the one may change. And they still asked for 2025 documents. So what we did is we preempted. And when they asked for the evidence, we provided them with the policies and procedures. Yes, before we went to them. We did a very silly thing. Rather than this time in the past, I guess under 2015, they would ask for specific continuous improvement process, the record retention process. For all of these audits, I've just got the client to send through their whole suite of documents from start to finish aligned to every single standard. And it's worked really well because I've found that actually all of them, I've had two external contractors and now three internal staff members. The approaches have been a little bit similar, but there still have been their discrepancies. But I find that the more documents that I get upfront, the less questions they're asking as well, which is very different to in the past. So, yeah, that was really interesting. But the one that really threw me, and this is a, I guess, a lesson for everyone, be prepared with all of your learning resources. Right. So I had one auditor on two occasions. At the end of the audit, say, now, can you share your screen and show me, take me through where all of your learning materials are, your guides, your assessment tools, session plans, PowerPoints, etc. If it's face-to-face delivery. Luckily enough, we had them ready, but it's just a very, it was one of those eye-opening things. Yeah, an auditor, a performance assessor has the right to request and change the scope if they feel that it's appropriate. That's right. And I have seen people who just get the assessment tools for those units. For those units. And that's not prepared. That's not prepared to start training. Correct. Yeah. Yeah. And so, so, yeah, look, each, like I said, each auditor has their own little style, their quirks and their little nuances. But overall, there has been a consistent approach about ensuring readiness and a general level of understanding. Not that you've memorized your documents, but that you know what they are, that you know how they are applied and what the requirements of the standards are. Including what the CEO's obligation for reporting is. Yeah. Which was an interesting one. Yeah. Yeah. So, I want to talk about accountability. Did you get any questions around accountability and like, did they ask for an organizational chart or anything like that? They didn't ask for them because we supplied are already. Yeah. So, but they did ask. And so, one of the, one of the audits that I had was, I say keep saying audits, but everyone for context performance assessment, etc. Was that the CEO actually had probably only about 5% input into the whole running of the RTO. They had a delegated authority as the RTO manager. And so effectively the RTO manager was a pseudo CEO within that environment. So, the reason, the accountability is not so much does the CEO know everything? Is there enough operational readiness across the, across the whole workforce? Which again goes back to the standard quality outcome three where it talks about does the RTO have all of the sufficient resources from a workforce perspective as well? Yeah. So, we preempted as well with position descriptions. So, we provided those with the accountable roles and the chart as well. And yeah, we provided. So, how we have done our policies and procedures is we've got a map of how they all work together. Correct. Yeah. Yeah. Yeah. Yeah. The only differences that we do, we, we, in all of our documents, we say the CEO or their delegate. And then we have a delegation table that allows that. And so, at the end of the day, we all know that the buck stops with the CEO because they're the ones legally signing that the RTO will remain compliant that will operate under the requirements of the standards. But at the end of the day, it's not always the CEO that has to do and be responsible for every aspect. There is the ability to delegate those tasks. Yeah. Yeah. Okay. So, out of all of your audits that you've heard so far, were they all initial or have you had a re-rich? No, since July 1, they've all been initial. So, what are we up to? Six, six initials. And they've all generally flown the same way. The one that I've got at the moment in progress was interesting. Even though we submitted the evidence on the second of July, they sent through a questionnaire of five or six questions to say how have you prepared for the 2025 standards, which I thought was really strange given that we submitted on the second of July. Joy. But either way, look, it was fine. So, you submitted your application on the second of July and you've already gone to audits? Yes. I know so many people still waiting for their audits and they submitted last year. Yeah. Look, I think the approach is an ASQUA openly say this that it's not a first come first serve application basis. I don't know the inner workings of ASQUA and I will never suggest that. that I do, but I do have a feeling that they will pick the industries that are quite niche and there's not many RTOs out there that are doing that. So, I know for example BSB qualifications, they just don't necessarily put that as a high priority and I haven't seen many BSB RTOs just dedicated to BSB go through very quickly. And I have seen in the past that RTOs that were set up with just BSB on their scope were being targeted by ASCO because it was an easy, apparently an easy to start with and then do an addition to scope following. And I think that's where the legislation changed a couple of years ago where it stopped RTOs who's applying for a change of scope within that first two-year period to try and combat that as well because the plenary of business, eight units of competency, it was the go-to co-whal to get something registered because you know it was low risk, easy to get through. So, look, a lot of the changes that ASCO have implemented, I think they've got a still a long way to go from a consistency perspective, but credit to them, they're trying. I know that there's a lot of fee that's promoted, but I think overall they're doing as best as they can. A lot of people refer to them as the ASCO standards because they think, you know, ASCO is just another stakeholder that is embracing what was basically thrown onto them as well. So, yeah. The one I worded is ASCO is like the police who need to enforce the regulatory. Or the ATO with, you know, it who doesn't create their own legislation, they're just another regulator that forms part of that whole cycle. Yeah, yeah. And they're just making sure that we are compliant against those standards. Correct. Yeah, so you've got to change that way of thinking and I see it all the time, ASCO standards. Yeah, ASCO standards or ASCO is, you know, the training packages that they developed, the Rabi Show Blower Blower, it's like, that's where people don't understand, I guess, the how the whole system works. And at the end of the day, ASCO doesn't pick and choose what training packages are created and how they're created. It's they just enforce what's in writing. Yeah. So, I know with my audit that I had, I was asked some specific questions and there were things like the client. You were your client. It was funny though, because the auditor said, you know, you're a consultant, you can't participate by blah blah blah, but then she asked me questions direct. For anyone listening, I think it's important to set the tone with anyone that the management of the RTO or the application understands it and that the consultant is often there just as an interpreter to change or rephrase something that the client doesn't understand it's being asked. Yeah. But if you can demonstrate that confidence as the applicant that you've got that knowledge, then the performance assessor doesn't have that fear of the consultant answering questions on your behalf. Yeah. That's been my experience. Yeah, yeah. It's really important that you know where the how to answer things, any questions that you get from the assessor, but also know where it is. So one of the things that I was asked was accountability, policy for trainers and assessors when it comes to difference of opinion and if they were working for other RTOs. Right. Yeah. I think that would come down to more of the 4.2 being the conflict of interest. That's it. Yeah. Yeah. So we didn't have one, but I had it under senior management. Right. But it was interesting that they wanted one for trainer as well. So a quickly row one around conflict of interest for the trainer. But that was what she was specifically asked to ask us. Yeah. I think the conflict of interest one, which is under that risk management, is an area that the ask where I think is still working through. Because it's new. It's new. And even though we provide a conflict of interest policy, a register and a declaration form, as well as a risk management process, no one has yet asked about risk management or a risk management matrix in any of the audits yet. And I dare say it's because they're still trying to work out how to navigate what would be an appropriate amount of evidence to show. Because when you read the actual, when you interpret the standards, there is a significant focus on overall risk management. Now that's not just financial, but that's, you know, what happens if a trainer is sick, what happens if a trainer leaves halfway through a course and you're suddenly left without a trainer. How do you manage that risk? So there's a lot of points that would need to be broken down into that risk management matrix. And I dare say they're just not quite sure what level is going to be compliant yet. Yeah. And being initial registration, we weren't asked anything about the risk. We've got a risk register, but we didn't go. We weren't asked anything yet. So for initial registration, what would be your advice to anybody who is waiting for their audit for initial registration? Probably the biggest thing is make sure that you are as prepared as possibly can be. Go through whether you're using a consultant or doing it on your own. Go through each quality outcome and ask yourself the questions, how do I do X? Right. So how do I ensure that training is fit for purpose or assessment is fit for purpose that it's engaging that allows sufficient time? Ask yourself those questions. By all means, use chat GPT or another AI platform to develop those questions. I know you've got questions that you've prepared as well. So basically go through and make sure you are sufficiently prepared to answer every question against every quality outcome, every KPI that's there so that nothing is a surprise for you. Yeah. And make sure you've got everything ready. Like make sure all your tazers are there. And you don't need a taz under these new standards, but tazers just are still the simplest way to present the information in the format that is recognised by most people. But yeah, like chain of matrices, make sure you've got them in place, the industry consultation, everything should be ready before, I mean, in theory it should be ready at the time of submission, but we know that that's not always the case. So at least for audit, make sure that all the documents are there and that you've got a solid understanding. And so does your team. Yeah, what I recommend is one shift submitted, what you should be doing is if you purchased materials contextualised, go through, you know, assess your tools, your assessment tools, test them because that's one of the requirements now is testing your tools. So you can do that following your submission. It's funny how it's listening to how many auditors try and drop the word accidentally prevalidation. And they sort of stop themselves. How do we do it this before we use the tools, how do you ensure that they aligns the units? So there seems to be an industry scare like to use that word prevalidation. But I think also we're still learning to change our language as well. Like we used to train our clients to hold a monthly quality and compliance meeting. Now we're calling it the governance meeting to tie in with the standards. No, we still call it a monthly management meeting as a concept, but it's the same principle. Whatever you call it is as long as you guys understand the terms and your system so that you're not referring it to a continuous improvement log when it's a systems register or something like that. So use the terms that you have been provided as part of your documents or that you've developed yourself. Yeah, yeah, and we call it the governance register now. So we have all of the governance requirements. So everything that we've got to track. The last thing I will say I think is people that don't choose not to use a consultant, which is obviously fine, but rely on AI or chat GPT. There is a big issue with regards to knowing not knowing what you don't know and thinking that. But you know, everything, everything. And even though you can train it, you can punch in the standards, etc. Personally, and I'm sure you've experienced it as well, it doesn't always get it right. It doesn't always get the numbering right. And it gets confused as we know between the old standards and the new standards. I've seen it come up with ridiculous standards that don't even exist. And so just be mindful that there is value in using consultants that actually understand that space and have been around long enough to guide you, not just basically present something that you think is right. Yeah, like we've trained our bots, chat GPT bots over four years, and it still makes mistakes. Correct. So be very careful if you're using AI. And as always, with anything you do with AI, you need to challenge it. And if it's a cross check and make sure it is actually accurate. Yeah. And developing something using AI doesn't mean that you're an expert or give you knowledge of that topic as well. Yeah. So read the practice guides, read Deer as policy guidance. There's some really, really good information. in there on how to interpret the standards. I'm liking the practice. Yeah. Look, the practice guides, I don't mind, but the dewa's document that they released in March to me is far better in terms of, yeah, it provides a lot more guidance. So, there's a lot of people out there that say, "Oh, you know, Asquire's not giving us enough information," et cetera. Asquire, they openly said that they're not going to. There's two paragraphs that say, "You know, the RTA's responsibility to interpret based on their size, their scope, their demographic, et cetera." And then it's the RTA's responsibility to demonstrate compliance. I actually don't have a problem with those two statements. I think the more that we encourage the ownership of the documents for our clients, the better as an industry that we're going to have as opposed to this running blind with ignorance. Yeah, and it should be contextualised to your learn-a-co-vort and your industry sector as well. And that's why we don't have one set of policies and procedures that everyone uses that come from the government because you can't with totally different size and scope. Correct. Yeah. Okay. Thank you very much, Maycheck. That was wonderful. So, if you're wanting to know more about initial registration and what that process is, I definitely recommend download the practice guide and also the D-Ware guide that they released as well to help you get a better understanding of what you need to know prior to going to your audit and what you need to do as part of your process following submission of your application and making sure that you have a good understanding. Yeah. What's your final last words? Don't be scared. Don't be, don't, don't buy into the fear that a lot of people are putting out in industry, that ask was evil, that the standards are difficult, that there's no interpretation. Don't be lazy. Don't be lazy and don't be scared of something that is your responsibility to own. Start by reading them. And, you know, if you ask how many CEOs you ask now that have actually read the standards, most will still say probably not. Yeah. And so, yeah, if you're applying for initial registration and investing a significant amount of money, read them, understand them and then seek guidance if you need to because it's not that complicated. Yeah. Okay. And, too. Next, we, the next episode, we're going to be talking about if you're coming up for a re-registration under the new standards. Surprise you with that one. Thanks for joining me on the RTO Superhero podcast. Use today's insights to strengthen your systems and lift the quality of your delivery. Subscribe, share the episode and keep building a strong and accountable RTO. See you next time. Bye.