Could inadequate systems be at least partly responsible for creating so called ‘rogue’ VET FEE HELP and CRICOS Providers?
VET FEE Help and CRICOS providers have had a pretty rough time in the press recently. Practices that entice unsuitable candidates to enroll into courses they are unlikely to complete are unforgivable. But this article explores how and why relatively innocent providers who fell into inadequate student management systems could be unfairly tarred with the same brush.
What makes a rogue provider?
If greed and dishonesty are the hall marks of "roguism" then we would have to exclude a completely separate category of providers who lost their registration because they simply lacked the systems and support necessary to implement the rigorous compliance requirements surrounding VET sector in general, but especially VET FEE Help and CRICOS providers.
What's the reason for this blog?
In the last few months Bluegem is pleased to have accepted several new VET FEE Help clients who unwittingly fell into this category. From all the information and evidence we've been able to collect these providers seemed to be good hard working people trying to do the right thing, but who unwittingly took poor compliance advise or purchased student management systems that:
- Are generally only average to ok for AVETMISS reporting
- Rely almost entirely on the USI website for Creation and Verification of Unique Student Identifiers
- Exhibit poor usability and were not at all easy to use
- Have little support or documentation for their products
- Do not properly or fully implement the HEPCAT reporting requirements or the key requirements of the National Code Part D: ESOS Standards
- Lack transparent financial reporting and billing services
- Provide no functionality for registering and resolving complaints and appeal
- Offer no faculties for planning and tracking continuous improvement
Add to that the prevalence of business owners who do not have English as a first language, coupled with little or no support from RTO and compliance experts to help them navigate the complex maze of standards, guidelines, data collection requirements and legal obligations. Its easy to say, "they should have done the due diligence and looked for the right advice".
Finding the right advice in what is ironically an unregulated area of an otherwise highly regulated industry is really not that easy. And when it comes to buying the right training management system the waters are even more murky.
So what can be done to prevent this?
In an ideal world vendors of 'compliant' student management systems would have their products assessed and deemed suitable for the industry, i.e. registration at levels of suitability against industry benchmarks.
There should also exist a register of RTO Consultants and Compliance officers who can demonstrate familiarisation with the standards and who have procedures and processes for considered appropriate for the industry.
A suitable product would have a registered certificate to cover all aspects of the provision of effective and compliant student management, learning management and training management systems. The certificate would include hosting, security, and other criteria necessary to deliver an industry compliant solution.
Each standard being assessed would be treated as an endorsement. So a vendor would be required to meet the baseline standard of AVETMISS, but have additional endorsements for VET FEE HELP, CRICOS, HEIMS, etc...
It seems ironic that in such a highly regulated environment as the VET Sector that the providers of primary tools, e.g. student management systems and expert advisors to the sector have no such registration framework. It makes it particularly difficult for new providers to know where to look and who they can trust to look after their interests.
I'd like to hear your comments and suggestions. Would you prefer to see these areas of the industry more tightly regulated?
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