15/03/12

1. Executive Summary

1.1 Introduction

All students undertaking government subsidised training under the VTG are required to contribute to the cost of their training through payment of fees as provided for by the Ministerial Directions about Fees.

Under delegation from the Victorian Skills Commission, Skills Victoria contracts Registered Training Organisations (RTOs) to deliver training to eligible individuals under the Skills for Victoria Program. In accordance with its Contract Compliance Audit Strategy, Skills Victoria undertakes a contract compliance audit program to ensure the contracted RTOs are complying with the terms and conditions of their Skills for Victoria Service Agreements (Service Agreements).

Skills Victoria conducts these audits using contractors from a panel of service providers.

Protiviti conducted the contract compliance audit at Flexible Training Solutions Pty Ltd (FTS) on 12 and 16 December 2011. This follow-up audit was conducted on Thursday 8 March 2012.

1.2 Objective and Scope

The objective of this follow-up audit was to assess the completeness and effectives of the actions taken by the RTO in implementing the management action plans agreed as a result of the contract compliance audit undertaken in December 2011.

1.3 Summary of Findings

Ref	Area	Control Weakness	Follow-Up Status
2.1	Internal Audit Checklist	The 2011 Internal Audit Checklist had not been completed within six months of the Commencement Date	Completed
2.2	Enrolment	Tuition fees are not always applied according to the fees applicable when is delivered	Completed
2.3	Enrolment	A Language, Literacy & Numeracy (LLN) test is not always conducted during the pre-training review	Completed
2.4	Training Delivery	Unit commencement dates have been incorrectly recorded using the course commencement date	Completed

Ref	Opportunity for Improvement	Follow-Up Status
3.1	Assessment task sheets should be dated for recognition of prior learning (RPL) units.	Completed

2. Detailed Findings

The table below sets out the control weaknesses identified, agreed management action plans and follow-up status:

Reference	Control Weakness	Management Action Plan
Internal Audit Checklist
2.1 The 2011 Internal Audit Checklist had not been completed within six months of the Commencement Date.	Finding The 2011 Internal Audit Checklist had not been completed within six months of the Commencement Date as required by section 10f(i) of the 2011 Service Agreement. We noted that the checklist had been completed on the 15th of September 2011. Potential Impact Untimely completion of the Internal Audit Checklist may lead to non-compliance with the 2011 Service Agreement.	Agreed Action Internal Audit Checklists will be completed as per the timeframe specified within any applicable Service Agreement in place between FTS and the Victorian Skills Commission. Follow-up Summary Internal Audit Checklist has been completed in September 2011 by responsible staff. FTS has commenced the 2012 Internal Audit Checklist and intends to complete this prior to June 2012. Management is now aware of the importance of completing the Internal Audit Checklist every six months and has made responsible staff aware of this requirement as per the Service Agreement. Status Completed.

Reference	Control Weakness	Management Action Plan
Enrolment
2.2 Tuition fees are not always applied according to the fees applicable when is delivered.	Finding During transactional testing we identified that tuition fees had not been calculated according to the fees applicable when training was delivered, where training for a course was delivered across 2010 and 2011. Although a tuition fee had been calculated, only the 2010 fee had been charged to students and no 2011 tuition fee had been charged. At least the minimum fee applicable should have been charged for each year in which training was delivered. Incorrect application of the Ministerial Direction about Fees may lead to non-compliance with the Service Agreement.	Agreed Action FTS will review and update its process to calculate student tuition fees to ensure that they are calculated in line with the requirements of current Service Agreements. Follow-up Summary FTS is now calculating tuition fees as per the Service Agreement. Although the 2012 Service Agreement does not require RTOs to charge a minimum tuition fee, management within FTS have decided to charge clients the $187.50 to cover the cost of administration. Management is in the process of reviewing clients/companies to determine students that have been enrolled into a course for a period of two calendar years (2010 and 2011) and will seek outstanding balances from clients/companies. Students affected equates to approximately 20 – 25% of the total population. Status Completed.
2.3 A Language, Literacy & Numeracy (LLN) test is not always conducted during the pre-training review.	Finding During transactional testing it was identified that FTS do not always conduct an LLN test during the pre-training review. Instead, for some trainees, FTS rely on the employer’s own assessment made during the recruitment process. It was also noted that FTS did not have a Pre-Training Review policy in place until after July 2011. Potential Impact Not undertaking a Pre-Training Review of current competencies including literacy and numeracy skills may lead to non-compliance with the Service Agreement.	Agreed action The FTS LLN test will be issued to all students enrolling in courses for which they are eligible for VTG funding. Follow-up Summary FTS now has a Student Handbook and Quality Manual which specifies that a Language, Literacy & Numeracy (LLN) test is required to be performed upon enrolment. The LLN assessment is conducted under trainer supervision. Furthermore, LLN assessments are tailored for the different types of courses that are offered by FTS. Although FTS was not able to provide the students specified by Skills Victoria, a random sample of five students selected for testing noted no issues. Status Completed.

Reference	Control Weakness	Management Action Plan
Training Delivery
2.4 Unit commencement dates have been incorrectly recorded using the course commencement date.	Finding During transactional testing it was noted that FTS incorrectly recorded course commencement dates instead of actual commencement dates for some units. This has led to funding being claimed in advance of training delivery for these units. It was noted that all end dates recorded in SVTS were accurate and therefore the amount of funding claimed was correct. However, funding will have been claimed in advance for any current units that have been assigned an incorrect commencement date in SVTS. Potential Impact Incorrectly recording the unit commencement dates will result in funds being claimed prior to delivery of training, and therefore may lead to non-compliance with the Service Agreement.	Agreed action FTS will review and update unit commencement dates in iCare for all active students. Follow-up Summary FTS now requires trainers to complete a ‘Master Assessment’ spreadsheet on a weekly basis. This spreadsheet captures the dates when students have started a unit within the course. Trainees with incorrect start dates were identified and corrected through SVTS resulting in incorrect payments being refunded to Skills Victoria for units started in 2011. For units commencing in 2012 FTS currently are not claiming until the unit has been completed to alleviate any possible errors Status Complete.

3. Opportunity for Improvement

The table below sets out additional opportunity for improvement, agreed management action plan and follow-up status:

Reference	Opportunity for Improvement	Management Action Plan
3.1 Assessment task sheets should be dated for recognition of prior learning (RPL) units.	Area for Improvement It was noted that although RPL assessments had been conducted by FTS as part of the pre-training review, not all of them had been dated. Potential Impact Not dating the RPL assessments sheets could result in a lack of evidence to confirm that the pre-training review was completed prior to the commencement of training.	Agreed action RPL assessment task sheets will be modified to provide a space for dates to be included by the Assessor. Follow-up Summary The RPL assessment task sheets now include a space which allows the assessor to date when the assessment was completed. Management has emphasised the importance of dating the RPL assessment to responsible staff to ensure assessments are dated once completed. Protiviti has sighted a completed RPL assessment with signatories and dates from both student and RTO. Status Completed.