Student file compliance review operating instruction

Purpose

This operating instruction is to outline the process for the Student File Compliance Review (SFCR) in relation to BPA (Business Process Audits) TCA (Transactional Compliance Audits).

The purpose of the review is to:

  • Capture, at a high level, responsibilities that support audit activities.
  • Support the annual Department of Education and Training’s “2018 Internal Audit Checklist” that is required by the Dual Sector VET Funding Contract-Skills First Program
  • examine the control effectiveness of student files administration process.

Scope

RMIT University is a registered training provider in receipt of state government funding and must abide by the Terms and Conditions of the Dual Sector VET Funding Contract Skills First Program. The VET Funding Contract sets a number of obligations with which a contracted training provider is legally bound to comply, including to ensure that the training delivered is high quality and suitable for the individuals to whom it is delivered, to ensure that funds are only claimed for eligible individuals who undertake the training, to generate and keep certain records, and to submit reports.

RMIT has an obligation to comply with the following requirements:

  • maintain registration as a registered training organisation (RTO) and deliver nationally registered training services;
  • comply with the Australian Quality Framework (AQF) or Standards for VET Regulators 2015 or Standards for RTOs 2015 and all applicable laws and regulations;
  • comply with the terms and conditions of the VET Funding Contract;
  • meet all requirements pertaining to determining student eligibility, student selection process, completing student enrolments, levying and collecting fees, applying fee concessions and waivers, teacher qualifications and competencies and maintaining evidence of student participation;
  • participate in audits as required by the Department of Education and Training (DET) and rectify any non-compliances that are identified.

Exclusions

This operating instruction is only relevant to government subsidised VET training and excludes all other cohorts.

Operating Instruction, steps and actions

External Audit

No

Description of instructions, steps and actions

Responsible Owner(s)

1

Notification

Receive the audit engagement letter from the external auditor nominated by the DET. The audit is a business process and transactional compliance audit.

DVC (Education)

2

Notification

Discuss and finalise the timing of the audit fieldwork with the external auditor.

Chief Audit and Risk Officer

3

Planning

Develop an audit process plan which includes key dates, audit schedule.

IACRR

4

Planning

Send a formal communication to all stakeholders advising them of the key dates, audit preparation arrangements, scope of the review and include the Student File Audit Checklist.

Student file compliance reviews are an integral part of the external audit process.

IACRR

5

Planning

Organise briefing sessions for all relevant stakeholders i.e Vocational Education Office (VEO), ARG, Colleges/VE Schools and Finance

Brief all relevant stakeholders i.e. VEO, ARG, Colleges/VE Schools and Finance. Scope of briefing is audit process, auditor/auditee engagement, audit fieldwork preparation, student file audit checklist, Q&A.

IACRR

6

Pre-audit preparation

Collate current RMIT policies, guidelines and forms that relate to:

Apprentices and Trainees

Enrolment and Eligibility

Pre-Training Review

Evidence of Participation

Training Plans

Fees

Training & Assessment Strategy (TAS)

Vocational Education Staff Qualifications Matrix

IACRR

VEO

ARG

7

Generate sample for student file audit review

Typically, within 24 hours of the external audit, the external auditor will provide IACRR with a list of student names and ID for sample testing.

Analytics and Insight generate a student report containing the selected students’ enrolment data and vocational education profile for circulation to the Colleges and VE Schools.

Analytics and Insight

8 a)

Prepare student audit file information

Provide the selected sample of students to the colleges and ARG for the preparation of student audit file documentation.

IACRR

b)

Prepare student audit files in accordance with Student File Audit Checklist.

Colleges

VE Schools

ARG

9

Quality assurance of student files

Perform quality assurance check on all student files.

Submit student files that have completed quality assurance checks to IACRR for final check prior to providing to the external auditor.

Colleges (1st QA)

IACRR (Final QA)

10

Audit entry meeting

Conduct introductory meeting between the external auditor and key RMIT audit contacts from IACRR and VEO (Chief Audit & Risk Officer and the Executive Director of Vocational Education) to discuss audit objectives, scope, audit process and any other matters relevant to the audit.

IACRR

VEO

External auditor

11

Review student files

Review sample student files to assess compliance with the VET Funding Contract.

Main contact for the external auditor during the audit fieldwork and will be responsible for coordinating responses to review queries and audit requests for further information.

Business process owners to speak to external auditors.

External auditor

IACRR

ARG

VEO

Finance

12

Exit meeting

The Chief Audit & Risk Officer and the Executive Director of Vocational Education will have the exit meeting with the external auditor to discuss audit findings and any follow up required.

IACRR

VEO

External auditor

13

Communicate results: Follow up and action

Report the results of the external audit to the colleges, ARG, the DVC (Education), any relevant forum.

Provide any additional evidence in relation to audit review queries.

Coordinate collection of additional follow up action and audit evidence artefacts that are required to address review queries.

IACRR

ARG

Colleges

VE Schools

IACRR

14

Draft Report

External auditor prepares draft report and provide to IACRR for management comment, usually within 7-10 days.

External auditors

15

Management Response

Comment on the draft report provided by the external auditors and develop an Agreed Management Action Plan to respond to and address audit findings and recommendations.

IACRR

VEO

16

Final Report

Final report with RTO comments is provided to the Department of Education and Training

DVC (Education) or delegate

Internal Audit

No

Description of instructions, steps and actions

Responsible Owner(s)

1

Planning

Develop a plan for the Student File Compliance Review including key timelines, scope of the review and schedule for when colleges/VE schools and ARG will conduct their review of student files.

Self-assessment approach is the University’s Student File Compliance Review method.

IACRR

2

Notification

Send a formal communication to all stakeholders (ARG, colleges/VE schools, VEO) advising of the Student File Compliance Review including key timelines, scope of the review and the Student File Audit Checklist

IACRR

3

Briefing meeting

Arrange a meeting to brief ARG, the colleges/VE schools and VEO regarding the internal audit process, the scope of the review, timelines, preparation of audit information and action owners.

IACRR

4

Generate student report

Generate a student report for audit sampling purposes based on government subsidised training profile.

Analytics and Insight

5

Sample students for audit testing

Select a sample of students from the student report (provided by Analytics & Insight) for audit testing purposes. The audit sample should cover the following parameters: trainees, apprentices, non-apprentices & trainees, concessions, normal tuition fees, activity start and end date, RPL/RCC/CT and special initiatives.

IACRR

6

Set up audit shared folders

IACRR to set up audit shared folders by college (sampled for audit testing) and provide access rights to key stakeholders in the colleges/schools, VEO and ARG.

IACRR

7

Communication

Provide details of the selected sample of students to both ARG and the colleges/VE schools for student file preparation and

self-assessment review.

Ensure that ARG and the colleges/VE schools have the Student File Audit Checklist for compliance review purposes.

IACRR

8

Upload internal audit evidence artefacts

Upload internal audit evidence artefacts (as per the Student File Audit Checklist) on to the Google Drive shared folders.

Colleges, VE Schools

ARG

9

Verify sample

Assess compliance requirements of selected sample of students in the following areas: Eligibility, Enrolment compliance; PTR, Training Plan, RPL/RCC/CT and EOP calling on any subject matter experts.

IACRR

10

Record keeping

The audit evidence is to be stored in designated electronic main internal audit folders.

IACRR

11

Circulate draft findings for factual check

Main findings, recommended actions and exceptions that require further follow up action.

IACRR

ARG

VEO

Colleges, VE Schools

12

Reporting

Produce and present the final internal audit checklist, and report incorporating the Student File Compliance Review findings to the DVC E, VE Executive, ARG, and any relevant forum.

IACRR

13

Sign-off

The VE Executive, on endorsement of completion of the internal audit must sign off the internal audit checklist and report.

DVC (Education) or delegate

14

Rectification Plan

Coordinate development of an internal audit rectification plan to address compliance gaps. The rectification plan requires consultation and engagement with VEO, ARG and the colleges/VE schools, and any other identified organisational unit/s to capture their rectification response.

IACRR

15

Notify the Department of Education and Training

Notify the Department of Education and Training of any non-compliances identified through the internal audit, as required.

VEO

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