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Do RTOs really need RPL kits?

Setting up and operating an RTO in Australia is an enormous and expensive undertaking. It’s made even more difficult by some auditor’s interpretation that a recognition of prior learning (RPL) kit is always required for all training products on scope. This is a major topic that we’ve been supporting our CRICOS consulting clients with and one which we’ve consistently pushed for change.

From our experience, ASQA and auditor interpretation of RPL requirements places a burden on many RTOs – particularly those with a focus on international students. 

Thankfully, we now have confirmation from ASQA that validates our interpretation of these requirements – that RPL kits are not always required. 

What is ASQA’s interpretation of RPL requirements?

Historically, it seems that ASQA’s position has been that every RTO must have RPL assessment tools ready and available for all units – in case students request recognition for their prior learning to: 

  • acknowledge existing skills,
  • shorten their qualification time frames, and 
  • lower their fees. 

Auditors often ask for these kits during an audit for initial set-up or during a performance assessment.

This interpretation, favoured by many auditors, means that RTOs must purchase RPL kits whether they will need them or not – potentially costing them a significant amount of money. 

Our approach, instead, is that RTOs must:

  1. have an RPL policy and process in place, 
  2. clearly state in their documentation that they can provide an RPL assessment to any student who wants one, AND 
  3. maintain the ability to quickly develop or purchase RPL kits when they receive a  request for recognition of prior learning. 

Why has the prevailing interpretation been unfair?

The need for RTOs to purchase RPL kits that they may never use is a colossal and unnecessary financial burden. It’s a particular pain point for CRICOS providers that focus on international students. These students rarely request recognition of prior learning.

Auditors and ASQA know that establishing and operating an RTO is a significant undertaking. We’ve always believed that VET providers should not be required to pay for material they’ll never use.

Let’s compare this with another industry. Would it be reasonable to mandate that all restaurants pre-purchase enough gluten-free food to serve to every patron at all times just in case there are gluten-free customers? No; restaurants are instead able to quickly prepare a gluten-free alternative if they receive a request from a customer.

Education is our biggest export. While it’s one of the pillars of our economy, it’s also been one of the most severely impacted by the COVID-19 pandemic. We should be doing everything we can to help education providers deliver quality outcomes, rather than undermining their success with unnecessary costs.

Has there been a change in the interpretation?

The team at RTO Works recently received official communication [ST1] from ASQA that substantiates our perspective on requirements for RPL kits:

“Whilst it is a condition of your registration that your college offers individual students an RPL pathway, you are not required to have RPL tools developed for scope items that you do not expect or intend to use. […] 

You should demonstrate that you are familiar with your student cohort and recognise that they will only seek an RPL option on a limited basis, and can demonstrate the capacity to promptly develop RPL resources as required on an ‘as needed’ basis.

This means that if:

  • it’s unlikely that your cohort would request RPL (i.e. it’s composed mainly of international students), and 
  • your RTO can show that you’re able to quickly develop or purchase RPL kits as needed, 

then you do not have to pre-purchase that material.

We’re extremely happy to have been able to get confirmation on this issue. It just goes to show that improvements are being advocated for and made every day in our industry. 

Is this an issue that has affected your RTO in the past? We’d love to discuss how we can help you keep your costs down and still meet your requirements. Get in touch with our team! 

Sally Tansley, Thought Leader


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