Evidence of Participation

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In their most recent Audit and Assurance Findings report, the Department of Education and Training pinpointed “missing minimum points of valid Evidence of Participation” as one of the five most common issues that auditors identified during the 2018-19 Skills First audit cycle. The collection and maintenance of Evidence of Participation (EOP) that aligns with the requirements set out in the Skills First Contract, is the backbone of your SVTS claiming process. Any breaches discovered during an audit can lead to re-payment of the funds to the Department or to enforcement of further assurance activities (e.g. special investigation) and may also be taken into account when considering future contractual arrangements. Clause 11 of Schedule 1 in the 2018-19 VET Funding Contract outlines the requirements relating to documenting and maintaining EOP in training and assessment in order to provide proof of claims for payment.

General Requirements

At a minimum, EOP must contain the following:

  • Eligible Individual’s name or identification number
  • Unit of Competency Code and
  • Date expressed in day/month/year format

The number of the EOP items that must be documented and retained depends on the delivery period of each unit of competency.  If this period is less than one month, only one item of EOP, dated within the delivery period, must be retained.  If this period is greater than one month then two items must be retained, one dated within the first month and another one dated within the last month as identified by the reported Activity End Date.  In this scenario, the items of EOP maintained must be two different items.

An auditor may also consider the elapsed time between the start and end date of the unit of competency and ask for demonstration of ongoing engagement in learning and/or assessment activity.  It is highly recommended that you document and maintain multiple items of EOP when a unit of competency is delivered across an extended period (ie. several months).

Evidence of Participation Examples

The following section provides some examples of EOP that are acceptable under the current Skills First contract.

Evidence of work submitted relating to engagement by the Eligible Individual in the unit of competency

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format

Comments

Additional evidence such as delivery schedule and/or session plans are required to allow it to be linked to the Eligible Individual; this is if the original piece of work doesn’t display any of the required information.

Examples

  • Formative Assessments
  • Non-assessable in-class activities
  • Online Quizzes

Skills First Teacher notes based on communication between the Skills First Teacher and Eligible Individual

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format
  • Skills First Teacher Name

Comments

These notes must establish engagement in learning and/or assessment activity of a unit of competency.  Notes referring to communication that doesn’t establish this type of engagement include confirmation of class attendance, material receival, withdrawal warning, etc.  They may include reference to notes from another person working alongside the Skills First Teacher, for example an industry expert or workplace supervisor.  Most Student Management Systems come with a feature for recording notes against student profiles here the notes are date and time stamped.  We strongly recommend that you utilise this feature and encourage your trainers and assessors to record their notes related to their communication with students within your SMS environment.  This is a great way of addressing this contractual requirement and preventing this type of information from being misplaced.

Examples

  • Personal interviews
  • Phone calls
  • Emails
  • Other communication modes
  • Diary notes
  • Student notes recorded within your SMS

Training Provider endorsed Attendance Roll

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format
  • Eligible Individual marked Present or Absent on the roll
  • Skills First Teacher Name
  • Skills First Teacher Signature

Comments

The Contract does not mandate student endorsement on attendance rolls; this is a common misconception which can create an unnecessary administrative burden.  Your attendance roll must be endorsed by your Skills First Teacher only.  When delivering units in clusters, you must provide additional evidence such as a delivery schedule or session plan that demonstrates the planned training at the unit of competency level.  When units are delivered concurrently, the roll must be annotated to indicate what training was delivered in the session.  The Department will also accept this type of EOP where classes have taken place in a virtual environment and not in a physical space (e.g. online delivery via a web-conferencing application).

Examples

  • Hardcopy or Electronic Attendance Sheets

Primary documentation that provides evidence of assessment

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format
  • Secure record that indicates an actual result consistent with assessment
  • Skills First Teacher Name and Position
  • Skills First Endorsement at the Unit of Competency level confirming accuracy of information

Comments

This type of EOP can also be used for RPL outcomes however it must include only the primary assessment tool used for any skills recognition assessment.

Examples

  • Summative Assessments (classroom, online, workplace)
  • Assessment Feedback Records
  • Assessment Cover Sheets

Practical Placement Logbooks (where the activities outlined in the performance criteria of the unit of competency must be performed during a specific period in a workplace environment)

Login Records to online plaftforms

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format
  • Demonstrates on-line engagement with learning and/or assessment activity for the Unit of Competency

Comments

The login record must demonstrate engagement in learning and/or assessment activity.  A login record indicating that the eligible individual received training materials alone is not sufficient Evidence of Participation.

Examples

  • Online Login Record from a Learning Management System
  • Record of a student participating in an online discussion forum
  • Record of the student completing a self-paced activity within an LMS

Records of Training Provider Personnel/Eligible Individual that indicates the individual has commenced working on the learning materials received

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format

Comments

This type of EOP applies to flexible and modes of learning only and must demonstrate engagement with learning and/or assessment activity at a unit of competency level.

Examples

  • Skills First teacher notes demonstrating a two-way communication and interaction via phone or email confirming the student is working on the learning materials

Signed statutory declaration from the relevant Training Provider Personnel and/or the relevant Eligible Individual

Requirements

  • Student Name or Student Identification Number
  • Unit of Competency Code
  • Date expressed in Date/Month/Year format

Comments

This evidence can be used only if extreme circumstances prevent the provision of any of the primary recording documentation (fire, flood or other equivalent circumstances).  It must affirm the eligible individual’s participation in learning and/or assessment activity at the unit of competency level.  This declaration must include the following:

  • Full explanation of the reasons why primary recording documentation is not available
  • Full explanation of the evidence being provided and affirmed that is sufficient to substantiate the claim that the Eligible Individual participated
  • Statement from the Eligible Individual that they have participated in the Unit of Competency

Examples

  • Statutory Declaration Form

Skills First Teachers

Where the EOP requires endorsement by a Skills First Teacher, training providers must ensure that the personnel signing are a trainer and/or assessor who is either:

  • directly employed by the provider or
  • engaged by the provider as a sole trader or
  • engaged by the provider under a subcontracting arrangement.

Training providers must also ensure that Skills First Teachers delivering training and assessment:

  • are listed on the Training Provider’s Register of Trainers and Assessors;
  • hold relevant qualifications as required by ASQA or the VRQA (as applicable); and
  • if the Skills First Teacher is engaged by the Training Provider through a subcontracting arrangement, you must ensure engagement is under a subcontracting arrangement which meets the conditions outlined in the Contract.

Bear in mind that an item that is endorsed by a person who at all times, did not comply with the Skills First Teacher requirements, does not form valid evidence of participation.  The Department is not liable to pay any funds for training and/or assessment being supported by EOP which is endorsed by an individual not fulfilling the above requirements.

Withdrawals

Previous auditing data has shown that retaining sufficient EOP for withdrawals have been a missing element of compliance for many training providers.  When it comes to EOP relating to withdrawn units of competency, it is important to note that the longer the organisation extends the reporting delivery period the higher the risk becomes for non-compliance.

Let’s think of the scenario where a student attends all classes related to the delivery of a single unit of competency but then disappears without submitting any assessments and does not respond to any of your re-engagement communication efforts.  Months after, the student sends you an email in which they formally request to be withdrawn from their course.  In this scenario, you have a withdrawn unit of competency delivered across a long period (greater than one month), thus the reported activity end date must reflect the date of formal withdrawal.  The only EOP available would be attendance records which form sufficient EOP to support the activity start date but not the activity end date.  Either because the attendance record date is outside the last month of delivery or simply because the Contract mandates two different types of EOP where the delivery period is longer than one month.

This is a common non-compliance among providers that are audited on their withdrawn students.  Revisit your EOP collection process to ensure that other types of EOP (Skills First Teacher notes or Evidence of Work such as non-assessable activities) are collected and retained in addition to your attendance rolls.  This is a good way to protect your organisation from failing to provide auditors with a valid second item of EOP, whenever this is required.  Furthermore, review your withdrawal policies and procedures to eliminate extended delivery periods without any student engagement.  This would require that enrolments of individuals who fail to engage in learning and/or assessment are withdrawn within a strict and fair timeframe.  Make sure that your student handbook accurately reflects your policies surrounding attendance and right to withdraw, to ensure that learners are informed of these rules prior to enrolment.

Retention Requirements

All records related to Evidence of Participation can be retained in either hardcopy or electronic format.  Under the 2018-19 VET Funding Contract, training providers must retain records until three years after the Eligible Individual to whom the records relate has completed or withdrawn from the relevant training course or qualification in which they are enrolled.

The above requirements apply only to commencements under the 2018-19 contracts.  For individuals commenced in a collection year prior to 2018, you need to refer to older versions of the contract for information about record keeping requirements.

For non-subsidised enrolments, the retention requirements for EOP is six months, as specified in the National Regulator’s general directions.

Don’t forget that training providers are expected to comply with all applicable laws and standards relating to record keeping in addition to the contract.  This means that you may be required to retain EOP for longer if mandated to do so by any applicable law or standard.  You must develop and implement a record keeping system to enable the Department to determine compliance and the accuracy of reports and claims for payments.  You should consider documenting and maintaining EOP records in electronic format.  If you decide to go down this path, then you should utilise your SMS and LMS capabilities towards this direction.  Almost every different type of EOP can be documented and saved in electronic format and this could lead to a significant reduction in administrative costs.

In relation to units of competency delivered across longer periods, ensure that multiple points of evidence of participation are documented and retained.  Try to embed the Skills First Teacher notes and the non-assessable evidence of work as much as possible in your learning strategies; these types of EOP are ideal for supporting evidence of ongoing student engagement.  As we already mentioned, tighten your withdrawal policies and procedures to minimise the risk of not having enough EOP in place.

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