The Department of Education pinpointed “inadequate evidence of participation” as one of the five most common issues that auditors identified during the 2021-22 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 9 of Schedule 1 in the 2023 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.
At a minimum, EOP must contain the following:
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 (i.e. several months).
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
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
Skills First Teacher notes based on communication between the Skills First Teacher and Eligible Individual
Requirements
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
Training Provider endorsed Attendance Roll
Requirements
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 may be requested to 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
Primary documentation that provides evidence of assessment
Requirements
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
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) as evidence of learning and/or engagement activity that occurs as part of a Skills First Student’s Practical Placement may also be accepted as Evidence of Participation.
Login Records to online plaftforms
Requirements
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
Records of Training Provider Personnel/Eligible Individual that indicates the individual has commenced working on the learning materials received
Requirements
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
Signed statutory declaration from the relevant Training Provider Personnel and/or the relevant Eligible Individual
Requirements
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:
Examples
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:
Training providers must also ensure that Skills First Teachers delivering training and assessment:
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.
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.
All records related to Evidence of Participation can be retained in either hardcopy or electronic format. Under the 2023 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 program in which they are enrolled.
For individuals commenced in past collection years, you can refer to this article 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.
Managing the transition from superseded training products can be a complicated and time-consuming process for RTOs. From time to time,
The 2023 Victorian VET Funding Contract came with significant changes to the eligibility settings. In this article, we cover the 2023 changes relating to the Skills First eligibility requirements and evidence retention.
In an effort “to increase the ability of Victorians to reskill and to continue to participate in an evolving economy”,
Not all Skills First funded training conducted in the workplace translates into an apprenticeship/traineeship enrolment. It is common for Training
At least once every month, training providers are required to successfully upload their training activity data for the current data collection year to SVTS. Training providers should check the Validation Outcomes report after every upload and must ensure that any data errors are rectified before re-uploading to SVTS.
The Victorian VET Funding Contract requires Training Providers to create and retain sufficient evidence relating to the services provided to eligible individuals.
