Managing the transition from superseded training products can be a complicated and time-consuming process for RTOs. From time to time, training packages are reviewed and updated to improve the clarity and consistency of the training materials and to be brought in line with current industry practices. This often leads to the replacement of existing qualifications with new ones which requires RTOs to design and implement a transition plan. This article aims to help you understand the procedures and requirements for managing the transition from superseded qualifications and uses the transition from HLT43015 Certificate IV in Allied Health Assistance into HLT43021 Certificate IV in Allied Health Assistance as an example.
The HLT43015 Certificate IV in Allied Health Assistance has been superseded since 24th November 2022, as part of release 8.0 of the Health Training Package. According to Clause 1.26 (a) of the Standards for RTOs 2015, the RTO ensures that where a training product on its scope of registration is superseded, all learners’ training and assessment is completed and the relevant AQF certification documentation is issued or learners are transferred into its replacement, within a period of one year from the date the replacement training product was released on the national register.
This means that all RTOs delivering the HLT43015 Certificate IV in Allied Health Assistance must stop delivery of training and assessment to all students enrolled in this superseded program by 24th November 2023 (assuming the regulator does not extend the transition period). By that date, students must either complete their training and be issued with their Certificate or transferred into the HLT43021 Certificate IV in Allied Health Assistance.
Both ASQA and VRQA, have the authority to extend qualification transition end dates beyond the standard 12-month period. RTOs can also apply for a transition extension. This application should demonstrate how an extension will benefit the students and/or the relevant industry. This application must be submitted at least 90 days before the transition period ends. RTOs delivering the HLT43015 Certificate IV in Allied Health Assistance can apply for a transition extension by 24th August 2023. Administrative errors or delays in preparing delivery materials are not valid reasons for a transition extension. If an extension is approved, it will apply to all providers delivering the specific product to the identified learner cohort.
During the transition period, students may still commence training in the superseded qualification; however, these students must then either be completed or transferred into the replacement qualification before the end of the transition period. Students should also be made aware of the fact that the training product is superseded and providers need to be transparent with the information they provide to prospective learners.
Impacts on Skills First Providers: Subsidised Training End Date (STED)
Every time a replacement qualification is introduced, Skills First training must align with the transition period set by ASQA. This applies regardless of whether an RTO is regulated by ASQA or VRQA. Under Skills First, the end of the transition period is referred to as the subsidised training end date (STED). If ASQA extends a transition period, then the Department updates the STED to match it.
The STED for HLT43015 Certificate IV in Allied Health Assistance is currently set to 24th November 2023.
Where an RTO is reporting Skills First funded training activity to SVTS for HLT43015 Certificate IV in Allied Health Assistance, they must ensure that all subjects under this program enrolment are reported with an Activity End Date that is no later than 24/11/2023. Otherwise the following content warning will appear on their SVTS validation report:
- 120097: Training activity in a superseded qualification cannot continue past the end of Transition Period.
This warning is associated with Reject Code 30 which leads to the cessation of payments for any training activity that continues past the transition period.
Scope of Registration
Before accepting new or transferring enrolments into a replacement qualification, RTOs must ensure that this qualification is on their scope of registration.
Where the developer responsible for the training package deems the replacement qualification as equivalent to the superseded qualification, ASQA will automatically update the RTO’s scope of registration to include the replacement training product. VRQA will automatically have the superseding qualification added to the RTO’s scope of registration, provided that the RTO has previously lodged a standing application. A standing application authorises the VRQA to amend an RTO’s scope of registration when a training package product is superseded by an equivalent product.
However, this is not the case with the superseding qualification of HLT43015 Certificate IV in Allied Health Assistance. SkillsIQ, the organisation responsible for developing and reviewing the Health Training Package (HLT), had deemed the HLT43021 Certificate IV in Allied Health Assistance as non-equivalent to the superseded qualification. Therefore, ASQA-regulated RTOs wishing to add the HLT43021 Certificate IV in Allied Health Assistance on their scope of registration must apply to ASQA to add this qualification on their scope of registration and have that application approved. This application must submitted via asqanet and does not require the submission of any supplementary evidence (e.g. training and assessment strategy), however RTOs are requested to declare in writing that they:
- have developed strategies for the delivery of training and assessment through effective consultation with the industry
- have access to sufficient trainers to deliver the HLT43021 Certificate IV in Allied Health Assistance
- have access to sufficient, industry-relevant resources and materials to train and assess the HLT43021 Certificate IV in Allied Health Assistance.
Similarly, VRQA-regulated RTOs wishing to add the HLT43021 Certificate IV in Allied Health Assistance on their scope of registration must apply to change their scope of registration using the relevant form. This application must be submitted to the VRQA in soft copy via post and based on the risk profile of the RTO, the assessment may involve a desk review or a site audit. Additional evidence will need to be submitted along with the application, including, but not limited to, the following:
- an appropriate training and assessment strategy
- appropriately qualified trainers and assessors
- fully developed assessment tools for all units you intend to deliver.
Both ASQA and VRQA apply a non-refundable fee to this application.
Please note that the superseded HLT43015 Certificate IV in Allied Health Assistance will be automatically removed from all RTOs’ scope of registration on 24th November 2023 or on the date the transition period expires if an extension is approved. From this date, RTOs must not:
- enrol or train students in HLT43015 Certificate IV in Allied Health Assistance
- issue a qualification or statement of attainment for HLT43015 Certificate IV in Allied Health Assistance.
Funded Scope means the specific list of programs an RTO is entitled to be paid funds for delivering under Skills First. The superseded HLT43015 Certificate IV in Allied Health Assistance is currently included in the 2023 Funded Course List and its subsidy rate is set to $12.50 per scheduled hour.
RTOs that already have the superseded HLT43015 Certificate in Allied Health Assistance on their funded scope don’t need to contact the Department to add the HLT43021 Certificate IV in Allied Health Assistance to their funded scope.
The Department will automatically update their funded scope to include the HLT43021 Certificate IV in Allied Health Assistance once this is:
- on their scope of registration as shown on the training.gov.au website
- added to the funded programs report on SVTS by the Department.
During the transition period, RTOs can still promote and accept enrolments into the superseded HLT43015 Certificate in Allied Health Assistance. However, according to Clause 5.2 (a) of the Standards for RTOs 2015, prospective students must be informed about the fact that they are enrolling into a superseded qualification and about the future transitioning arrangements. This is also a Skills First requirement, as prescribed in Clause 1.2 (a) of the Guidelines about Fees. The Statement of Fees, given to each Skills First student prior to the commencement of training, must include the code, title and currency of the training program. RTOs currently enrolling students into the superseded HLT43015 Certificate in Allied Health Assistance must ensure that the currency of the program in the Statement of Fees is shown as “superseded”. This way they achieve compliance with both the Standards for RTOs 2015 and the Skills First Contract.
After the transition period expires, RTOs must neither advertise nor accept enrolments into the HLT43015 Certificate in Allied Health Assistance.
Marketing and advertising activities for the HLT43021 Certificate IV in Allied Health Assistance may occur only after this qualification is added to the RTO’s scope of registration. However, before marketing this program as Skills First subsidised training, the RTO must ensure that the HLT43021 Certificate IV in Allied Health Assistance has been added to their funded scope.
Skills First Training
When a Skills First student transitions into HLT43021 Certificate IV in Allied Health Assistance, this doesn’t consume an additional commencement allocation, provided the new program enrolment is reported correctly. If the RTO has previously assessed the student as eligible for Skills First training under the HLT43015 Certificate IV in Allied Health Assistance, then they don’t need to re-check their eligibility when transitioning into HLT43021 Certificate IV in Allied Health Assistance. Furthermore, transitioning into this program isn’t counted towards the “2 in a year” limit for future enrolments.
RTOs don’t need to conduct a new pre-training review for a student transitioning into HLT43021 Certificate IV in Allied Health Assistance. However, they should consider whether the new learning strategies and materials remain suitable and appropriate for the student. If not, they may need to think about whether the student needs any extra support to succeed.
In addition, the training plan must be kept up to date with details about the new subjects and program and the updated version of the training plan must be shared with the student.
This is probably the most complex part of the transitioning process and RTOs must ensure that the superseded and the superseding program enrolments are linked. This will help SVTS avoid counting them twice against the RTO’s commencement allocation.
The superseded program enrolment needs to be closed off or finalised before the new superseding program enrolment can be reported to SVTS. Let’s have a look at the example of a student who is enrolled into HLT43015 Certificate IV in Allied Health Assistance and is transitioning into HLT43021 Certificate IV in Allied Health Assistance on 1st September 2023. On 30th August 2023, their training activity data under the superseded program enrolment look like below:
At some point in September, the RTO actions the transition and therefore needs to withdraw the existing program enrolment. For subjects reported with a “Continuing Enrolment (Code 70)” outcome, the Activity End Date is set to 01/09/2023 and the number of hours of supervised training and assessment provided prior to transition are reported as the “Hours Attended” for each one of those subjects. Subjects that will be delivered under the replacement qualification (e.g. BSBMED301) must be reported with a “Withdrawn/discontinued (Code 40)” outcome while subjects that have been superseded and their superseding subjects will be delivered under the replacement qualification (e.g. HLTAHA001) must be reported with a “Superseded subject (Code 61)” outcome.
Subjects that have not yet started (e.g. CHCCCS001) must no longer be reported against the old program enrolment, as they will be reported against the new program enrolment instead.
Straight after the old program enrolment is finalised, the RTO needs to start reporting the replacement qualification under a new program enrolment. Subjects reported as withdrawn (e.g. BSBMED301) or superseded (e.g. HLTAHA001) against the old program enrolment must be reported with a “Continuing Enrolment (Code 70)” outcome and with an Activity Start Date of 02/09/2023 (one day after the Activity End Date for the withdrawn/superseded subject). The RTO has already received payment for some of the hours under the old subject enrolment, therefore they need to report the balance of the scheduled hours for the new subject enrolment. The balance must be calculated by subtracting the old subject’s hours attended from the new subject’s scheduled hours.
Any new subjects that didn’t commence under the old program enrolment must be reported in the same way that any other subject would be reported.
Evidence of Participation (EOP)
Keep in mind that training and assessment in a superseding subject is the continuation of the previously commenced superseded subject.
Therefore, when a student is transferred to a new subject, the old and new subjects are treated as a single subject for the purpose of EOP. For instance, if an auditor requests to sight EOP for HLTAHA044 then the first point of EOP provided by the RTO can be an attendance roll dated no later than 30 days from 27/07/2023 which references the code of the superseded subject (HLTAHA024).