Withdrawing students from Skills First funded courses is often an awkward and confusing process for providers, but an unavoidable scenario.
Regardless, training providers must be well prepared to handle withdrawals in a manner that complies with their contractual obligations and ensures maximisation of their claims.
Withdrawal Policy and Procedure
You must have a clear and well documented withdrawal policy and procedure in place. This document must outline all processes relating to how you attempt to re-engage your students, at what point a withdrawal is triggered and what evidence you use to calculate the hours attended for each unit of competency reported with a Withdrawn/Discontinued outcome.
As per Clause 13.28 of Schedule 1, withdrawals must be reported no later than two months from the actual point of withdrawal. This means that your attempts for re-engaging students should start earlier than this, perhaps 1-2 weeks after a student either stopped attending or fell behind their assessment submissions. Your process should describe what types of re-engagement methods you have in place (e.g. formal withdrawal warnings) and after how many failed re-engagement efforts a withdrawal is triggered. This information must be included in your Student Handbook as well; this is a good way to ensure your students are aware of what the process is in case they show no activity for an extended period. Finally, don’t forget to notify withdrawn students via email or other means of communication about their withdrawal.
This communication must also remind students that their withdrawal will impact their future eligibility for government subsidised training.
Withdrawn Program Enrolments
The 2020 Victorian VET Student Statistical Collection Guidelines v1.2 outlines three different Program Status Identifiers pertaining to withdrawn programs. One of these identifiers must be reported in the NAT00130 (Program Completion file) when an individual has been withdrawn from a course.
40 Withdrawn – Official
This is used when a student has stopped their training without fully completing their program and has notified the training provider of their withdrawal. Students must advise the RTO of their formal withdrawal in writing or verbally. Many training providers use a “Withdrawal Form” to record their students’ consent before withdrawing their enrolments. This is a safe practice however the Contract does not mandate or prescribe the use of such a form. An email sent by the student or a file note documenting the outcome of a phone conversation between the provider and the student is also sufficient evidence for official withdrawals.
41 Withdrawn – Apparent
This is used when a student has stopped their training without fully completing their program but has failed to advise the training provider of their withdrawal. This is where your Withdrawal Policy and Procedure comes into play since the Department expects that training providers will attempt a re-engagement process before withdrawing students. As already mentioned above, your Withdrawal Policy and Procedure should outline at what point of the re-engagement process the withdrawal will occur. This code also covers scenarios where the training has ceased through no fault of the student (e.g. RTO closure).
42 Withdrawn – Deferred
This is used when a client has stopped their training without fully completing their program and has negotiated an agreement with the RTO of their intention to defer training to a later date.
Withdrawn Subject Enrolments
When reporting a withdrawal, regardless of whether or not the student has notified the training provider of their withdrawal, all incomplete units of competency under the withdrawn program enrolment must be reported with the Outcome Identifier – National set as “40 Withdrawn/Discontinued” in the NAT00120 file. This is also applicable when reporting a program enrolment as “Withdrawn Deferred”. Withdrawn/Discontinued units of competency can be later reverted to “continuing” if the student decides to recommence their studies.
Students can withdraw from selected units of competency within a qualification being delivered under Skills First and continue to receive funding for other units delivered under that Program. That said, the impact that this has on potential employment or skills outcomes for the student should continue to be considered.
It is mandatory to report the “Hours Attended” where a student withdraws from a unit of competency after participating in training and/or assessment activity in that unit of competency.
Hours Attended must not exceed the Scheduled Hours for a withdrawn unit of competency, otherwise SVTS will trigger a 120067 error which falls under the “rejected” validation rule category. This simply means that your statistical report will not upload successfully to the SVTS database unless you first rectify these issues.
Hours Attended must reflect the hours of training delivered prior to withdrawal. Your Withdrawal Policy and Procedure must outline the process for calculating hours attended, considering all Evidence of Participation (attendance rolls, evidence of work, skills first teacher notes, assessments) collected prior to the student being withdrawn. Where no attendance or other evidence of participation has been recorded, the Hours Attended must be set to zero.
When students withdraw from a unit of competency, the Activity End Date must be amended to reflect the relevant withdrawal date. This date is either:
- The date of formal withdrawal or deferral (applicable to Withdrawn – Official and Withdrawn – Deferred program identifiers) which reflects the date when the student verbally or in writing agreed to withdraw or defer their enrolment; OR
- The date of last engagement (applicable to the Withdrawn – Apparent program identifier) which reflects the date when the student last participated in training and/or assessment. This date may refer to class attendance, participation in online activities, submission of non-assessable/assessable work, supervised observation at the workplace, etc.
When a qualification/program is reported as either Withdrawn – Official or Withdrawn – Deferred, the withdrawal date should be the same across all withdrawn units of competency.
However, if a qualification/program is withdrawn as Withdrawn – Apparent, the withdrawal occurs at the unit of competency level. Therefore, a different withdrawal date must apply to each unit of competency. The Activity End Date for each unit of competency will have to match the date of last engagement in that unit of competency.
If a unit of competency is extended into the following collection year but the student doesn’t return to training and the last evidence of participation is dated in the previous collection year, then the withdrawal date should be changed to 1st January of the new collection year. This is common around the time of your end of year reporting and training providers should be attaching a file note to the latest evidence of participation explaining the situation that lead to the reporting of a different activity end date.
Withdrawn/Discontinued (40) or Competency Not Achieved/Fail (30)
Many training providers become confused between these two outcome identifiers, but the Victorian VET Student Statistical Collection Guidelines provides guidance on when each code should be reported.
If a student has engaged in some learning activities and then stopped attending or submitting assessments, then the withdrawn code (40) will apply, even if the student has completed some assessments and has been assessed as not competent in one or more of them.
The competency not achieved/fail code (30) will apply only when the student has attempted all of the required assessments and has been deemed as not competent in one or more of them. In this case, you do not need to report hours attended because the Department will subsidise the total amount of scheduled hours for that unit of competency.
To ensure continual compliance, ensure that your Withdrawal Policy and Procedure is reviewed and in line with the most recent Departmental Fact Sheets in relation to Factsheet – Withdrawn (and Deferred) Program Enrolments (V2.0) and Factsheet – Withdrawn Subject Enrolments (V2.0). It is very important to withdraw students in a strictly specified but fair timeframe and to eliminate extended delivery periods without any student engagement. Our auditing experiences have shown that retaining sufficient EOP for withdrawals is something that many training providers fail to comply with. Consider that Withdrawal – Official requires less administrative work than Withdrawal – Apparent since the same withdrawal date applies across all units of competency. On the other hand, Withdrawal – Apparent minimises EOP compliance risks since the Activity End Date always reflects an engagement date.
Still confused? Book in a discovery session with one of our consultants to clarify these rules.