Offshore Quality Assurance - National Skills Standards Council

Contact
NQC Secretariat
TVET Australia
Level 21/390 St Kilda Road Melbourne Vic 3004
Telephone: +61 3 9832 8100
Email: nqc.secretariat@tvetaustralia.com.au
Web: www.nqc.tvetaustralia.com.au
Disclaimer
This work has been produced on behalf of the National Quality Council with funding provided through the
Australian Government Department of Education, Employment and Workplace Relations and state and
territory governments. The views expressed herein are not necessarily those of the Australian Government or
state and territory governments.
The recommendations are under consideration by the National Quality Council but it should not be assumed
that they will necessarily be implemented in the future.
Acknowledgement
Prepared for the National Quality Council by Sue Foster and Moira Schulze.
© Commonwealth of Australia 2010
This document is available under a “Preserve Integrity” licence – for details: http://www.aesharenet.com.au/P4
All other rights reserved. For licensing enquiries contact sales@tvetaustralia.com.au.

CONTENTS
CONTENTS ....................................................................................................................................................... I
EXECUTIVE SUMMARY ..................................................................................................................................... I
BACKGROUND AND INTRODUCTION................................................................................................................5
External context ...........................................................................................................................................5
Review of the literature ................................................................................................................................5
Current arrangements for quality assurance of VET delivery and assessment ................................................7
Challenges in offshore provision ...................................................................................................................9
Approaches to managing quality frameworks ............................................................................................. 11
METHODOLOGY ............................................................................................................................................. 17
Research questions .................................................................................................................................... 17
Data collection ........................................................................................................................................... 17
DISCUSSION OF FINDINGS .............................................................................................................................. 19
Issues from the perspective of industry ...................................................................................................... 19
Issues from the regulators’ perspective. ..................................................................................................... 19
Issues from the providers’ perspective. ...................................................................................................... 20
THE PROPOSED MODEL ................................................................................................................................. 28
The National policy context ........................................................................................................................ 28
Locus of control.......................................................................................................................................... 28
Quality monitoring ..................................................................................................................................... 31
ELEMENTS OF PROPOSED MODEL: OPTION B ................................................................................................ 35
Element 1: Improved information to the offshore market .......................................................................... 35
Element 2: Compulsory national annual data collection of all offshore VET ................................................. 36
Element 3: Initial Enhanced Risk Assessment .............................................................................................. 37
Element 4: Offshore site visits .................................................................................................................... 37
Element 5: Publication of Audit Results ...................................................................................................... 38
Element 6: Results provided to national accrediting body ........................................................................... 39
Three ways of reading the 6 elements ........................................................................................................ 39
Concluding Comment ................................................................................................................................. 40
Recommendations ..................................................................................................................................... 40
REFERENCES ................................................................................................................................................... 41
APPENDIX A QUESTIONS POSED IN CONSULTATION ................................................................................. 42
APPENDIX B PARTICIPANTS IN CONSULTATION ........................................................................................ 44
APPENDIX C NOTIONAL COSTING OF OFFSHORE PILOTS ........................................................................... 47

EXECUTIVE SUMMARY
Offshore delivery of accredited training is growing in size and spread for both public and private providers. This
activity provides both commercial opportunities for providers and considerable financial and reputational
risks. These risks apply to both individual providers and the Australian VET system as a whole. The National
Quality Council (NQC) commissioned this project to bring together the findings of previous work with current
research on quality assurance of offshore VET. The project considered:
• current arrangements for quality assuring offshore delivery by Australian Registered Training
Organisations against the Australian Quality Training Framework (AQTF)
• challenges encountered by providers when resolving the requirements of the AQTF with VET quality
systems in the countries of offshore provision
• how the VET sector might benefit from the experiences of Higher Education (i.e. through AUQA) in
monitoring Higher Education quality offshore, and
• a possible model for quality assuring (or monitoring) offshore delivery, including the cost and
workforce development implications of implementing the model.
This research should be viewed in the context of changes to the VET regulatory environment that are likely to
involve a transition stage to a national system. The approach to research involved a literature review,
consultation with key stakeholders through interviews and consultation forums to test the preliminary
findings. A sample of 101 respondents from national and state departments and regulators, peak provider
bodies and public and private providers contributed to the consultation process. In summary, the research
found that:
• there is limited information on the nature of offshore delivery
• there is no state-based offshore monitoring except via desktop processes in existing onshore AQTF
audits, which is auditing at a distance. Different jurisdictions have different approaches to monitoring
offshore delivery.
• AUQA conducts offshore audits in the higher education sector, which provides a potential model for
monitoring offshore delivery in VET. This system will change with the implementation of a new
national approach to regulation through the Tertiary Education Quality and Standards Agency
(TEQSA).
• The Transnational Quality Strategy’s approach to providing better information to offshore clients is
available on a voluntary basis, but is not widely used by VET sector providers. It is not generally
viewed as a badge of VET provider quality.
• The approach to offshore delivery has matured as providers have recognised the potential financial
and reputational risks inherent in offshore VET. This has resulted in improved, robust internal quality
systems by large public and private providers
• Providers fear approaches to monitoring that involve culturally inappropriate practices that may
destroy relationships with offshore partners and business arrangements
• There is strong support for a national approach to monitoring offshore delivery. A national approach
was seen to provide greater consistency for local providers and a simpler system for offshore partners
and regulators in host countries.
• Providers would prefer an approach to monitoring offshore VET that is not onerous and recognises
their efforts toward quality assurance.
1

The research identified 17 challenges to providers operating in offshore markets. These challenges may also be
seen to constitute the major risks that apply in this form of activity. When managed effectively, the challenges
become the basis of good practice examples for the system. These challenges relate to the key phases of
planning and implementation as described in Figure 1. Effective practice in offshore activity also involves
strategies to manage providers’ exit from offshore markets. These strategies need to manage the strategic
interests of the provider following an initial evaluation of the offshore market as well as the moral and ethical
responsibility to protect the interests of students for completing their courses.
Figure 1
17 challenges: Risks to good practice
Exit strategy
Quality assurance
17. Monitoring, review &
continuous improvement
Preparation
1. Strategic fit/ Business
planning
2. Understanding in country
laws & regulations
3. Partner choice
4. Detailed partner contracts
5. Developing exit strategies
Assessment
15. Assessment standards &
moderation
16. Certification
Exit strategy
Delivery
6. Appropriate offshore
delivery models
7. Quality of offshore
facilities
8. Teacher/trainer skills &
qualifications
9. Student destination &
selection
10. English language
competency
11. Contextualisation of VET
programs
12. Learning resources
13. Student support
14. Educational leadership,
coordination & support
The proposed model for managing regulation of offshore VET activity seeks to balance central control with
provider responsibility and compliance approaches to quality assurance with continuous improvement
approaches. The preferred option involves:
• information to the market and voluntary accreditation, and
• risk based quality assurance.
The notion of a voluntary accreditation process is consistent with the current AusLIST arrangements, except
that the emphasis on quality providers is strengthened through the extent to which demonstrated quality
performance is required for membership.
The risk based quality assurance option is consistent with anticipated change to a national approach to quality
assurance through TEQSA and the current risk based approach of the AQTF 2007. It extends the approach to
include consideration of providers’ deployment of their policies and processes offshore through site reviews.
The model consists of six elements, which are consistent with the proposed TEQSA approach. It is based on
three central elements along with three elements that support the overall approach (Figure 2). The model is
independent of which organisation is to implement it. That is, whether the accrediting body is a government
department, an industry body or a professional association.
2

Figure 2
Proposed model: Option B
1. Improved information and badging to the offshore market – voluntary membership listing with strong
incentives to achieve listing (supporting element).
2. Compulsory national annual data collection from all public and private providers regarding programs,
enrolments and location of offshore delivery (central element).
3. Initial enhanced risk assessment – desktop audit based on enhanced/more detailed guidelines. High,
medium and low risk offshore providers identified (central element).
4. Detailed offshore site visits of high risk providers as per enhanced risk guidelines (central element).
• strong quality improvement focus, not only AQTF compliance
• supplemented by AEI/AUSTRADE offshore intelligence
• conducted by experienced specialist national audit team.
5. Results of offshore visits in public domain, as per current AUQA model (supporting element).
6. Membership / badging informed by site visit results, e.g. major noncompliance as a provider
(supporting element).
It is suggested that these elements can be viewed through any one of three lenses,
1. As a linear and sequential process in which each element is interdependent on the others. In this
view the model would be implemented in its entirety.
2. As a weighted set of elements that were weighted according to the risk based judgements required.
It would provide, for example, for stronger barriers to entry combined with professional
continuous improvement approaches to monitoring offshore delivery. Alternatively, broader
accreditation approaches could be supported through strong compliance based approaches to
managing risk.
3. As a set of elements that are central to risk identification and mitigation and those that support the
central purpose of a centrally coordinated, risk based quality assurance model.
There are a variety of views on the elements of the model. Indeed it is unlikely that there could be complete
agreement given the diversity of the Australian VET system. The issue is which approach affords the greatest
protection to the quality and reputation of the Australian VET qualifications and those responsible for
delivering them.
3

Recommendations
It is recommended that the NQC:
1. Supports the proposed 6 elements of the model as a basis of monitoring and managing the risks of
offshore delivery of Australian VET qualifications.
2. In order to identify and mitigate immediate risk, a pilot and evaluation of the three central elements
of the model is conducted and evaluated in 2010. Estimated costs are attached (Appendix C).
3. That an implementation plan is developed which:
a. Facilitates commencement of the pilot as early as possible in 2010.
b. Assesses the costs and practicality associated with progressively implementing the three
support elements (information to the market and/or strengthened accreditation, publication
of results, informing accreditation body) to the model.
c. Identifies any potential changes to current regulations needed to implement the three
supporting elements.
d. Takes into account the effect of impending changes to the VET regulatory arrangements via
TEQSA.
e. Takes into account the effect of any other changes to roles and responsibilities as a result of
reviews that are currently underway or are planned.
f. Ensures that the NQC is provided with the evaluation results of the 2010 pilot by October
2010 so that future action can be recommended.
4. Develops a VET specific offshore delivery manual/guide that includes examples of best practice in
offshore delivery.
4

BACKGROUND AND INTRODUCTION
External context
Offshore delivery of accredited VET training by both public and private providers is growing in quantum of
delivery, provider numbers and geographic spread. This trend is likely to continue as offshore markets and
their education and training systems ‘mature’. This presents both opportunities for individual providers and
for the VET system more broadly. The opportunity to deliver commercially viable fee-for-service activity is
growing, particularly in those densely populated countries that do not yet have a strong vocational education
and training system, for example, the People’s Republic of China and Vietnam.
Providers are aware of the commercial opportunities and the financial and reputation risks involved in
offshore delivery. Reputational risks are invariably related to the quality of program delivery. This risk applies
to individual providers and the Australian VET system as a whole.
This project builds on initial work conducted by the National Quality Council (NQC). The NQC has identified
international VET quality as a priority for 2009. The Council established an international VET Action Group to
progress its work in this area and endorsed an Action Plan which presents four broad strategies for
implementing the reference from the NQC.
• Quality assure off-shore delivery of VET by Australian RTOs.
• Quality assure on on-shore delivery of VET by Australian RTOs.
• Quality assure the use and standing of Australian VET qualifications internationally.
• Implementation and change management.
This project relates to the first strategy. It considers:
• current arrangements for quality assuring off-shore delivery by Australian Registered Training
Organisations against the Australian Quality Training Framework (AQTF)
• challenges encountered by providers when resolving the requirements of the AQTF with VET quality
systems in the countries of off-shore provision
• how the VET sector might benefit from the experiences of Higher Education (i.e. through AUQA) in
monitoring Higher Education quality off-shore, and
• a possible model for quality assuring (or monitoring) offshore delivery, including the cost and
workforce development implications of implementing the model.
This research needs to be viewed in the context of changes to the VET regulatory environment that are likely
to involve a transition stage to a national system.
Review of the literature
The definition of offshore delivery taken in this report is, “VET which leads to an Australian qualification
(award courses) and non-award courses, and is delivered to students located in another country (and who are
not normally based in Australia)”. (DEEWR, 2007: 6). An Australian or an Australian-approved provider
undertakes the delivery and assessment services.
There is a range of approaches to service delivery that fall under the banner of offshore delivery. These include
models such as: full delivery, articulation, franchising, branch campus, distance learning or corporate
institutions (International Education Association Australia, IEAA, 2008). A brief summary of these
arrangements is provided in Table 1.
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Table 1 Models of offshore delivery (IEAA, 2008)
Model
Full delivery
Articulation
Franchising
Branch campus
Distance learning
Corporate institutions
Description
The Australian provider provides all offshore delivery and assessment.
Joint study programs are negotiated between two or more providers. These
include negotiated provision for study credits, credit transfers and advanced
standing in another institution’s award program.
One tertiary institution authorises another institution to offer part or whole of an
approved study program using pre-developed training and assessment material.
A tertiary institution in one country establishes a campus in another country to
offer programs and qualifications.
Students are provided with training and assessment material via the web or post.
They complete these activities under guidance of home-based staff and may be
supported by some face-to-face delivery.
Higher education institutions or award programs that are set up by large
transnational corporations that operate outside national education systems.
The extent to which these models are implemented will vary between providers, the host countries, the
nature of the qualification and its potential to lead to a higher AQF qualification.
The Scope of offshore delivery
Comprehensive and accurate data on offshore delivery is limited. While RTOs are required to notify their
registering body that they are delivering offshore there is no formal central reporting of data on offshore
delivery. Indeed the tool established to provide data on delivery to offshore locations, AusLIST, is largely
restricted to listing higher education providers. There is very little data on VET providers and courses delivered
offshore. The data that is available is confined to the activity of public providers of VET.
The Department of Education, Employment and Workplace Relations (DEEWR) commissioned a study of
offshore delivery of VET (DEEWR, 2007). This research found that Victorian providers dominated offshore VET
with more than two-thirds (61.5%) of providers, followed by NSW (22.4%). Just under two thirds (64.9%) of
courses in 2007 were delivered through partnership arrangements.
The majority of Australian public providers with offshore operations deliver in China, followed by Indonesia,
Hong Kong and Papua New Guinea. China is also the largest student market with 35,475 students (80%)
studying with Australian public providers. The next largest markets are in Fiji (1964 students) and Vietnam
(1320 students).
In 2007, the overall number of offshore students with Australian public providers grew by 42.3%. This growth
was strongest in China, Vietnam, South Korea, Mauritius, Kuwait, Iran and Fiji. The majority of growth was in
courses at Diploma and above levels, followed by certificates III and IV. Management and commerce programs
represented over half (56.1%) of enrolments. The majority of courses enabled articulation to Australian higher
education (86.7%) and VET (75.1%) courses (DEEWR, 2007).
The key message from this data is that, for public providers, the extent of offshore delivery is focussed on a
few markets and it is growing. However, the full extent of offshore activity is not known as the data on the
offshore training and assessment services delivered by private RTOs is limited to voluntary surveys conducted
by the Australian Council for Private Education and Training (ACPET) and the Office of the Skills Commission,
South Australia.
6

Current arrangements for quality assurance of VET delivery and
assessment
Providers delivering AQF vocational education and training qualifications do so under the provisions of the
AQTF 2007 Essential standards for registration. These provisions apply to both on- and offshore delivery of
accredited Australian qualifications. The AQTF 2007 includes three components:
• Essential Standards for Registration, which outlines the standards that registered training
organisations (RTOs) must meet to deliver and assess nationally recognised training and to issue
nationally recognised qualifications. They include three standards for registration relating to training
and assessment, client services and management; a requirement for RTOs to gather information on
their performance against three quality indicators to assist their continuous improvement processes
and system monitoring; and nine conditions of registration to be met while operating as a training
organisation (Table 2).
• Standards for State and Territory Registering Bodies, which outline the parameters for registering
training organisations and for quality assuring the training that they provide under the AQTF 2007 and
relevant legislation. The standards include operational protocols to ensure national recognition of
registration decisions, that regulatory services meet the needs of industry and clients, and that
management systems are responsive to the needs of the VET sector.
• Excellence Criteria – that RTOs may use in improvement of training and assessment and to gain
recognition of their performance. Use of the criteria is voluntary. The Excellence Criteria provide
national and international recognition. They encourage a focus on quality and continuous
improvement. There are five interrelated criteria of: leadership; learning and assessment; people
development; relationship management; and integrated information management (DEST, 2007).
Table 2 The AQTF Essential standards for registration as an RTO (DEST, 2007)
Three standards for registration Three quality indicators Nine conditions for registration
1. The Registered Training
Organisation provides quality
training and assessment
across all of its operations.
2. The Registered Training
Organisation adheres to
principles of access and equity
and maximises outcomes for
its client.
3. Management systems are
responsive to the needs of
clients, staff and stakeholders
and the environment in which
the Registered Training
Organisation operates.
1. Employer satisfaction – with
competency development, and
training and assessment quality
2. Learner satisfaction – learner
engagement and competency
development including
perceptions of the quality of
support from RTOs.
3. Competency completion rate –
calculated for qualifications and
units of competency/modules
delivered.
1. Governance – ensure that the RTO
complies with the AQTF 2007.
2. Interactions with the registering body
– re. cooperation with the registering
body on audits, performance and
operational data and records
management and archiving.
3. Compliance with legislation – relevant
legislation and regulatory
requirements.
4. Insurance – for public liability.
5. Financial management – of advance
payments, refunds and annual
accounts certification.
6. Certification and issuing of
qualifications and statements of
attainment as per AQF requirements
and retention of records of attainment.
7. Recognition of qualifications issued by
other RTOs.
8. Accuracy and integrity of marketing
9. Transition to Training Packages/ expiry
of accredited courses – to be managed
within 12 months of publication.
7

The National Guidelines for Risk Management provide a framework for nationally consistent management of
monitoring the performance of RTOs against the AQTF using a nationally agreed risk assessment process. The
risk assessment process is based on performance risk indicators to gain a risk rating, and supplementary
indicators that include having multiple sites and delivery of training offshore. Delivery of training offshore
must be assessed for evidence of compliance at least once during the registration period.
The registration requirements for RTOs are described in Figure 3. The diagram highlights that the registration
requirements for delivery offshore are minimal. In addition to their normal registration requirements RTOs
merely notify the relevant registration body of their intention to operate offshore. They must also operate
within the regulatory frameworks of the host country. These regulatory frameworks vary from country to
country and require different practices by RTOs.
Figure 3
Current registration and monitoring requirements for RTOs
RTO Regulatory authority –
state & territory and NARA
Registration to deliver & issue If delivering to international
Australian qualification students • Register RTOs
• Accredit courses
Apply to regulator
• Monitor and review RTOs
Onshore:
according to risk including
• Comply with ESOS Act
offshore delivery and delivery
Comply with AQTF – 3
• Register on CRICOS
to multiple sites, etc.
standards:
• Apply state/territory
• Quality training &
legislation
assessment
• Join a Tuition
Assess risk using:
• Principles of access &
Assistance Scheme
• history of compliance
equity, maximising
• Maintain PRISM
• quality indicator data
outcomes for clients
records
• history of complaints
• Responsive
management systems
Offshore:
9 conditions of registration • Notify regulatory
Manage audit work program for
authority
initial, post initial, re-registration,
Full reporting Quality
extensions to scope, strategic and
Indicators as of July 2010
If multi-sector:
complaints audits
• AUQA – negotiated
process based on
Observe Australian State &
deployment of
AEI – Transnational Quality
Territory laws re training,
intended QA
Strategy
OHS, etc.
• May include audits of • Web portal
offshore sites
• Liaison with overseas
Optional – Forthcoming
authorities
AQTF Excellence Criteria
• Promotion of Australia’s TNE
Assessing offshore delivery of training and assessment services by Registering Bodies (national, state and
territory) is largely a desktop process conducted as part of the AQTF 2007 audit program. The intentions of the
RTO are reviewed within an AQTF 2007 audit if the RTO has notified the regulator of its offshore delivery.
However, the deployment of these policies and procedures offshore is not assessed.
An exception to this was a pilot study of auditing offshore delivery and assessment that was conducted by the
Training Accreditation Council of Western Australia against the previous AQTF 2005 standards for registration.
The Council conducted a strategic industry audit of the delivery and assessment of AQF qualifications offshore
(Department of Education Services, 2007). The audit included a three-phase approach of:
• A survey of all Western Australian RTOs to identify the level of delivery offshore. The survey looked at
whether or not the RTO was delivering offshore; size of the overseas operation (number of students);
frequency of delivery; type and level of qualification being delivered; delivery and staffing
arrangements; customization; and intentions for the future. The survey provided a basis for
8

understanding the scale and nature of offshore delivery of AQF qualifications. It also identified which
RTOs would be examined in terms of the risk associated with their offshore activity.
• A desk audit of RTOs identified as conducting offshore audits. This was found to be essential for
collecting information to inform the decision of whether to conduct a site audit and, where one was
required, to ensure that the process was conducted efficiently and cost effectively.
• A site audit of the offshore operations of a selected RTO based on a risk assessment informed by the
risks of the proportion of the delivery profile conducted overseas; partnership arrangements;
outcomes of previous audit; and that the RTO delivered a high risk qualification. This step added value
to the general approach to monitoring RTO’s compliance to the AQTF 2007 as it went beyond a desk
audit to examine the RTO’s deployment of their stated policies and procedures.
Other jurisdictions reported that they had undertaken individual site reviews, but these were not against the
AQTF 2007 and were concerned with ensuring that delivery arrangements met with industry requirements for
resources and practices.
The WA pilot provided a model based on evidence based risk management and that included offshore
appraisal of the quality of delivery and assessment of VET in an offshore context. It examined the deployment
of the RTO’s policies and processes, management of partnership arrangements; management of delivery and
assessment across multiple sites; and mechanisms to assure quality of training and assessment offshore is
consistent with training and assessment delivered in Australia. While the potential risks of offshore delivery
were extensive, the overall findings were positive. The pilot concluded that
the majority of Western Australian RTOs endeavoured to provide a high quality of delivery
and catering specifically to the needs of the client (Department of Education Services,
2007: 1).
The recommendations of the trial audit were for,
• national guidelines and production of audit tools and resources;
• holistic auditing of RTO’s on- and offshore operations to ensure vertical comparisons and to minimise
the impact on the RTO’s business operations;
• strategies to maximise resources including a phased approach: initial survey, desk audit of a
comprehensive set of evidence to identify need for an offshore site audit; offshore site audit to
targeted evidence and auditing a number of RTOs in the same visit.
Challenges in offshore provision
Providing training and assessment in Australian qualifications in an offshore context can be problematic for
providers. While the overall findings of the WA pilot were positive in its assessment of the quality of offshore
delivery and assessment of VET (Department of Education Services, 2007) the project also identified a range of
areas of risk for AQTF compliance including,
• a lack of understanding by overseas teaching staff of the competency based system. This was a
particular risk where the partner is an offshore higher education institution that requires a graded
score assessment.
• the challenge of ensuring that overseas staff qualifications, experience and expertise in the relevant
course is appropriate to the AQTF requirements
• maintaining compliant record keeping processes at the off-shore delivery site
• ensuring valid, fair, reliable assessment in a competency based context. There were risks associated
with protecting the integrity of AQF qualifications when the offshore partner was delivering a noncompetency
based program, which is then mapped to the Australian qualification. The validity and
reliability of assessment must be ensured.
• ensuring accurate translation and full understanding of requirements of training and assessment in a
competency based system in countries where English is not the first language
9

• a danger of double standards where off-shore and on-shore delivery are separated. That is, difficulty
in providing equivalence to on-shore delivery when trying to provide training and assessment that is
customised to the client’s requirements and cultural context. Noncompliance was often a result of
attempts to customise delivery and support services to the requirements of the international clients
• demonstrating industry validation of delivery and assessment offshore
• deficiencies in approaches to planning, delivery, moderation and validation of training conducted
overseas.
Many of these risks were also reflected in research into good practice in offshore delivery and quality
assurance in the VET sector (Bateman, 2007) and in transnational education conducted by universities
(International Education Association Australia, 2008). The challenges of offshore activity identified in these
research activities were,
• selecting partners and managing risk including relationship development and communication
• the availability of suitably qualified teachers with appropriate qualifications, involvement and
experience
• equivalence and comparability of nationally recognised quality assurance arrangements, processes
related to delivery and delivery standards and course outcomes
• financial pressures, for example, that arise from variations in the exchange rate
• the implications of the different offshore context for implementing the requirements of Australian
Training Packages, eg. workplaces, regulatory context
• different policy approaches to quality between the Australian and offshore partners
• cultural differences and awareness of both parties
• knowledge of the VET system of both on- and offshore providers
• understanding of competency based training and assessment
• English language skills of both students and the offshore teachers
• Effective communication processes
• Availability of suitably trained auditors in Australian providers
• Stable technology.
• The complexity of these challenges grow for multisector institutions that operate across both higher
education and VET external quality assurance regimes (Silver and Yang, 2008).
• The need for carefully designed and executed exit strategies during the initial planning stages as well
as exit strategies from existing training arrangements offshore was identified in the AUQA process
and in a recent forum on international delivery by the University of South Australia The University of
South Australia highlighted the need to review operations in transnational education and, in some
cases, to withdraw from its operations in some offshore markets. This required implementation of a
phased withdrawal process to ensure that the interests of students were protected (Ciccarelli, 2009).
• Careful planning along with monitoring and auditing programs were seen to be critical to
management of these challenges. Planning that integrated quality frameworks across the onshore
and offshore activities of the provider rather than seeing offshore activity as separate to core business
was also critical (Bateman, 2007; IEAA, 2008). The key messages from case studies of good practice
for VET practitioners (Bateman, 2007) were:
• a need to balance the requirements of Training Packages with client needs and expectations
• careful selection of appropriate offshore institutions is critical
• providers need a ‘well documented, flexible and fit-for-purpose quality management system’ (p. i)
10

• a need for flexible, adaptable learning and assessment by trainers that champion competency based
training and assessment and contextualisation of resources and instruction
• careful planning that involves negotiation, communication and relationship development, tolerance
of difference, flexibility and respect.
• These reviews of good practice in offshore delivery identified a range of key messages for practice
that relate to areas of activity including planning, equivalence, trainer qualifications, learning,
teaching and student experience, associate selection and relationship management and business
management.
Approaches to managing quality frameworks
Australian initiatives
Transnational Quality Strategy
There are also challenges for system regulators in managing the implications of offshore delivery for Australian
quality frameworks and the reputation of the education and training system. To date, the parameters for
quality assurance are against the Australian Qualifications Framework (AQF). The AQF defines nationally
consistent outcomes irrespective of location or mode of delivery. The AQF applies across each of the
educational sectors including schools, VET and higher education.
A recent national initiative was directed to offshore, or transnational, delivery of AQF qualifications across all
sectors. The Transnational Quality Strategy (TQS) was agreed in 2005 as a framework for promoting the quality
of Australian education delivered offshore by schools, higher education, VET, English language and foundation
providers. The TQS was directed to improving understanding and international regard of Australia’s quality
assurance. It was designed to improve accountabilities in delivery and quality assurance of transnational
education and training, through effective and efficient approaches that minimise bureaucratic processes and
costs. It is directed to assuring the quality of transnational education through three areas of activity:
• Communication and promotion of Australia’s quality assurance arrangements to improve overseas
understanding of the Australian education and training system
• Improved data collection on the scale and scope of offshore delivery, and
• A stronger national quality framework that protects and promotes the quality of Australian
transnational education and training (IEAA, 2008).
Implementation of the TQS is through:
• a portal publishing details of institutions delivering nationally accredited courses or qualifications
overseas based on voluntary registration by providers countries (AusLIST)
• a declaration of what stakeholders can expect from Australian providers offshore
• more effective and efficient approaches to quality assessment, and
• publication of host country regulatory fact sheets to assist Australian providers and supporting good
practice in quality transnational delivery including developing best practice models and case studies.
The strategy includes liaison with overseas governments and qualifications recognition bodies to promote
improved understanding of the Australian education and training system.
Australian Universities Quality Agency
Key quality assurance frameworks and arrangements in higher education are also outlined in the National
Protocols; AVCC Guidelines and Code of Practice; AQF and the processes of the Australian Universities Quality
Agency (AUQA), which promotes, audits and reports on quality assurance in Australian higher education
including for delivery offshore. AUQA is an independent, not-for-profit national agency for quality assurance
in higher education. As stated above, AUQA promotes, audits and reports on quality assurance in Australian
higher education including for delivery offshore.
11

The AUQA approach is based on quality improvement, with the educational organisation’s own objectives
providing the basis for review rather than an externally prescribed set of standards. This is a ‘quality audit’
approach,
Quality audit’ is defined as ‘a systematic and independent examination to determine
whether activities and related results comply with planned arrangements and whether
these arrangements are implemented effectively and are suitable to achieve objectives’
(Standards Australia & Standards New Zealand Joint Technical Committee QR/7 1994).
This definition has been adopted by AUQA as the foundation of its approach to audit.
(AUQA, 2009)
The test applied is the extent to which institutions are meeting their objectives and how they monitor and
improve their performance in relation to the dimensions of objectives, approach, deployment, results and
improvement or OADR. The process is one of a critical self-review as well as judgement against external
academic and professional points of reference,
“It is the responsibility of the auditee to devise a systematic process for evaluating its
objectives with respect to criteria which may include relevance, desirability, feasibility,
distinctiveness, and measurability … Audit panels do not investigate the absolute value of
these strategies but the extent to which they support the auditee in achieving its
objectives, including the ones related to internationalisation” (Stella and Liston, 2008: 1)
Two cycles of audits have been conducted since 2001. The first round cycle between 2001 and 2007, included
site visits of offshore campuses. The second round cycle began in 2008 with a focus on academic outcomes
and standards.
The AUQA approach to site auditing of transnational education involves sampling TNE sites based on seven
tests of:
• materiality – the quantum or scale of operations
• significance – that the institution sees the site as strategic, eg. discipline area, region, relationships
• risk management – high risk site
• risks to students – high risks
• other quality arrangements such as MoUs, local regional requirements
• necessity – do you need face-to-face data collection or can it be via a teleconference
• practicality – can it be done (Carmichael, 2009).
As at December 2008, AUQA had conducted visits to 127 partner/transnational campuses across South East
Asia, the Pacific, Africa and the Middle East. The process of conducting audits includes extensive data
collection from the offshore partner’s staff and students, agents and the local quality assurance agency. The
audit framework addresses seventeen areas of investigation rather than standards: Philosophy; Partner
selection; Contract/Agreement; Host country approvals; Governance; Research; Curriculum; Marketing and
promotion; Student standards; Language; Teaching; Assessment; Academic support; Pastoral support;
Community links; and Evaluation and review.
The AUQA audit approach included a focus on the theme of internationalisation and offshore delivery. The
findings against the theme of internationalisation from the Cycle 1 audits that
‘services to international students’ emerges as an area of commendation while ‘quality
assurance systems for international programs’ and ‘internationalization strategy’ emerge
as areas that need improvement. ‘Standards and quality of offshore teaching’ was high on
both Commendations and Recommendations, implying that audit panels have found both
areas of weaknesses as well as exemplary practices in this aspect (Stella, et al., 2008).
12

Areas that required more attention included: management of off-campus programs; monitoring offshore
partners; clear lines of responsibility and accountability; systems for review of transnational programs; internal
audit reporting of international arrangements; staff orientation; policies for entrance and advanced standing
and consistency in standards. Effective management of partnerships were characterised by: enrolment
decisions were made at the Australian institution; excellent materials as the basis of quality distance provision;
quality of support staff; professionalism of the offshore partner’s staff; all assessment is conducted by the
Australian institution; and there is explicit mechanisms for cross-mode and cross-location consistency in
admissions, curriculum, teaching and assessment (Stella, et al., 2008). Analysis of Cycle 1 outcomes also found
that:
• provider behaviour is influenced by commercial interests
• recent activity is less ad hoc than early growth in TNE; and non-viable or poor quality activities were
discontinued by the provider.
Findings from Cycle 2 audits to date are that:
• TNE activities are often run as a ‘commercial’ rather than ‘academic’ activities
• universities are increasingly using private corporate arms to manage TNE activities in a commercial
manner
• use of private corporate arms may tighten commercial risk management, but this may be at the cost
of potentially disenfranchised academic governance
• quality assurance arrangements for transnational activities range widely in effectiveness
• a university’s usual quality assurance system may not be enough for its transnational activities
• there is scope for more explicit standards in offshore education
• there is a shift in thinking away from Australian education provided overseas, to locally-relevant
education provided by an Australian university. That is, customising to the local requirements
• the relationship between customising provision and ‘comparability’ needs to be clearer
• unfavourable audit reports may affect a university’s ability to recruit; but sensitivity to this concern
should not compromise audit responsibilities (Carmichael, 2009).
The fundamental difference between the AQTF 2007 approach to auditing a providers’ offshore delivery and
that of AUQA is that the latter process is guided by the providers’ approach to quality assurance rather than
compliance to standards and that there is a site visit involved in the process. Offshore data collection from a
range of sources including in-country regulators, local agents, students and in-country staff is also a feature
that strengthens the basis of the AUQA findings.
NSW TAFE model
In the past three months NSW TAFE has acted to strengthen its internal monitoring and review of offshore
delivery by public TAFE Institutes in NSW. This is in recognition of the risk that offshore provision poses to the
reputation of NSW public providers. The process commenced in August 2009 under instruction from the
Deputy Director General, NSW TAFE and Community Education. The approach consists of three stages,
• AQTF 2007 audit processes - Current processes for reviewing Institutes’ compliance against the AQTF
2007 by the State regulator (VETAB) will continue.
• Notification of intention to deliver offshore - All public providers who deliver offshore are required to
provide the details of the delivery to TAFE NSW. The Deputy Director General signs off on all offshore
contracts.
• Offshore Review Panel - TAFE NSW have established an Offshore Review Panel to focus on risk
identification and management, and continuous improvement. The work of the Review Panel is
consistent with that of the AQTF 2007, but does not duplicate it. The Panel comprises senior
practitioners, such as CEOs of TAFE Institutes who contribute their time as a collegiate contribution to
the NSW TAFE system. A risk template assists the Review Panel.
13

• The Review Panel conducts onsite review visits and prepares reports for the Deputy Director General.
TAFE NSW intends to review the offshore activities of eleven public TAFE Institutes by the end of
December 2009 (TAFE NSW, 2009).
The TAFE NSW approach recognises the inherent risks in offshore delivery. It addresses these risks through
existing arrangements for the AQTF 2007 together with an appraisal of institutes’ deployment of continuous
improvement processes by personnel with experience in senior management. It combines an ethicalprofessional
approach to accountability by experts and educational leaders with accountabilities associated
with compliance requirements of registration. It is both educative and cost efficient and addresses outcomes
as well as the processes that lead to them. The focus of the model is on system improvement, enhanced
reputation and confidence in the quality of training services provided to clients. The question is whether such
a model could provide guidance to a national system of offshore quality monitoring.
The lesson that can be learnt from this is that the regulatory body need not necessarily drive monitoring. A
professional association could provide oversight of an accreditation and quality assurance process, as is
discussed in the next section.
International examples
The United Kingdom is a key competitor in offshore delivery of training qualifications internationally. Table 3
outlines two approaches to registration and monitoring of offshore delivery in Scotland through the Scottish
Qualifications Authority and in England through the City and Guilds approach. Both examples address
monitoring and managing delivery of qualifications frameworks for vocational education and training in an
offshore location. One is concerned to represent the interests of government in managing a national
qualifications framework (SQA), the other is interested in managing commercial risks associated with a
corporate institutions’ qualifications framework.
The researchers were also referred to the Hong Kong and Malaysian systems. In Hong Kong registration
processes were directed to provision of non-local qualifications. The Malaysian approach was concerned with
providing an education hub to provide marketing and liaison services to member RTOs. Neither of these
approaches related to the challenges of protecting the reputation and implementation of a qualifications
framework or of a national education system.
Table 3
Approaches to quality assurance of qualifications frameworks.
Organisation Registration Quality assurance
Scottish
Qualifications
Authority
(SQA)
Approval to deliver Scottish
qualifications as a SQA Centre is
processed through the SQA. The SQA
requires Centres to notify it of all sites
of delivery and assessment, including
offshore sites.
Monitoring services through audit. The audit process
included provision for offshore site visits with costs of
the process charged to the provider.
The audit process is conducted against five areas or
‘statements of excellence’.
• Leadership and management
• A robust quality framework
• Administration and support
• Experience and ability to design and deliver
qualifications including assessment
• Methods of verification, which are required to be
the same at all sites.
In 2007/08 only 20 awarding bodies were audited,
seven for self-assessment (all are required to conduct
a self-assessment) and 75 centres for centre
monitoring (Scottish Qualifications Authority, 2009).
14

Organisation Registration Quality assurance
City and
Guilds
This is a UK provider of vocational
qualifications with over 8500 centres in
100 countries.
Registration is for two years against
four areas of operation
- management and
administrative systems
- physical and staff resources
- assessment
- quality assurance
An initial assessment is conducted for
registration to ensure that the
organisation has the overall systems in
place to deliver City and Guilds
qualifications.
Separate approvals are required for
qualifications, such as International
Vocational Qualifications (IVQs).
A separate compliance assessment is conducted at all
sites at which assessments or examinations are
undertaken. Reapplications are largely through desk
based procedure, but there is provision for offshore
site audits. A separate compliance assessment is
undertaken of ALL sites at which assessments or
examinations are undertaken.
Quality Inspectors are appointed to ensure
compliance regarding systems and quality assurance
rather than qualifications and assessments
requirements which are conducted separately.
External verifiers also examine specific resources
relevant to qualifications, such as staff qualifications
and expertise and physical resources.
All sites at which assessments/examinations are to be
conducted are visited to ensure compliance with the
approval criteria.
There is provision for unannounced visits to check
the conduct and integrity of City and Guilds
examinations (City and Guilds, 2009).
It is notable that both the public (SQA) and private agency (City and Guilds) approaches involved similar
processes. Each required member organisations to satisfy externally set benchmarks of performance. They
were both compliance-based approaches that were directed to ensuring that providers of the qualifications
provided quality services irrespective of the location of delivery. Each approach involved audit visits by
external auditors to offshore sites either on registration or during a re-registration process. Both models
examined a range of performance areas including administration, resourcing, assessment services and quality
assurance. The SQA approach included verification processes employed across sites as well as performance in
relation to ‘statements of excellence’. This model extends a compliance focus to concern with system
capability and improvement. These interests do not feature in the City and Guilds approach, as its registered
members are responsible for their own commercial risks.
The Scottish approach may also reflect recognition that compliance is not enough to assist in system
improvement. A system driven solely by compliance might provide policymakers with greater confidence that
they are intervening with a view to managing risks, but this may be naïve and is unlikely to lead to system
improvement. Merely monitoring practice does not necessarily lead to change in a positive sense. While
Skilbeck (1988) was referring to the perceived limitations of testing programs in the school sector, the
following statement may be extrapolated to describe the relationship between monitoring processes and
improvement. That is, the belief that,
if we weigh the pig often enough it will get fat, or if we count enough pigs they will
multiply themselves … *this+ gives us no clues as to how we might effect improvements in
the case or even what an improvement might consist of in any particular case (Skilbeck,
1988).
In summary, approaches to monitoring offshore delivery of qualifications frameworks exist, but they vary in
the strategies used. In the university sector the AUQA approach is based on quality assurance through
continuous improvement processes, although recent evaluation suggests that the model would be improved
through more compliance oriented elements (Carmichael, 2009). The recent offshore models examined
approach quality assurance through a compliance orientation. However, these approaches may benefit from
an interest in fostering continuous improvement to assist system capability rather than system control. It
seems that there needs to be a balanced approach to quality assurance that takes account of both dimensions
of compliance and improvement.
15

Silver, et al. (2008) summarised the major trends in quality assurance of transnational education as follows.
• the process of overseeing and regulating the development and operation of offshore programs by
universities/colleges has generally become more centralized and controlled.
• more aggressive risk management strategies with an emphasis on fewer but stronger partnerships in
a range of markets.
• AUQA has had a major impact on Australian universities [sic] activities offshore since its establishment
in 2000.
• balancing the quality and profit motives when operating offshore is a constant challenge for
universities/colleges.
• Having a quality system is a competitive necessity and is required as the cost of entry to the global
marketplace (p. 7)
The research by Silver, et al (2008) was primarily concerned with the higher education sector, but was also
concerned with research into good practice quality assurance in transnational education by community
colleges in the USA and a specific focus on an Australian multisector institution. It is relevant to transnational
activity by the VET sector.
16

METHODOLOG Y
The objective of this project was to provide a report and recommendations to the NQC and the International
VET Action Group about:
• current arrangements for quality assuring offshore delivery by Australian Registered Training
Organisations against the Australian Quality Training Framework (AQTF); and
• challenges encountered by providers when resolving the requirements of the AQTF with VET quality
systems in the countries of off-shore provision.
Research questions
The project investigated the following research questions:
• What are the current arrangements for quality assuring offshore delivery within (or against) the AQTF
2007?
• What challenges are encountered by providers in resolving AQTF 2007 requirements with VET quality
systems in countries of offshore provision?
• How is this affected by delivery of VET through foreign partner providers or franchisees?
• How might the VET sector benefit from the experiences of Higher Education in monitoring Higher
Education quality offshore?
• What are the possible models for quality assuring (or monitoring) offshore delivery?
• What is the preferred model for quality assuring (or monitoring) offshore delivery?
• What are the implications of the preferred model for costs, VET workforce development, equity
groups, implementation by providers and system wide implementation?
Data collection
The approach to data collection included:
• a review of related literature on offshore delivery, registration and quality assurance of providers;
previous research into Australian offshore context for delivering and assessing AQF qualifications
offshore
• Qualitative data collection through telephone and face-to-face interviews with key stakeholders
including national, state and territory training authorities and regulatory bodies, peak provider bodies
and a sample of public and private providers that deliver offshore VET in selected countries. The
questions posed during consultation are provided in Appendix A.
• Consultation forums with public and private providers in New South Wales and Victoria to test the
initial findings and preliminary model for monitoring offshore delivery of VET.
Details of the participants in consultation are provided in Appendix B. The sample of 101 respondents (Table 4)
included:
• Representatives of national regulatory bodies including the National Audit and Registration Authority
(NARA); the Australian Universities Quality Agency (AUQA); and Australian Education International
(AEI)
• Representatives of State and Territory training authorities and regulatory bodies in New South Wales,
Victoria, Queensland, South Australia, Western Australia and the Australian Capital Territory
• Peak provider bodies of TAFE Directors Australia and the Australian Council for Private Education and
Training
17

Table 4
Stakeholder
group
Sample groups by location of the head office
ACT NSW Vic Qld SA WA National Total
Public provider 2 15 2 1 1 21
Private provider
- Interviews
Private provider
– consultation
forums
Government
department /
regulatory body
Peak provider
body
2 4 6
27 20 47
2 1 2 4 2 1 9 21
1 5 6
TOTAL 2 30 39 6 3 6 14 101
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DISCUSSION OF FINDIN GS
The consultation process was conducted in two phases. Phase One involved interviews with representatives of
public and private providers offering VET qualifications offshore, state regulators and officers from state and
commonwealth government departments. Interviews were also held with provider professional associations
and the Australian Universities Qualifications Authority (AUQA). Consultation forums were conducted with
public and private providers in Phase Two. These forums explored the general findings regarding the
challenges that providers face when delivering offshore. They also provided an opportunity to test the
preliminary models for monitoring offshore delivery with providers. The following discussion outlines the
issues identified during consultation.
Issues from the perspective of industry
Qualifications provide common skills currency for the system. They offer a measure of comparability of skills
no matter where people are trained. This is the fundamental premise that underpins the notion of recognition
in the Australian vocational education and training system. Fundamental to the quality of the system is that
Australian industry can have confidence that training offshore is equivalent to that provided onshore and not a
lesser qualification. Graduates of Australian qualifications gained through offshore training should be equally
prepared to graduates and workers onshore.
Issues from the regulators’ perspective.
Representatives of state and territory departments and regulatory bodies were consulted. They provided
consistent viewpoints on the nature of offshore delivery, its size and associated risks along with their
approaches to monitoring offshore training and assessment services.
Small market
State and territory representatives highlighted the small scale of the offshore market. Each jurisdiction
identified very small numbers of providers who have notified regulators that they operate offshore. This is
contrary to unpublished data collected by ACPET from their membership (Quirk, 2009), which suggest that the
market for private providers is high at approximately 40,000 offshore students and growing. The final report of
this survey has not been released publicly. Regulators also highlighted that Australian providers access a small
share of the offshore market in terms of the proportion of the potential number of students, particularly in
China. However, the actual extent of offshore provision is unknown. The National Centre for Vocational
Education Research (NCVER) collects data on public providers’ delivery offshore, but there is no data on
private providers other than that collected through voluntary submissions by ACPET members, in the surveys
conducted in Western Australia and South Australia.
Current arrangements
As described in the literature review, RTOs are required to notify the relevant regulatory authority of their
intention to operate offshore on initial registration or as required under the AQTF for significant changes to
their operation. In NSW those RTOs that indicate their intention to undertake offshore delivery are
interviewed to assist understanding of the nature of the activity.
Monitoring of offshore delivery occurs through the current provisions of the AQTF 2007 as part of the normal
audit process. None of the regulatory authorities conducts off-shore audits as part of their audit program. The
Victorian Qualifications and Registration Authority (VRQA) stated that there was no legislated authority for it
to conduct audits in offshore contexts. The VRQA also questioned whether it was appropriate to conduct an
audit within another authority’s jurisdiction, particularly in offshore contexts. Other authorities believed that
there were no barriers to offshore auditing of RTOs registered within their jurisdictions other than the costs.
For example, NARA has specific direction to conduct offshore audits as part of its Charter.
NSW TAFE recently introduced a quality assurance process for TAFE Institutes that included offshore site
audits, which is described in the literature review. This process includes offshore site audits for all TAFE
19

institutes delivering offshore. It is conducted separately from the processes implemented by the NSW
regulatory authority.
Respondents stated that AusLIST provides a potentially valuable resource for informing the market, but it has
been undersubscribed by VET providers. They believed that the reasons for providers not registering on
AusLIST related to the limited incentives to do so. Disincentives may arise if those registered are singled out for
scrutiny by onshore and offshore regulatory bodies.
Each of the respondents recognized that it is difficult to manage a risk which is unknown. They believed that
increased risk will accompany growth in offshore delivery of Australian qualifications. This risk is difficult to
manage under the current approaches to monitoring offshore delivery as current approaches assess only the
stated intention of providers (where that is known), not their deployment of policies and procedures, which is
different to arrangements for onshore provision. However, based on the current evidence available to them
and current approaches to risk management, there were no reports of evidence of a need for concern
regarding offshore delivery other than some isolated instances where investigation had not supported
complaints.
Preferred approaches and attributes of an approach to regulation
Regulators agreed that the following aspects would be relevant to monitoring offshore delivery:
• Risk management: A risk management approach was stated to be preferable to ‘hairy chested’
compliance approaches. Risk management provided more efficient direction of resources as well as
minimizing the costs and intrusion of compliance to providers’ businesses.
• Improved data: Improved data collection was seen to be essential to improved understanding of the
nature of offshore delivery, to identifying risks and implementing a risk management approach.
However, current data collections were largely voluntary as in South Australia or restricted to data
provided by public institutes as in the NCVER collection. The full quantum of offshore activity by
Australian registered providers was unknown and was unlikely to be identified within the current
Quality Indicators data at a level that would assist in monitoring and managing risks.
• Provider capability: Regulators believed that providers delivering offshore should have a
demonstrated history of provision onshore.
• Minimal burden: Any approach taken should be within existing arrangements rather than added on. It
should not add unreasonable burden to regulation and costs for providers.
• Cultural awareness: Cultural sensitivity and liaison with offshore authorities is important if the
approach involved offshore site audits.
• Negotiated approach: The AUQA model of advice to audit teams along with the negotiated peer
appraisal provide useful models for the VET sector.
Issues from the providers’ perspective.
For providers the main issues related to their motivation for offshore delivery, costs, quality and competition.
Motivation.
Both public and private providers had a variety of motivations for engaging in the offshore delivery of VET
programs. Some viewed offshore delivery as the first step in an international student pathway to onshore
delivery. Typically the provider would offer a VET Diploma of Business (or part thereof) with the intention of
recruiting students for full fee paying places onshore. They intended to cover their offshore delivery costs but
did not have high expectations of offshore commercial margins. They expected to gain the commercial return
when the student came onshore. Other providers had clear commercial aims and targets in their offshore
delivery, the largest provider indicating that these commercial margins were only achievable through
economies of scale. Another (public) provider indicated that it was clearly focused on commercial margins so
that it could better service their disadvantaged resident students onshore. Some larger experienced providers
have also been motivated by the desire to win offshore VET training contracts, either those funded by
Australian Government aid agencies and/or Government or industries offshore.
20

Cost Considerations.
Whatever their motivation, all providers were unanimous in stating that the provision of offshore VET
programs was a costly enterprise in all of its phases: preparation, partner engagement, project management,
course delivery and assessment. Those providers who had been operating for a considerable time offshore
indicated that the costs and drain on onshore resources/capacity are frequently underestimated. Their
capacity to recoup costs and deliver a commercial margin is also influenced by local policy and economic
situations. For example China’s recent cap on charges for foreign delivery and its policy to mandate that
Australian teacher/trainers must deliver 30% of course content have had a significant impact on delivery costs.
This is particularly significant as China is the location of over 60% of known Australian VET offshore delivery.
Several experienced providers commented on their need to constantly balance the need to keep costs down
while not compromising on the quality of their delivery.
Quality and competition.
All providers were unanimous in their view that ensuring their offshore delivery met or exceeded AQTF
standards was a primary consideration. They are acutely aware of the highly competitive offshore
environment and are aware that offshore governments and educational bureaucracies, and global commercial
companies are ‘shopping around’ for what they consider to be the best international vocational training
credentials they can purchase for their country and/ or workforce. Providers noted that currently the UK and
Canada are strong and growing competitors. Providers are therefore acutely aware that the quality of the
Australian VET qualification must be maintained and enhanced or it will not be a qualification of choice in an
increasingly competitive global environment.
Provider Approaches to Quality Assurance
Challenge and Risk
Providers have learnt from past experience that offshore delivery, particularly when delivered by partners,
presents special challenges in comparison to onshore delivery where they have direct management control of
both delivery inputs and outputs. Several providers also commented on the unfavourable reception they are
experiencing offshore as a consequence of recent issues surrounding the quality of VET provision to onshore
international students. It was stated that some contracts for offshore delivery are now at risk or have been
cancelled. The offshore provider’s need to counter negative publicity, to protect their reputation and that of
Australian VET credentials and clearly demonstrate quality has become more urgent.
Monitoring Quality
Subsequently the larger and most experienced providers are investing more not less effort in their own
offshore quality assurance measures. They are doing this in a variety of ways. Their approaches appear to be
strongly influenced by commercial imperatives and by their past experience, rather than by any external
regulatory drivers. While in the past some providers seem to have regarded offshore provision as a separate
arm of their business, there is a growing awareness that there is a strong correlation between the quality of
what they deliver onshore with that delivered offshore. In organisational terms many of the larger providers
are therefore taking a more holistic and non geographical approach to quality assurance, often seeking to
replicate their onshore quality assurance practices offshore. For example, many larger providers are now
routinely conducting offshore on-site quality audits as part of their internal audit of AQTF compliance. They
acknowledge that this approach carries with it significant costs.
As a result of the internal audits and of the growing experience and expertise amongst providers, it is evident
that a significant number of providers are constantly reviewing their offshore delivery practices. These reviews
are not only of activities directly involved in teaching and learning, but also include reviews of partner
relationships, contracts for partner delivery, project management, information/data management,
intercultural communication and offshore policy contexts. These reviews are seen as a total organisation wide
approach to continuous improvement in business operations and are not necessarily restricted to reaching
base level compliance with the AQTF requirements.
21

Steps in developing and delivering quality offshore VET delivery.
Providers are unpacking, interrogating and seeking to improve they way in which they address each step in the
complex business of delivering quality VET programs offshore. The steps outlined below (Figure 4) are a
summary and synthesis of information gathered from a number of large and experienced providers. They
describe the challenges of offshore delivery, which in turn become the risks to providers and the system.
Ultimately, effective management of these risks provides examples of good practice for other providers to
draw on and a basis for a risk management approach to monitoring offshore VET delivery.
Figure 4
17 challenges: Risks to good practice
Exit strategy
Quality assurance
17. Monitoring, review &
continuous improvement
Preparation
6. Strategic fit/ Business
planning
7. Understanding in country
laws & regulations
8. Partner choice
9. Detailed partner contracts
10. Developing exit
Assessment
15. Assessment standards &
moderation
16. Certification
Exit strategy
Delivery
6. Appropriate offshore
delivery models
7. Quality of offshore
facilities
8. Teacher/trainer skills &
qualifications
9. Student destination &
selection
10. English language
competency
11. Contextualisation of VET
programs
12. Learning resources
13. Student support
14. Educational leadership,
coordination & support
1. Strategic fit/business planning.
The decision as to what to deliver and where is the primary and most important decision for the provider.
While in the past providers may have been inclined to embrace offshore opportunities as they presented
themselves, experience has taught them that a more targeted and considered approach to opportunities is
appropriate. This more considered approach takes into account financial considerations, in particular,
assessment of the ‘true’ cost of offshore delivery. This is consistent with their more ‘holistic’ approach to
planning offshore delivery. In the past this delivery may have been regarded as a project(s) separate from the
core business of the provider but, as the level of activity and has grown, and due to the lessons learnt from
experience, providers are now more likely to be examining their offshore activity in the light of their total
institute/ organisation strategic and business directions and/or including global delivery as one of their core
goals.
2. Understanding in-country laws and regulations.
Assessing and understanding the particular legislative, regulatory and policy environment of the countries to
receive the delivery of Australian VET qualifications is a necessary, complex and time consuming precursor to
planning VET delivery. The environments vary greatly between countries and in larger countries, eg. in China,
there is a complex set of national and provincial laws which impact on both the Australian provider and local
22

partner institutions. In the Middle East several countries have sophisticated regulatory regimes for educational
quality assurance which equal or surpass Australian requirements. A culturally respectful understanding of
offshore requirements and, in particular, an assessment of how these impact on AQTF requirements, is
essential.
3. Partner choice.
Almost all offshore delivery is done via offshore partner organisations. The offshore partners might be public
or private universities, vocational colleges, commercial vocational providers or individuals. The nature of the
partnership and the degree of autonomy the partner has in delivery of the Australian qualification varies
enormously. Whatever the arrangement, Australian providers are increasingly aware that their choice of
partner is a crucial determinant in the quality of VET delivery. As a result, experienced providers routinely
review and evaluate their existing partner arrangements and are tightening their due diligence checks of
prospective new partners.
4. Detailed partner contracts.
Providers see negotiating a detailed and mutually understood contract as an important ‘platform’ for delivery.
Most providers are reviewing their current and proposed contracts to make them more specific. Providers
agree that more detailed contracts are required, with several developing a ‘stem plus annexure’ contract
model; the annexure specifically relating to AQTF requirements. In addition, to ensure that contracts are
mutually understood and agreed, contracts are being prepared in bilingual formats.
5. Designing exit strategies
A decision to exit the proposed project if there is not a good strategic fit and/or if it is not financially viable is
an important part of the planning process. The result is a more planned and considered approach to what
providers will, and importantly, will not deliver offshore now and in the future.
Providers also have an ethical / moral responsibility to manage student interests, including through phased
withdrawal, in the event that they decide to withdraw from offshore delivery after a period of operation.
Planning for disengagement should commence at the earliest possible stage in the project to ensure that it is
well managed from the perspective of the student as well as protection of a provider’s reputation.
6. Appropriate offshore delivery models.
Providers have learned that the choice of program delivery model requires careful consideration which takes
into account: the capacity of the host partner, the nature of facilities including IT, the language levels of
students, the skills of teacher/trainers, and the preferred learning style of students. Successful Australian
delivery models cannot simply be exported to offshore environments.
7. Quality of offshore facilities.
Providers have learned that a careful evaluation of learning facilities is required prior to delivery to determine
if the offshore facilities meet AQTF requirements. While it is acknowledged that offshore facilities may not be
identical to those in Australia, it is important that AQTF standards are met. This is often challenging,
particularly in developing countries and particularly in certain discipline areas such hospitality and trade
training.
8. Teacher/ trainer skills and qualifications.
As in onshore delivery, offshore providers have realised that the quality of VET teaching has perhaps the most
significant impact on student retention and results. This realisation has presented a major challenge for
providers. Partners undertake most delivery, many of the partners employ local staff who are highly qualified
in their home country. In order to meet AQTF requirements these staff must have the Certificate IV in TAA or
demonstrate equivalence in their teaching qualifications. Many staff therefore have to undergo additional
training, and in particular gain a sound understanding of competency based assessment. In turn Australian
staff who have Certificate IV TAA may lack the intercultural competencies to undertake offshore teaching,
23

course coordination or assessment roles. In both circumstances, ensuring that all teaching staff involved in
offshore delivery have the required skill set involves considerable time and financial investment.
9. Student destination and selection.
Prerequisite requirements for entry into most VET programs are clearly specified. In onshore delivery it is
relatively simple for providers to ensure that students selected for programs meet the entry requirements. In
almost all offshore delivery the partner organisations select students. Monitoring offshore adherence to
student selection guidelines is more difficult but it is a crucial element in determining quality delivery and
positive student outcomes. Providers have realised the need for clear, detailed documentation of entry
requirements and the need to train offshore staff in their application.
Students’ intentions are also an important consideration when designing course content and delivery modes.
That is, whether they are undertaking their VET qualification as a pathway to higher education or whether they
are seeking an Australian VET qualification for local employment.
10. English language competency.
As for student selection most providers have documented English language entry requirements for
international students but as can be seen above, the application of these requirements is challenging to
monitor. In addition the language skills of teaching staff are also challenging to monitor. While it is acceptable
that program content can be delivered in a bilingual mode, it is important that adequate English Language
levels are present or developed, particularly if the Australian VET qualification is issued as to the individual as
having the AQTF competencies within an English language framework.
11. Contextualisation of VET Programs.
Providers are aware that they must ensure that contextualisation of programs meets AQTF requirements while
also striving to meet:
• the cultural, economic and social environments relevant to the country of delivery
• group and individual learner needs
• the work requirements of the program taking into account the working environments prevalent in the
country of delivery.
Providers note that achieving the balance between in-country relevance and AQTF compliance is often
difficult.
12. Learning Resources.
Most providers see the provision of high quality learning resources as an essential element in maintaining the
quality of their delivery. Over time many providers have invested considerable effort and resources in further
developing on-shore learning resources to meet the needs of offshore students. These resources are much
valued and used by offshore teachers and provide the Australian provider with a degree of ‘control’ over the
content of the delivery of the VET training packages.
13. Student Support.
As in any VET learning situation, it is common that a number of students will require additional support to
achieve positive results. In the offshore environment, additional ongoing support in English language is also
often required. Providers report that cultural norms often mean that students do not want to ‘lose face’ by
admitting their needs. If support is not carefully tailored and provided in culturally sensitive ways, there is a
risk that retention rates, completion rates and the integrity of the VET credential are compromised.
14. Educational Leadership, Coordination and Support.
Providers have learnt that the educational leadership provided to onshore teachers/trainers by way of course
coordination, peer meetings and professional development is also made available to offshore
teachers/trainers. Providers have realised that the quality of offshore delivery can be compromised if
24

inexperienced teachers are left to work in isolation. In addressing this risk some providers have recently
implemented staffing arrangements to ensure that onshore course coordinators/leaders also have an offshore
leadership role. In this way they are hoping to achieve a more seamless approach to delivery, regardless of its
geographic location.
15. Assessment Standards and Moderation.
Providers note that it is vital that VET assessment methodology is clearly understood by all offshore partner
staff. This is challenging because many staff are unfamiliar with the philosophy and practice of competency
based assessment. Some experienced providers recently acknowledged the need for ongoing professional
development. They have also seen the need to strengthen their testing controls and moderation practices to
ensure that standards are consistent across on- and offshore locations. Anecdotal reports were provided at a
range of forums that some offshore providers are using assessment-only modes of delivery as a means of
avoiding scrutiny through the audit process. This practise would pose a significant risk to the reputation of AQF
qualifications.
16. Certification.
There are associated risks of poorly managed or even fraudulent activity related to issuing certificates.
Providers realise that the integrity of VET credentials issued under their name has the greatest influence on
their reputation and that of the Australian VET system. It is a major risk which can best be mitigated by
ensuring strict onshore control of all credentials which are issued in their name offshore. Several providers, via
their own internal reviews/audits have taken steps to tighten their processes for certification, including
ensuring that the language of assessment is noted on the documentation.
17. Monitoring, Review and Continuous Improvement.
Most large and experienced providers interviewed are working to ensure that offshore arrangements and
programs are subject to the same internal review and continuous improvement policies and practices which
apply to onshore delivery. This occurs in a variety of ways but most frequently within the framework of the
provider’s quality management and internal audit processes. They realise that each of the steps outlined
above represents a delivery challenge and a risk. They realise too that making a ‘graceful and ethical exit’ can
be the consequence of a rigorous review of an offshore program. In the absence of the kind of safety nets
which protect onshore students, it is very important that the provider makes arrangements to ‘teach out’
programs in ways which protect the interests of both students and delivery partners. Their quality assurance
processes therefore seek to address each of these risk elements. The degree to which face-to-face offshore
audits are conducted depends on a variety of factors including provider size and capacity, quantum and
location of offshore provision, internal assessment of risk against AQTF and other internal quality indicators.
The tension between cost factors, AQTF compliance and continuous improvement is a common and ever
present issue. Whatever the model and frequency of offshore monitoring/ audits, it is universally
acknowledged that their internal auditors must have skills in cultural understanding and knowledge of the
particular offshore contexts that they are reviewing. Most have invested in additional training for their internal
auditors. Providers universally commented on the negative consequences of culturally insensitive audits on
offshore partnership and delivery arrangements.
While the description of the 17 steps above suggests a linear process, as represented in the diagram below
(Figure 2) the providers view the process as a program delivery and continuous improvement cycle. In
unpacking and addressing each part of the delivery/quality improvement cycle experienced providers have
provided some valuable insights into what might constitute good practice and also what might guide the
development of an offshore quality monitoring system.
Provider Concerns Regarding Offshore Quality Monitoring.
i. Culturally Sensitive Auditing
From the above it is clear that many providers are investing significant time and resources in quality assurance
and continuous improvement. It is therefore understandable that they expressed a fear that an externally
imposed system of offshore quality monitoring may impede and/or undermine their current efforts. As the
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overwhelming majority of external offshore auditing is currently conducted via desktop audits, this is not a
major current fear. If however AQTF compliance offshore is to be conducted via on site audits, there are
concerns that external auditors will have little understanding of the political, economic, social, commercial and
cultural context within which the provider is delivering. There is therefore a fear that external audits will not
help but harm both the business and the partner relationships, which have been carefully built over a period
of time.
ii.
Risk assessment/continuous improvement
Providers are aware that the 2007 AQTF Guidelines clearly outline a strong focus on continuous improvement
as a focus of external AQTF audit activity. A majority of providers commented that despite this, in their recent
experience of onshore audits, there was still in practice, a focus on monitoring and measuring compliance.
Some providers asserted that if this ‘forensic’ audit approach was to be exported to offshore locations it would
not be helpful. Others commented that a ‘one size fits all’ audit approach was not appropriate and that a more
detailed, accurate informed approach to risk assessment should be the primary determinant of onsite offshore
audits. It was asserted that those providers who are investing in their own offshore audits and quality
improvement measures should be acknowledged for this effort in the risk assessment process.
iii.
Less not more.
Every provider interviewed complained of the burdensome level of external reporting that they currently have
to undertake to meet the requirements of funding bodies and the AQTF. Private providers in particular
stressed that they feel overwhelmed and overburdened by reporting requirements, particularly those
associated with AQTF compliance. They strongly requested that any external auditing that might apply to their
offshore activity should strive to minimise the impost on providers. All providers were also concerned with the
negative impact that an external Australian audit would have on their delivery partners in offshore locations.
Dual sector providers who have experienced on-site AQUA audits in offshore locations, stressed that if not
properly managed and supported by the provider, external audits can be both confusing and confronting for
the foreign partners. This partner confusion may well be increased if AQTF audits were to be undertaken by
seven different (state/territory based) authorities who might have differing interpretations and emphasis. A
streamlined, national approach which avoids duplication of provider/partner effort is therefore likely to be
preferred.
iv.
Portability, equivalence and global relevance of AQTF qualifications.
A significant number of providers questioned the ‘portability’ and ‘global relevance’ of AQTF qualifications.
Some suggested that parts of the framework and training package competencies were very ‘Australian centric’
and not relevant to offshore work environments. OHS competencies were frequently quoted as an example of
lack of relevance outside Australia. The requirement that all offshore trainers have Cert IV in TAA was also
seen to be ‘insulting’ to many offshore teaching professionals who were very well qualified in their own
countries.
A related issue was the degree to which the VET qualification could be contextualised to better meet offshore
requirements while still being AQTF compliant. While contextualisation is specified in the AQTF guidelines; on
the ground providers are grappling with the need to balance offshore student needs and still maintain
compliance. The issue of ‘equivalence’ of AQTF qualifications was raised in this context with most providers
indicating that balancing the requirement to be compliant and yet deliver a locally useful qualification was
problematic. One major provider suggested that ‘comparability’ of qualifications would be a much more useful
approach than that of ‘equivalence’.
One major private provider took a broader and stronger position on this issue. The provider agreed on the
issue of the Australian centric nature of VET qualifications and compared them unfavourably to more globally
portable qualifications offered by the UK via City and Guilds. It was argued that the latter were better designed
to be a globally recognised and relevant qualification than was the AQTF. As workers are increasingly
peripatetic there is a growing demand for portable, international vocational qualifications. It was also argued
that perhaps two qualifications should be developed within the AQTF; one for those who intended to work in
Australia and another international qualification for those who were destined to work in their home countries
or who were destined to join the global, peripatetic work force.
26

In contrast those providers who were delivering VET programs to students who were on pathways to
Australian onshore higher education were understandably less concerned with the ‘Australian centric’ nature
of VET qualifications.
Clearly the providers’ viewpoint on this issue is influenced by the motivations and vocational/ educational
destination of their offshore students.
A summary of major themes/issues from the Consultations
In summary, the major themes identified during consultation were: the limited knowledge of the offshore
market for regulators and for the market; there is no offshore auditing; there is no common view of the
regulator’s role in monitoring offshore VET; and experienced providers recognise risks and address them, they
would prefer a process that is not onerous and recognises their efforts.
• No state or national authority has accurate and comprehensive national and state data in regard to
the quantum, location and nature of VET offshore delivery. State and national regulatory authorities
collect data only if it is relevant to a particular audit scheduled in a given year. Public providers submit
data to NCVER on request and in two states (NSW and WA), public providers are required to provide
data to their state bureaucracies. Apart from a voluntary submission to a member organisation
(ACPET), private providers do not submit data unless it is part of a scheduled AQTF audit.
• There is no state or national onsite monitoring/auditing of offshore VET provision except in a very
small number of dual sector institutions that undergo offsite AQTF monitoring as part of their AUQA
audit. Offshore quality is currently judged via desktop audit.
• Regulatory authorities do not have a unanimous view regarding their mandated role in monitoring
offshore activity. They are however unanimous in their view that they do not have the resources for
offshore auditing. They are also unanimous in stating that a risk based approach is preferable to a
routine compliance approach and that the AUQA focus on self assessment and continuous
improvement was a useful approach for offshore monitoring.
• The offshore market has no single point of information that might guide their assessment of the
quality of Australian VET providers. While AusLIST was established to provide this service, it is
voluntary and while, widely used by Australian universities, very few VET providers are listed.
• Experienced public and private providers delivering offshore are acutely aware of the risks and
challenges involved. Experienced public providers are investing heavily in their own internal quality
monitoring and improvement systems that are closely aligned to AQTF requirements. Large
networked global and badged private providers also have robust internal quality systems. Both public
and private providers are driven by commercial and reputational imperatives.
• Providers who are investing heavily in quality monitoring/improvement want to be acknowledged for
this effort and do not want an onerous, burdensome additional layer of monitoring which requires
duplication of effort and more resources. Providers also fear the negative business consequences of
culturally insensitive external audits.
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THE PROPOSE D MODEL
The National policy context
The current policy context for VET is one of change to a more national system of tertiary education in which
VET is more closely aligned to the higher education sector and regulation is more centralised at a national
level. The direction to national reform in the VET sector was outlined in the outcomes of the April meeting of
the Council of Australian Governments (COAG), which
“endorsed the need for stronger and more cohesive national regulatory arrangements for
Vocational Education and Training (VET), including in-principle support for a national
regulatory body to oversee registration of providers and accreditation of VET
qualifications and courses. A report on operational models, including for a national
regulatory body, will be provided to COAG by September 2009” ( COAG, 2009).
The Commonwealth Government is also working to establish a national higher education quality agency to
provide greater integration of the regulation of tertiary education by 2013. The Tertiary Education Quality and
Standards Agency (TEQSA) will develop stronger quality assurance arrangements to protect the quality of the
Australian tertiary education system. It is directed to provide for greater consistency and efficiency in quality
assurance. TEQSA will be established in 2010. It’s role will include a focus on risks associated with operating in
particular geographic regions or particular programs of study. It is intended that TEQSA will oversight the
entire tertiary sector, including VET, from 2013 (DEEWR, 2009).
There are also changes in tools of regulation signalled in current reviews commissioned by DEEWR to examine
the AQTF along with the review of the Education Services for Overseas Students (ESOS) Act 2000 (DEEWR,
2009). A focus of the ESOS review on “nationally consistent quality, the quality of providers entering the
market and mechanisms for ongoing, monitoring, quality assurance and quality improvement of registered
providers” (p. 1) is consistent with the focus on the offshore market as undertaken in this project.
These reviews are progressing in parallel with this and other projects. They signal a change in the regulatory
environment and an opportunity for policymakers to ensure that there is greater consistency in the regulatory
system across sectors and to reduce duplication in arrangements for those providers who operate as multisector
providers to international students on- and off-shore. Any recommendations that emerge from this
project should be viewed in the broader context of reform. The researchers are also aware that
implementation of recommendations from this project will need to be viewed in terms of meeting immediate
needs as well as processes of transition to a national system of tertiary regulation by 2013. As stated below,
the proposed model is consistent with the TEQSA approach. The model is independent of which organisation is
to implement it. Whether the accrediting body is a government department, an industry body or a
professional association.
There are two dimensions to the proposed model for managing regulation of offshore VET activity – locus of
control and quality assurance of offshore delivery of training and assessment services for accredited Australian
qualifications.
Locus of control
This dimension is concerned about whether control of offshore VET activity is centralized within bureaucratic
mechanisms or decentralized to the market.
A centralized system assumes that it is possible to control offshore VET activity. A completely decentralized
market oriented system assumes that the market is aware of the quality of VET providers. Neither extremes of
the model are likely, as is discussed below.
Option B is the preferred option. It recognizes that it is not possible to be completely aware of all providers
operating offshore, particularly those who are likely to operate outside AQTF requirements. Option B
strengthens the potential for clients to choose quality providers, which is likely to influence providers’ interest
in being part of a quality system that can be monitored.
28

Option A:
Mandated
registration for all
offshore VET
Option B:
Information to the
market & voluntary
registration
Option C:
Provider-Client
relationship
CENTRAL AUTHORITY
MARKET
Option A – Mandated registration for all offshore VET
This option requires that in order to offer AQF qualifications offshore a provider must have gained approval
from a national or state authority to offer accredited AQF qualifications offshore. It would involve:
• mandated central accreditation of all providers who wish to offer AQF qualifications offshore
• assessment of their preparedness to offer AQF qualifications in a non-Australian context using criteria
such as demonstrated performance in delivery of quality training and assessment services prior to
registration for offshore delivery
• ongoing monitoring of provider accreditation.
Advantages
• this option provides a greater sense of control to those with responsibility for managing the
reputation and credibility of Australian education and training system and AQF qualifications
• the lines of accountability could be readily defined
• providers who did not have a demonstrated history of quality provision would be excluded from
registration for offshore delivery
Disadvantages
The model assumes that
• all providers who operate offshore can be known to an Australian authority
• it is possible to monitor all providers offering qualifications offshore, and
• the administrative burden and costs can be borne by providers and the system.
Option B – Information to the market and voluntary accreditation
This option is based on an assumption that clients’ choice of quality providers and the commercial motivation
of providers will influence their willingness to ensure quality training delivery and assessment services. The
option involves providers of offshore training ‘buying in’ to a regulated quality system that provides access to a
quality ‘badging’ process. It involves:
• recognising member providers against quality criteria and prior demonstrated delivery of quality
training and assessment services
• information to the market on which providers are approved as members
• ongoing membership to be contingent on demonstrated quality performance
• information to the market on provider performance in external and internal quality assurance
processes
• strong relationships between the registration body and host countries to ensure that they know that
the register exists and to ensure that it is seen to promote only quality RTOs.
• strong relationships with the regulatory bodies in host countries to gather intelligence on who is
offering Australian qualifications in these locations and whether there are any problems with their
operations.
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Advantages
• reputation in the market is a more powerful motivation for providers than accountability to regulators
• those who are most affected by the quality of training and assessment services (clients) have a basis
for selecting quality RTOs
• RTOs who operate outside the system are likely to be identified by competitors and regulatory bodies
in host countries
• RTOs who do not provide quality training and assessment services will be excluded from the positive
marketing opportunity that membership would provide. It is a ‘buyer beware’ approach
• that Australia is interested in protecting the quality of its qualifications will be seen as a positive by
clients, which would enhance the reputation of the Australian education and training system
• information to the market on the outcomes of internal and external quality assurance processes
rewards those providers that have invested in comprehensive quality assurance systems
• the approach depends on thorough quality assurance and sanctions so that it is perceived to be a
thorough and comprehensive approach.
Disadvantages
• The system depends on provider buy-in, which has not been a feature of the current AusLIST model,
as it pertains to VET providers.
• The system depends on registration being seen as a badge of quality by both providers and the
market.
Option C – Provider-client relationship
Option C is based on an assumption that providers will be motivated to ensure that their continued operation
in a competitive market is based on their clients’ positive perceptions of the quality of their training and
assessment services. The option is dependent on the strength of the contracts between the provider and their
clients.
Advantages
• training and assessment services are likely to be directed to client needs
• clients will go elsewhere if they are not satisfied with the training and assessment services provided
by the RTO
• less burden and cost to providers and the system
• commercial-in-confidence information is protected, because information is not in the public domain.
Disadvantages
• there are no mechanisms to ensure that training and assessment services reflect AQTF requirements
• clients and host countries may be suspicious of an education and training system that is not
interested in checking the quality of its ‘badge’ as represented by the AQF qualifications
• assessment of performance assumes that the client knows what to expect from the provider and
receives information on their prior performance.
• dissatisfied clients are not likely to choose to undertake further Australian qualifications, which would
represent a loss of market to international competitors and a cost to the reputation of the AQF and
commercial interests of all Australian offshore providers.
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The preferred option is Option B as per the following set of decision items:
Is there risk in
offshore delivery?
Yes
Is a provider-based
quality assurance
system sufficient to
manage the risk?
No
Then there is a need for some form of control/regulation
That leaves the choice of model between control by Option A Central authority or Option B Information to the
market and voluntary accreditation. The discussion above suggests that Option B provides a more workable
option that is more likely to gain ‘buy in’ from those outside the system that provide the greatest risk to
system reputation.
Given the anticipated changes to national regulation of a VET system (via TEQSA by 2013) it is assumed that
the operation of the model and subsequent quality monitoring would also operate through a national body. As
stated above, the national body could be a government department, an industry body or a professional body.
Quality monitoring
This dimension is concerned with how the quality of offshore delivery of AQF qualifications is monitored and
assured. The approach to quality under the current AQTF 2007 is based on quality assurance rather than
‘quality control’, because in reality it is not possible to absolutely control quality of delivery and control
approaches can constrain innovative good practice. The system can only ensure that appropriate processes
that lead to quality outcomes are in place for those providers registered to offer AQF qualifications on- or
offshore.
Option A:
Mandated regular
audits of all providers
Option B:
Risk based quality
assurance by
accrediting body
Option C:
Providers’ continuous
improvement
processes
COMPLIANCE
CONTINUOUS IMPROVEMENT
The options range from quality assurance of all activities by all providers (Option A) to reliance on the
processes that providers have in place to ensure continuous improvement as a requirement of their
registration (Option C). Option B Risk based quality assurance is the preferred model. It is more efficient and
does not add unreasonable burden to providers’ operations. It is driven by the power of the market to
influence provider behaviour and efficient, risk-based approaches to quality assurance.
Option A – Mandated, regular audits of all providers of offshore training and
assessment services.
Under this option all providers of offshore delivery would be audited regularly. The audits would include
detailed consideration of their offshore training and assessment services. The audits would automatically
occur within existing AQTF 2007 registration requirements, but could also include additional audits as
determined by the registering body. This option involves:
31

• application of existing AQTF 2007 requirements for registration and the associated auditing program
on registration, within 12 months of registration and prior to re-registration. That is, at least once in a
registration period. It would apply to all providers of offshore training and assessment services
irrespective of the nature and scope of their activity
• auditing the deployment of stated policies offshore is a feature of the process
• providers notify the registration authorities that they intend to deliver training and assessment
services offshore
• thorough professional development for auditors to ensure that they are sensitive to the offshore
cultural, educational and regulatory environment.
Advantages
• registration bodies would assume that they have greater control over compliance to standards and
the opportunity to identify RTOs that are not delivering quality services
• registration bodies would develop a stronger understanding of the nature and extent of offshore VET
delivery and assessment to assist in managing potential risks.
Disadvantages
• there may be little reason to be confident that a compliance approach to all providers will ensure that
only quality RTOs will operate offshore. It is possible that there will be providers that operate offshore
that are not known to regulators. The approach may not expand the scope of existing approaches and
may not in reality address the providers that pose the greatest risk to system reputation and the
quality of services to clients
• this would involve ‘heavy handed’ auditing processes directed to compliance rather than continuous
improvement. A compliance focus is less likely to influence actual practice than is a continuous
improvement focus
• it adds a burden of compliance that replicates and magnifies existing quality monitoring processes
associated with the AQTF 2007, providers’ existing quality assurance arrangements such as ISO 9001
registration, registration for delivering English language qualifications and quality assurance
associated with membership of franchising arrangements for some RTOs
• it is not ‘risk sensitive’ and is extremely resource intensive. It would come at considerable expense to
the system and to providers irrespective of the size and nature of their activities.
Option B – Risk based quality assurance by the registering body
This option is based on managing quality through a system of determining which areas of delivery and
assessment services are likely to pose the most risk to the reputation of the education and training system. It
involves:
• annual national data collection from all public and private providers regarding programs, enrolments
and location of offshore delivery to form the basis of an evidence-based risk assessment process
• initial enhanced risk assessment using the data collection as well as data from quality indicators and
information received from the host countries
• offshore site visits to all high risk providers and identified providers as per enhanced risk guidelines
• ongoing registration is dependent on performance.
Advantages
• the approach is consistent with the existing AQTF arrangements, but makes offshore delivery a more
explicit and targeted area for risk assessment
32

• it involves assessment of the deployment of providers’ quality assurance approaches rather than just
their intentions
• the approach is more resource efficient than Option A as only high risk providers of offshore training
and assessment services are subject to audit
• providers’ existing quality assurance processes may become a feature of the audit process in terms of
selection of candidates for audit. This rewards providers that have comprehensive quality assurance
systems.
Disadvantages
• offshore audits are costly to the system and potentially providers depending on funding arrangements
• it depends on appropriate criteria for identifying high, medium and low risk providers
• it depends on providers’ agreeing to submit data and answers to the survey.
Option C – Providers’ continuous improvement processes
This option is based on providers having comprehensive continuous improvement processes that lead to
better training and assessment services rather than external audit processes.
Advantages
• costs to providers are reduced
• improvements are directed to areas of relevance to the providers’ business model rather than
external compliance criteria
• there are incentives to providers to implement quality improvement processes.
Disadvantages
• it depends on providers implementing quality assurance processes
• the areas of improvement may be directed to areas of relevance to the providers’ business model
that are actually contrary to the interests of the AQF qualifications and compliance with the
requirements of the AQTF 2007
• the lack of external points of reference may reduce the quality of information taken into account in
quality assurance processes
• the improvements to providers’ activities may be from a very low base and not represent any form of
quality provision relative to ‘satisfactory’, let alone ‘good’ or ‘best’ practice
• relying on providers’ own practice is not likely to identify those providers who operate outside the
system and are driven solely by commercial rather than educational quality interests
• continuous improvement as the sole form of quality assurance is unlikely to contribute to clients’ or
host countries’ confidence in the overall quality and reputation of Australian qualifications and
provision of education and training services, and
• it is not consistent with quality assurance practices for onshore delivery.
Concluding comment
It should be clear that the preferred model for quality assurance, Option B Risk based quality assurance by the
registering authority, is consistent with the current risk management approach of the AQTF 2007. It does not
require anything in addition to what is already in place and available to regulators. In principle, the AQTF 2007
National guidelines for Risk Management provide for a focus on offshore delivery as part of a strategic
approach to risk management. However, the current practice of catering for offshore delivery through desktop
33

audit processes is insufficient to manage the risk that providers’ stated policies and procedures are not
deployed appropriately.
It is recognized that the implementation of the proposed options may impose an additional process that
focuses on off-shore delivery separately from the audit regimes that apply to providers’ onshore activity. That
is, as the offshore component is referred to a national body in addition to their state-based processes.
However, this is likely to be a short-term effect during the transition to a national system.
The notion of a voluntary accreditation process is also consistent with current AusLIST arrangements, except
that the emphasis on quality providers is strengthened through the extent to which demonstrated quality
performance is a requirement for membership. This can only be achieved through publication of performance
results, which have a successful precedent as demonstrated through the AUQA model.
The following section describes six elements of the model based on Option B. Provider responses to the
elements are also included. It is also important to note that feedback from DEEWR officials who are charged
with establishing the new national tertiary regulatory model (TEQSA), indicates that the six elements are in
agreement with the philosophy and intent of the reform of the national higher education regulatory system in
the first instance. This work will no doubt inform the VET component of the national regulatory system when it
is implemented (planned for 2013). As stated above, the model could be implemented through a government
department, an industry body or a professional body depending on the reading of the elements and whether
the weighting is toward compliance or professional capability.
34

ELEMENTS OF PROPOSE D MODEL: OPTION B
The six elements of the proposed model are described below (Figure 5). The responses from providers during
consultation are also outlined for each element in the model. Elements 2 to 4 are core to the model, while the
other three elements are seen to support the overall approach.
Figure 5
Proposed model: Option B
1. Improved information and badging to the offshore market – voluntary membership listing with strong
incentives to achieve listing (supporting element).
2. Compulsory national annual data collection from all public and private providers regarding programs,
enrolments and location of offshore delivery (central element).
3. Initial enhanced risk assessment – desktop audit based on enhanced/more detailed guidelines. High,
medium and low risk offshore providers identified (central element).
4. Detailed offshore site visits of high risk providers as per enhanced risk guidelines (central element).
• strong quality improvement focus, not only AQTF compliance
• supplemented by AEI/AUSTRADE offshore intelligence
• conducted by experienced specialist national audit team.
5. Results of offshore visits in public domain, as per current AUQA model (supporting element).
6. Membership / badging informed by site visit results, e.g. major noncompliance as a provider
(supporting element).
Element 1: Improved information to the offshore market
Element 1 is a strengthened, voluntary accreditation process for offshore delivery. It is intended to provide the
market with clear information on providers that are recognized as having satisfied specified quality assurance
processes. It would involve a national body establishing some clear criteria and assessing each voluntary
applicant against these, prior to accepting the provider for membership on a publicly available, quality
branded list. This will assist the market to make an informed choice of provider and to reward providers who
have implemented quality effective assurance processes. Element 1 recognizes that limited information is
available on who is delivering AQF qualifications offshore. It also recognizes the limited adoption of the current
AusLIST system by the VET sector.
Implications
• Providers continue to notify a national body of their planned offshore delivery. The national body has
the task of ensuring that the provider meets specified conditions of membership. Membership is
voluntary but the status and ‘badge’ of the authority is such that there are strong imperatives to join.
• Accredited providers are widely publicized via a website. The website is marketed widely as a badge
of VET quality in all countries where offshore delivery is occurring.
• A similar process is currently undertaken by AusLIST and is widely used by higher education.
35

Provider response
• There is no uniform provider view regarding the provision of authoritative information to the market
via a single point. A large number of private providers see this as an unnecessary intrusion into their
commercial marketing domain. Other providers have asserted that local accreditation in the offshore
location is more valuable than an Australian ‘badge’. Others believe that an accreditation/ badging
system could be effectively achieved by membership/ peer group organisations acting as an
accreditation body. Some public and private providers also doubt the value of the current AusLIST
model and they fear that publication of their activities will result in loss of business to competitors
and may also result in increased ‘external scrutiny’.
• A minority of public providers believe that the proposed accreditation process does not go far
enough. They propose mandatory registration for all intending offshore providers including very
rigorous registration requirements. This option, if adopted, would require significant changes to the
current regulatory environment. Others thought that this approach might encourage providers to
seek to operate outside the system and that these providers could present offshore VET provision
with its greatest reputation risk.
Element 2: Compulsory national annual data collection of all offshore
VET
Element 2 recognizes that it is difficult to monitor and regulate offshore activity when you do not know who is
providing offshore and whether there are any associated risks to their provision. This element involves a
compulsory annual national collection of all public and private providers to determine the nature and extent of
offshore delivery. It reflects recent state based initiatives undertaken in South Australia and Western Australia
to better understand the extent of offshore delivery and its potential risks.
Implications
• Data could be collected as part of an AVETMISS collection, or as part of the collection of the Quality
Indicators. The latter approach has an advantage in providing ‘outcomes data’ that is linked to the
nature of the offshore delivery.
• Data would be collected annually from all public and private providers. Data would not include
financial information. Data required would be based on existing data sets that are already required or
have been identified by recent research.
• Public providers currently provide information to NCVER. Private providers do not provide any
information to a central body, except to the state regulator if they are scheduled for an AQTF audit or
to their member organizations if requested.
• If mandated for both public and private providers, accurate and comprehensive data would be
available for the first time to government stakeholders and regulators. It would provide an enhanced
platform on which to identify potential risk, conduct research, analyze trends and to inform future
policy and practice.
Provider response
• Private providers generally supported compulsory annual data collection and suggested ways in which
this might be collected in a cost effective manner. The reservations expressed were not related to the
data collection as such, but to gaining reassurance that the data would be collected by a ‘neutral’
body, would be kept confidential and would not be released in the public domain in ways which
would be commercially harmful to individual providers.
• Public providers generally supported this element because they believe that non disclosure of
overseas delivery has the potential to condone questionable delivery, to compromise quality and
negatively affect the reputation of Australian VET providers overall. Some public providers raised
practical issues regarding the timing of data collection to fit the academic years offshore and the need
36

to clearly specify the use to which the data would be put. However, even for these providers there
was in principle support to collect information to identify the scope and nature of offshore delivery.
• Protocols regarding nondisclosure of sensitive information would need to be developed.
Element 3: Initial Enhanced Risk Assessment
While desktop audits of some offshore providers are conducted by state regulatory authorities Element 3
recognizes that, while many aspects of offshore delivery are mirrored by that in onshore delivery, there are
risks and operational challenges which are particular to offshore delivery. The way in which providers address
these challenges has a direct bearing on the quality of VET delivery and student outcomes. Element 3
therefore seeks to augment existing AQTF risk guidelines with a more detailed description of the
challenges/risks relating to offshore delivery. The aim is to produce a desktop tool that will more accurately
measure risk in offshore delivery.
Implications
• The 17 operational challenges outlined earlier in this report provide a basis on which to more closely
identify and calibrate offshore risk. These challenges have a great deal in common with the 17 facets
which AUQA currently use as a base for monitoring the quality of higher education delivered offshore.
The guidelines recently developed by TAFE NSW to guide the work of their offshore (non regulatory)
visits may also inform a uniform set of guidelines.
• The task of developing and implementing enhanced risk guidelines lends itself to a coordinated
national approach.
Provider response
• Private providers supported a risk based approach to monitoring quality but their views on the need
for enhanced risk guidelines were divided. A significant number believe that the current guidelines are
adequate but the assessment of these by regulators is flawed. They cited cases where private
providers had passed audits and subsequently failed to provide quality programs to students and thus
compromised the reputation of quality VET providers. Those who supported an enhanced risk
assessment were generally keen to ensure that ‘risk’ should encompass financial risk/ provider
viability as a primary assessment tool.
• Public providers, especially those with significant offshore experience, were in general agreement
with a more detailed assessment of offshore risk. They requested that the descriptors of high,
medium and low risk be clearly outlined. They also believed that the risk assessment should take into
account the national quality systems, which apply in the country of delivery and also acknowledge any
international quality accreditation held by the provider. This last point was endorsed by private
providers.
Element 4: Offshore site visits
The intent of this element is to ensure that, as an immediate priority, providers that are identified as being
high risk via an enhanced risk assessment undergo an offshore site visit as soon as possible after initial
assessment. Due to the nature of the risk it is likely that the focus of these offshore visits is one of examining
compliance to AQTF requirements. A program of risk based site visits is based on the understanding that,
however detailed a desk top audit might be, it cannot replace the judgments made by observing delivery first
hand and receiving information and feedback from offshore staff and students. Pending the availability of
resources it is suggested that, in addition, a sample of low/ medium risk providers are visited on a cyclical
basis. The focus of these visits should be to ‘value add’ to the internal quality improvement measures that the
provider is undertaking, should reward the provider and should provide useful system information on good
practice.
37

Implications
• This process will be new to most providers. A significant exception is NSW public offshore providers
who will be visited by an Offshore Review Panel (not associated with their state regulator) during
2009.
• Given that levels of offshore activity vary between states and given the need to ensure that offshore
auditors have specialist skills, are trained in cultural competencies and briefed on particular in country
environments, the development of a national offshore audit panel is recommended.
• This panel might be formed by inviting NARA and state based auditors to undertake additional
training on the understanding that they would be prepared to undertake offshore work.
• An alternative way of forming the panel might be an adaptation of the process used in the recent pilot
of the Business Excellence Framework where experienced practitioners led by an auditor undertook
the site visits.
• In either model of panel formation, training and management/coordination will be required. A
national approach to this task is likely to be more efficient and cost effective.
• The active engagement of Australian offshore expertise (Austrade, AEI) will be essential if offshore
visit preparations are to be cost effective and if culturally appropriate auditing is to occur.
• Prior to implementing a comprehensive and potentially costly program of off site visits it is proposed
that a limited pilot be conducted during 2010. This pilot would be subject to an independent
evaluation prior to further implementation. This time frame and evaluation would also allow any
further activity to be informed by emerging national regulatory requirements.
Provider response
• Some private providers believe that the current arrangements are adequate to monitor offshore
delivery, if implemented according to the AQTF 2007 guidelines. However others indicated that the
risks of offshore activity were largely unknown and that targeted offshore visits may be necessary to
protect the reputation of all providers. If such visits and assessments were to occur, a number believe
that evidence of student experience should be central to the assessment of providers.
• Public providers raised a number of concerns. They fear that external offshore site visits will add
additional costs to their delivery in a situation where margins are tight. They believe that current
methods of self-assessment and continuous improvement will be compromised by an external
process and merely add another burdensome layer of regulation. Those who have experienced AUQA
offshore site visits also doubt whether an external audit adds value to an institution that already has a
robust quality system.
• All providers expressed a fear that poorly briefed, culturally insensitive, external auditors could harm
business relationships and delivery partnerships.
Element 5: Publication of Audit Results
This Element is premised on the notion that, as is currently the case with AUQA audits, results should be
transparent and publicly available to all stakeholders. A positive report can be a useful promotional tool for
those providers who fare well. A less positive report involving major non-compliances will also provide useful
messages to offshore organisations who may be seeking to establish partnerships with Australian providers. It
can also provide an external point of reference to assist providers’ improvement processes.
Implications
• If this policy is adopted it is a relatively simple task for the national coordinating body to place results
on a website and also provide the offshore reports to state authorities for inclusion on state websites.
• It will be important that the form of the reporting is appropriate to meet market and provider needs.
38

Provider response
• Public providers, while they had some reservations, had no real objections to audit results being in
the public domain. Some actively advocated for the disclosure of both results and sanctions imposed
on providers with major non-compliances.
• While some are strongly opposed to publication of results, many private providers consulted support
the publication of audit results on the understanding that auditors have appropriate backgrounds and
experience, were trained and unbiased in their approach to providers. The remainder are strongly
opposed to the publication of results as they believe they could be misinterpreted by offshore
partners and misused by onshore competitors.
Element 6: Results provided to national accrediting body
This element is fundamental to ensuring that the accreditation process has integrity and has currency and
credibility in signalling quality training and assessment services. Only providers who have a demonstrated
current record of quality performance should be included in the published register at any given time. Those
who have current major non-compliances will be removed from the register. This will ensure that the offshore
market will value the accreditation and that Australian providers will have confidence in the veracity of the list.
Implications
• It will be a relatively simple matter to transfer results to an accrediting body in a timely fashion,
although the form in which the results appear may need careful consideration to ensure that the
needs of the offshore audience and the (potential) concerns of providers are addressed.
Provider response
• In principle there was no objection from public providers to this element. There was a view that the
accreditation process should be more rigorous than that which currently exists for AusLIST
registration and that risk could be reduced by limiting the number of ‘approved’ registered providers
operating in offshore markets.
• Private providers were almost equally divided on this element.. As can be expected, those who
supported Element 1 (central accreditation) also supported Element 6 (audit results to the
accreditation authority). Those who opposed Element 1 also opposed element 6.
Three ways of reading the 6 elements
How the elements of the model are implemented depend on how they are viewed and the work that they are
to do to achieve quality assurance goals. There are three perspectives that can be applied to the elements.
1. The six elements described above can be seen in a linear and sequential way and can be implemented
from element 1 to 6 in logical succession. Each might be seen as an integrated ‘package’ with each
element interdependent on the others. In this reading the model would need to be implemented in its
entirety.
2. The elements could also be read as separate elements that could be weighted differently or ‘tweaked’
according to (risk based) judgments that authorities might make. For example, if one were to take into
account the views of some providers that the way to reduce risk is to make entry into the market more
difficult, then one might want to weight element 1 more heavily. This might involve a strengthening of
the element, turning a voluntary accreditation process into a mandated registration process with rigorous
entry hurdles. Presumably this would reduce the number of players in the market and would assure the
market of the quality of those who are authorised to deliver. This would mean that ‘risk’ was addressed
more strongly at the front end (element 1) of the process and the need for risk based offshore audits
(element 4) might be lessened. This approach is likely to require considerable change to the existing
regulatory frameworks and may therefore be one which is considered in the longer term as a national
(TEQSA) system evolves.
39

3. Another way if reading the elements takes into account the individual functions of each element. If it is
agreed that a centrally coordinated, risk based quality assurance model is preferred it can be seen that
the 6 elements are comprised of elements which are central to risk identification and risk mitigation and
those that are supportive to the central purpose. The diagram below (Figure 3) represents the elements
in a functional way. This may be a useful distinction particularly, as noted above, any model adopted is
likely to be a temporary transitional one which will meet short-term needs. In addition, the costs to
government agencies and providers of implementing a relatively short-term model are also an important
consideration. In this reading it is possible to identify the three central elements that will be essential if
offshore delivery risks are to be identified and mitigated in the short term. Comprehensive data
collection (Element 2), risk assessment (Element 3), and offshore monitoring visits (Element 4) are the
essential activities if risk mitigation is to occur. While no less important, there is a sense in which
Elements 1, 5 and 6 ‘wrap around’ and support the three essential activities.
Concluding Comment
The six elements of the proposed model are based on consideration of two underlying dimensions: locus of
control and approaches to quality assurance. The locus of control dimension moves along a continuum from
centralised authority to free market forces. The dimension of quality moves along a continuum from externally
determined compliance to self-assessment and continuous improvement. Option B seeks to find a ‘middle’
practical way through the extreme positions on each ends of the dimensions while providing a strong basis for
managing the risks associated with offshore delivery of Australian qualifications. In addition a ‘functional’
division of the elements into 3 central elements and 3 supporting ones provides an opportunity to consider a
shorter term solution to identifying an addressing risks in current offshore VET delivery.
It can be seen from the above that there is a wide variety of provider views in regard to the three ‘central’ and
three ‘supporting’ elements in Option B. This is not surprising. The Australian VET system is remarkably
diverse. It unlikely that any model presented would achieve unanimous or even majority support from the very
diverse cohort of providers. The issue is not one of provider support but rather one of protection of the quality
and reputation of the Australian VET qualifications and those responsible for delivering them.
Recommendations
It is recommended that the NQC
1. Supports the proposed 6 elements of the model as a basis of monitoring and managing the risks of
offshore delivery of Australian VET qualifications.
2. In order to identify and mitigate immediate risk, a pilot and evaluation of the three central elements
of the model is conducted and evaluated in 2010. Estimated costs are attached (Appendix C).
3. That an implementation plan is developed which:
a. Facilitates commencement of the pilot as early as possible in 2010.
b. Assesses the costs and practicality associated with progressively implementing the three
support elements (information to the market and/or strengthened accreditation, publication
of results, informing accreditation body) to the model.
c. Identifies any potential changes to current regulations needed to implement the three
supporting elements.
d. Takes into account the effect of impending changes to the VET regulatory arrangements via
TEQSA.
e. Takes into account the effect of any other changes to roles and responsibilities as a result of
reviews that are currently underway or are planned.
f. Ensures that the NQC is provided with the evaluation results of the 2010 pilot by October
2010 so that future action can be recommended.
4. Develops a VET specific offshore delivery manual/guide that includes examples of best practice in
offshore delivery.
40

REFERENCES
Australian Universities Quality Agency (2009) Quality audits. Melbourne: AUQA
http://www.auqa.edu.au/qualityaudit/qa/ (as at 30/10/09)
Bateman, A. (2007) Quality assurance of offshore delivery in VET: Synthesis report. Adelaide: NCVER.
Carmichael, R. (2009) Auditing TNE activities. Unpublished briefing paper. Melbourne: AUQA.
Ciccarelli, A. (2009) A managed approach to TNE disengagement. Paper presented at the Australian
International Education Conference, Sydney Convention and Exhibition Centre, 13-16 October 2009.
City and Guilds (2009) Centre guide – Delivering international qualifications: Edition 2. London: City and Guilds.
Council of Australian Governments (2009) Directions for Vocational Education and Training Reform,
Communique, April 2009. http://www.coag.gov.au/coag_meeting_outcomes/2009-04-30/index.cfm#jobs
Department of Education, Employment and Workplace Relations (2007) Delivery of VET offshore by public
providers, 2007. Report on a consultancy undertaken for the Department of Education, Employment and
Workplace Relations. Canberra: DEEWR.
Department of Education, Employment and Workplace Relations (2009) Fact sheet: A national quality and
standards agency. Canberra: DEEWR. www.deewr.gov.au/.../09_FactSheet_
Department of Education, Employment and Workplace Relations (2009) Terms of reference for the review of
the Education Services for Overseas Students (ESOS) Act 2000 and associated regulatory and legislative
frameworks. Canberra: DEEWR.
Department of Education, Science and Training (2007) AQTF 2007: Building Training Excellence. Canberra:
DEST.
Department of Education Services (2007) Transnational Quality Strategy Trial Quality Assessment: Western
Australian Trial Site Audit. Perth: Department of Education Services.
International Education Association of Australia (2008) Good practice in offshore delivery: A guide for
Australian providers. Draft June 2008, Canberra: DEWR.
Quirk, S. (2009) Positive trade … private international education in Australia. Paper presented at the Australian
International Education Conference, The International Student Experience in ELICOS and VET.
www.aiec.idp.com
Scottish Qualifications Authority (2007) Awarding body criteria. Edinburgh: Scottish Qualifications Authority.
Silver, A. and Yang, H. (2008) Best practice in quality assurance for transnational programs – A case study for
Victoria University, Melbourne Australia. Paper presented at the CCID 32 nd Annual Conference, 23-26 February
2008, Long Beach, California, USA.
Skilbeck, M. (1988) The yearning for tests, Australian Teacher, n20, 18-20.
Stella, A. and Liston, C. (2008) Internationalisation of Australian Universities: Learning from Cycle 1 Audits.
Melbourne: Australian Universities Quality Agency
TAFE NSW (2009) Personal communication with senior personnel from TAFE NSW in September 2009.
41

APPENDIX A QUESTIONS POSED IN
CONSULTATION
Providers
Delivery
QA
• What do you deliver offshore currently? [Country? Quantum? Programs? Delivery model/strategy?]
• Who are the main competitors – Australian providers and overseas providers - in this market?
• How has the market changed in the past three years?
• What are the main challenges in offshore delivery? [eg. Staffing qualifications and suitability; language
of instruction; partner selection/management; managing consistency and quality; appropriateness of
training materials; customisation Vs equivalence; facility standards; AQTF pathways; assessment and
moderation.]
• What systems for QA are in place now?
• What is your institution’s approach to monitoring quality system [specifically regarding offshore
delivery]
• What external requirements apply for your registration and compliance for offshore delivery?
• Is there any perceived tension between in-country requirements and the AQTF requirements? If so,
how do you resolve these?
• Given your experience what features should an external QA monitoring system have or not have?
• … Could you walk me through the process from
start to finish. What they read, who they spoke to, evidence looked at … specific to offshore, etc.
• What are your impressions of the process?
• Are there special provisions in the overseas regulatory environments?
• Do you treat off-shore and on-shore as same or different for QA? Does this change for different
courses?
• Has quality assurance changed under the new AQTF? How?
Workforce delivery
• How do you manage workforce development issues around offshore? Which staff groups? Skills
issues? Costs?
• Additional questions for dual sector institutes
• What is your experience of AUQA audits offshore? What are the key features of the model?
• What are your views on its appropriateness for offshore delivery?
• Are there particular issues in managing both regulatory requirements (AUQA & AQTF)?
• How do they fit with the other requirements around eg. CRICOS/ESOS? Is it a comfortable fit or are
there difficulties in managing the processes?
• What are the relative merits of the AQTF / AUQA systems?
• In a new model what should we make sure was included?
• What are the costs of QA/audit process? (external/internal) Who bears the costs?
42

Regulatory bodies
NARA
AUQA
• What are your requirements for monitoring offshore now?
What processes? Who does it apply to? Are there differences for public and private? What does it
look like in practice? Is there an agreed code of practice -= state / national level for offshore delivery?
• What are the levers available to you now to monitor the quality of offshore delivery?
• What are the risks in the current model?
• What issues have emerged? That you’re dealing with? *re. the process+
• In a new and improved (national) system for monitoring quality of VET programs offshore – what are
the key principles that should drive the system?
• What work should it do?
• What would you want to see in it?
• How would that differ to what you have now?
• Are there features of the AUQA model that have benefit for VET if included in an AQTF model? Or
would not be useful?
• How do they fit with the other requirements around eg. CRICOS/ESOS?
• Is there a comfortable fit?
• How do the current provisions under the Transnational Quality Strategy assist monitoring?
• Should registering offshore delivery through AusLIST be mandatory?
• What do you understand as current practice across jurisdictions for monitoring the quality of offshore
delivery?
• What do you see as the main challenges to monitoring offshore delivery? generally? In a national
system?
• What changes would you see as valuable to the current strategies?
• What approaches might be effective in a monitoring process?
• What approaches would you not consider?
• What do you see as the relative merits or complimentarities of the AUQA and AQTF 2007 models?
• Do you know of models from overseas that might be useful to the Australian context?
• What are your views of the main changes and trends in monitoring offshore delivery in general?
• What advice would you have for setting up a system of monitoring offshore delivery?
• Are there challenges that are specific to managing quality improvement in the offshore environment?
• Are there specific considerations that would apply to particular countries?
• From your knowledge of multisector institutions, would you anticipate any particular considerations
for applying the AUQA approach to quality improvement to the VET sector?
• Do you know of models from overseas that might be useful to the Australian context?
• What are the key cost elements of the process? Who bears these costs?
43

APPENDIX B PARTICIPANTS IN
CONSULTATION
Janice Anderson, Trades Recognition Australia, Department of Education, Employment and Workplace
Relations (DEEWR)
Robin Austen, Private consultant
Robyn Adams, RMIT
Andrew Borman, Office of the Skills Commission, South Australia.
Dino Bettiol, Northern Melbourne Institute of TAFE (NMIT)
Farman Ullah Babar, Australian Institute of Entrepreneurship
Helen Bately, Blue Mountains International Hotel Management School
Kylie Black, Group Colleges Australia
Peter Bakker, C Management Services
Rebecca Biazos, Gold Coast Institute / TAFE Directors Association
Ruth Browne, Pivot Point International Academy
Wendy Blair, MHM Australasia P/L
Andrew Crevald, Perth Institute of Business and Technology
Inder Cheema, Amtech Institute of Management and Technology
Kim Cleary, International Quality Branch, Department of Education, Employment and Workplace Relations
(DEEWR)
Marjorie Christianson, Training, Quality and Regulation, Queensland
Martin Cass, JMC Academy
Richard Clifford, Box Hill Institute of TAFE
Rob Carmichael, Australian Universities Quality Agency (AUQA)
Tulip Chaudury, Department of Education Employment and Workplace Relations (DEEWR)
Kate Dempsey, TAFE International, Victoria.
Ann Edmunds, North Coast Institute of TAFE, TAFE NSW
David Endean, Holmesglen Institute of TAFE
Julie Eisenbise, RMIT
Claire Field, National Audit & Registration Authority (NARA)
Gael Fraser, Office of Skills Commission, South Australia
Roger Ferrett, Cambridge College
David Garner, Training, Quality and Regulation, Queensland
Ed Green, Australian College of Applied Psychology
Kay Ganley, Charlton Brown
Lyn Glover, Victorian Registration and Qualifications Authority (VRQA)
Peter Gainey, International Vision Education
44

Robyn Gilkes, International Quality Branch, Department of Education, Employment and Workplace Relations
(DEEWR)
Roy Gibbs, C Management Services
Tanya Gwin, The Australian College of Hair Design
Bruce Hunter, International College of Management, Sydney
Carol Hunter, Training, Quality and Regulation, Queensland
Jenny Harwood, Education and Training International, Western Australia
Lesley Harris, Academies Australasia
Maureen Houssein-Moustafa, MHM Australasia P/L
Michael Hunter, Australian Council for Private Education and Training (ACPET)
Roland Hermens, Acacia Group Ltd.
Stephen Henderson, Gurkhas Institute
Sue Hamilton, VETASSESS
Sue Hepperlin, ACT Accreditation and Registration Council
Sue Honeywell, NSW Vocational Education and Accreditation Board
John Iacono, Academies Australasia
Jeff Brownrigg, Education Training and Employment Australia
Beverley Jeffreys, Chisholm Institute of TAFE
Peter Jasonides, ITHEA
Peter Jackson, Mediagogy
Bill Karkamitsis, Australian Institute of Technology and Education
Domenica Kemp, Education Training and Employment Australia
Ewa Kuriata, Skills Victoria
Maria Kouppas, Victoria University
Peter Kyriacou, ITHEA
Spiro, Kardamitsis, Australian Institute of Technology and Education
Sue Kearney, Box Hill Institute of TAFE
Joscelyn Langdon, The Australian College of Hair Design
Melinda Larkin, Australian Council for Private Education and Training (ACPET)
Adrian Marron, TAFE SA – North
Bruce Mc Kenzie, Holmesglen Institute of TAFE
George Markakis, JMC Academy
Heidi Merriman, ABC College
Julie Moss, Australian Council for Private Education and Training (ACPET)
Neda Morris, The Education Group
Brian O’Mahony, AVTI
Dianne Orr, Training, Quality and Regulation, Queensland
Fiona O’Sullivan, Australian College of Applied Psychology
45

Hannah Park, ABC College
Stuart Page, Evolution
Farooq Qamar, Edward Beale Training Salon
Steve Quirk, Australian Council for Private Education and Training (ACPET)
Carrie Roach, Trades Recognition Australia, Department of Education, Employment and Workplace Relations
(DEEWR)
Dr Madeleine Reeve, RMIT
Ian Rozdal, Hostec
Lina Ridley, Perth Institute of Business and Technology
Mal Rowe, Northern Melbourne Institute of TAFE (NMIT)
Oksana Razoumova, Australian Institute of Technology and Education
Adam Souss, Southbank Institute of TAFE
Gavin Slattery, Chisholm Institute of TAFE
Joanne Stavely, North Coast Institute of TAFE, TAFE NSW
John Steer, Kangan Batman Institute of TAFE
Kristine Shead, Australian Nationwide College
Lesley Smith, Western Institute Institute of TAFE, NSW
Lesley Smith, Western Institute of TAFE, TAFE NSW
Moninderjit Singh, Australian Academy of Management & Science
Rajan Sharma, The Education Group
Virginia Simmons, TAFE Directors Australia
Wendy Schwedes, VETASSESS
Alan Silver, Australian College of Trade
Gary Thomas, Acuto Consulting
Karen Treloar, Australian Universities Quality Agency (AUQA)
Ben Vivekananden, Australian Council for Private Education and Training (ACPET)
Catherine Vandermark, TEQSA, Department of Education Employment and Workplace Relations (DEEWR)
Tony Vulic, Kent Institute of Business & Technology
Chris Whitton, ACT Accreditation and Registration Council
Dr David Woodhouse, Australian Universities Quality Agency (AUQA)
John Wood, Navitas
Russell Welch, John Paul International College
Scott Wesley, MHM Australasia P/L
Emily Xu, Kent Institute of Business & Technology
46

APPENDIX C NOTIONAL COSTING OF
OFFSHORE PILOTS
It is assumed that costs associated with elements 1, 4 and 5 will be identified during the development of the
Implementation Plan (see recommendation 3). If accepted Recommendation 2 will require additional
resources as described in Table 5.
Table 5
Estimated costs and assumptions of implementing the model for monitoring offshore VET
delivery
Task Assumptions Subtotal
Development of enhanced
risk guidelines.
Training and coordination of
specialist offshore panel.
Offsite monitoring visits
Evaluation of the offshore
pilot site visits.
Development of delivery
manual/guide for providers
That most of the work will be done within existing
resources. A small allocation to enable some outside
advice may, or may not, be needed.
That some outside assistance may be required and that an
operational manual for offshore assessors may be
advantageous to assist in ensuring consistency of
approach.
That an offshore review team would comprise of two
panel members drawn from the national trained pool. This
may need to be augmented by an industry expert,
depending on the nature of the qualifications being
delivered.
That some salary costs would be absorbed by reprioritizing
existing work loads and/or an honorarium would apply if
external experts were used.
That eight delivery sites in two countries might be visited
in the pilot .It is intended that high risk providers would be
visited in the first instance. If there were not 8 high risk
sites by the desk top risk assessment process, then review
team may wish to visit assess the quality measures
undertaken by low risk providers. Information gained may
inform future action.
That the offshore visits would be scheduled to minimize
trips to and from Australia and to maximize the number of
sites that would be visited in a single country within a
short timeframe.
As per current practice, it is assumed that a visit would be
two to three days per site at an average cost per site of
approximately $15,000
That the evaluation will be undertaken by an independent
evaluator and that some offshore visits may be required.
This will be VET specific; will build on existing documented
best practice and cross sectoral information currently
available.
$15,000
$20,000
$15.000
(per site)
$40,000
$30,000
47