7 days to go and getting my head around the NEW VET Quality Framework

The NEW VET Quality Framework  - Under Section 3 definitions this is defined as:

VET Quality Framework means the following:

(a) the Standards for NVR Registered Training Organisations;

(b) the Australian Qualifications Framework;

(c) the Fit and Proper Person Requirements;

(d) the Financial Viability Risk Assessment Requirements;

(e) the Data Provision Requirements.

This also sort of relates to the issue of Legal instruments ... to be further reviewed later .. But for now the other points are:

1. It seems like (a) the Standards for NVR Registered Training Organisations will replace what we currently call the AQTF (2010). (Some people have asked if it will be as well as . BUT it really seems to be instead of ... )

2. Under Section 21 it states NVR RTOs have to comply with “Conditions” which in and of itself isn’t new. While the term “Conditions” is not defined under Section 3 (s21) states “with the conditions set out in sections 22 to 28” and “comply with any conditions imposed on the organisation’s registration under subsection 29(1)” (which is pretty much anything else we are told to do).

There is then a note

Note:     Failure to comply with a condition of registration is a contravention of a civil penalty provision, see section 111.

(more on this to come later)

But the ACT is ‘formatted’ (for want of a better word) like this ..

22 Condition—compliance with the VET Quality Framework

And so I think .. YUP .. saw the definition of what is the VET Quality Framework!

(1)        An NVR registered training organisation must comply with the Standards for NVR Registered Training Organisations.

Yup listed (a) in the definition ..

(2)        An NVR registered training organisation must comply with the Australian Qualifications Framework.

Yup listed (b) in the definition ..

(3)        An NVR registered training organisation must comply with the Data Provision Requirements.

Ok .. listed (e) in the definition – so it is not in the same order ..but I am following this 

BUT then it goes on with the missing (c) and (d) parts of the VET Quality Framework (according to the definition) as referring to them as Condition 23 and 24.

I know in the big scheme of things it is probably just semantics but my question is ..

“So are (c) the Fit and Proper Person Requirements and (d) the Financial Viability Risk Assessment Requirements part of the VET Quality Framework and if so then WHY aren’t they listed above rather than detailed in their own ‘conditions’? “

Condition 25 – 28 pretty much just talk about providing information, telling the NVR about changes and co-operating as per the requirements under AQTF.

One interesting thing is that the second part of Condition 28 is that “The National VET Regulator must publish a general direction on its website”

So hopefully we should all know  “on the way in which the VET Quality Framework or other conditions of this Subdivision are to be complied with.” (s28 1)

The last term for this post is:

Risk Assessment Framework has the meaning given by section 190.

And under Section 190 it says ..

(1) The Minister may, by writing, make guidelines for the National VET Regulator to use when assessing risk, as agreed by the Ministerial Council.

(2) The agreed guidelines are to be known as the Risk Assessment Framework.

(3) The guidelines made under subsection (1) are not a legislative instrument.

(and I say ‘thank goodness for that I have had all I can take of LIs for the moment)