Comments

Document Feedback - Review and Comment

Step 1 of 4: Comment on Document

How to make a comment?

1. Use this Protected Document to open a comment box for your chosen Section, Part, Heading or clause.

2. Type your feedback into the comments box and then click "save comment" button located in the lower-right of the comment box.

3. Do not open more than one comment box at the same time.

4. When you have finished making comments proceed to the next stage by clicking on the "Continue to Step 2" button at the very bottom of this page.

 

Important Information

During the comment process you are connected to a database. Like internet banking, the session that connects you to the database may time-out due to inactivity. If you do not have JavaScript running you will recieve a message to advise you of the length of time before the time-out. If you have JavaScript enabled, the time-out is lengthy and should not cause difficulty, however you should note the following tips to avoid losing your comments or corrupting your entries:

  1. DO NOT jump between web pages/applications while logging comments.

  2. DO NOT log comments for more than one document at a time. Complete and submit all comments for one document before commenting on another.

  3. DO NOT leave your submission half way through. If you need to take a break, submit your current set of comments. The system will email you a copy of your comments so you can identify where you were up to and add to them later.

  4. DO NOT exit from the interface until you have completed all three stages of the submission process.

 

Third Party Arrangements - Third Party Arrangements Procedure (VET)

Section 1 - Summary

(1) This Procedure outlines the responsibility for, and processes involved in, engaging third parties to deliver and/or assess vocational education and training (VET) qualifications on behalf of Victoria University, (VU) Polytechnic. The Procedure addresses the Polytechnic's responsibilities in relation to:

  1. the National Vocational Education and Training Regulator (Australian Skills Quality Authority [ASQA]), including the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS);
  2. the Victorian Registration and Qualifications Authority (VRQA); and
  3. the Victorian Department of Education and Training (DET) VET Funding Contract.
Top of Page

Section 2 - HESF/ASQA/ESOS ALIGNMENT

(2) Standards for Registered Training Organisations (RTOs) 2015 (Cth): Standards 2, 4, 5 and 6.

Top of Page

Section 3 - Scope

(3) This Procedure is applicable across the University's VET operations, including when establishing and managing third-party arrangements for the delivery and/or assessment of Vocational Education programs in Australia and offshore.

Top of Page

Section 4 - Definitions

(4) Nil.

Top of Page

Section 5 - Policy Statement

(5) Third Party Arrangements Policy

Top of Page

Section 6 - Procedures

Part A - Summary of Roles and Responsibilities

Roles Responsibilities
Victoria University Polytechnic Executive Directors 1. Inform Legal Services of any notifications of changes to obligations and reporting requirements by regulatory bodies.

2. Update the Responsibility Matrix in line with changes imposed by regulatory bodies and/or identified internal continuous improvement actions.

3. Liaise with VUI about the delivery of any services to international students. Manage the contract execution process.

4. Where relevant, liaise with TNE Partnerships to ensure that partnership delivery complies with VU policies and procedures and with Australian and host country regulation.

5. Allocate a Contract Manager.

6. Overall responsibility for all services delivered by the third party, both on and offshore, in line with regulatory body requirements.

7. Overall responsibility for ensuring any recruitment or brokering services delivered through third party arrangements conform to regulatory body requirements.

8. Ongoing monitoring of contract and associated reporting requirements.
Senior Leadership Team 1. Assess and approve recommendations to engage with a third party for the delivery of education and training services.

2. Review due diligence outcomes.
Deputy Vice-Chancellor, Vocational Education 1. Notify regulatory and funding bodies - ASQA, VRQA and DET - in writing of all new third-party arrangements, entering into the delivery and cessation of delivery (within 30 days) and seek prior approval as required.
Legal Services 1. Develop a standard contract for VET Third Party Arrangements.

2. Develop and maintain due diligence tool to be used for assessing the suitability of prospective partners.

3. Periodically review Third Party contracts and matrix of responsibilities.
Quality, Risk and Compliance
1. Review the Agreement in compliance with the Standards for RTOs 2015 and other relevant regulatory bodies and legislation.

2. Track and report on Third Party Arrangements as required by Department of Education and Training and ASQA.

3. Conduct an internal audit of Third Party Arrangement courses against the Standards for RTOs 2015 and the relevant VET Funding Contract.
Victoria University Polytechnic Education Manager/Contract Manager 1.Liaise with the relevant partner Project Manager to complete the Victoria University Polytechnic - Quality Responsibilities Matrix; Third Party Agreements for Training and/or Assessment of Nationally Recognised Programs.  

2. Finalise costing/pricing for projects. 

3. Oversee the third-party arrangements, including the identification of potential risk or issues.

4. Liaise with Finance and manage the payment schedule.

5. Liaise with VU services, e.g. Marketing, Enrolments etc., about third-party arrangements.

6. Ensure training to third-party staff in relation to VU procedures, e.g. Authorised Enrolment Officer training, resulting etc. 

7. Ensure the publishing of third-party arrangements and potential/existing students are aware of such arrangements.

8. Operational responsibility for all services delivered by the third party, both on and offshore, in line with regulatory body requirements.

9. Operational responsibility for ensuring any recruitment or brokering services delivered through third party arrangements conform to regulatory body requirements.

10. Ongoing monitoring of contract and associated reporting requirements.
TNE Partnerships 1. Liaise with the VUP Education Manager/Contract Manager for offshore delivery services. 
 

Part B - Procedures

(6) The Education Manager/Contract Manager and/or Executive Directors will identify business opportunities, public benefits and associated risks of working in partnership with a third party and make recommendations in writing (Business Case and Costing tool) to the Deputy Vice-Chancellor, Vocational Education.

(7) A due diligence review of the proposed partnership is undertaken by the Education Manager/Contract Manager or Executive Director and reported to the Senior Leadership Team. Legal Services as well as TNE Partnerships and VU International for offshore services delivery, are consulted as part of the partner assessment, due diligence review, and probity check. The VU Legal Due Diligence Checklist is to be used as a guide to this process and decision making, not as an exclusive indicator.

(8) For projects whose projected revenue is up to $500,000, due diligence checks to be completed within 5 working days. For projects with projected revenue of $500,000 or above, due diligence checks to be completed within 10 working days of the request.

(9) The Deputy Vice-Chancellor, Vocational Education with the Senior Leadership Team, will assess the recommendations (Business Case, Costing Tool, due diligence evidence) to engage with a third party for the delivery and/or assessment of education and training services in line with the relevant regulatory requirements.

(10) The Deputy Vice-Chancellor, Vocational Education to notify regulatory bodies - ASQA and VRQA - in writing of all new third-party arrangements and seek prior approval from the Victorian Department of Education and Training (DET) as required:

  1. To notify ASQA, use the Third Party Service Notification Form which is accessed and submitted via ASQAnet/Notifications/Third-Party Arrangements. Notification made within 30 days of program commencement and cessation.
  2. To obtain prior written approval to proceed from the Victorian Department of Education and Training for subcontracting of training and assessment by a third party in compliance with Clause 6 of the VET Funding Contract.

(11) The Deputy Vice-Chancellor, Vocational Education to notify DET of Brokering Services entered into within 30 days of entering into any arrangement.

(12) The VU Polytechnic Executive Directors will ensure that any changes to obligations and reporting requirements by regulatory bodies are reflected in the Agreement or Responsibilities Matrix.

(13) The VU Polytechnic Executive Directors will liaise with VU International senior officers and TNE Partnerships about all international delivery contract execution and management matters.

(14) All delivery of courses will comply with external and internal regulatory requirements of both Australia and the host country (if delivered outside of Australia).

(15) No third-party delivery arrangement will be entered into without consultation with internal stakeholders, the completion of due diligence checks, and the development and signature of a formal contract between VU and all partners. Any third party agreement for offshore services delivery must be signed by the Vice-Chancellor, upon joint endorsement of the Deputy Vice-Chancellor, Vocational Education and the and Deputy Vice-Chancellor, Higher Education.

(16) Before finalisation of the Agreement, the Education Manager/Contract Manager will liaise with the relevant partner Project Manager and complete the Victoria University Polytechnic - Quality Responsibilities Matrix; Third Party Agreements for Training and/or Assessment of Nationally Recognised Programs, clearly articulating responsibilities for each aspect of the program.

(17) After completing the matrix, the VU Polytechnic Education Manager/Contract Manager will finalise costing/pricing for the project taking into consideration the responsibilities allocated to the Polytechnic and use of Polytechnic copyrighted documentation and templates for the program. Directors will manage the contract execution process.

(18) VU Polytechnic Executive Directors will liaise with the relevant Education Manager/Contract Manager to provide direct contact with third parties and monitor activities in line with the Polytechnic's quality system and regulatory bodies' requirements.

(19) The Education Manager/Contract Manager will:

  1. be responsible for the oversight of the third party arrangements, including identification of potential risks and corrective actions required to manage risk, as well as ensuring regulatory and funding bodies' requirements are met and provide regular reports to the relevant Polytechnic Executive Director.
  2. liaise with Finance and manage the payment schedule.
  3. liaise with VU services about third-party arrangements, e.g. VUI, Marketing, Enrolments etc., and TNE Partnerships for offshore delivery.
  4. ensure relevant training to third-party staff in relation to VU procedures, e.g. resulting etc., along with relevant notifications from regulatory bodies.
  5. ensure third-party arrangements are published, and potential/existing students are fully aware of such arrangements.

(20) The VU Polytechnic Executive Directors are responsible for all services delivered by third parties - both on and off shore - including: providing data; co-operating with regulatory bodies such as ASQA, VRQA and DET; complying with the Education Services for Overseas Students Act 2000, meeting the requirements for CRICOS registration, complying with advertising and marketing standards; informing prospective students about courses and course admissions requirements; dealing with complaints and appeals; collecting fees; and recordkeeping.

(21) The VU Polytechnic Executive Directors and Education Manager/Contract Manager are responsible for the ongoing monitoring of contract and associated reporting requirements. In particular:

  1. Initial site visit before finalising the agreement.
  2. Set up a monitoring schedule that will include at least one audit of activity at the partner organisation each semester and at least two site visits each year.
  3. Conduct systematic monitoring, taking corrective action as necessary.
  4. Ensure that the partner understands and complies with the requirement to make themselves and course / staff / student documentation available at short notice to the VU Polytechnic, DET and the national VET regulator.