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VET Third Party Arrangements Procedure

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Section 1 - Purpose / Objectives

(1) This Procedure outlines the responsibility for, and processes involved in, engaging third parties to deliver vocational education and training qualifications on behalf of the Polytechnic. It 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) 2017 Funding Contract.
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Section 2 - Scope / Application

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

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Section 3 - Definitions

(3) Nil

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Section 4 - Policy Statement

(4) Nil

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Section 5 - Procedures

Part A - Roles and Responsibilities

Roles Responsibilities
Polytechnic Managers / Directors Identify business opportunities, public benefits and associated risks of working in partnership with a third party and make recommendations to the Vice-President, Vocational Education.
Vice-President, Vocational Education Assess recommendations to engage with a third party for the delivery of education and training services.

Notify regulatory bodies - ASQA, VRQA and DET - in writing of all new third party arrangements and seek prior approval as required.
Director for Quality Learning and Support Inform Legal Services of any notifications of changes to obligations and reporting requirements by regulatory bodies.

Update Responsibility Matrix in line with changes imposed by regulatory bodies and/or identified internal continuous improvement actions.
Senior Manager Commercial Operations Conduct due diligence reviews of proposed partners for projects.

Consult with Legal Services for projects whose revenue is estimated to exceed $500,000.
Legal Services Develop standard contract for VET Third Party Arrangements.

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

Periodically review Third Party contracts and matrix of responsibilities.
Polytechnic Directors
Liaise with VUI in relation to delivery of any services to international students.
Manage contract execution process.

Appoint a Contract Manager.

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

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

Ongoing monitoring of contract and associated reporting requirements.
Contract Manager Oversight of third party arrangements, including the identification of potential risk or issues.

Seek approval from Director for pursuing Third Party Agreements.

Initiate negotiation of responsibilities using the Polytechnic Quality Responsibilities Matrix to record individual responsibilities for each key area.

Liaise with Finance and manage the payment schedule.

Liaison with VU services, eg Marketing, Enrolments etc, in relation to third party arrangements.

Ensure third party staff are provided with training in relation to VU procedures, eg Authorised Enrolment Officer training, resulting etc.

Ensure third party arrangements are published and potential/existing students are aware of such arrangements.

Ongoing monitoring of contract and associated reporting requirements.

Part B - Procedures

(5) The Polytechnic Managers and/or Directors will identify business opportunities, public benefits and associated risks of working in partnership with a third party and make recommendations to the Vice-President, Vocational Education, using the Partnership for Training Delivery and/or Assessment Proposal.

(6) The Vice-President, Vocational Education will assess the recommendations to engage with a third party for the delivery of education and training services in line with the relevant regulatory requirements.

(7) The Vice-President, 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 must be made within 30 days of program commencement.
  2. To obtain permission to proceed from the Victorian Department of Education and Training, application is made through the Skills Victoria Training System (SVTS). This application is only required if students undertaking learning and/or assessment with the third party are eligible to receive funding under the Skills First program. Application must be made prior to program commencement.  Delivery and assessment activities with the third party cannot commence until written approval from DET has been received.

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

(9) The Director for Quality, Learning and Support will ensure that any changes to obligations and reporting requirements by regulatory bodies are reflected in the Agreement or Responsibilities Matrix.

(10) A due diligence review of the proposed partner must be undertaken by the Senior Manager Commercial Operations. For projects whose revenue is projected to be $500,000 or above, Legal Services must be consulted as part of the due diligence review and probity check.

  1. For projects whose projected revenue is up to $500,000, due diligence checks will be completed within 5 working days.
  2. For projects with projected revenue of $500,000 or above, due diligence checks will be completed within 20 working days of the request.

(11) The Polytechnic Directors will liaise with VU International senior officers in relation to all international delivery contract execution and management matters.

(12) Prior to finalisation of the Agreement, the Polytechnic Manager will liaise with the relevant partner Project Manager and complete the 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.

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

(14) The Polytechnic Directors will appoint a Contract Manager to provide direct contact with third parties and monitor activities in line with the Polytechnic's quality system and regulatory bodies' requirements.

(15) The Contract Manager will 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 bodies' requirements are met and provide regular reports to the relevant the Polytechnic Director.

(16) The Contract Manager will liaise with Finance and manage the payment schedule.

(17) The Contract Manager will liaise with VU services, e.g. Marketing, Enrolments etc., in relation to third party arrangements.

(18) The Contract Manager will ensure the relevant third party staff are provided with training in relation to VU procedures, e.g. Authorised Enrolment Officer training, resulting etc., along with relevant notifications from regulatory bodies.

(19) The Contract Manager will ensure third party arrangements are published and potential/existing students are fully aware of such arrangements.

(20) The Polytechnic 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 and DET; 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 Polytechnic Directors and Contract Manager are responsible for the ongoing monitoring of contract and associated reporting requirements. In particular -

  1. Set up a monitoring schedule that will include at least one audit of activity at the partner organisation each semester and at least one site visit each year.
  2. Conduct systematic monitoring, taking corrective action as necessary.
  3. Ensure that the partner understands and complies with the requirement to make themselves and course / staff / student documentation available at short notice to the Polytechnic, DET and the national VET regulator.
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Section 6 - Guidelines

(22) Nil

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Section 7 - References

(23) CRICOS Registration Requirements - ASQA

(24) Standards for Registered Training Organisations (RTOs) 2015, made under the National Vocational Education and Training Regulator Act 2011

(25) User's Guide to the Standards for RTOs 2015 - ASQA

(26) 2017 Dual Sector VET Funding Contract Skills First program

(27) Non-school Senior Secondary Education Providers: Minimum Standards for Registration - VRQA

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Section 8 - Forms

(28) PO06-F01 VET Partnership for Training Delivery and or Assessment Proposal

(29) PO06-T01 Victoria Polytechnic Quality Responsibilities Matrix; Third Party Agreements for Training and/or Assessment of Nationally Recognised Programs