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The Devil is in the Data

AVETMISS, RTO, VET, Student, Data, Quality, CRICOS, Quality Indicators, Competency Completion Counts, Submissions, NAT Files, NAT00120, Course Progress, Competency, Modules, Compliance

How well is your data managed?

Every RTO, regardless of size or type, has a responsibility to manage the quality of its data to meet compliance requirements. On a day to day basis how much data do you collect relating to your students’ or their studies or your Employers, Agents, Schools and so on? All this data means something to your RTO and generally a large component of it affects your compliance requirements.

Poor data quality costs RTOs large amounts of time, resources and money every year. It is a significant problem not only for compliance management but it can also lead to inferior customer service, reduced employee productivity, lost sales opportunities etc. Many RTOs are struggling in managing the quality of their data and there are just as many that have no idea how important the quality of their data is to their compliance requirements.

Data quality management is not rocket science or something to keep at arm’s length or even avoid, it’s something you need to consider seriously and take action to put a plan in place to manage your data.

Firstly you need to take a step back and identify what compliance requirements do you manage and of them what ones require you to store and manage very specific data? The main ones that are data specific include:

Now not all of the above may affect your RTO but at least 1 if not 2 of them, Quality Indicator Competency Completion Counts & AVETMISS data submissions, will be important to your RTO. If you also are a CRICOS registered RTO then 1 extra of these would be added to your list.If you take a look back over the history of the Industry and compliance requirements it’s probably in the last 4+ years that compliance has become more regulated and monitored and hence a problem for RTOs.

If you are an RTO that has been managing Apprentices & Trainees or other funded contracts for a few years you may say “what’s all the fuss, it’s simple or pretty easy” but is it really? Do you every month, without fail; receive a successful submission on the first attempt? If you answer yes then CONGRATULATIONS you are one of the minority of RTOs that are successfully managing your data, typically speaking most RTOs, even funded ones, have to do more than one submission per month to get a successful submission through.
Devil in the data

Now add all the other compliance requirements listed above that you are responsible for and this will build up to a lot of data that is not being managed properly.

Understanding what problem data is.

Let’s look at some simple examples of problem data.

AVETMISS data submissions One of the most common errors that RTOs receive relates to a student’s address. In many databases a user can enter a suburb themselves and save it. More than likely they can also search and find the suburb but it is much easier in the mind of a user, especially someone who is good at data entry, to just type the information in and save it not stopping to think how that impacts the database.

The problem is validation of the student’s address, especially the Suburb; State & Post Code is done by mapping it to the Australia Post website data. The first entry below would be rejected if it was submitted.

Red Cross melbourne, victoria 3000
Green Tick MELBOURNE VIC 3000

Many times common suburbs like Melbourne, Sydney, Brisbane and so on, have all been entered into databases as melb, syd, bris etc due to lack of care by the person entering it. Another example for addresses is where the suburb, state & post code are entered but no street address is entered or vice versa.

(Street Address Line 1) – left empty by staff member.

Red Cross MELBOURNE VIC 3000
Green Tick 657 Elizabeth Street

In the first example above the format of the Suburb, State & Post Code is correct because there is no street address line 1 data it would be rejected.

Now reverse the above example and have 657 Elizabeth Street but no suburb, state or post code and again it is incorrect. Simple little data mistakes like this can cause large amounts of errors and stress when your AVETMISS data is rejected.

The next BIG data problem relates to DATES and this relates to all compliance requirements above if you think of it this way: AVETMISS Data Submissions: Most states, other than NSW, generally only want to see ‘current activity’ in the NAT files. How do you or your student management system know what ‘current activity’ activity is? It is basically when a student is meant to start and complete a unit of competency and/or module that determines if it should be included in the NAT00120 or not so very date specific.

Quality Indicators – Competency Completion Counts: especially think about the module activity file for started & completed counts. A student that is studying over more than one calendar year will NOT start or finish studying their competencies and/or modules in the one year and counting them in this way could have a dramatic completion count from one year to the next which can affect your Risk Rating.

DEST/DIAC Course Progress: this is CRICOS specific compliance but is very dependent on dates. RTOs must monitor a student’s performance/progress within each study period, how do you do this if you do not know when a student is meant to start and finish studying each of their competencies and modules? You can’t just count every competency/module a student must study over the entire duration of their enrolment where it is more than 26 weeks. The logic is that student’s do not start studying every competency/module at the commencement of their studies and finish them all at the end of their studies, they have different start and end dates typically based on your term/semester dates.

Typically for a CRICOS RTOs they never worried about recording a result date against the student’s competencies/modules as there was never a need so with the introduction of the above 3 compliance requirements for them meant many data nightmares and a lot of confusion and in some cases panic purely due to the amount of data they had.

National Code 2007 – Attendance Monitoring: this is another CRICOS specific compliance requirement for RTOs but it also can impact ELICOS colleges if they have enrolments that are greater than 26 weeks as you must then separate it into different ‘study periods’ for monitoring.

As you can see all of the above are heavily reliant on dates yet many RTOs still do not understand the importance of this. You need to get your dates correct against a student’s course of study/enrolment so that you can manage the specific compliance requirements. Please don’t think that a date isn’t data, it absolutely is. And it isn’t just CRICOS RTOs that had problems with the introduction of these compliance requirements, many RTOs who chose the path of distance/ online learning, in a lot of cases to reduce and avoid as much compliance requirements as possible, also struggled when they realised they actually had to comply as well.

So how can you better manage the quality of your data?

The bulk of your data management for compliance relates to a student and their studies. If you think about the life cycle of a student there are 3 main stages that are:

Devil in the data 1

Each one of these stages would mean you are collecting very specific, if not critical, data that impacts your compliance. For example:

Potential Students: collection of demographic data from enrolment forms is critical to AVETMISS data. Even data you collect from employers and even agents at this stage impacts how you handle student data.

Active Student: this is the major & critical data collection point. You have points such as:

i) Competency/module start & end dates
ii) Results & results issued dates
iii) Attendance
iv) Qualifications/Statement of Attainments issued
v) Withdrawals/deferments

Completed Student: this is minor but still a completed student’s data affects AVETMISS and Quality Indicator Competency Completion Counts.

For each of these stages you need to identify the following:

  • What is the data that is compliance specific that you collect in a stage?
  • Who is entering that data into your systems? Is it more than one person?
  • How do they enter data into your systems?
  • Are there changes that can be implemented to improve the entry of this data into your systems?

Once you have identified this you then need to:

  • Make the changes identified and update any existing policies/procedures to include the change or create new policies and procedures to protect these changes.
  • Train your staff on what the changes are and how important the data they enter into your systems affects your compliance requirements. You can build this into their KPIs and manage it as part of your staff ’s performance reviews.
  • Monitor your data with random daily or weekly data quality checks. The rule should be 10% of all data entered that day/week should be randomly checked. If you are still finding a large number of problems in data revisit what you have done and look for gaps/holes and remove them.
  • Review your data quality management policies and procedures on a regular basis to identify improvements.
  • For AVETMISS data files get to know them, understand their structure and what each piece of data means and then over ti me you will be able to open each NAT file and do a scroll down glance and you will be amazed at how easily you can view and pick up data problems.

Remember the devil is in the detail or more importantly the devil is in the data

Reference: RTO Success Magazine

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