QCTO expects pre-approved FISAs and a unique test for every cohort, yet does not clearly communicate this upfront. The result is a compliance trap that creates delays, rework, and unnecessary risk for training providers.
QCTO Assessment Department FISA Compliance Trap Explained
The issue
QCTO emails newly accredited training providers a “Process for Skills Programmes document” (click to download) outlining the FISA steps and process the fresh and newly accredited provider must follow.
This is sent out in the same email as every successful applicant’s accreditation letter.  The problem is simple: what is written in the process, and what is expected by QCTO do NOT match.
That document does not require FISA pre-approval, and nor does any other document the training provider recieves in their pack from QCTO (click to download).
The process document requires the training provider to submit FISA tools at Step 7, after enrolling, training, and assessing a learner.
As a result, training providers following the process document may reasonably believe that FISA pre-approval is only required at a later stage.
In practice, training providers who simply follow QCTO’s documented process without first obtaining FISA pre-approval may later encounter compliance-related delays and administrative rework.
The downstream impact of this can also affect learners awaiting certification.
The timing of when training providers are told they are ‘non compliant’ is extremely problematic – they are told after enrolling and training a cohort of learners. At this pont it is already too late to comply without recalling learners for more assessment for skills programs and shortcourses, as the learner will already have completed it and moved on.
This creates a significant compliance risk (a compliance trap) for training providers because the documented process and operational enforcement oppose one another. Despite the issue having been raised with QCTO over several years, the process document has not yet been updated accordingly.
I raised this issue directly with QCTO (Diane Kemp and Motshedisi Maake, by email) in 2024 and again in 2025 but the process document has not yet been updated to address the issue (FISA approval remains at step 7, no pre-approval is recommended before training).
I raised this issue again in person at the QCTO stakeholder engagement in November 2025, in front of everyone there, to Motshedisi Maake who said she was unaware of the problem, yet was included in my 2025 email to Diane Kemp about it.
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What is a FISA?
A FISA is a Final Integrated Summative Assessment that training providers use as a tool to assess and declare a learner competent in a QCTO skills program.
A FISA is not the same as an EISA which applies to qualifications only.
- FISAs – Conducted by the training provider, for QCTO skills programs
- EISAs – Conducted at an assessment centre, and is for qualifications only
The solution
QCTO requires training providers training QCTO skills programs to pre-approve their FISA with QCTO before using it for learner assessment.
Ensure you submit your FISA to the QCTO assessment department before you train. This appears inconsistent with the assessment process diagram currently issued to providers, but this is what QCTO actually enforces in practice.
Furthermore, if newly accredited, QCTO will want to conduct a QA verification visit, which is booked / triggered when you train a learner.
Because the visit often takes QCTO 6 months or more to book and conduct, all learners trained (usually your first class or cohort) are delayed for months while you wait for QCTO to do the first QA verification.
Be aware that QCTO will not provide certification to your learners while you wait for FISA pre-approval, or while you wait for your QA verification.
QCTO can and does deny or delay certification to your learners beacuse you followed this process document.
This has major downstream problems. It creates a situation where you cannot comply with QCTO’s other policies on learner enrolment and results submission (5 days, 21 days) because it is impossible to do within the QCTO waiting period (such as 6 months or more for QA verification).
To avoid this compliance trap, it seems best to first train a test learner to simply trigger QCTO’s lengthy processes that happen after you train a learner, but before the competent learner is given a certificate.
The contact at QCTO to submit your FISA to is:
assessmentstandards@qcto.org.
SDPs report that response times can be slow and repeated follow-up is often required.
Note that when you pre-approve your FISA, QCTO expects you to have a unique FISA for every cohort.
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Wait, a unique FISA for every learner cohort!?
QCTO requires that every cohort of learners must complete a unique FISA. That means you cannot reuse the same assessment, you need a very large number of unique FISAs, and each one may be subject to review by QCTO.
Given that tall order, you have two choices: try manage this manually, or build a system around it.
For those who do not use a LMIS, or want to purchase one, this can be tricky.
That is why Lime Green provides a FISA generator, as standard, with all learning material. The generator is a visual basic-driven excel document with sufficient questions loaded into an editable bank.
The generator selects and randomises which questions are used from the pool, ensuring each outcome requirement of the curriculum is still covered (i.e. the bank is segmented).
The generator will generate a massive number of unique possible tests at the click of a button, so there is no doubt there is sufficient variety.
Along with the generator, MS Word templates are given that you place the generated test into, and then the corresponding rubric into.
I have proven by video presentation that the training provider can do this in 60 seconds. See that video demonstration here. It is extremely user freindly.
The FISA generator works with MS Office and is completely compatible with various versions of Office and its alternatives.
That means you do not need a LMIS to run it. For training providers training short skills programs this is a huge win because many of them do not use a LMIS, or cannot afford one.
NB: Providers should ensure their solution includes a practical method for generating sufficiently varied FISAs.
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