A question at a recent ASQA webinar exposed a real tension: how far must a pre-enrolment LLND review reach into a unit's performance criteria, and why would "perform CPR to Australian Resuscitation Council guidelines" ever appear in an LLND analysis when that is the very skill the student enrolled to learn? Standard 2.2 answers it through a single principle of proportionality. The LLND review is a suitability and support-planning tool calibrated to the skills a student needs to engage with the training, not a pre-assessment of the competency the training exists to develop, and not a barrier to enrolment. This article maps how far the analysis must go, and what it means for RTOs, their trainers and the students they enrol.
The Tension Behind the Question
A question raised at a recent ASQA webinar identified a genuine tension in how language, literacy, numeracy and digital literacy requirements operate in the VET system. LLND must be aligned to the foundation skills and performance expectations of each unit, but some units have no explicit foundation skills section and instead express their demands through performance criteria. So how deeply should the LLND analysis reach into those performance criteria? And, taking HLTAID009 Provide CPR, where performance criterion 2.1 requires CPR to be performed in accordance with Australian Resuscitation Council guidelines, why would that appear in an LLND analysis at all when the student enrolled specifically to learn that skill? The answer runs through Standard 2.2, its interaction with Standards 1.1 and 2.4, and a proportionality principle that governs how far LLND analysis must reach into any given unit. The short version: LLND analysis under Standard 2.2 is an enrolment suitability and support-planning tool. It is not a barrier to enrolment, and it is not a parallel assessment of the skills the student enrolled to learn.
1. The Statutory Purpose of Standard 2.2
Standard 2.2 requires the RTO to review, prior to enrolment, each prospective student's existing skills and competencies, including their language, literacy, numeracy and digital literacy, and, based on that review, to advise the student whether the training product is suitable for them. The performance indicators are specific: subsection (2)(a) requires procedures to conduct that pre-enrolment review, and subsection (2)(b) requires the RTO to advise each prospective student, based on the review, whether the product is suitable. The statutory purpose is suitability advice and the support planning that flows from it. It is not competency pre-assessment, not a screen designed to exclude students who lack the skills the product develops, and not a parallel LLND qualification to be passed before the student can engage with their chosen course.
This distinction matters for how RTOs design their tools. An LLND tool that functions as a barrier, turning away students whose literacy or numeracy sits below an arbitrary threshold without reference to what the qualification actually demands, is not satisfying Standard 2.2; it is contradicting it. The Standard asks whether the product is suitable for the student given their skills, and suitable means able to commence and, with appropriate support, complete, not already proficient. Where the review identifies a gap, the appropriate response is support during the training, not a refusal to enrol. The obligation to provide that support is grounded in Standard 1.1, which requires training to be structured and paced to support progress, with sufficient time for instruction, practice, feedback and assessment, and in the support and reasonable-adjustment standards. Good practice is to document, as a support plan, how an identified gap will be addressed during the training. The gap is a design and support input, not an enrolment veto.
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Suitability, Not Pre-Assessment |
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The pre-enrolment LLND review exists to determine whether the student's existing skills make the product suitable, and to plan the support that makes success achievable. It is not a pre-assessment of the competency the training develops. Its proper output is advice on suitability and a documented support response to any gap, not an enrolment decision that excludes a student because they do not yet hold skills the course is designed to build. |
2. Foundation Skills: Where They Appear and Where They Do Not
How deeply LLND analysis must reach into a unit is partly a question of how foundation skills are represented, which varies by training package, qualification level and unit. In many units, particularly in community services, business services and higher-level technical qualifications, foundation skills are listed as a distinct section identifying the specific reading, writing, oral communication, numeracy and learning skills required. Where they are explicit, the analysis is relatively straightforward: calibrate the review to whether the student's existing skills are sufficient to engage with the listed demands.
In other units, particularly practical and technical units in trades, health and emergency services, explicit foundation skills are absent or minimal. HLTAID009 Provide CPR, the webinar's example, sets out performance criteria, performance evidence and knowledge evidence, but has no explicit foundation skills section of the kind found in business or community services units. That absence does not mean the unit has no LLND demands. Every unit requires some language, literacy, numeracy and digital capacity: HLTAID009 requires the student to read and follow ARC guidelines, to understand numerical information about compression ratios and ventilation rates, and to communicate with a casualty and other responders. These are real demands, simply not labelled as foundation skills. What the absence means is that the analysis must take a different form: a functional analysis of the literacy, numeracy, oral communication and digital skills the student needs to engage with the training and demonstrate the performance criteria, rather than a checklist comparison against an explicit list. That is more demanding than ticking a list, but it is also more accurate and more proportionate.
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The Absence of a List Is Not the Absence of Demands |
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A unit with no explicit foundation skills section still creates LLND demands, embedded in its performance criteria, knowledge evidence and assessment conditions. Those demands must be identified by functional analysis: what the student must read, write, calculate and do digitally to engage with the training, not inferred from a missing list or imported from a generic benchmark. |
3. The HLTAID009 Question Answered
The webinar participant's instinct was correct. Performance criterion 2.1 of HLTAID009, performing CPR to ARC guidelines, is not an LLND demand. It is the competency outcome the student enrolled to achieve. Treating it as an LLND item, as though the student must already perform CPR before commencing, would be both illogical and contrary to the purpose of Standard 2.2. The LLND review is not a pre-assessment of the competency the product requires; it is an assessment of the foundational skills the student needs to engage with the training that develops that competency.
The correct analysis for HLTAID009 does not ask whether the student can already perform CPR. It asks what skills the student needs to engage with the training: reading and comprehending instructional material about ARC guidelines at an appropriate level; following numbered sequences of steps; understanding numerical information such as compression rates and depths; connecting an observed demonstration to written instructions; and completing the brief documentation required after performing first aid. For a short, practical, hands-on qualification with minimal written assessment, those demands are modest, and the review should be calibrated to that functional threshold, not to an inflated reading or writing level the unit does not actually require.
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The HLTAID009 Insight |
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The review should assess whether the student can read basic instructional material, understand simple numerical sequences, follow a demonstration and connect it to written steps, and complete basic documentation. It must not assess whether the student can already perform CPR. That is the competency the training develops, not a prerequisite for starting it. Over-mapping a practical first-aid unit against every performance criterion as if each is a discrete LLND competency does not produce a better review; it produces a disproportionate barrier and obligations the Standard does not impose. |
4. The Functional Analysis Method
For units without an explicit foundation skills section, the analysis reviews the performance criteria, knowledge evidence, assessment conditions and any range of conditions to identify the literacy, numeracy, oral communication and digital demands the student will meet. Four questions structure it.
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Functional analysis question |
What to identify and characterise |
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What must the student read? |
Instructional materials, workplace documents, technical manuals, regulatory frameworks, assessment tasks; characterise the level by text complexity, vocabulary and inference demand. The reading demand, not a generic reading score, sets the threshold |
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What must the student write or record? |
Assessment responses, workplace records, incident reports, care documentation, production records; characterise by length, complexity and formality. A daily prep list in a Certificate II differs sharply from clinical progress notes in a Diploma of Nursing |
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What numerical or measurement demands arise? |
Measurement, calculation, estimation, data reading, ratios, dosage or financial calculation; characterise against the Australian Core Skills Framework. Identify the specific operations the training requires rather than applying a generic benchmark |
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What digital skills does engagement require? |
Using the learning platform, submitting work electronically, operating equipment with digital interfaces, industry software, email or messaging; for many practical qualifications the digital demand relates to the equipment, not general digital literacy |
The threshold that emerges is one of functional sufficiency: can the student, with appropriate support, engage with the reading, writing, numeracy and digital demands the training creates? That is a capability question, not a level-comparison exercise.
5. The LLND Analysis Matrix
The following matrix frames the analysis across unit types, distinguishing explicit foundation skills analysis from functional analysis, and identifying the threshold and the support implication at each level.
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Unit type |
Analysis approach |
Threshold |
Support implication |
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Units with explicit foundation skills (many diploma-level BSB, CHC, HLT units) |
Map each listed foundation skill to its ACSF level and demand description; use the explicit list as the primary framework |
The minimum ACSF level at which the student can engage with the listed demands; use a specified reading level where given, or derive it from the demand description |
At or above threshold: note and proceed. Below: include specific support activities for the identified domain and level |
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Units without explicit foundation skills but with implicit demands (many Certificate II to III HLT, SIT, CPC units) |
Apply the four-question functional analysis; derive the threshold from the functional demands, not a generic benchmark |
Functional sufficiency: can the student, with support, engage with the demands the training creates? A capability assessment, not a level comparison |
Where a functional gap is found, specify a proportionate support strategy for that domain; a minor document-completion gap differs from a significant technical-reading gap |
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Mixed units with explicit and implicit demands (common in Certificate III to IV HLT and some SIT units) |
Apply explicit analysis to the listed skills and functional analysis to the criteria not covered; document both |
The higher of the two analyses where they overlap, without double-counting the same demand |
Consolidate both into one integrated support strategy, not separate plans for explicit and implicit demands |
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Short practical qualifications with minimal written demands (HLTAID009 and many Statement of Attainment units) |
Apply a proportionate functional analysis focused on the minimal demands the training actually creates |
Reflect the actual demands, often around ACSF Level 2 to 3 for reading and oral communication and lower for writing; do not apply a Certificate III benchmark to a short practical unit |
Where a gap arises in a genuinely minimal demand area, consider whether it is material; for oral and demonstration-based delivery, a writing gap may need no support strategy at all |
6. The Reasonable Adjustment Pathway Under Standard 2.4
Standard 2.4 requires reasonable adjustments for students with disability, including adjustments that enable the student to demonstrate competency, and it interacts directly with the LLND review. Where a review identifies a gap attributable to a disability or learning difficulty rather than to general educational background, the response is a reasonable adjustment under Standard 2.4, not simply a heightened LLND support requirement. A student with dyslexia entering a Certificate III in Construction will likely present a literacy profile below the reading and writing threshold for some units; the right response under Standards 2.2 and 2.4 together is a support plan that includes adjustments such as oral presentation of written content, extended time, and alternative assessment formats where the product permits, not a conclusion that the student cannot engage.
The word reasonable matters. An adjustment is reasonable if it does not alter the fundamental nature of the product, does not impose an unjustifiable burden, and still enables the student to demonstrate the required competency. Removing a genuine assessment requirement because the student finds it difficult is not a reasonable adjustment; it is an invalid assessment. Changing the format through which an unchanged competency is demonstrated is a reasonable adjustment. The review should therefore identify whether a gap is attributable to a disability, because that determines the pathway: a gap from educational background is addressed through training support under Standard 1.1; a gap from disability is addressed through reasonable adjustment under Standard 2.4. Many students present with both, and the support plan should integrate both responses.
7. Avoiding Over-Engineering: The Proportionality Test
The most common compliance problem with LLND tools is over-engineering: instruments more complex and demanding than the product they serve. Over-engineered tools cause three problems. They function as de facto entry tests that exclude students who could complete the training with support, contradicting the suitability purpose of Standard 2.2 and the inclusion intent of Standard 2.4. They create disproportionate administrative burden, a two-hour assessment battery for a two-day first aid course consumes resources better spent on the genuine support Standard 1.1 requires. And they generate support obligations that exceed what the product requires, for instance flagging a need for Certificate IV reading support to complete a Certificate II qualification.
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The Proportionality Test |
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A proportionate LLND tool assesses the literacy, numeracy, oral communication and digital skills the student needs to engage with this specific product, at the level those skills are genuinely required by it. If the tool tests skills at a higher level than the product demands, it is over-engineered, it operates as an exclusion mechanism, and it should be recalibrated. The question is never "how literate is this student in the abstract," but "does this student have what this training actually requires, with support." |
8. Sector Notes: CHC, HLT and CPC
These three training packages generate the largest share of LLND activity and the widest range of foundation skills structures. In CHC community services and early childhood, units at Certificate III and IV commonly include explicit foundation skills, with reading often around ACSF Level 3 and writing around Level 2 to 3, and the highest functional demand is usually oral communication, given the relationship-based nature of the work; the review should focus on reading care plans and procedures, writing basic records, professional oral communication, and the digital demands of the systems used. In HLT health, demands vary enormously, from a two-day first aid course to a Certificate IV in Allied Health Assistance, which is where proportionality matters most: the analysis for HLTAID009 must look nothing like the analysis for a longer allied health qualification. In CPC construction and plumbing, the reading demands centre on technical documents (plans, specifications, standards), the numeracy demands are often significant (measurement, estimation, areas and volumes, reading drawings), the writing demands are usually lower, and the oral communication is work-oriented (giving and receiving instructions, communicating safety), so the review should reflect that context rather than a formal academic standard. These figures are practical guidance, not statutory levels, and each RTO should calibrate against the actual units it delivers.
9. The LLND Record
Standard 2.2 requires the review to be conducted and its outcome to inform the suitability advice, which creates a documentation obligation. A defensible LLND record contains the following.
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Record component |
What it must contain |
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Review tool used |
The tool or instrument used; where different tools serve different contexts, the specific one used for this student; for a locally developed tool, its calibration rationale |
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Student's existing skill profile |
The student's identified levels in each relevant domain (reading, writing, oral communication, numeracy, digital), reflecting actual performance on the review, not a credential or self-report alone |
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Training product LLND demands |
The demands of the specific product, derived from the explicit foundation skills analysis or the functional analysis; the reference point against which the profile is compared |
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Gap identification |
Any gap by domain and level, stated specifically, not "reading gap identified" but, for example, "reading gap at the ACSF Level 2 to 3 transition for technical document reading in Units X and Y" |
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Suitability assessment |
The assessment of whether the product is suitable given the student's skills and the support available; where significant support is needed, the support plan must reflect it |
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Support strategy |
The specific strategies to address each gap, by domain and level, with the type of support, the point in the training it will be provided, and how its effectiveness will be monitored, not a generic reference to "LLN support" |
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Reasonable adjustment flag |
Where a gap appears to relate to a disability or learning difficulty, identification of that connection and a cross-reference to the Standard 2.4 adjustment process |
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Student acknowledgement |
A record that the student has been advised of the review outcome and the support strategies developed in response |
10. What This Means for RTOs
For an RTO building a defensible LLND process, the work falls in a clear order.
First, calibrate the tool to the product, not the abstract. Build or select LLND tools that test the skills each product genuinely requires, at the level it requires them, using explicit foundation skills where listed and functional analysis where not. A single generic tool applied across a diverse scope will be over-engineered for short practical units and under-specified for document-heavy ones.
Second, treat the review as a door, not a gate. Use the outcome to advise on suitability and to plan support, not to exclude students who could succeed with reasonable support, and route disability-related gaps to the Standard 2.4 adjustment pathway rather than treating them as ordinary LLND deficits. The suitability purpose of Standard 2.2 and the inclusion intent of Standard 2.4 both point the same way.
Third, document the chain. Record the tool, the student's profile, the product's demands, the specific gap, the suitability finding, the support strategy and any reasonable adjustment, and confirm the student was advised. A review that is conducted but not documented, or documented but not connected to a support response, satisfies neither the Standard nor its purpose.
11. Conclusion: A Door, Not a Gate
The depth of LLND analysis is governed by a single idea: proportionality. The review must reach as far into a unit as the unit's genuine demands require, and no further. For a document-heavy diploma that means a careful analysis of reading and writing against listed foundation skills; for a two-day practical course it means a brief, targeted check of the modest skills the training actually uses. The error the webinar question exposed, treating the competency a student enrolled to learn as though it were an LLND prerequisite, is the clearest sign of an analysis that has lost sight of what it is for.
Standard 2.2 is a suitability and support tool, not a screen. Read with Standard 1.1 and Standard 2.4, it asks a generous and practical question: can this student, with the support this RTO can reasonably provide, engage with this training and succeed? An LLND process that answers that question proportionately opens the door to students who can succeed with support. An over-engineered one quietly closes it. The Standard wants the door open.
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Summary: LLND Analysis Under Standard 2.2 |
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1. Standard 2.2 requires a pre-enrolment review of the student's skills, including LLND, and advice on whether the product is suitable; it is a suitability and support tool, not a competency pre-assessment or an exclusion screen. 2. Suitable means able to commence and, with support, complete, not already proficient. 3. Where a gap is found, the response is support during training, grounded in Standard 1.1 and the support standards, not refusal to enrol. 4. The competency a student enrols to learn, such as performing CPR in HLTAID009, is the outcome, not an LLND prerequisite. 5. Units without explicit foundation skills still have LLND demands, identified by functional analysis of what the student must read, write, calculate and do digitally. 6. The four functional questions cover reading, writing, numeracy and digital demands, with thresholds derived from the product, not a generic benchmark. 7. The analysis must be proportionate: it reaches as far into a unit as the unit's genuine demands require, and no further. 8. Over-engineered tools operate as exclusion mechanisms and generate support obligations the product does not require; recalibrate them. 9. Gaps attributable to disability or learning difficulty are addressed through Standard 2.4 reasonable adjustments, not heightened LLND requirements, and the two responses are integrated where both apply. 10. The LLND record should document the tool, the student profile, the product demands, the specific gap, the suitability finding, the support strategy, any reasonable adjustment, and the student's acknowledgement. |
References and Further Reading
Federal Register of Legislation (2025). National Vocational Education and Training Regulator (Outcome Standards for NVR Registered Training Organisations) Instrument 2025, Outcome Standards 1.1, 2.2, 2.3 and 2.4.
Australian Skills Quality Authority (2025). Practice Guides on Information, Training Support, and Diversity and Inclusion.
Department of Employment and Workplace Relations. Australian Core Skills Framework.
Disability Standards for Education 2005 (Cth). Federal Register of Legislation.