Rebecca Taylor, 55, director of third-party training provider TayTell, and her daughter Heather Taylor (also known as Snelleksz), 39, swindled scarce public funds from tertiary institutions, including Bendigo Kangan Institute, in 2013 and 2014.

They pleaded guilty to two counts each of obtaining financial advantage by deception and in December 2023 Taylor was jailed for eight months.

She will be released on a correction order that will run for four years and involve 400 hours of unpaid community work.

Her daughter was placed on a three-year order with 250 hours of unpaid work.

The pair appeared in Melbourne County Court again on April 9, 2024, where the Office of Public Prosecutions made an application for a pecuniary penalty order (PPO).

The order, which can only be made after conviction, compels an offender to pay money for the benefits derived from criminal activity.

Previous forfeiture proceedings saw Taylor lose her "precious family home" in Hepburn Shire, which was deliberately built next door to her parents in order to provide them care, as well as cars and superannuation funds.

A PPO is discretionary and restorative, meaning the non-compulsory order must restore the offender to the position they were in before they committed and benefited from an offence.

Prosecutor Ashleigh Harrold said an extraordinarily large amount of money was defrauded by the offender and the order sought to disgorge those benefits.

She said the order was "quite fair" with her director reducing the amount sought from $2 million to just over $1 million.

But the court heard such an order was unlikely to be paid due to financial hardship.

Barrister Diana Price, representing Taylor, said because her client had lost her family home and superannuation, any PPO would set her "further back in time" than immediately before the fraud took place.

She said if not for a 10-year delay in the case, Taylor may have had the capacity to earn, save and buy other assets which would have satisfied the order.

"Because of the passage of time... we are in a position where they are facing a pecuniary penalty order where their lives are very different to what it would have been if an application was made in proximate time to the offences," Ms Price said.

Snelleksz, who was self-represented, told the court that if the order was granted and a sheriff or otherwise ordered it be paid, she would be homeless.

"We have no way of ever recovering from what has happened..." she said.

Snelleksz, who pleaded guilty to the offences after accepting a sentence indication, said if she'd been found not guilty at trial, she would not be arguing against the PPO in order to save her family home.

But Judge Gerard Mullaly said if Snelleksz was found guilty at trial she would have been jailed.

"You wouldn't be with your (family), you would not be seeing them for some time and you would have a pecuniary penalty order," he said.

"... The chances of there being a defence to this (at trial) were minimal to vanishing point."

The judge accepted a PPO would cause "quite catastrophic" hardship to Snelleksz.

He will hand down his judgement on July 12.

In 2013 and 2014 Taylor and Snelleksz falsely claimed more than $2 million from Warrnambool's South West TAFE and Bendigo Kangan Institute for training that never took place.

Enrolment forms and assessment workbooks were falsified in a process Taylor described in text messages at the time as a "sausage factory".