VU would like to highlight two areas which we suggest were overlooked in the panel s report:

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1 Professor Anne Jones Deputy Vice Chancellor & Director TAFE Stakeholder Consultation Apprenticeships for the 21st Century Expert Panel Report Department of Education, Employment and Workplace Relations Footscray Park Campus PO BOX MELBOURNE VICTORIA 8001 AUSTRALIA PHONE Dear Sir/Madam Victoria University (VU) believes that the Australian apprenticeship system is fundamentally important to meeting the skills needs of our industries and to providing individuals pathways to rewarding careers. As a dual-sector University that delivers vocational training to over 4,000 apprentices and trainees and also offers pre-apprenticeship and pre-vocational training, VU welcomes the opportunity to make a submission on the findings of the expert panel s report: A Shared Responsibility- Apprenticeships for the 21st Century. Firstly, VU would like to commend the panel on the identification of the need for system reform. While an integral component of our training and employment landscapes, current performance clearly demonstrates the Australian apprenticeship system has both significant inadequacies and vast opportunities for improvement. In-line with national trends, in recent years VU can report stagnant to declining levels of growth in apprentice and trainee enrolments and is strongly committed to improving outcomes for students. Demonstrating this commitment, and our broader commitment to the local industry and community in Melbourne s West, VU has approached this submission by addressing each of the Panel s recommendations as well as highlighting areas that we believe should be further considered by the Commonwealth Government. Attachment 1 provides VU s position on each of the panel s 14 recommendations. These views were developed through a consultation process with a range of stakeholders in the university community. VU would like to highlight two areas which we suggest were overlooked in the panel s report: 1. Failure to consider whether the current apprenticeships model, including apprenticeship curriculum and delivery practices, prepare young people for current and future industry needs; 2. Inadequate recognition of Registered Training Providers as key stakeholders in the apprenticeship system. To address the first issue, VU suggests the report could have gone further in considering what an apprenticeship of the 21 st Century might actually look like. In an increasingly complex and knowledge based economy it seems unlikely that current models of apprenticeships and traineeships and the vocational training that underpins them will be fit-for-purpose. In designing an effective model, consideration should be given to changes in external work environments, such as advances in technology and industry demand for a highly skilled and flexible workforce. There is already good evidence that current apprenticeship and traineeship curricula and delivery methods are not preparing young people to thrive in current industrial settings. For example, current apprenticeship programs tend to emphasise trades skills development at the expense of general education with the result that many apprentices complete without attaining literacy and numeracy skills at AQF level 3 the level required to ensure a good foundation for lifelong learning. If we consider, further, that technological change and other global economic pressures are rapidly changing work, there are compelling reasons to develop new apprenticeship programs that equip young people with the higher level skills that they will need to thrive as 1

2 workforce demands change. Most importantly twenty-first century apprentices need to be prepared for further learning. The lack of attention to the design of apprenticeship learning in the panel s report can perhaps be explained through the second major gap that VU has identified the failure to acknowledge that Registered Training Organisations (RTOs) play an integral role in the Australian apprenticeship system. Further consultations with RTOs would have resulted in greater insight from educators who work at the interface of course delivery and employer and student experience. In addition to course design, further opportunities for enhanced engagement with RTOs on issues such as appropriate support services for apprentices and trainees and ways to encourage competency based completion have been highlighted throughout attachment 1. I would also like to highlight the introduction of eligibility criteria for government support as an area of concern. While VU acknowledges the need for a more strategic approach to directing employer incentives and student support, we fear that an over-reliance on the needs of the broader Australian economy will lead to unintended inequalities for regional economies and for individuals. As outlined in the attachment, VU is concerned that employers may be dissuaded from taking on apprentices or trainees in employment areas that are ineligible for government support. Fewer opportunities for individuals to gain employment through apprenticeships or traineeships will eventually lead to poor outcomes for the unemployed, young people disengaged from school and for equity groups. VU urges the Commonwealth Government to take these concerns into account when considering the panel s proposal to this initiative. In closing, Victoria University would like to again acknowledge the significant work of the panel and the spirit of improvement and reform to the Australian apprenticeship system that the report brings. I thank the Commonwealth Government for the opportunity to submit this response to the report and for the opportunity to highlight areas that VU believe warrant further attention. Any queries on this submission should be directed to Kirsten Bright, Senior Advisor, Vocational Education, Victoria University on or at Victoria University looks forward to working with government, industry, employers and at the heart of our operations our students, for better outcomes across the Australian apprenticeship system for the future. Professor Anne Jones Deputy Vice Chancellor and Director TAFE 2

3 ATTACHMENT 1 RECOMMENDATION VICTORIA UNIVERSITY S RESPONSE 1. Establish a National Custodian to oversee reform that will ensure Australia has a high quality Australian Apprenticeships system that: responds to the needs of the economy supports nationally consistent standards for employment and training of apprentices and trainees focuses on retention and completion of apprentices and trainees supports high quality skill development to ensure all apprentices and trainees have well rounded and highly respected skills required by the economy. As a first step an independent taskforce should be established to work with the eight jurisdictions to align their systems and develop a framework and process for the establishment of the National Custodian. The taskforce would be led by an independent chair and have a representative from each state and territory government, a union and an employer group Victoria University strongly agrees that there is a fundamental need to streamline, harmonise and simplify the Australian Apprenticeship System to optimise outcomes for all users. While system reform would logically be coordinated from a national vantage point, without further details of the structure and responsibilities of a national custodian, its establishment is not supported. Victoria University suggests that the necessary reform could be driven through a national strategy, inclusive of all state and territory jurisdictions, industry, unions and RTOs. Victoria University notes the Panel s suggestion that a national custodian take the form of an independent statutory body (pg. 42). Victoria University feel s that the establishment of another formal body for users to interact with, may actually add to the complexity of the system. This observation is made noting that there is insufficient detail in the Panel s proposal on the implications a national custodian would have on the role of State and Territory Governments. 2. Enhance the quality and effectiveness of the Australian Apprenticeships system by clarifying the roles and consolidating the number of stakeholders in the system, ensuring that services are provided by the most appropriate provider, duplication of service delivery is reduced and administrative processes are streamlined. The National Custodian would ultimately be tasked with this role and will require Australian and state and territory governments in consultation with industry, unions and other key stakeholders to work together. In the interim the independent taskforce would progress this work. As a Registered Training Organisation (RTO) that has direct contact with apprentices, employers, governments and various other support bodies across the system, Victoria University strongly supports a comprehensive exercise to clarify roles, limit duplication of service delivery and to streamline administrative processes. Again, Victoria University does not necessarily believe that this needs to be the task of a national custodian in the form of statutory body, but could rather be driven by a joint working party or by COAG policy settings. Victoria University also notes that throughout the report, RTOs do not seem to be given the same level of consideration as stakeholders as others (employers, governments, industry and unions). Given the key role RTOs play in delivering skills for the economy, increasing support services to apprentices and working with employers, it is strongly suggested that RTOs should be consulted as a top-tier stakeholder to achieve the best outcomes for the system. Educators are able to contribute understanding of learning 1

4 design, skills development and literacy and numeracy requirements to the consultation expertise that other stakeholders cannot provide. In order for reform to occur at the necessary swift rate, this task should be actioned as a matter or priority. 3. Establish a formal accreditation process for the pre qualification and training of all employers of apprentices and trainees to ensure a nationally consistent minimum standard of high quality employment and training is provided. In addition establish an Excellence in Employment Scheme to recognise and reward those employers who have consistently demonstrated their commitment to excellence in training apprentices and trainees. Victoria University acknowledges the strong link between employer quality and apprenticeship and traineeship outcomes. Victoria University supports an approach that encourages employer quality through incentives and increased support. However, Victoria University does not feel that a one-size-fits all approach could be appropriately applied across the system, given the wide range of employers of varying sizes and missions that engage apprentices or trainees. Victoria University believes that individual accreditation may be a deterrent for some employers to take on apprentices, particularly those small to medium sized enterprises who may not have sufficient resources to manage additional accreditation and compliance measures. In such cases perhaps an alternative accreditation model could be developed. For example SMEs could be encouraged to join accreditation networks which would coordinate quality systems and accreditation on behalf of members. Obviously if SMEs are discouraged from taking on apprentices because of the accreditation process, the desired improved outcomes for the system will not be achieved. Furthermore, these challenges may contribute to an ongoing gap in quality between large and small employers. 4. Establish structured support for employers to provide high quality employment and workforce development experiences for eligible apprentices and trainees. The focus of Australian Government support should be on assisting employers to provide high quality on the job and off the job training through support services such as mentoring and pastoral care. Victoria University supports the Panel s findings on the need for additional support services, such as mentoring and pastoral care, to increase both the level of quality and completion rates of apprenticeships and traineeships. Victoria University believes this is one area which would particularly benefit from a joint national strategy and suite of harmonised support materials. Again, given the depth of experience providers hold on student support, Victoria University advocates for RTOs to be involved in the design of such policy and materials. For instance, providers could play an important role in ensuring elements, such as appropriate attention to selection and orientation are included in the design. Victoria University acknowledges that the quality of apprenticeships and traineeships is heavily linked to the apprentice/employer experience; however Victoria University would like to draw attention to the range of support services that RTOs currently offer students during training delivery. Obviously, the coordination and development of materials should not occur without a strong understanding of the types of things 2

5 already occurring in RTOs. For example, Victoria University has recently invested significantly in training for teacher and student support staff to deliver support services to apprentices and trainees. In addition to investing in staff capability, Victoria University has also invested heavily in resources, such as cars, laptops and phones that enable staff to better access apprentices and trainees out in the field. In the spirit of a shared responsibility this integrated support model should also be cognisant of ongoing funding requirements incurred by RTOs. 5. Redirect current Australian Government employer incentives to provide structured support services to eligible apprentices and trainees and their employers in occupations that are priorities for the Australian economy. While a wide range of occupations should be trained through apprenticeship and traineeship pathways, Australian Government support should focus on occupations that have tangible and enduring value for the economy both in the traditional trades and the newer forms of apprenticeships and traineeships, such as community services, health services and information technology. Victoria University acknowledges that the current one-size-fits-all approach to employer incentives for apprenticeship and traineeship takeup will be difficult to maintain and is not currently achieving targeted outcomes for individuals, employers and economies. While Victoria University sees merit in a more strategic approach to the allocation of support, limiting incentives to apprentices and trainees to occupations that are priorities for the Australian economy may have adverse affects to many. With a strong presence in Melbourne s Western suburbs, Victoria University has a deep commitment to servicing our local economy, our local industry and our local community. Victoria University are concerned that areas that are considered of priority for the Australian economy, such as traditional trades servicing resource -rich states and industries will be positioned to grow, where areas that are considered important for our local economy, but which may not compete with priorities of a national scale, will be positioned to decline. As one of Australia s largest tertiary providers to students with low socioeconomic -status (Low SES) (37% of our TAFE students are from a low SES background), Victoria University would also like to draw attention to the adverse effects the proposed eligibility criteria may have on equity groups. A flow on effect from such reform may be that some employers who would have previously taken up an apprentice or trainee may be discouraged from doing so if they are not eligible for support. This will lead to less employment options for Australians that may be disengaged from study or work. For instance, Victoria University currently delivers training components for retail traineeships to many young people, predominately women. Should these students be forced to compete for less traineeship opportunities, not only will their opportunities to enter the labour market decrease, but unemployment rates in our local economy would increase. 3

6 For these reasons Victoria University advocates that any modelling around eligibility criteria be more sophisticated than relying on specialised occupation lists and be extended to consider regional economic needs and the additional support needs of Low-SES and equity groups. (Victoria University addresses the need to broaden the Panel s initial recommendation on equity groups in recommendation 10). 6. Reinforce the need for a shared responsibility for the Australian Apprenticeships system by establishing an Employer Contribution Scheme in which employer contributions will be matched by the Australian Government. Employers who meet defined benchmarks for training and support of eligible apprentices and trainees would have their contribution rebated, either in part or in full. Victoria University acknowledges the need for industry and employers to increase their commitment and level of responsibility for the Australian apprenticeship system, however notes that the Commonwealth Government has announced that the introduction of an Employer Contribution Scheme will not be considered for implementation. Victoria University advocates that the Commonwealth Government pursue an alternative model to increase industry and employer responsibility, rather than keep the balance of responsibilities as they currently stand. 7. Facilitate a cooperative and flexible approach by governments and industry bodies to allow for the continuation of both training and employment of apprentices and trainees during periods of economic downturn. Early intervention should be a key element of this approach. Support for a range of measures to be in place until economic recovery occurs could include: reduction of work hours offset by additional training increased off the job training placement with other employers within the industry increased mentoring and support. Victoria University agrees with the Panel s finding that economic downturns lead to adverse outcomes across the Australian apprenticeship system and supports the Panel s recommendation to facilitate a cooperative and flexible approach by governments and industry bodies to allow for the continuation of both training and employment of apprentices and trainees during periods of economic downturn. Given that the Panel recommend an increase of off-the-job training, Victoria University again insist that RTOs should join governments and industry bodies in designing this strategy. Obviously, additional off-the-job training will require additional funding for RTOS. 4

7 8. Formally regulate the quality of VET in Schools within the VET system to enhance the consistency and quality of training across all jurisdictions and to recognise the potential of VET in Schools as a pathway into an apprenticeship or traineeship. Victoria University supports the recommendation of an increasingly comprehensive, and nationally consistent approach to regulating the quality of VET in schools through the VET system. Consideration should be given to how the system will relate to the expansion of Trade Training Centres and the need to ensure schools are adequately resourced to deliver VET qualifications. We hope to see more flexibility in the diversity of trades recognised for Commonwealth funded programs such as the Trade Training Centres. Given the changing nature of work and of young people, it is shortsighted to restrict these programs to a limited number of trades. 9. Increase national consistency in preparatory training by directing the National Quality Council to develop definitions for pre apprenticeship and pre vocational training. Victoria University supports improving nationally consistency, and therefore quality of provision and outcomes, of pre-apprenticeship and pre-vocational training. Again, RTOs are well placed to work with the National Quality Council to develop definitions and modelling. 10. Provide additional support for apprentices and trainees who face specific challenges, such as: Indigenous Australians disability located in regional or remote Australia having poor language, literacy and numeracy skills. Victoria University strongly support the recommendation to provide additional support to apprentices and trainees who face specific or additional challenges. Victoria University strongly suggests that support be extended to individuals of low socio-economic status, those who live in outer-urban areas and to youth. Australian Government support will be provided to these apprentices, trainees and their employers to assist in overcoming barriers to participation and completion of their apprenticeship or traineeship. Support will be through the provision of tailored structured support services and the continuation of some current Australian Government employer incentives. 5

8 11. Implement a strategy to raise the status of apprenticeships and traineeships including promotion as a valued career choice for both males and females. This should be led by the Australian Government, in consultation with state and territory governments, industry bodies and unions. The National Custodian, when established will lead the ongoing effort to raise the status of apprentices and trainees: Victoria University agrees with the Panel s findings on current poor perceptions of apprenticeships and traineeships as a career path and supports the development of a national promotional strategy. Victoria University suggests that such a campaign would benefit from consultations with RTOs to develop messages around positive experiences apprentices and trainees incur through off-the job-training. As a shared responsibility, Victoria University also feel there is a greater role for industry to play in both the development and funding such an initiative. and 12. Promote a culture of competency based progression in apprenticeships and traineeships, in partnership with industry bodies and employers. Additionally, a greater acceptance and achievement of competency based wage and training progression should be supported by all stakeholders. 13. Improve the implementation of Recognition of Prior Learning and Recognition of Current Competence and support provisions for such recognition in modern awards to ensure that flexibility and mobility are supported. Victoria University support the promotion of a culture of competency based progression (CBP) in apprenticeships and traineeships. Victoria University notes that the partnership described in the recommendation does not include RTOs. As major players in the successful implementation of competency based progression activities, Victoria University believes that RTOs should be consulted in the development of nationally consistent strategies to promote CBP, and should also be considered when allocating support to drivers of this cultural change. For instance, Victoria University is already working on a program to revitalise our apprenticeship and traineeship delivery and embed competency based practices, such as increased RPL and changed teaching and assessment practices. RTOs should be further supported to do this. While CBP should be promoted to employers as a priority, Victoria University also believe that ACAs have a strong role to play in facilitating competency based arrangements and should also be considered as key stakeholders and vehicles for change in a national strategy. 14. Support a review of apprenticeship and traineeship provisions, wages and conditions by Fair WorkAustralia, considering: the removal of barriers to competency based wage progression in modern awards apprentice and trainee award pay compared to going rates of pay age, diversity and circumstances of commencing apprentices and trainees Victoria University support a review of apprenticeship and traineeship provision, wages and conditions by Fair Work Australia and suggests that this review be fast-tracked. Victoria University also believes that RTOs would be a valuable stakeholder for consultations in this space. 6

9 allowances (travel, tools, clothing, course fees) cost to apprentices and trainees of participation in an Australian Apprenticeship part time and school based arrangements recognition of pre apprenticeship and pre vocational programs supervision ratios for apprentices and trainees. 7

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