Shared responsibilities, shared solutions Analysis of the Training Package Continuous Improvement Process for the Industry Skills Councils Forum

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1 Shared responsibilities, shared solutions Analysis of the Training Package Continuous Improvement Process for the Industry Skills Councils Forum April 2014 Page 0

2 CONTENTS Contents Contents... 1 Glossary... 2 Executive summary... 3 Findings of the analysis... 4 Shared responsibilities, shared solutions... 6 Shared responsibilities, shared solutions... 8 Introduction... 8 Context to the analysis... 8 Overview of Industry Training Packages... 9 What Training Packages are and how they re used... 9 How Training Packages are maintained Impacts on RTOs Quantifying the problem What is driving change? Points of amplification Tension between continuous improvement and the regulatory model Technical difficulties Inconsistent interpretation of change types Quality assurance prior to publication RTO capability to manage change List of solutions Appendix A: Count of changes to Training Packages, 15 August August Appendix B: List of all Training Package versions and drivers of change Appendix C: Drivers of changes to Training Packages, over time Appendix D: Count of Qualifications and Units of Competency Page 1

3 GLOSSARY Glossary ASQA Australian Skills Quality Authority CISC COAG Industry and Skills Council Industry Skills Councils ISCs ISC upgrade NATESE National Advisory for Tertiary Education, Skills and Employment National Skills Standards Council National Training Information Service National Quality Council NSSC NSSC Endorsement NTIS NQC Registered Training Organisations RTO TGA TPCMS Training Package Content Management System Training Packages Victorian Registration and Qualifications Authority VRQA WA TAC Western Australia Training Accreditation Council VET See: Australian Skills Quality Authority The national regulator for Australia s vocational education and training sector See: COAG Industry and Skills Council Chaired by the Australian Government Minister for Industry with members drawn from State and Territory ministers with responsibility for industry and skills portfolios. Replaces the former Standing Council on Tertiary Education, Skills and Employment (SCOTESE) Industry Skills Councils develop and maintain Training Packages and provide advice to governments on industry training. Also referred to as ISCs. See See: Industry Skills Councils A type of change to a Training Package that does not alter the vocational outcome and does not have to be submitted for endorsement See: National Advisory for Tertiary Education, Skills and Employment Previously responsible for independent policy advice and secretariat support to the key councils, committees and groups of SCOTESE. Functions of NATESE are being transferred to the Department of Industry as part of COAG s new governance arrangements for the national training system. Previously responsible for policy, standards and endorsement of Training Packages. Dissolved 3 April The previous National Register for VET in Australia, superseded by Also referred to as NTIS Predecessor to the National Skills Standards Council See: National Skills Standards Council A type of change to a Training Package that does alter the vocational outcome of a unit of competency or qualification and must therefore be submitted for endorsement. See: National Training Information Service See: National Quality Council A training provider registered by a VET regulator to deliver nationally recognised and accredited VET qualifications. Also known as RTOs See: Registered Training Organisations See: See: Training Package Content Management System The interface used by Industry Skills Councils to upload Training Packages to Industry specifications for the skills and knowledge required to perform effectively in the workplace A statutory authority responsible for the registration of VET providers who deliver accredited training to domestic students in Victoria only or Victoria and Western Australia only. Also accredits courses in Victoria See: Victorian Registration and Qualifications Authority See: Western Australia Training Accreditation Council A statutory authority responsible for the registration of VET providers who deliver accredited training to domestic students in Western Australia only or Victoria and Western Australia only. Also accredits courses in Western Australia The official National Register for VET in Australia and the authoritative source of information on Training Packages, qualifications, accredited courses, units of competency, skill sets and Registered Training Organisations. Also referred to as TGA Vocational Education and Training Page 2

4 EXECUTIVE SUMMARY Executive summary Training Packages serve as the central currency of Australia s Vocational Education and Training (VET) system. In 2012 there were 1.5 million publically funded students enrolled in Training Package qualifications. This accounts for over 75% of students in the VET system, a figure that continues to grow year on year. Training Packages are demand driven products responsive to the current and emerging skill of industry so by their very nature must be dynamic. As the rate of change within the economy increases, and that change impacts on individual sectors and job roles, Training Packages will continue to evolve. Transition from a supply-side system where training providers develop curricula at a change rate of their making, to a demand-driven system where industry and national VET policy largely dictate the rate of change, has not been without tension. In part this is about training providers and policy evolving from a centrally planned and funded system with long horizons to one where responsiveness and autonomy are paramount. It is also about the change rate within industries which will continue to gather pace regardless of whether the VET system or Registered Training Organisations (RTOs) are ready and able to respond. RTOs with weak business models premised on the status quo will struggle to remain relevant while those that continue to innovate and work alongside industry as they forge new markets and evolve their practices will thrive. This is not to say that parties involved in the Training Package Continuous Improvement Process and in getting Training Packages to the marketplace cannot do things more efficiently and more effectively to reduce the burden of change on the system. A healthy balance must be struck between updating Training Packages too slowly to maintain currency and equally what RTOs have described as change overload. The drivers of change to Training Packages are not well understood. This analysis shows that the stakeholders most impacted on and most critical of the volume of continuous improvement also contribute to the problem by virtue of the model for regulation, poorly designed systems, business processes and quality assurance. Problems that exist right along the supply chain have compounded to create an imperfect process in need of improvement. This report identifies a number of clear actions that can be taken by each stakeholder, Industry Skills Councils (ISCs) included, to significantly improve the efficiency and effectiveness of their part of the process while ensuring industry s evolving skill are still met by the VET system. As an evidenced based analysis, it brings together the complex strands of the problem and identifies: How much change is actually occurring What is driving the change Where pressure points exist in the system that amplify the impact of each change; and What can be done to reduce the impact. All stakeholders party to the development, endorsement, regulation, delivery and assessment of Training Packages must take responsibility for where the identified problems lie and work together to create a more robust, efficient and responsive continuous improvement process. Page 3

5 EXECUTIVE SUMMARY Findings of the analysis The extent and drivers of change Using historical data available on the national register the analysis identified the number of changes made to Training Packages during the period 15 August 2010 and 15 August This mirrors the timeframe examined by the Australian Skills Quality Authority (ASQA) in an earlier piece of work which brought the issue to the fore. With the assistance of ISCs, the modification histories of all Training Packages were then analysed to determine the drivers underpinning changes during that period. The analysis shows that rarely does a single driver trigger change. Usually multiple drivers play a role, and is testament to the fact that ISCs consciously cluster changes together in order to minimise impact on RTOs and other stakeholders. Because there are often multiple drivers for a single change, percentages attributed to the drivers for change do not total 100%. It is important to note that Training Packages analysed in this review were largely developed under previous policy for Training Packages, and the benefits of the new Standards for Training Packages particularly their capacity to limit the unnecessary impact of change - are still to flow through to the system and therefore not reflected in the report s findings. The analysis found that during the period 15 August 2010 and 15 August 2013: The majority of change to Training Packages was driven by industry need - 79% of all changes to Training Packages included industry driven change. Change was also driven by a succession of government policy reforms intensified by demanding implementation timeframes - 32% of all changes included changes due to government policy. During the period under analysis, several factors combined to create significant issues with data entry onto the national register. For the first 11 months of the review period, the National Training Information Service (NTIS) served as the national register. In July was put in place as the new national register involving mass data migration of all Training Packages from NTIS which in itself created errors. Quality assurance of Training Packages through has also been problematic and software enhancements to assist with the final editing and quality assurance of content were not introduced until late in This enhancement is reducing problems although extensive manual data entry and manual cross referencing across multiple fields remain an inherent weakness of During August 2010 and August 2013, 36% of changes had issues associated with data entry onto the national register. Change to Training Packages was also driven by maintenance policy mandated in the Standards for Training Packages (and previously the Training Package Development Handbook). 10% of all changes included some aspect of maintenance policy driven change. 8% of changes included corrections to errors caused by during the publishing process, such as needing to re-publish components that were lost in the data transfer, or errors in metadata and mapping that occurred during publication. Some of these errors originated during the migration of data from the NTIS to The analysis also shows that: Overall, changes to Training Packages increased over the period reviewed. National Skills Standards Council (NSSC) endorsements spiked during the 2011/2012 period as ISCs sought to put through submissions prior to the cut-off date for Training Packages developed under the former Training Package Development Handbook. Only a small number of Training Packages had a disproportionately large number of changes. Just seven (7) of the 58 Training Packages that fell within the scope of the analysis had six (6) or more Page 4

6 EXECUTIVE SUMMARY changes made over the three year analysis period. This equates to two (2) changes per year, about double the average for all Training Packages. The remainder of Training Packages experienced only moderate rates of change, and some were not changed at all. Over 62% of Training Packages (36 of the 58 in the scope of this analysis), changed on average once per year or less over the three year analysis period. Training Packages which experienced the greatest amount of change were often high volume Training Packages, with a large number of student enrolments. All but two (2) of the seven (7) most changed Training Packages are in the Top 20 Training Packages in terms of student numbers, suggesting that a single change to these Training Packages is likely to have more widespread impact given the number of RTOs with qualifications from these Training Packages on scope. Training Packages with a large amount of change also tended to comprise a large number of qualifications and Units of Competency. For example the Agriculture, Horticulture and Conservation and Land Management Training Package contains 91 qualifications and 802 Units of Competency, compared to an average of 29 qualifications in other Training Packages. The Property Services Training Package includes 50 qualifications. These Training Packages are large and cover multiple industries as a result of rationalisation policy driven by the then Australian National Training Authority in its bid to drive greater recognition of cross-industry skills. Points of amplification Consultation with stakeholders has identified several critical points within the Continuous Improvement Process that exacerbate the impact of changes on stakeholders, particularly RTOs. These include: 1. A fundamental tension between a VET system premised on being responsive to changing industry, and the current model for regulation where changes to Training Packages often trigger fee impacts and/or compliance activities on RTOs. 2. Sweeping government policy reforms which require change to all Training Packages with fixed and often demanding timeframes for implementation, and which frequently sit at odds with industry priorities and timeframes for change. 3. Technical and policy/process limitations of the system for publishing Training Packages on including: A content management system that relies too heavily on manual data entry and manual cross referencing, risking error and omission. Recent enhancements to now allow ISCs to more easily view and download pre-published content and check metadata of the Training Package are helping to address this issue, however extensive manual data entry and manual cross-referencing across multiple fields remains an inherent weakness of the system; Minor editorial corrections to provide more clarity, improve readability or correct content due to omissions during upload triggering the release of new Training Package versions; Incorrect or missing data on triggering inappropriate regulatory responses. For example, incorrect Training Package release dates on can lead regulators systems to apply incorrect transition periods to RTOs and has the potential to lead to RTOs being incorrectly non-compliant. 4. Differing interpretations of policy by ISCs when determining: What can be included in an ISC Upgrade ; What constitutes equivalency of outcomes in relation to new and superseded units of competency; and Page 5

7 EXECUTIVE SUMMARY The point at which quality assurance of Training Packages is undertaken prior to publication, and the rigour applied by members of the Training Package Quality Assurance Panel - a mandated step in the process which functions as third party QA. 5. The need for RTOs and State Training Authorities to better manage change and continuous improvement as part of a sustainable business model and industry driven VET system. Shared responsibilities, shared solutions All stakeholders can take steps to improve the effectiveness of the Continuous Improvement Process, minimise the number of changes to Training Packages, and reduce the impact of changes on the system. The following lists opportunities for improvement, all of which are discussed in more detail within the report. Solutions for Industry Skills Councils 1. Adopt a set of guiding principles to ensure a more consistent and purposeful approach to implementing the Training Package Continuous Improvement Process. These could include: a. Limiting full endorsements of Training Packages to once annually (except where extraordinary industry circumstances dictate, for example changed market access requirements, legislative, regulatory or licensing changes); b. Undertaking proof-reading and final content edit on the pre-published version of the Training Package now available on c. Building capability across ISCs to ensure currency of knowledge in respect to and consistent interpretation of standards and guidelines 2. Work with to correct existing errors and inconsistencies on 3. Work with to identify system enhancements that improve the capacity for prepublication quality assurance. 4. Undertake a review of how ISC upgrades are used to change Training Packages - particularly what constitutes a no change to outcome - with a view to development of clearer policy and greater consistency of interpretation by ISCs. 5. Undertake a review of the interpretation of equivalency for new versions of units of competency and qualifications, and develop clear policy to improve consistency and appropriate interpretation across ISCs. Solutions for government and VET policy setting bodies 6. Introduce an agreed authorising process to allow simple editorial corrections to be made to Training Packages without triggering regulatory changes. 7. Undertake cost benefit and impact assessment tests prior to significant policy reforms being agreed, to consider timeframes and the impact on Industry, RTOs, ISCs and other stakeholders. 8. Align timeframes of multiple VET policy changes to minimise the number of changes required to Training Packages. 9. As part of a broader review of quality assurance arrangements for Training Package development, endorsement and publication: a. Evaluate the role and effectiveness of the new Training Package Quality Assurance Panel arrangements; b. Develop a national approach towards capability building among RTOs in managing change in the implementation of Training Packages to address poor compliance. Page 6

8 EXECUTIVE SUMMARY 10. Analyse underpinning policy for the Standards for Training Packages to ensure it supports consistent interpretation in the development and maintenance of Training Packages. Solutions for regulators 11. Review the business rules and fee structures applied by regulators to recover costs with a view to greater compatibility with a system premised on responsive and dynamic Training Packages. Solutions for Increase the functionality and usability of the national register, by: a. Eliminating problems with data freeze and lag time to enable ISCs to efficiently develop Training Packages directly on the Training Package Content Management System (TPCMS). b. Enhancing by: a. programming dynamic relationships between Training Package components (such as automatic updating of codes); and b. replacing manual entry of identical data into multiple fields with automated updates across related fields. c. Investigating the implications of managing notifications of change at the unit of competency or qualification level to only notify RTOs of the change if they have the relevant unit or qualification on their scope of registration; d. Publish a formal link to the ISC Continuous Improvement Plans on to enable RTOs and State Training Authorities 1-3 years advance notice of planned change to Training Packages. 13. Work with ISCs to correct existing errors and inconsistencies on Page 7

9 MAIN REPORT Shared responsibilities, shared solutions Introduction Building a world-class workforce requires Training Packages to reflect the latest industry practice, technology, licensing and market access requirements. Change to Training Packages can be a point of tension for Registered Training Organisations (RTOs), particularly if they struggle to maintain the vocational currency of their practitioners, equipment and resources in line with the changing of industry. Industry Skills Councils (ISCs) consider this to be a matter internal to each RTO and the viability of its business model within in a highly competitive marketplace of close to 4700 training providers. 1 There are however, legitimate concerns around the efficiency of the Continuous Improvement Process for Training Packages, the volume of change, and whether it is being driven by industry or other factors. All parties are keen to reduce the burden on RTOs and the system more broadly but without compromising the ability of Training Packages to respond to the of industry. As the bodies responsible for continuous improvement of Training Packages, ISCs have undertaken an evidenced based analysis of the Training Package Continuous Improvement Process to identify precisely how it can be made more efficient. The findings of this analysis highlight opportunities for improvement for action by all stakeholders, ISCs included, and which together will deliver an effective and efficient process. The aim of this work is to assist with the design and implementation of new policy to improve the delivery of skills to the Australian economy. Context to the analysis In 2013 the national VET regulator, the Australian Skills Quality Authority (ASQA), undertook a desktop analysis of the changes to Training Packages for the period Aug 2010 August 2013 which brought this issue to the fore and crystalised the need for a more efficient and effective process. ISCs have sought to expand on ASQA s work by undertaking a more detailed analysis of both the quantum of change and the drivers of change what they are and whether they add value to the system. The analysis is occurring in a changing policy environment. As of 3 April 2014, the COAG Standing Council on Tertiary Education, Skills and Employment (SCOTESE) and its committees have been dissolved. This includes the body responsible for Training Package policy, standards and the endorsement of Training Packages, the National Skills Standards Council (NSSC). At the time of writing, Ministerial decisions about governance arrangements for the VET sector are yet to be announced and until this occurs no Training Packages will be considered for endorsement. It is also important to note that the Training Packages analysed in this review were largely developed under previous policy for Training Packages, and the benefits of the new Standards for Training Packages particularly their capacity to limit the unnecessary impact of change - are still to flow through to the system. 1 Table 1, p15 Page 8

10 MAIN REPORT Key policy changes that significantly impacted on the period under analysis and the discussion within the paper include: Establishment of ASQA in 2011 which triggered changes to the nature of VET regulation. Replacement of the previous national register for Training Packages in July 2011with some 11 months into the analysis period and which in itself created a number of errors during data migration. Introduction of new Standards for Training Packages in November 2012 which requires every Training Package to be redeveloped by 31 December Overview of Industry Training Packages What Training Packages are and how they re used Training Packages specify the skills and knowledge required to perform effectively in the workplace. Training Packages are not curriculum and they do not prescribe how an individual should be trained. RTOs use Training Packages as the basis for developing learning strategies to support individual learners, abilities and circumstances. 2 It is estimated that Training Packages cover around 85 per cent of Australian occupations. 3 Each Training Package is made up of the following: 4 1. Nationally endorsed components: Units of competency: the specifications of knowledge and skills required to perform in the workplace. Qualifications: created by packaging units of competency into meaningful groups to make up a nationally recognised qualification. Assessment requirements: specify the evidence and required conditions for assessing competency in the specified industry, industry sector or enterprise. Credit arrangements: between Training Package qualifications and Higher Education qualifications. 2. One or more quality assured Companion Volumes: This implementation guide is mandatory and must be submitted with the Training Package Case for Endorsement. Less well understood is that Training Packages are used in many contexts across the Australian economy as part of an integrated approach to skills development and workforce planning: They provide the standards and qualification structures against which RTOs train and formally assess skills of individuals. They are utilised in licensing, regulation and certification, and in the development of industrial awards. 2 Training Packages, What Are They?, National Skills Standards Council, accessed 1 April 2014, 3 National Industry Skills Standards: Taking Training Packages beyond training, Manufacturing Skills Australia, Service Skills Australia and E- Oz, This describes Training Packages as they exist under the new Standards for Training Packages. During the analysis period most Training Packages aligned to the old standards which did not include Assessment Requirements or Companion Volumes. Page 9

11 MAIN REPORT They are integrated into enterprise workforce development strategies and provide a structured framework for job design, recruitment, work organisation and skills audits, up-skilling and performance management in the workplace. They are leveraged by governments to give effect to specific policy imperatives or skill in the economy and to drive economic and social reform, for example, building drought preparedness. They allow industry to benchmark against national and international industry best practice. They provide a framework for career progression and support pathways into further education through VET in Schools programs and articulation, apprenticeships and traineeships and on-the-job training. They support national and international recognition of skills, portability of qualifications, and provide benchmarks for recognising informal learning and experience. 5 In July 2013, the Australian Chamber of Commerce and Industry, the Australian Industry Group and Australian Council of Trade Unions jointly signed an Industry Compact which reaffirmed their collective support for national Industry Training Packages as the central currency of Australia s VET system. In the accompanying media release, the peak bodies agreed: Countries that out-skill us will out-compete us in what s widely recognised as a global skills race. We need the VET system and policy makers to understand that Industry Training Packages aren t just a codification of skills and knowledge needed to work effectively in a given job role, they re one of industry s most prized strategic assets in building a world class workforce and securing our position in the global economy. 6 Prior to the establishment of Training Packages, there were in excess of 16,000 accredited courses developed by individual training providers to varying degrees of quality and currency. In recognition of the pivotal role skills play in a highly competitive global marketplace, and the need for a unified and coordinated plan for building a world class workforce, 1996 saw national agreement to introduce Training Packages with the very first endorsed in 1997 by the then National Training Framework Committee. They ensure that regardless of skill level, industry sector or where within Australia the training takes place, a learner s skills are nationally recognised and portable between enterprises and across jurisdictional boundaries. At their most elemental, Training Packages serve as the bedrock of a mobile, highly-skilled workforce. In March 2014 there were: 72 Training Packages Qualifications Units of Competency 7 From a peak of over 90 Training Packages which included enterprise Training Packages developed by major corporations and which have largely been absorbed the number of Training Packages, qualifications and units of competency have been progressively consolidated. This is in response to the strategic need for recognition of cross-industry skills and increasing convergence of job roles and sectors. In simple terms, rationalisation as it is often called has been driven by two strategies: 5 Manufacturing Skills Australia, Service Skills Australia and E-Oz, 2013, National Industry Skills Standards: Taking Training Packages beyond training. 6 Industry Skills Councils, 25 June 2013, Media Release: Industry leaders join to confirm Australia s VET qualifications as central to the challenges ahead by signing a A Compact with Industry. 7 At 31 March 2014, 74 Training Packages were listed as current on however two of these are listed in error: TDM07 and SUG02, both of which have been superseded. The count of Training Packages, Qualifications and Units of Competency has been adjusted to take this in to consideration. Page 10

12 MAIN REPORT 1. Combining sector based Training Packages into larger industry-wide Training Packages; and 2. Importing units of competency from other Training Packages rather than developing new or replacement units. In the context of this analysis, rationalisation and specifically the importation of units has added to the interdependent nature of Training Packages. For example, the unit of competency Apply first aid is imported by 157 qualifications, meaning any change made to it has wide ranging impact. How Training Packages are maintained As a core role within their funding agreement with the Commonwealth Government, ISCs are required to develop Training Packages to meet the skills of industry, and to provide clearly defined pathways into employment, up-skilling and reskilling for individuals and articulation pathways into higher education. The agreement requires ISCs to continuously improve Training Packages to reflect industry, other stakeholder inputs and relevant policy. The Continuous Improvement Process includes extensive nation-wide consultation with industry stakeholders, governments and RTOs, culminating in endorsement of the Training Package and its publication on the national register for Training Packages, Once published, new Training Packages or Training Package components flow through to RTOs via the systems of the national regulator (ASQAnet) and the state-based systems for RTOs registered with the Western Australian and Victorian regulators. Current approaches to regulation mean that changes to Training Packages often trigger new compliance requirements for RTOs such as applications for changes to scope of registration. 8 Publication may also initiate activities within State Training Authorities related to funding and apprenticeship arrangements. Figure 1 represents these processes and relationships. 8 An RTO s scope of registration comprises the Training Package qualifications, Units of Competency and state accredited courses which the regulator authorises them to deliver. Page 11

13 Figure 1 - Training Package Continuous Improvement and flow-on effects This diagram outlines the Training Package Continuous Improvement Process from development through to implementation by RTOs. It also highlights points along the supply chain where the impact of change to a Training Package is amplified, and where opportunities for improvements exist. Page 12

14 MAIN REPORT Types of changes Two main types of changes can be made to Training Packages, both of which have differing degrees of impact on RTOs: 1. NSSC endorsements: Where changes to endorsed components change their vocational outcome, the Training Package must be submitted for endorsement. 9 This results in a re-issue of the Training Package which triggers compliance requirements and regulator fees for those RTOs with the changed components on their scope of registration. 2. ISC Upgrades: Where a change to a Training Package does not change the vocational outcome of an endorsed component, it does not have to be submitted for endorsement. ISC upgrades are often made to provide greater clarity or to correct minor issues with the Training Package identified during implementation. 10 ISC upgrades do not lead to codes being changed or have fee impacts on providers, however RTOs with the changed components on their scope do need to check that their systems reflect the change and may need to undertake administrative changes such as updating marketing materials. 11,12 Figure 2 The Training Package Development and Endorsement Process 9 At the time of writing the NSSC has been dissolved and replacement arrangements for the endorsement of Training Packages have yet to be announced by the COAG Industry and Skills Council. 10 The exception is where the NSSC or its predecessor the National Quality Council (NQC) allowed ISC upgrades to be made in order to speed up the implementation of policy changes. 11 NSSC, Training Package Products Policy, p5 12 ASQA, Registering for revised training package components, p1 Page 13

15 MAIN REPORT Speed to market of Training Packages At the 3 April 2014 COAG Industry and Skills Council meeting, Ministers agreed on objectives for reform of the VET system, including the need for a national system of streamlined industry defined qualifications that is able to respond flexibly to major national and state priorities and emerging areas of skills need. 13 Industry stakeholders are concerned that the need to improve the Continuous Improvement Process will generate an arbitrary policy response to artificially slow the rate of continuous improvement which will achieve little more than compromise the currency, industry relevance and agility of the national training system to respond to changing. The findings of this analysis prove that without all stakeholders addressing a range of issues within the Continuous Improvement process, there is little to gain and much to lose in such a move. Speed to market is about more than just getting the product endorsed. No matter how quickly a Training Package gets to endorsement, it may still take a further 6-12 months before an RTO is able to access public funding or respond to the changes and deliver the qualifications or units. This is particularly true for RTOs that have only one or two enrolment intakes per year, as is often the case in TAFE. State and territory funding arrangements and regulatory transition activities also lengthen the time between endorsement and new Training Packages hitting the ground (Figure 3). 14 Figure 3 Post-endorsement processes that impact speed to market Training Package endorsement Publication on training.gov.au Production of Implementation Guides/nominal hours State and territory funding decisions Declaration of Apprenticeships/ traineeships RTO transition to new qualifications/ units First intake of students in new qualificaiton/unit 6 to 12 months In 2008 a new Training Package development and endorsement process was put in place to address concerns that Training Packages were too slow to reflect industry changes and not responsive to the nation s skill. In 2010 a review of the process found that the majority of stakeholders viewed it as smoother, more streamlined and less bureaucratic. No stakeholders expressed a view that a return to the older, slower process would be a positive step. 15 Concerns about the rate of change There are however legitimate concerns about the number of changes to Training Packages in recent years. While industry is the primary client and driver of change to their specific Training Package, the introduction of a number of significant VET policy reforms under the previous government led to sweeping changes to all Training Packages in a short space of time. Change will continue to ramp up over the next period as ISCs redraft every Training Package to meet the new Standards for Training Packages introduced by the NSSC in November Exacerbating this are the technical limitations of which serves as the platform to publish Training Packages. As an off-the-shelf system adapted to Training Packages rather than software designed specifically for Training Packages, its functionality is not ideal, although a number of recent enhancements have helped in this regard. staff work with ISCs behind-the-scenes to fix issues as they arise, but there are a number of outstanding concerns that remain around the need for repetitive manual data entry and manual cross referencing, the lag time of the system when used by developers and its capacity to freeze or lock up for extended periods during usage all of which contribute to ISCs frustrations and the potential for error. 13 Communiqué for the COAG Industry and Skills Council Meeting, 3 April NQC, Speed to Market of Training Packages, December 2010, Final Report, p5 15 Ibid. Page 14

16 MAIN REPORT Impacts on RTOs Some stakeholders, particularly RTOs and regulators, are concerned that the number and rate of changes to Training Packages are excessive and impact too greatly on RTOs. The costs to providers in terms of changes to their business operations, updating their delivery and assessment materials, ensuring staff are abreast of the changes, changing their promotional materials websites and handbooks, advising students and (where necessary) transitioning them into new qualifications; as well as the fees charged by ASQA, are real costs and a significant burden on business. 16 Recent consultations with RTOs by COAG s VET Reform Taskforce noted that in some cases Training Packages are not sufficiently responsive and flexible, while in other instances there is change fatigue from the amount of Training Package updates. 17 The relationship between the Training Package Continuous Improvement Process and the regulatory model used by regulators sits at the heart of this tension. Regulatory impacts of change Currently three VET regulators operate in Australia the national regulator the Australian Skills Quality Authority (ASQA), Western Australia Training Accreditation Council (WA TAC) and the Victorian Registration and Qualifications Authority (VRQA). Each regulator has different business rules and fee schedules, however all charge fees based on the requirement to transition to new Training Packages. 84% of RTOs are registered with ASQA (Table 1). When a Training Package transitions from one version to the next a change is signalled in the data link between and the national regulator s registration system ASQAnet. A range of regulatory activities are activated that affect every RTO with the changed units or qualifications on their scope of registration. Where a Training Package is updated through an ISC upgrade the impact on RTOs is lessened as there is no requirement to apply to update their scope and no associated fees. They are however, required to ensure they reflect the change in their internal RTO systems and practice as appropriate, so there is usually administrative work involved checking and updating systems, and possibly updating marketing materials. Table 2 outlines the regulatory and fee impacts of Training Package changes on RTOs registered with ASQA. Where multiple full version changes are made in a short period of time RTOs may be faced with paying multiple fees and making multiple changes to programs to ensure they remain compliant. RTOs who quickly transition to the new Training Package may find they are penalised for doing the right thing, paying much higher fees than RTOs that take longer to transition and skip intermediate versions. ASQA has had to change its business rules and refund fees to accommodate these situations. All of these scenarios highlight a fundamental tension between the fee-for-service regulatory model and a system premised on the concept of continuous improvement of VET qualifications. 16 ACPET, August 2013, More changes to Training Packages, 17 VET reform taskforce, Australian Government Department of Industry, Summary of stakeholder feedback from Canberra workshops February 2014, Page 15

17 MAIN REPORT Table 1 Number of RTOs registered with the three VET regulators, as at 1 April Regulator Number of RTOs % of total RTOs Australian Skills Quality Authority (ASQA) 3,937 84% Western Australia Training Accreditation Council (WA TAC) 342 7% Victorian Registration and Qualifications Authority (VRQA) 415 9% Total 4, % Table 2 Regulatory impacts on ASQA RTOs of different types of Training Package changes 19 Change to Training Package Implication for RTO Regulator fees Endorsed change Qualification or unit no longer exists in the new version of the Training Package. RTOs have 12 or 18 months to teach out the unit of competency or qualification. During that period they cannot accept new student enrolments. No fees apply. Qualification or Unit of Competency superseded by non-equivalent product The RTO must teach out the previous product and also apply to ASQA to add the new product to their scope. Full fees apply. Qualification or Unit of Competency superseded by an equivalent product The RTO must teach out the previous product. Transition fees apply. New product is released that did not previously exist. If the RTO wishes to be able to teach the new product they must apply to ASQA to add the new product to their scope. Full fees apply. ISC Upgrade Change to content not changing its vocational outcome The RTO must ensure their delivery, assessment and procedures reflect the change. No fees apply. 18 Data provided by ASQA 19 NOTE: ASQA has reviewed these processes and some of these business rules will change to reintroduce flexibility to the teach-out arrangements and reduce the impact to providers. These business rules are current at the time writing. For more information see Page 16

18 MAIN REPORT Quantifying the problem There has been extensive commentary and anecdotal statements about the volume of change to Training Packages however this analysis has sought to quantify the actual amount of change based on the hard evidence in the national register. Using as the primary source, the modification history of every Training Package over a three year period was analysed in detail. Any conflicts between information on summary tables and within the Training Package modification histories/companion volumes were reconciled by direct verification with each ISC. The scope for the analysis encompassed: Training Packages released on and its predecessor between 15 August 2010 and 15 August This time period was chosen to mirror that used by ASQA in an earlier analysis; Both ISC upgrades and NSSC endorsements, acknowledging that both have impacts on RTOs, although to differing extents. The analysis does not include behind-the-scenes or system updates to to correct minor technical problems or errors caused during the upload process as these do not generally cause a new version of the Training Package to be released. The results have been extensively verified with individual ISCs and the full list of Training Package versions and the drivers of change are published in Appendix B. Limitations of the data Although using the same source of data and same time span, there were significant problems in reconciling the results with those identified by ASQA in its earlier desk top analysis. Consultation with ASQA has led to an acknowledgement by both parties that it is very difficult to reconcile the two analyses, despite methodologies that are essentially the same. This may be due to discrepancies in the information on and the published Training Package. This highlights a significant problem with the existing data on where accurately monitoring change is next to impossible when errors and discrepancies exist in the official records. The volume of change The analysis shows that changes to Training Packages have increased over the last few years, from 59 total changes in 2010/2011 to 70 total changes in 2012/2013 (Figure 4). This total includes both ISC upgrades and NSSC endorsements. NSSC endorsements spiked in the 2011/2012 period, while at the same time less ISC upgrades occurred, indicating significant change to Training Package content occurred during that time. This may in part be due to ISCs seeking to put through submissions prior to the cut-off date for Training Packages developed under the previous development policy, the Training Package Development Handbook. Despite this, statements that Training Packages are changing too often are misleading as although some Training Packages have changed many times in the last few years these are in a very small minority. Just seven (7) of the 58 Training Packages that fell within the scope of the analysis had six (6) or more changes made over the three year analysis period. 20,21 This equates to two (2) changes per year, about double the average for all Training Packages (Table 3). The remainder of Training Packages have experienced only moderate rates of 20 At 31 March 2014, 72 Training Packages were current on however for the purposes of this analysis (and based on the approach taken by ASA in its earlier analysis): Six (6) Training Packages are currently in transition to the new Standards for Training Packages so multiple versions of it appear on These multiples have been rolled into the one record. Superseded Training Packages that were current during the analysis period have also been counted as part of the one record. The eight (8) Enterprise Training Packages have been excluded. 21 Appendix A Page 17

19 MAIN REPORT change, and some have not changed at all. Over 62% of Training Packages (36 of the 58 in the scope of this analysis) changed on average once per year or less over the three year analysis period. 22 The Training Packages which experienced the greatest amount of change were often high volume Training Packages, with a large number of student enrolments. All but two (2) of the seven (7) most-changed Training Packages are in the Top 20 Packages in terms of student numbers. This suggests they will have an impact on more RTOs as they are more likely to have qualifications from these Training Packages on scope. 23,24 Predictably, Training Packages with a large amount of change also tended to have a large number of qualifications and Units of Competency within them. For example the Agriculture, Horticulture and Conservation and Land Management Training Package include 91 qualifications and 802 Units of Competency. The Property Services Training Package includes 50 qualifications and 648 Units of Competency, compared to an average of 29 qualifications and 307 Units of Competency in other Training Packages (Appendix D). 25 It is unsurprising that Training Packages such as these will change more often than smaller Training Packages with only a small number of qualifications. The rate of change differs between Training Packages, and care should be taken when interpreting these averages. After the initial development of Training Packages in the 1990s, Government pushed for their widespread consolidation to better recognise common skills and job pathways between sectors and industries. As a result, a single Training Package can cover several industries and many more industry sectors. For example, the Construction and Property Services ISC and the Community and Services and Health ISC each maintain two Training Packages however the industry coverage is extensive and includes dozens of major industry sectors Figure 4 Number of changes to Training Packages, 15 August August 2013 Number of changes ISC Upgrade NSSC Endorsement Total Changes / / /2013 Years changes were made NOTE Years are from 15 August to 15 August the following year, i.e. 2010/2011 refers to the period 15 August 2010 to 15 August Appendix A. 23 Currently only publically funded VET activity is captured in the data, although this will change with new measures to collect total VET activity. Use of Training Packages by private RTOs and enterprise based RTOs is not currently collected. 24 NCVER, Students and courses 2012, p14 25 Source: Page 18

20 MAIN REPORT Table 3 - Average number of changes by ISC during the analysis period, including NSSC endorsements and ISC upgrades Industry Skills Council Average over the 3 year analysis period Average changes per year AgriFood Skills Australia Innovation and Business Skills Australia Manufacturing Skills Australia Construction and Property Services Industry Skills Council E-Oz Energy Skills Australia Service Skills Australia Government Skills Australia Transport and Logistics Industry Skills Council Community Services and Heath Industry Skills Council Auto Skills Australia ForestWorks Industry Skills Council Skills DMC All Training Packages Page 19

21 MAIN REPORT What is driving change? This review is not only concerned about the quantum of change. It also looks deeper into the drivers of change to identify those which are legitimate and add value to the relevance of the system, and those which are borne from poor policy, business process or action. Primarily, industry drives changes to Training Packages which are adjusted through the Continuous Improvement Process as Australia s skill shift. In recent years however, successive government reforms to VET policy as well as the technical limitations of the new platform for publishing Training Packages have added to the number of changes made in a short period of time. This analysis at Appendix B looks specifically at the following drivers of change: 1. Changing industry 2. Introduction of new VET policy 3. Corrections to Training Packages post endorsement 4. Ongoing maintenance to Training Packages in accordance with existing policy 5. Publishing and system errors It is important to note that rarely does a single driver trigger change. Usually multiple drivers are responsible and this is testament to the fact that ISCs consciously work to cluster changes together in order to minimise impact on RTOs and other stakeholders. For example, where a policy change is required by government, ISCs will take the opportunity to make industry changes or editorial corrections at the same time, rather than put those changes through as another version release. 1. Changing industry 79% of all changes to Training Packages between 15 August 2010 and 15 August 2013 included some aspect of industry-driven change (Table 4). These include changes to reflect new legislation, regulation and licensing requirements, or advances in technology or industry practice. Industry-driven changes to Training Packages are flagged within ISCs Continuous Improvement Plans which are posted on each ISC s website and broadcast the changes to be made to their Training Packages over a one to three year horizon. Figure 5 shows that slightly more (37%) of the industry driven changes occurred during the 2011/2012 period (compared to 27% in 2010/2011 and 36% in 2012/2013). As the end-users of Training Packages, RTOs can provide valuable input about improving Training Packages, particularly to aid implementation. The most common avenue for RTO feedback is ISC Continuous Improvement Registers which are hosted on each ISC s website. Most ISCs report that the majority of feedback received through their registers is from RTOs, for some as much as per cent. Feedback is rarely related to content, but more often identifies where clarification is needed to aid implementation or typographical errors. RTO input is generally channelled through ISC Continuous Improvement Processes and verified by industry before being altered in the Training Package. 2. Introduction of new VET policy 32% of all changes to Training Packages between August 2010 and August 2013 included changes due to government policy reforms (Table 4). Significant VET policy reforms that resulted in sweeping changes to every Training Package during the analysis period, included: the embedding of Sustainability Skills into every qualification as part of the COAG Green Skills Agreement; new qualification packaging rules aimed at increasing flexibility for RTOs; new Standards for Training Packages. Page 20

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