Service Skills Australia Submission: Proposed Standards for Training Providers and VET Regulators

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1 Service Skills Australia Submission: Proposed Standards for Training Providers and VET July 2014 Page 1 of 7

2 About Service Skills Australia Service Skills Australia is the Industry Skills Council for the service industries, one of 11 notfor-profit, independent organisations funded by the Australian Government Department of Industry to support skills and workforce development. The service industries encompass the following sectors: Wholesale, Retail and Personal Services (wholesale, retail, hairdressing, beauty, floristry, community pharmacy and funeral services) Tourism, Travel and Hospitality (travel, tourism, meeting and events, accommodation, restaurants and catering, holiday parks and resorts) Sport, Fitness and Recreation (sport, fitness, community recreation and outdoor recreation). Service Skills Australia s role and responsibilities are to: Provide integrated industry intelligence and advice to government, industry and enterprises on workforce development and skills needs for the service industries. Actively support the development, implementation and continuous improvement of high quality training products for the service industries, including training packages. Engage in workforce development activities and services for the service industries. 2

3 Introduction Overall, Service Skills Australia believes that the revised standards for Registered Training Organisations (RTOs) and VET regulators represent a significant improvement to the previous drafts and the current standards. In the revised Standards for RTOs, we specifically commend the requirement for industry responsiveness, as opposed to mere engagement, and the measures relating to the quality of assessment, particularly systematic validation of assessment. The greater clarity and removal of ambiguity within the revised Standards for RTOs, in conjunction with the greater specificity within the Standards for Training Packages (2013), will also considerably improve the quality of training and assessment. With regard to the revised Standards for VET, Service Skills Australia believes the focus on encouraging quality through general education and the provision of information is a move to best practice regulation. However, there are opportunities to further strengthen the revised standards for both RTOs and VET. These include: the expansion of industry involvement in assessment validation strengthened wording in relation to minimum competence requirements for trainers and assessors and auditors, including workplace assessors inclusion of a definition for volume of learning consideration of the measures that will be needed to bring about cultural change in regulators the inclusion of industry experts in audit teams for technical areas clarification in the wording related to the accreditation of courses by the regulator. To assist the VET Reform Taskforce in their review of the standards, our submission will provide further detail on the areas that we believe to be particular strengths or opportunities for further improvement. Standards for Registered Training Organisations (RTOs) 2014 Industry responsiveness The move to meaningful industry engagement which results in a demonstrable effect on training and assessment and the currency of industry skills for trainers and assessors has been an important shift in the revised Standards for RTOs. Combined with the requirement of an annual declaration of compliance with the standards to the regulator, this will ensure that industry engagement is genuine, rather than a tick and flick exercise. Service Skills Australia strongly supports this mandated role for industry, which will contribute to the creation of a truly industry-led system. We are also pleased to see the focus on the currency of industry skills of trainers and assessors and the industry relevance of training resources. This reflects the principles of quality that industry sees as vital, and hence, the areas of accreditation (in conjunction with quality facilities) under Service Skills Australia s Right Way program. 3

4 The inclusion of a definition of industry engagement is also an important and welcome addition, as it will provide clear guidelines for RTOs on how to improve in this important area. Assessment Clauses 1.8 and 1.9, which relate to the RTO s assessment system, are critical components of the revised standards that will ensure quality outcomes for industry. Service Skills Australia is particularly pleased to see the inclusion of an assessment system measure. This represents an adoption of the recommendation contained in the VET quality project (2013), which was jointly commissioned by the industry skills councils. We also welcome the inclusion of systematic validation of assessment and the clear guidelines in relation to who this can be undertaken by. This is further strengthened by the guidance in the standards that industry experts can be involved in the validation of assessment to meet the requirements of (a) and (c) under Clause 1.9. Indeed, we believe there would be value in mandating the use of industry experts in all validation of assessment activities. Alternatively, this could be specified for high-risk areas at a qualification or unit of competency level within training packages, as recommended in the VET quality project. We also note the cross-reference to the Assessment Requirements component of training packages within Clause 1.8, which will give effect to the inclusion in the Standards for Training Packages and enable regulators to enforce the assessment requirements that industry deems to be essential. This will ensure greater consistency and rigour in the assessment activities of RTOs. Finally, the inclusion of the Principles of Assessment and Rules of Evidence are also important. In the design requirements of the Standards for Training Packages, these principles are no longer included in the mandatory text and, therefore, there was a risk that these underpinning principles would be lost. Trainer and Assessor Requirements In relation to the specification of competency requirements for trainers and assessors within clauses and Schedule 1, we are concerned that there are aspects that are unclear. We request that the standards further clarify the capacity to involve workplace assessors in the assessment judgment. Given that workplace assessors are unlikely to hold the skill set or qualification described in Schedule 1, it is currently unclear within the standards whether a workplace assessor would be able to be a member of the assessment team. It is crucial that this be clarified, as industry strongly supports the role of workplace assessors. Additionally, we have some reservations about the designation of a specific unit of competency, qualification or skill set. Given these will soon be reviewed as part of the transition to the Standards for Training Packages, we can already expect these to be outof-date rather quickly. Furthermore, we believe the wording or its successor could be unclear, particularly if the revised unit of competency, qualification or skill set is deemed non-equivalent. Similar issues apply to Schedule 1 of the revised Standards for VET. We would recommend the term equivalent replacement, or similar, be used instead. 4

5 Furthermore, once the specified unit of competency, qualification or skill set is superseded, confusion could arise as to whether holding the superseded component remains compliant with the standards. That is, if only the most current version can be held, this should be stated more clearly. It is also unclear as to why the table in Schedule 1 has the heading, Upon commencement of these Standards and prior to 1 January 2016, given the schedule will continue to apply after 1 January 2016, albeit without the option to demonstrate equivalence. Volume of learning The Taskforce is correct to identify that industry has concerns that in some cases qualifications have been delivered and assessed within an insufficient duration. Hence, we welcome the emphasis that has been given to this component of the AQF specifications. Once training packages are transitioned to the Standards for Training Packages, the volume of learning will be stated for the qualification. Standard 8 requires qualifications to comply with the AQF specification including volume of learning. As training packages are transitioned to meet the Standards for Training Packages, volume of learning requirements will be confirmed in consultation with industry. However, it should be noted that there is no field within the template for units of competency under the Standards for Training Packages that would enable similar duration information to be provided at the unit of competency level. Service Skills Australia, however, is concerned by the wording within Clause 1.1, which states that training and assessment practices, including volume of learning, are consistent with the requirements of training packages and VET accredited courses and enable each learner to meet the requirements for each unit of competency. We believe that this may further entrench the practice of unit-by-unit delivery and assessment and limit Recognition of Prior Learning (RPL). The standards should make some reference to the fact that the arrangement and sequencing of delivery and assessment is at the discretion of the RTO and should favour contemporary, integrated and holistic assessment practice. Furthermore, it is requested that the standards make it clear that volume of learning is in reference to a particular cohort in a particular mode. Additionally, to provide further clarity, we recommend that the term, volume of learning, be added to the Dictionary within Part 1 of the RTO standards. Standards for VET 2014 Regulator behaviour We strongly support the strengthened educative role of the regulator to provide general education and guidance materials, to encourage RTOs to improve their performance (as opposed to focusing on sanctions and compliance) and to adopt best practice auditing approaches. We believe that some providers are not clear as to what the standards call for, while others, given the ambiguity of the standards, have a fear that some practices will be considered non-compliant if certain interpretations are made. As such, greater guidance and a less punitive approach will allow providers to be confident in their ability to meet the standards and free them to focus on quality training and assessment, rather than be fixated on compliance. We are also particularly pleased to see that Clause 1.9 5

6 seeks to bring about greater consistency in the interpretation of the standards, as the lack of moderation has been a cause for concern to date. While these changes are to be commended, we urge the VET Reform Taskforce to consider how to ensure these standards are successfully implemented. Significant cultural change will be needed within VET regulators, particularly in relation to the approach and practices of auditors. Just as the providers need greater education and guidance, so too will the auditors. As noted by the Productivity Commission in its report, Regulator Engagement with Small Business (2013), Regulator culture is crucial. Those regulators with effective engagement practices have adjusted their culture by focusing on senior management priorities, training and skills of enforcement staff, performance monitoring, stakeholder feedback, and rewarding behaviour consistent with desired practices. In particular, we believe there is a need to focus on professional development and training related to the regulation of the new Assessment Requirements component of training packages, as well as assessment practices under a competency-based framework in general. A specific example of this need is the practice of holistic assessment. This is a practice that is supported by industry as it is reflective of workplace practices and therefore ensures the job readiness of graduates and hence, will be a focus of the companion volumes of training packages for the service industries. However, auditors reportedly prefer individual unit of competency assessment over holistic assessment. This has meant that providers have actively avoided holistic assessment for fear of being assessed as non-compliant, despite it representing best practice. We recognise that skills councils could also play a more proactive role by holding implementation workshops specifically for auditors, which would ensure that auditors are equally aware of the changes within training packages as training providers. While professional development and management practices within the VET regulators, coupled with the greater specification of assessment requirements within training packages, may go a long way towards ensuring auditors are auditing against what industry believes to be best practice, in some cases this may still be insufficient. For highly technical areas, we believe that industry experts may also be needed within audit teams to ensure the correct judgements can be made. Accredited courses An additional area that we believe could be further clarified is the wording in the standards in relation to accredited courses. The context statement for Standard 2, states that the development processes [for accredited courses] must involve consultation with industry stakeholders where they are relevant to industry regulation and occupational licensing. We are concerned that this may imply that industry consultation is not required for courses not related to industry regulation or occupational licenses, which of course would not be the case. 6

7 Conclusion Service Skills Australia thanks the VET Reform Taskforce for providing the opportunity to make comment on the revised standards for RTOs and VET, and would be happy to further assist the Taskforce in the future, should it be required. Overall, the revised standards for both RTOs and VET have been significantly improved, carefully balancing a focus on training and assessment quality and the management of the burden on providers. However, following the finalisation of the standards, we believe the strength of the system would be further improved with continued work on the adoption of the amendments to the Standards for Training Packages, as identified within the VET quality project. References Allen Consulting Group, 2013, VET quality project, report prepared for the Industry Skills Councils, the National Skills Standards Council and the Department of Industry Innovation, Science, Research and Tertiary Education, available at isc.org.au/pdf/vetqualityreport-final12apr2013.pdf. National Skills Standards Council (NSSC), 2012, Standards for Training Packages, available at nssc.natese.gov.au/training_packages/standards_and_policies. Productivity Commission, 2013, Regulator Engagement with Small Business, Canberra. 7