Melinda Brown General Manager P +61 2 9392 8100

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skillsiq.com.au

Re: VET Consultation on Unduly Short Course

Please find attached my feedback on this topic for your consideration.

Kind regards Rona

Rona Goold

Client Services IRC.

PO Box 3113

Robertson NSW 2577

Phone: 02 4885 2393

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Discussion questions for recommendation one

1. Recommendation ASQA proposes that a definition of the ‘amount of training’ that focuses on supervised learning and assessment activities be included in the Standards for Registered Training Organisations (RTOs) 2015, the Standards for VET Accredited Courses 2012, the Standards for Training Packages 2012 and the Training Package Development and Endorsement Process Policy.

• What are the important elements in a definition of amount of training in a competency-­‐ based training system?

The “amount of learning” needs to include supervised and non-­‐supervised learning activities, so that potential students have a clear idea of what is expected of them.

Amount of training needs to cover:

• a range of learning opportunities
• include supervised and non-­‐supervised learning activities
• in the time percentages that are applicable to the particular qualification in question, and
• clearly summarised in each qualification

for students to understand how much time would be expected for them to complete to gain a qualification and for a particular RTO to be clear as their responsibilities.

Amount of training could cover a range of these ten learning opportunities:

Face-­‐to-­‐Face education; Individual interaction, Group Interaction; Supervision/  Mentoring; Placements; Written Assessments; Research; Use of Equipment; Written Assignments; Auditory Assignments; Audio-­‐Visual Assignments.

The time percentages or proportions need to be those applicable to the particular type of qualification in question.

Note: Assignments work would include estimates of reading time required.

Reasons for differences may be related

• specifically to the type of employment available for that occupation (employed or self-­‐

employed), and

• to the skills required for that occupation (people oriented or technology oriented)

For example, for the training for an occupation such as an independent celebrant, the opportunities for placements and mentoring are minimal because:

• celebrants are self employed
• in competition with each other, and
• ceremonies are one-­‐off, once in a life-­‐time events (i.e. one may remarry but usually not to the same person, a person may have birthdays but not for the same number of years) that cannot be redone/ fixed if mistakes are made.

Therefore for course primarily about technology and using certain equipment may have percentages as follows:

Whereas people oriented qualification, such as counselling, may have a different mix of learning opportunities.

Here a qualification needs to have a greater proportion of face-­‐to-­‐face learning, and using assignments and technologies to provide the level of opportunities for students to apply theoretical concepts in practical situations.

Currently some Cert IV courses have 100 to 400 hundred hours placement, plus 10+ units of competency.

Celebrancy could not offer that type and simplicity of placement of say a Veterinary Assistance Course, without analysis of the skills and where opportunities of where these could be found for celebrancy students.

As ceremonies and celebrations are primarily inter-­‐personal events that are group based (family and community), a celebrancy qualification needs to have a very significant proportion of learning based upon face-­‐to-­‐face, individual/ couple interactions and group interactions where communication, public speaking and presentation skills can be practiced and assessed.

For people oriented occupations, online learning presents a particular set of challenges for the RTO s as these types of activities cost more to deliver.

For these types of qualifications, there needs to be a mandated minimum number of hours of face-­‐to-­‐face learning plus a mechanism for students to rank the quality of their training in an independent setting.

For example, if the VET system had a website that enabled students of the RTOs of a particular qualification, much like the Home Stayz or Air B&B websites have customers rank accommodation on a range of points then potential students may have an independent source of information.

Such a site would be useful for the celebrancy qualification, as celebrant associations could encourage celebrants to also give feedback after a period of time in the field to give feedback about the value of the training in the “work” place.

Fortunately most celebrancy students have assess to family or friends or community groups, who would be willing to act as potential clients in contacting the student, being interviewed by the student, and have a celebrancy student lead a ceremony or celebration (except a valid marriage)

– all parts of which can be recorded for assessment purposes.

RTOs should also be encouraged to look at alternative ways of delivering learning experiences. For example in Celebrancy community groups such as Rostrum and Toastmasters, Senior Citizens, business groups etc. could be approached for “placement-­‐type” experiences.

Technology is increasing a part of professions and businesses, which as self-­‐employed workers, is critical to their ability to access and/or interact with clients; and/or provide services to clients.

All RTOs need to develop strategies that use 21^st century technologies, such as:

audio-­‐recordings, online forums, closed face-­‐book groups, Skype interviews, creating and using websites (with functions to sell services and products), video recordings, open source learning platforms; etc.

in their delivery (including assignments) and assessments of a qualification.

The fact that many RTOs are business can undermine the incentive to spend time in reviewing and changing the delivery of the qualification to adapt to innovation and emerging roles, services or products.

What is your suggestion for a definition of ‘amount of training’?

For the qualification as being offered by an RTO, the “amount of training” is the total nominal hours of study (both supervised and unsupervised) for the core and particular elective units, in the time proportions for that range of learning opportunities that is being offered by that RTO.

• Where in the regulatory framework would this definition best sit to improve student outcomes?

The amount of training should be in

• the description of a Qualification or Accredited Course on the training.gov.au website as the range of nominal hours – minimal to maximum for that particular qualification and
• in course information on the RTOs website as the actual hours, this RTO expects and detailed in the various proportions required.

The AQF could also benefit from a minimum to maximum nominal hours translation. To a novice/ new learner, ½ a year to 2 years means nothing in terms of how many hours of work are actually involved.

• If an amount of training is defined,

How can industry ensure that innovation and flexibility in delivery of training is retained?

The industry through the IRCs should be able to make recommendations on Amount of training on a regular basis as well as be able to recommend certain changes to the qualification, without necessarily having to compete for funding in the overall VET.

The industry should not be the only part of the VET system to ensure innovation and flexibility in delivery of training. The RTOs also need to be required to demonstrate they are:

• keeping up with changes in educational techniques and changes in technology, and
• adapting their training delivery and assessments as a consequence

which it is understood, they are currently required to demonstrate as a part of the audit process.

What criteria could be used to ensure the RTO has the scope in which to justify its rationale for shorter course duration?

“Shorter course duration” has an underlying assumption that all training only needs to be to a minimal standard. Whilst it is vital to ensure all graduates have a minimal standard, the training could also be assumed to enable some of the group to go beyond minimal knowledge, skills and experience.

There should be little justification for a shorter course duration, unless all students in the course group have been assessed as competent in those areas that are being excluded from the course, as the volume of learning is based upon the assumption of all the students is that they are new learners (i.e. have no previous knowledge or skills in the field related to the qualification

For example, it cannot be assumed that because all the students in a particular group are over the age of 50 or that all have worked in a specific job role, that they will all have certain skills or knowledge in relation to a specific topic. Perhaps 80% do, or even 95% do, but no providing the required learning experiences to a student who is not competent, does no favours to student, the recipient/s of their services, their colleagues, their employers or the VET system.

This is not to say that some students are not able to satisfy some units (or partial units) through RPL. For example, if they have been a marriage celebrant and their registration has lapsed, they could potentially complete a shorter version of the course, only completing the units of competency that cannot be satisfied through the RPL process.

For a quality-­‐training product, the RTO needs to ensure that all students have the required knowledge and/or skills to be exempted from certain competency units in the course.

The student would be spending time by being assessed for

• recognised prior learning / current competencies if they have worked in the occupation, or completed a previous qualification that has been superseded, or
• the ability to apply their knowledge and skills in the new industry/ context, if they have passed the unit of competency delivered in another qualification

with unit’s assessment tools by the RTO to ensure that the student has the knowledge and skills competency required for the occupation).

So in reality the same volume of learning would apply whether the qualification is delivered as

• if all students as “new learners”, or

• a mixture of an apparent shorter course and extra time spent by the RTO and students to ensure all students are competent in the required knowledge and skills.

• For qualifications that would

have a prescribed duration, what are the implications for recognition of prior learning, credit transfer and transition of students when qualifications are updated?

As noted in 1.3 the volume of learning recognition of prior learning, credit  transfer and transition of students when qualifications are updated should be able to be accommodated.

• What is your suggestion for a definition of ‘new learner’?

A student who has no previous knowledge or skills or experience in the field related to the qualification and who has school leaver’s levels of literacy and numeracy and ability to participate in a learning environment.

What processes would an RTO need to establish to verify a student’s new learner status? All students need to be initially assessed for entrance into the qualification on their

• English literacy, language and numeracy
• their learning skills ability
• their identity

as part of their application for entrance into the qualification?

The identity issue has been highlighted in the celebrancy field, when some non-­‐English speaking graduates of the Certificate IV in Celebrancy are authorised by the government for marriage work, then attend professional development. At this point their inability to participate raises questions as to whether or not, the person who was qualified was in face the person who did the assignments and completed the work.

Any student not performing well at the application stage may be required to do LLN competency units before entrance into the qualification or the RTO organise support so that the learner can complete the course.

If a student has not completed a school leaving level qualification in Australia, and does not perform well in any area of the assessment for entrance, then the RTO needs to arrange an assessment in their first language and the need for prior LLN units or support services to assist their participation in the course.

What documentation would support audit processes?

The RTOs application process for entrance into the qualification, and how this is used for assessing literacy, numeracy and their learning skills ability.

The RTOs processes for managing those applicants who have not performed well in any area of the assessment for entrance, entrance into the qualification, both those with English as a first language and those not.

• In establishing a definition of amount of training, what are the implications for current definitions of volume of learning in the AQF?

As noted in 1.2 above the Australian Qualifications Framework needs to set overall number of hours required for that level of Qualification as Volume of learning.

How could the definition of an amount of training (which includes only supervised learning activities) best be aligned in order to inform the review of the AQF and volume of learning (which currently includes supervised and unsupervised learning activities)?

Volume of learning in the Australian Qualifications Framework needs to set overall number of hours required for that level of Qualification to include both supervised and unsupervised hours.

As noted in 1.1 above, our suggested definition of “amount of training” would equal the Volume of learning in the AQF in hours, but specify the proportions or percentages of the different learning opportunities to meet the Volume of learning for a specific qualification.

Discussion questions for recommendation two

2. Recommendation ASQA proposes the development of a risk-­‐based approach to the inclusion of an appropriate amount of training when training packages are revised or developed by industry reference committees (IRCs).

How well are IRCs equipped to provide technical expertise on course delivery arrangements to able to determine an appropriate amount of training?

The IRCs are made up of a unique range of representatives of relevant bodies for a set of occupations that have some common skills and target groups.

Therefore they can advise as to the amount of training in consultation with the industry workers, associations, and employers.

There should be at least one representative of an RTO / training provider in each IRC. It is imperative that the IRCs have a solid representation from RTOs, as they are the ones who understand how a unit of competency needs to be implemented.

Who is best placed tovprovide the technical expertise to IRCs to assist in determining an appropriate amount of training?

A competent trainer with an understanding of the VET system would be best placed as they have had practical teaching experience and understand the nuances of training.

An ASQA representative may be helpful for IRCs to understand how ASQA auditors will implement their recommendations.

How do RTOs provide input given they are largely excluded from IRC participation?

There needs to be a step in the system for

1. comments and feedback from RTOs to the IRC, and
2. for ASQA auditors to comment upon RTOs’ concerns to the IRC

before any major changes are recommended by an IRC to a specific qualification.

Any comments/feedback from the RTO that is not taken on board need to be addressed and reasons for the non-­‐inclusion should be noted and made available to the RTOs.

• ASQA has identified a range of factors that increase the risk for unduly short courses (page 11).

The impact is likely to be greater for those qualifications:

• with highest enrolment numbers (indicates market demand and extent of risk)
• needed to skill workers in growth industries
• offered to disadvantaged learners
• required for job roles with vulnerable clients or
• with implications for community or workplace health and safety.

Do you agree with these factors?

Yes

Are there any other factors that should/could be considered in the context of unduly short courses?

• The perceived status of an occupation
• An occupation’s perceived earning ability
• The opportunity for part-­‐time or casual work
• The fact that RTOs and other learning institutions rely on fees from students and are in competition with each other, rather than having direct funding from government, means some RTO are pressured to drop fees and standards, cut corners and not ensure that all students are fully competent when they graduate.

• What other sectors, other than those identified by ASQA, would benefit from this risk based approach to training package development?

All qualifications that do not deliver competent graduates waste time and money and impact on the economy. People based occupations impact on mental health and wellbeing, social and family health, and in some cases physical health.

Competent people based services, early intervention and support can improve individual and family’s health, well being and functioning, which in turn can reduce the cost to government of a range of legal, welfare, health and other services.

Celebrancy would benefit from a mandated number of hours of face-­‐to-­‐face learning because of the increasing tendencies of training to be done online and as self-­‐directed learning.

How did you identify these sectors ? (for example, what factors regarding this sector were relevant in making this opinion/decision?)

Prevention and harm minimization strategies are more cost effective in addressing a range of mental and physical health related illnesses.

For example, doctors and mental health workers supported the recent change to the Marriage

Act as an important strategy to minimise the risk of mental health, alcohol and other drug problems and suicide in LGBTI communities.

Each contact with services, particularly in the area the legal, health, welfare, and associated fields are opportunities for change for an individual, couple and family, which may be used or lost.

For example, celebrants deliver once in a lifetime event for families and other groups that cannot be replicated. A poor performance is not simply disappointing -­‐ it ruins an opportunity to build stronger and more respectful and positive relationships. For funerals, a poor performance by the celebrant can be harmful rather than helpful for the grieving of those most affected by the loss of a loved one. For marriages, a poor performance can fail to highlight the significance of marriage for the marrying couple and their family, and leave a bitter experience for family and friends who have usually invested time and considerable expense in the wedding.

Family and community networks are hugely important as a safety net in troubled or difficult times, or for families with inter-­‐generation problems.

• Do recent and proposed changes and reforms in the VET sector contribute to dealing with these issues, and are there alternative ways to achieve the same goal?

As these changes proposed by ASQA that are aimed to increase the quality of training provided, and thus the competency of graduates, appear to be evidence based, they should assist.

As part of an RTO’s compliance, there needs to be regular validation (working with another RTO to cross check a sample of assessments to ensure consistency).

One alternative strategy may be as noted above, a more transparent and easily assessable system of finding the RTOs who deliver a particular qualification with a ranking by graduates as to their training experience and its application in the industry,

For example, if the VET system had a website that enabled students of the RTOs of a particular qualification, much like the Home Stayz or Air B&B websites have customers rank accommodation on a range of points then potential students may have an independent source of information.

Discussion questions for recommendation three

3. Recommendation summary ASQA proposes that RTOs would be required to publish a product disclosure statement (PDS) that includes the range of learning activities expected for each training product on their scope of registration. The PDS, to be developed by the Australian Government Department of Education and Training (the department), would be available on RTO websites and the RTO’s entry on the My Skills website.

• What impact and costs would a provider face in implementing ASQA’s proposal?

If, as recommended here, the IRC would, in consultation with the industry, RTO’s and ASQA, recommend the “Amount of Training” and the proportionate to the learning activities in hours and arrange this to be available on training.gov.au.

The costs would be in providing advice and feedback to the IRC before the Amount of Training is determined. This cost to the RTO could be offset by reducing contacts by potential students trying to ascertain what time they would need to set aside to commit to the training.

If the RTO is to determine the mix of learning activities for the “Amount of Training”, rather than the IRC, then the same applies. The cost to the RTO in providing information of the amount of time for each time of learning activity, would be offset by reducing contacts by potential students trying to ascertain what time they would need to set aside to commit to the training.

• What impact would this have on the flexibility of RTOs to deliver training?

If the RTO were to determine the mix of learning activities for the “Amount of Training”, rather than the IRC, then there would be more flexibility.

However as noted earlier, incentives for updating in the current system are few.

Either change needs to be mandated or funded to ensure that the delivery of qualifications is updated, as the industry requires.

How could a product disclosure statement (PDS) take into consideration the various flexible and innovative ways in which a single training product may be undertaken?

Each qualification could outline the Volume of Learning and Amount of training in a table such as follows:

What would trigger an RTO to update each PDS?

As noted in 3.2, either change needs to be mandated or funded to ensure that the delivery of qualifications is updated as the industry requires, or as noted, if there were a feedback system as noted in 2.3, then poor reviews may assist in an RTO updating its PDS.

• Are there alternative ways in which training product information could be provided to students to enhance consumer protections, As noted in 3.2 above. and at which point in their enrolment/training should this be provided?

PDS needs to be available pre-­‐enrolment and be confirmed in their application process.

How to provide feedback

Stakeholder consultations begin with the release of this discussion paper in December 2017 and continue through to March 2018.

Respondents may provide feedback on some or all of the discussion paper’s themes. To assist with the compilation and analysis of the views of all stakeholders, respondents are encouraged to provide feedback via the discussion paper submission portal, available on the department’s website at www.education.gov.au/VET-­‐consultation. Submissions in alternative formats will also be accepted.

Written responses will be made publicly available on the department’s website, unless respondents direct otherwise. Terms and conditions for public submissions are available on the department’s website at www.education.gov.au/terms-­‐and-­‐conditions-­‐public-­‐submissions-­‐department-­‐education.

How feedback will inform policy decisions

Stakeholder responses to the discussion questions will form the basis for CISC’s considerations in responding to ASQA’s recommendations.