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Thoughts on ‘Strengthening Skills Expert Review of Australia’s Vocational Education and Training System’ by the Honourable Steven Joyce.
Another year, another review? Is that how you see it or will this review and its outcomes stir the pot and reframe the VET sector for the future?
The Joyce Report makes 71 separate recommendations around the six points of a plan:
• ‘Strengthening quality assurance,
• Speeding up qualification development,
• Simpler funding and skills matching,
• Better careers information,
• Clearer secondary school pathways, and
• Greater access for disadvantaged Australians.’
The author has also recommended short term, medium and long term changes with some of the short term changes focussing on changing the VET Sector Structure (again). These changes are suggested in terms of making the sector more responsive to industry change and to improve turn around times for training package development etc. Another area for early development is the establishment of a National Careers Institute. This organisation would have a number of roles but one important area would be revamping the attractiveness of apprenticeships to both employers and trainees. All of these recommendations are commendable. But we will watch this space and see how another restructure impacts the sector.
But the areas that I would like to focus on today are the recommendations about:
- quality assurance,
- assessment and
- benchmarking hours for units and qualifications.
I believe that these issues will become controversial. So lets talk about each of the issues and consider the merits and problems in the context of the current state of the sector (or at least how we see the sector at the moment!).
Just over 12 months ago a review was published called ‘All eyes on quality: Review of the National Vocational Education and Training Regulator Act 2011 report’ by Prof Valerie Braithwaite. This report spoke of the need for ASQA to play a stronger role in assuring quality across the sector rather than just enforcing compliance with legislation.
‘As a regulator its role is to motivate RTOs to reflect on their performance, what they might do better and how they might go about improving their performance. Recommendations in this review favour continuous improvement over mandating quality standards that all RTOs must achieve. Ultimately, the way ASQA should regulate for quality (as opposed to sufficiency) is to look at how well RTOs go about setting their own higher standards, checking if such standards are met, motivating through praise and encouragement and support when they have achieved improvement, and advising on options when they have not.’ P8.
Twelve months on, the Joyce report reiterates the need for more active quality assurance of RTO practices.
Recommendation 3.2 is as follows:
‘The Australian Skills Quality Authority to provide more information and guidance to Registered Training Organisations as to how it conducts its regulatory activities in order to improve ongoing understanding of and compliance with the Australian Skills Quality Authority requirements, and to reduce the cost and compliance burden to Registered Training Organisations.’
This suggests that the regulator will have to work to establish good relationships with providers and provide advice and support in the area of quality training and assessment practices. This is a model that is used in other education sectors. For example, in the child care sector where services are given a rating based on self-assessment quality improvement plans and regulatory authority visits etc.
The proactive approach to management of quality and compliance is of course one that we are very familiar with and promote tirelessly! We believe that compliance management is just part of good business practice and that we should all be looking forward with a continuous improvement mindset to ensure consistent and quality training and assessment practices! So, whilst I applaud these recommendations, I suspect that RTOs will struggle to put their confidence in a regulator who has policed the sector and operated in such an impersonal way for so long.
Over the past 8 years since ASQA was established there has been little opportunity for providers to develop a relationship with the regulator. Granted, they have been holding the yearly update sessions, but with so many people attending webinars as opposed to face to face events these days, the perception is one of distance. And of course, with the implementation of the risk-based auditing system, visits from the regulator are becoming increasingly rare for many RTOs. We see RTO owners who are delighted about this, particularly when they receive the email that tells them their registration has just ticked over without the need for an audit. Some of the RTOs we have visited recently haven’t been audited in the last 4 years and are re-registered for the next 6-7 years. The message from these providers is clear – the longer ASQA stays away the better!
In reality, it will take a vastly different approach to win the confidence of the providers and become actively engaged in promoting a quality and continuous improvement approach to managing RTO operations and compliance.
I think that one of the most controversial points in the report is the suggestion that to increase transparency, ASQA should publish details of all audit outcomes for the public to see. Whilst on the surface it may seem a logical way to go. But in reality, until there is a sense of trust and collaboration between the regulator and providers and until the providers are won over and we see a vast change in attitude towards compliance and quality management, such a decision is more likely to be seen as a declaration of war rather than an enticement to become proactive about quality.
There is a strong focus in the Joyce Report on the need for stronger links with industry, particularly in terms of assessment. I am delighted to see this because after all we are working in the Vocational Sector. One of our biggest struggles working as consultants in this sector is helping RTO’s to recognise the need for assessment of skills as well as knowledge. Students need to be able to demonstrate skills and knowledge to be deemed competent.
What does the report recommend?
- Broadening the requirement for independent validation.
- Enabling ASQA to use independent re-assessment of students as an audit and reinforcement tool where there is concern over a provider’s training and assessment practices.
- The introduction of proficiency-based assessment in addition to assessment as outlined in training packages.
This all sounds encouraging. But we need a reality check here.
The Learning Community will always encourage RTOs to take a quality approach to managing their business and this goes for assessment validation as well. If you are providing good quality training and assessment your students are more likely to achieve their desired outcomes and employers are kept happy! So it makes sense to be proactive with validation, and use the process to improve what you are doing – for real.
I’m not so sure that independent validation will achieve this. Why? Let’s take a look at the effectiveness of the last attempt to engage providers in validation before we focus on the current proposal.
It is now 4 years since the Standards for RTOs 2015 kicked in. RTOs were given 3 years to validate 50% of their training products. This deadline came and went just over a year ago. RTOs were in a mad scramble to make sure that 50% of their training products had been validated. And that’s great because validation is a useful tool to help improve your assessment practices, correct? In an ideal world this might have been the focus of the validation activities. But what we are still finding is that RTOs:
- Don’t know what a ‘training product’ is,
- Have a limited perspective about the type of assessment that is required in the VET sector so the validation process becomes an ineffective exercise
- Are only required to validate 2 units / training product so that’s what they do i.e. they are not really interested in taking a quality approach, just ticking the compliance box!
- Do not know how to conduct validation and do not sample student work
- Resent that fact that the trainer who is delivering the training cannot make decisions about the validation outcome, particularly if they are a small operation and have no spare trainers to include in the process
- Struggle to engage their trainers in the validation process and,
- In some industries struggle to find the right people to be part of their validation panels.
So in reality, did imposing a deadline actually change the attitude towards validation and actually help improve assessment quality? Perhaps in some RTOs, but for many, I very much doubt it.
Let’s think back to the 1st April validation deadline from last year. What happened on the 2nd April if the RTO didn’t meet the deadline? Nothing, because the regulator does not have the capacity to check up on these activities. And for many RTOs who are having their registrations stretched out as far as 2026, it is unlikely that their validation activities will be reviewed for a very long time.
In this context let’s look now at the recommendation for independent validation. This practice is already a requirement for RTOs who deliver TAE qualifications. And perhaps it is helpful in this instance. This is because there are fewer of these RTOs, and they are subject to a higher level of scrutiny than many other RTOs. In other words, the regulator is likely to check that the validation is done and that the recommendations of the validation has been implemented. Will this work across the whole sector? As I mentioned earlier, there is less and less likelihood of repercussions from the regulator as the frequency of audit is reduced.
For the independent validation approach to work, providers will need to fully engage with the process with the intent to improve their practices. This will require education, encouragement and a change in practice to become proactive in managing quality and compliance.
We have certainly seen some great outcomes in RTOs who embrace the quality approach to validation and actively seek to improve their assessment practices. Do you need help with this? Ask us and we will provide the guidance you need.
This recommendation specifies that this practice be associated with audit and as a reinforcement tool where there is concern over a providers’ practices. I wonder if this will be a helpful approach at a time when the regulator is attempting to become more educational and quality focussed? Rather, it is more likely to be perceived as extra interference by the regulator. In this sector where customisation of training and assessment is possible and flexibility of approach so important to meet the needs of students and industry, I also wonder how this could really happen? Would the use of a standardised assessment administered by an independent assessor be helpful in determining the quality of a provider’s practice? Or would there be a need for the independent assessor to work with the provider to design the task etc?
I don’t have the answers for these questions now but would like to suggest a more positive approach to assessment to improve the practice across the sector…
A strong focus of this review is the need for stronger ties with industry, to have more students in industry while they are learning i.e. more opportunity for integrated learning and assessment. So why not help providers and industry work together to design realistic work-based assessment that actually assesses skills and application of knowledge?
I realise this poses a problem for the CRICOS sector where there are no or very little connections to a real industry but we need to get back to the purpose of the VET sector i.e. to equip people for the workforce!!
Proficiency based Assessment
The general goal of proficiency-based assessment is to ensure that students are acquiring the knowledge and skills that are deemed to be essential for success, i.e. in this case to either enter the workforce or progress within their current role, step up to leadership and so on. I have to ask: isn’t that the whole point of competency-based assessment? Shouldn’t RTOs already be doing this?
Adding on extra requirements will only be effective if those requirements are embraced by providers, trainers and assessors, industry and students. This requires a shift in attitude in terms of assessment from something we do to tick the boxes to an opportunity to demonstrate readiness for work. If this shift doesn’t take place, we will see an additional hurdle placed in front of providers and students that will be side stepped by many and will become just one more thing to police.
We like to remind RTOs that ‘The primary risk for ASQA to manage is an RTO certifying that a person has competencies that do not reflect his/her skills, knowledge and attitudes. The potential damage flows not just to the individual, but to employers, and the wider community (Regulatory Risk Framework, Version 1.0 April 2016). We all play a role in helping students to achieve their goals and in serving the industry and community. So lets all get on board and do it properly! We work with RTOs all the time to help them develop good assessment practices and to help them understand the significance of assessment in the sector. Call us if you need some help with this.
Benchmarking of units and qualifications.
Now for a few final words on the topic of benchmarking.
The idea is that ‘hours should be specified in qualifications by qualification developers as a guide to the average amount of training required for a new learner with no experience in the industry to develop the required competencies in the qualification.’ (Recommendation 3.9).
Will this be helpful or will it add another layer of compliance requirements onto providers? How will this impact on the flexibility of learning in this sector? I think the key word to look at here is ‘guide’. A guide can be helpful and we have all used the Victorian Purchasing Guide hours over the years to guide the development of qualifications, particularly for funded training and in CRICOS Colleges. On the other hand, the regulator has been enforcing Volume of Learning and Amount of Training based on AQF hours and this has caused a great deal of anxiety across the sector. Unfortunately, we still find RTOs who do not understand these requirements and do not know how to adapt what they deliver for different target audiences and justify why they have shortened the course duration.
I do wonder how these benchmark hours will be implemented – as a guide or as a mandatory requirement? In reality I believe that what is really needed is providers taking a “student focussed” rather than just a “money saving, one size fits all” approach to training design. Of course providers need to make money but if they want industry to work with them and students to keep coming back for more training, the provider needs to ensure that it delivers on its promises and provides a quality training experience!
This blog may have seemed negative to you but that was not my intention in writing it. I am pleased that there has been research done into the sector and delighted that there will be investment in the sector. I would love to see providers move to a proactive good for business approach to operating their business and I really do hope that the regulator can be of more assistance in the future. However, a change of attitude and culture is required across the sector to achieve this change and some of the recommendations within the Joyce Report will require some deep thinking and a great deal of good will and collaboration across the sector and industry!
If you are wanting to make that shift to a proactive approach to RTO management and implement a continuous improvement approach to quality management, we can help you.
Contact us at firstname.lastname@example.org
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