The report on unduly short course duration and what it means

Unless you have been hiding under a rock recently you will have heard, I am sure, about the ASQA report into Unduly short duration courses.  This 171 page behemoth of a report looks into and makes recommendations regarding, what has been viewed by a lot of people as a significant issue with the deliver of VET qualifications, courses of study with very short actual duration’s.   Now I am not going to dig through the entire report, if you want to know what got us to this point and the general research and thinking behind the recommendations feel free to dive into it and have fun. Today I am just going to look at the recommendations made towards the end of the report, what I think of them and what effect they might have on the sector.

So the three recommendations that come out of the report are;

  1. Strengthening the Standards for RTOs by defining the term ‘amount of training’ to include the supervised learning and assessment activities required for both training packages and VET
    accredited courses.
  2. Ensuring effective regulation of training by enabling Industry Reference Committees (IRCs) to respond to identified risk by including appropriate training delivery requirements, including the amount of training, and
  3. Enhancing transparency by requiring public disclosure of the amount of training in product disclosure statements, presented in a consistent way to enable comparisons across courses.

Of these three, it seems at least to me that it is the last one which is the least contentious, that is requiring public disclosure of course duration.  Of course for it to be able to be effective recommendation one does really need to be sorted out first.  If there is no consistent definition of what constitutes  amount of training, and no consistent way of presenting this information, then three is really pointless.  let’s however put that to one side and I will come back to it later when I talk about the first recommendation.  I see no real issue with providers being required to publicly disclose the duration of their courses, both in a product disclosure statement and on MYSKILLS, and that the PDS be provided to every student.  One of the advantages here is that having this information publicly available is that not only does it provide the consumer with additional information which can be used to realistically compare programs, but also it provides the regulator with a metric which can be audited and the provider held to account were they don’t meet their own durations.

Let’s take a step back now though and look at recommendation one.  If recommendation three is fairly uncontentious then one and two are pretty polar opposites. There have long been arguments about what constitutes the amount of training, with a range of divergent opinions such as nominal hours meaning essentially face to face delivery hours to what constitutes supervised and unsupervised learning and to try and get a definition out of anyone about how long a course should actually be and to have some consistency around the answer if you do get it is almost impossible.

So let’s have a look at what the report says in recommendation one about what should or should not constitute ‘amount of training’ It is proposed that amount of training could include:

  • supervised or guided learning, such as:
    • tuition and other trainer-directed workshops or activities
    • structured self-paced study
    • structured work placement
    • projects and prescribed set tasks
  • Assessment activities.

It would not include unsupervised learning, such as:

  • private study or preparation, including prescribed reading, or
  • self-initiated learning or research.

Here is the thing, when I look at what is being recommended it seems pretty reasonable, or at worst it seems to cover all of the things I would want a definition like this to cover and excludes the things it probably should.   Anything that is instructor led is included which, well, should be an obvious inclusion, structured self-paced covers elearning, distance and those other forms of non instructed led delivery, this is certainly in my opinion another obvious one, but one which has been challenged (wrongly I would suggest) by some.  Structured work placement and a catch all for projects and other set tasks rounds out the list and a pretty fair list at that.  With a definition out of the way we can now move onto the Recommendation Two, the one that has been worrying people the most.

It is recommendation two where the rubber meets the road so to speak with the report suggesting that where the IRCs feel that there might be an unacceptable risk—including a risk to the learner, the workplace, the community or the environment—or where there are already systemic issues with the quality of training that the IRCs recommend a strategy to effectively mitigate the risk which may include:

  • specifying mandatory training delivery or assessment requirements (including the amount of
    training where this is warranted), and/or
  • providing enhanced guidance to RTOs through the inclusion of recommended training delivery or
    assessment requirements, including the amount of training.

We have already seen a movement towards this in a number of training packages, with mandatory work placement hours and specific assessment criteria (Student must have provided information to at least 3 clients) forming part of the newest iteration of the CHC package for high number of units and qualifications.  These kinds of criteria and placement hours have long been part of other packages and were sorely need in the CHC package and are probably something with most of the training packages should, if they already don’t include.  What the report doesn’t say is that mandatory ‘amount of training’ should be included in all packages and qualifications.  It does suggest that in;

  • aged and community care
  • early childhood education and care
  • security operations
  • equine programs
  • construction safety induction (‘White Card’), and
  • training and education,

that consideration be given, due to the fact that considerable risks have already been noted in these areas, to including a mandatory ‘amount of training’ for new learners as a matter of priority. Given the quality of some of the training which has been delivered in these areas I can’t say that I am adverse to this idea, importantly I am not adverse to this idea for new learners.  For people with experience in the sector undertaking training, placing the same mandatory ‘amount of training’  is unwarranted and would create undue difficulties for experienced people needing to obtain qualifications.  That being said, having a mandatory ‘amount of training’ for new learners would provide a guide or a benchmark from which training provided to more experienced learners could be judged.

While I understand that part of the argument against minimum durations is the how long does it take a person to be competent argument, to which the answer is of course well as long as it takes, which could of course vary widely between learners.  I might be a much faster learner than others and get competence in  half or a third of the time the average person takes, but also it may be the case that I may be slower and may take twice as long as average.  This doesn’t I think negate the fact that for new learners, we can probably come up with a fairly reasonable minimum mandatory ‘amount of training’ in those areas where this kind of intervention is required.

The other argument raised is that employers are ones who are pushing for quicker and quicker delivery times, they want new staff to be trained as quickly as possible. But here’s the thing, employers can’t have it both ways, they can’t have staff trained as quickly as possible and then complain about the quality in the next breath.  I have had this argument so many times with managers over the years in a variety of roles both in and out of RTOs, you can either have it fast, cheap or good, pick two because you can’t have all three and anyone who tells you you can is either lying or trying to sell you something.  Having  mandatory minimum ‘amount of training’ however cuts the legs of this argument straight away, the answer to the can we have that quicker question is simply no and we have official documentation to back it up.

All in all I can’t say that I have any real problems with the recommendations, yes, having a minimum mandatory ‘amount of training’ worries some people, however I would suggest that for a lot of the high quality providers in the market, they would be meeting or exceeding any minimum requirements that were ever made mandatory.

Anyway that just my opinion.

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About pauldrasmussen
Paul Rasmussen is one of Australia’s most widely read Vocational Education and Training Commentators. He provides deep, unbiased analysis and insights not only on topical issues, but also on the underlying structure and policy which supports the industry. His writing and analysis has been praised for its uncompromising and thought provoking style and its ability to focus on the issues of real importance to the sector. He has advised various government departments and ministers, training providers, public and private organisations, not for profits and small to medium enterprises on the VET sector and the issues and opportunities facing it. He is one of Australia’s most awarded learning professionals and a regular speaker at a range of conventions and forums. His extensive experience in vocational education, and learning and development coupled with formal qualifications in philosophy, ethics, business and education management allow Paul to provide a unique view of the road ahead and how to navigate it.

2 Responses to The report on unduly short course duration and what it means

  1. Paul Saunders says:

    Hi Paul
    another thought provoking article. My reaction to this report may be summed up in your words from your “Competing agendas article;

    ” It is both unfortunate and true that most elected officials in charge of the VET sector have very little knowledge of how the sector works”.

    My next statement will probably cause raucous laughter amongst your followers; I believe that the Australian training package concept is an elegant design and particularly well suited to the rapidly evolving education landscape of the 21st century.

    Unfortunately the conflation of competency based training with the marketization of the vocational education sector has undermined and diminished the training package design. What is now occurring are attempts to bring the failings of the training market under control through poorly conceived modifications to training packages.

    The training package concept was brought into play in Australia when vocational education was almost exclusively provided by large, publically owned, quality assured educational institutions. These well regarded professional entities had the resources and funding to appropriately develop learning programs in response to ‘skills standards’ as described in training packages. In simplistic terms industry documented the skills and knowledge they required in the work place, vocational institutes developed and provided the educational programs to enable learners to meet these requirements.

    The elegance of this design is that the ‘means’ of bringing learners to competence is not defined. The learning program can be matched to the learners needs and can utilize emerging more efficient learning processes ( elearning etc.) as they become available.

    The poorly conceived modifications to the training package design that I refer to above will severely restrict the utility of training packages. We have already seen quite ridiculous undeliverable Assessment Requirements added to some training packages and now the suggestion is to mandate some arbitrary duration of training. Industry representatives have neither the time, experience, training nor skills to design curriculum. This must be left to the educational experts who have been trained in curriculum design, training delivery, assessment methodologies – dare I say pedagogy?

    We can do better than this and we can control poor usage of training packages by removing from the vocational education sector organisations that do not have the capacity to provide high quality training. If we must have a market place for education provision (personally I have grave doubts that marketization of public services will ever achieve the remarkable outcomes that we are told will ensue).then let us at least have robust processes to manage entry and behavior within the market.

    • pauldrasmussen says:

      Paul,

      I pretty much agree with you wholeheartedly (we probably have a slightly different view on marketization, but not one that is worth quibbling about). I have long maintained that out system, including the training package concept is at its core an incredibly robust system which can and should provide us with the means to meet our workforce and education needs moving forward. I also agree that the way in which training packages have been developed over the last few years has really not been as good as it should have been, and we end up with packages which either had glaring gaps in them or which were so tightly constrained as to be almost impossible to work with, and yes when you add to this entrants into the market who should have, under any credible system of regulation, never been allowed to enter in the first place, taking advantage of this and other system anomalies, it has left us were we currently are. We need to only have providers in the system who have both a commitment to and evidence of high quality standards of delivery and outcomes, and we need to have training packages, which underpin this commitment.

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