The problem of opinion and misinformation in VET

Australian VET is a regulated industry, in fact if you spend more than five minutes talking to almost anyone in the sector, you will understand just how abundant these regulations and other associated controls are.  Given that this is the case, and given that because this information is written into legislation, and other associated documents linked to and referenced in the legislation, I am sometimes dumbfounded how it is possible not to know the answer to a lot of the questions I hear being asked in the sector, and worse still giving an opinion, which is wrong, on something that is clearly articulated in black and white in the various documentation for the sector.

Now I am the first to admit two things, one, there is a lot of documentation to look through (the Standards, Data Definitions, funding agreements, AQF, to just name a couple) and second, I am the kind of person who loves, reading and assimilating information and data.  That being said however, how is it possible for someone to be in a position of relative power, (CEO, Consultant, Compliance Manager, whatever) and not have read and more importantly understood at least the very basic documents which regulate the sector, and given the amount of misinformation, and glaringly wrong opinions which are offered by people who should really no better, it can only be assumed that they either haven’t read or haven’t understood the documents, or have simply shifted all of the responsibility for knowing what the right answer is to someone else.  Now to some extend I don’t, by necessity, mind if people, say a CEO of an RTO doesn’t have all the answers and relies on his compliance person to understand everything and to get it right, however if this is you, then don’t give an answer when someone asks a question.  If you don’t know the answer, all you are going to do is muddy the water and make it more difficult for the person asking the question to get the right answer, which then probably need.

What is far more concerning to me is when people, who are supposed to be senior leaders in the sector or who are consultants who work with large numbers of providers, voice opinions which are clearly incorrect on subjects where your opinion doesn’t matter because the answer or the definition is written clearly into some form of regulatory document.  Not only does this provide whoever is asking the question, or who they are working with, with the wrong answer, which could have catastrophic consequences for that person or organisation, but if they say it enough and it gains momentum and gets passed around enough, this clearly wrong piece of misinformation, becomes gospel.

One of these, as an example, came up a number of years ago, at an ASQA briefing and was categorically answered, but the myth, wrong, opinion, or misinformation still exists today and is still quoted by people.  At this briefing a gentleman stood up during the time allocated for questions and asked, why it was the case that highly experience industry people had to hold all of the units of competency that they were teaching.  He said that it was making it difficult for him to find trainers because a lot of people in his industry didn’t have the newest UOC’s and therefore couldn’t teach and assess those units.  The person from ASQA (who is a person who is highly regarded, highly skilled and help draft the standards) looked dumbfounded for a moment and then replied that the standards didn’t say that and asking him where he had learned this from.  This of course bought a hue and cry from the audience many of whom insisted that that was exactly what the standards said.  The ASQA representative carefully explained that all the standards said was that trainers had to have, small c vocational competencies.  They didn’t have to hold the exact unit they just had to be able to prove that they were competent in the skill that they were teaching if and when they were audited.  Another round of discontent emerged with a lot of people say that TAFE had always required them to RPL the most recent units at the very least.  Again, the ASQA person reiterated that while that may be the practice of TAFE, that was simply a management decision, was not required by the standards and should not actually be considered to be best practice. Now not only was this information shared at the briefing, it was also shared through FAQ’s on the ASQA website and through recordings of the briefing.  Yet, much to my disbelief, I heard this very question being asked in another forum late last year, a a great many of the people who answered spouted the very same information which has been debunked numerous times since that first briefing.

The real problem is that this is only one example of this kind of opinion masquerading as fact which is doing a substantial amount of damage to the sector.  It is no wonder that RTO’s are failing audit if they are relying on opinions from so called experts rather than actually going and reading the cold hard, black and white information contained in the various acts and other documents.  The vast majority of the questions I see posed on online forums, at conferences and in general discussion, aren’t the subject of opinion, and do in fact have definitive answers if you can just be bothered to go and read the documents that govern what we do.

So how about before we ask or answer a question, we all go and read, not just The Standards, but all of the ancillary documentation associated with the sector, or if you don’t have the time or the inclination to do that, (I personally think our sector would be better off if more people did though) just google the question, ignore the opinion and go to the actual source documents.  We all talk about wanting the VET sector to be more professional, and I have to say, actually reading and understand the legislation etc which underpins might be a good start.

Some Quick Facts about ASQA regulatory decisions and uneven playing fields

Since 2011, ASQA has made 592 regulatory decisions (according to their own website) of those only one decision, or about 0.15% of all regulatory decisions, were in relation to a TAFE.  The one and only regulatory decision which was made by ASQA about a TAFE was in 2012 and related to TAFE NSW Western Institute, where they suspended four units of competency from being delivered and said if the TAFE wished to deliver the program in the future they would have to submit an application to do so.

Now Mark Patterson the Chief commissioner of ASQA in a comment on Linkedin said the following “We have taken in excess of 50 regulatory decisions which impact directly on TAFE. They like other RTOs are provided the opportunity to rectify non compliances. The VET market is dominated by private RTOs both in market share and numbers of RTOs so it should be unsurprising that there are more regulatory decisions that impact on private RTOs.”

The first question this raises is, if you have made in excess of 50 regulatory decisions against TAFEs where is the evidence of this, certainly not in your own database it would seem.  Now Mark did say that providers are given the opportunity to rectify non-compliance’s which is fair enough, however if we look at the information, about what decisions they publish, again according to their own website,

ASQA publishes decisions:

• to impose an administrative sanction—either to cancel registration, to suspend or amend the scope of registration, to shorten the period of registration or to give a written direction—on a registered training organisation under Section 36
• to impose a condition on a registered training organisation’s registration under Section 29(1)
• to reject an application to renew a registered training organisation’s registration under Section 17.

It would seem according to the only publicly available evidence that in all of the 50 plus regulatory decisions made by ASQA in relation to TAFE, on only 1 occasion, was anything that fitted into their publications rules done.  So let’s be clear here, on the available evidence in more than 50 decisions ASQA has (except in one case) not even given a TAFE a written direction or imposed a condition.

Now certainly there are substantially more non-public providers in the market than TAFEs, however it also needs to be remembered that TAFEs in general have much higher enrollment numbers that the vast majority of non-public providers and to be fair it is statistically probable that we should see more regulatory decisions in relation to non-public providers than TAFE, however I find it difficult to believe that the ratio is 591:1.  If we look at it as a percentage 14% of non-public providers have had some kind of regulatory decision published against them, as opposed to 2% in relation to TAFE.  Again the size of the margin is something that I find difficult to see as justifiable.

The other question which I have in relation to this is a really simple one.  Does ASQA have the power to actually deregister a TAFE and would they ever be willing to do that.  I think there is a simple answer here and that is that regardless of what a TAFE  did, (and we have seen TAFE do some things, which at least in my opinion a private provider would be deregistered for), ASQA would never be allowed to deregister one, and even that by itself is enough to suggest that there is not an even playing field.  If one part of the sector gets, it seems, to say sorry, we won’t do it again, we have a new process, and then just move on, there will always be a grand canyon of inequity in terms of regulation between the public and private sector.

 

ASQA: A divided and broken system of regulation

Back on the 20th of September I posted a piece entitled ‘One set of rules for all providers?‘, suggesting that far from it being the case, as ASQA so vehemently pronounces, that there is one set of rules for every provider regardless of there size, or whether they are publicly or privately owned, the State owned providers are treated far more leniently than any private provider and given access to modes of rectification which are simply not available to non-public entities.   So now six weeks or so later and after the lapse of the month deadline TAFESA was supposedly given by ASQA to rectify the debacle that was, and probably still is their training and assessment practices what has happened?

NOTHING!

Why has nothing happened you may well ask, and that really is the burning question here.  But first let me remind everyone that the last sanction listed on the ASQA decisions database against a TAFE was back in 2012.  So why time and time again do we see public providers, TAFEs, being caught out breaching the RTO standards, having poor, or in some cases it appears non-existent assessment practices and never do we see any of these breeches met with any sanctions.  We see this because despite what ASQA might claim and want us to believe, the regulatory system for the VET sector in this country is broken and divided and certainly not one system for all.  In fact I am amazed that ASQA representatives can claim that all providers are treated the same with a straight face, when there is overwhelming evidence that this is not the case.  The issues with TAFE SA alone are enough to show this.  If the level of non-compliance that has allegedly been found there was found at a non-public provider, they would have been deregistered by now. Will that happen to TAFE SA?  Not a chance, they will apologize, say that have changed their systems and processes and will do better, and at worse they might stop delivering some of the programs for a few months, but then it will be straight back to business as if nothing has happened.

How then have we got to a system that is so broken and so badly weighted against non-public providers.  To be fair at least some of it is our own fault.  As a sector we saw the issues of VET Fee Help and the actions of the Careers, ACNs and Pheonixs and we (or at the very least those bodies who were supposed to be acting on our behalf) didn’t speak up or take action against them.  This of course played into the hands of the media and those like the AEU and others whose agenda is to end non-public delivery of VET, by giving them ammunition to smear the entire sector.  So bad were the excesses of the few that Ministers had little choice but to react with a big stick, if for no other reason than to save their own political skins.  If we then add to this the fact that TAFEs are state owned entities, which the state utilises not simply as educational facilities but as weapons of policy enactment across a range of areas, and in  addition so heavily heavily unionised, that whenever something happens which the unions don’t like, the social media storm which erupts is of category five proportions.  It is no wonder the system is broken. Any minister or even the regulator itself that ever suggested closing or curtailing the activities of a TAFE due to non-compliance, would be met with such a media storm, both through traditional and social channels, that it is unlikely they would emerge with their skins, let alone their careers, still intact.  So as a result of this we now have a system of regulation which is deeply skewed in favour of the public provider and which actively over regulates and over sanctions private providers while all the while claiming this is not the case.  ASQA has become a political weapon rather than a fair and equitable regulator.

So what is the answer?  It is simply that peak bodies like ACPET need to step up and call out this atrocious and unfair treatment and the inequity which exists, because this is supposed to be a level playing field and ASQA is supposed to treat all providers the same.  In fact everyone needs to step up, everyone needs to voice our opinions and call out these issues.  We need to embarrass and force the regulator to do its job properly and the government to let it.  Lone voices in the wilderness are not enough here.  If as non-public providers you want to actually see some change to this, if you actually want to be treated fairly, you, yes you, need to step up and you need to force those bodies that are supposed to represent you to step up as well.  Create a storm on social media, don’t let the news stories die, be loud.  Why do you think so many people believe the rhetoric from the AEU, it’s not because they are right it is just because they are loud.  And if you don’t step up then this situation will continue because no one else is going to do anything about it.

Anyway that’s just my opinion.

One set of rules for all Providers?

Right, first off the bat, this is probably going to get a little ranty, so if you don’t feel like listening to me have a rant, albeit a rant with some facts to back it up, you might want to stop reading now.

Secondly, I am a supporter of TAFE.  I think as with non-public providers, public provider (TAFE) for the most part do a fantastic job and are a vital part of the fabric of VET in this country.

As I said in a post more about 18 months ago the VET system in this country is supposed to be regulated against one set of standards, which apply to all providers whether they are public, private, not for profit, community education or whatever.  If you deliver vocational in this country you are supposed to meet the standards and if you don’t there are supposed to be penalties for such non-compliance.  Clearly this is the biggest pile of horse s**t that has ever been perpetrated on this sector.

For the last few years we have seen the media, the unions, governments and regulators attack, on what at some points seemed to be a daily basis, non-public RTOs.  Now to be fair some of this was legitimate, but it is also fair to say that there was a hell of a lot of massaging the truth, to sell more papers, push a particular agenda or to grab the best sound bite.  The reputation of the sector and in particular the non-public part of the sector was basically covered in petrol, lit on fire, and burnt to a crisp, while at the same time the AEU and others held TAFE up to be a shining paragon of how Vocational education should be delivered.  The regulator (ASQA) took those RTOs who had done the wrong to task, deregistering some, applying sanctions and constraints, taking others to court and generally pursuing breeches vigorously.  The same can clearly not be said for how TAFE in general is regulated and treated.  Let’s just for a minute look at some of the ‘issues’ there have been with TAFE over the last couple of years and particularly very recently.

Kangan – Unsecured student records in an abandoned building

TAFESA – Aircraft maintenance certificates ‘not worth paper they are printed on’ 

TASTAFE – Jobs for the boys, or in the case girls

Kangan (again) and South West TAFE – rorting funding around engineering training and assessment

GOTAFE – What appears to be enrollment fraud

So let’s exclude the TASTAFE jobs for the girls scandal for the time being and just look at the other examples.  Any single one of these would have resulted in serious regulatory action if not deregistration of any non-public provider who had been found doing these things.  In fact the most recent with GOTAFE was exactly what a relatively large non-public provider was in fact deregistered for last year.   What then has happened to the TAFEs involved, well GOTAFE appear to have been reprimanded by the Department and TAFEA are embarrassed.

REALLY!

Where are the sanctions, were is the action from the regulator, where is the constant media attention day after day, where are the politicians jumping up and down.  I notice the Greens who were so quick to condemn the actions of private providers have been, well, silent and invisible about these issues.  And the AEU, the AEUs response to the most recent GOTAFE scandal was basically, its not the TAFEs fault they were forced to do it because the government didn’t give them enough money.   Again, you have got to be kidding me.  When a non-public provider did the same thing the AEU wanted them hung drawn and quartered but now that it is a TAFE its not their fault. Hypocrites.  

And where might one ask is ASQA, the national regulator, who is the regulator of note of all of the providers mentioned.  Nowhere to be seen.  I don’t think ASQA has made any single comment on any of these issues, not a single one, yet again had this been done by a non-public provider they would have been making statements about how they were cleaning up rouge providers, applying sanctions and deregistering providers.

Why nothing from ASQA you may ask?  That’s easy these TAFEs are state owned entities, who are clearly being protected by their respective state governments as the government knows that forcing a TAFE to close because it was well, rubbish, and deserved to be deregistered would have such a detrimental backlash on their electoral chances in the next election that not a single one has the backbone to actually let these activities by properly investigated and regulated.

So while non-public providers are still being sanctioned and have penalties imposed for their assessment practices not being perfect, or their compliance paperwork not spot on, these TAFEs are off doing whatever the hell they want with what only can be described as impunity.

The idea that there is one set of rules that apply to all of the providers of vocation education in this country is a steaming pile of garbage, and perhaps all of those people who have banged on for months and even years about the evil horrors of non-public providers, should perhaps, just once, look in their own back yard, take responsibility, and get their act together before they some vitriolically attack the non-public sector.  But we all know that is not going to happen.

Oh and on top of all of this Victorian TAFE teachers through the AEU Victoria have taken their bat and ball and gone home because it is outrageous to expect them to teach for about half of the time they are at work.

Anyway that’s just my opinion.

 

Higher level teaching degrees and VET

So as many of you are aware there has been some new research which has come out about degree qualifications and teaching in VET.  Now it is important to note that I have not at this point had an opportunity to look over the entire study and the conclusions that it draws, however given the information which is available there are at least some questions I think are worth airing.

Firstly however a comment, I always find it interesting when academics suggest that VET needs better teaching qualifications when most academics don’t have any formal teach qualifications at all, they are simply experts (they have a PhD or similar) in their field. So I always tend to think that if University ‘teachers’ are considered to be capable because they have experience in their field, why is their this suggestion that it should be different in VET. Some if not most of the VET people who get the best outcomes for their student are those with the deepest industry experience and currency.  So with that little comment out of the way.

My first worry here is study size and knowing who it was that the survey was sent to.  570 and 360 respondents out of a supposedly 80,000 strong workforce seems a little low to me to be jumping to conclusions from.  I mean that is after all less than 1% of the total workforce.  My other initial concern is who it was sent to.  I don’t think I ever remember seeing anything about this survey anywhere or anyone at all mentioning that it was underway.  I could be wrong or my memory could be going, but if anyone out there got an invitation to respond to the survey let me know I would be really interested.  I am interested because, often these studies do not cover what could be called a definitive cross-section of the industry.  I am reminded of some research done around supporting students with disabilities which was presented a NCVER No Frills a number of years back, where it turned out that the researcher had only spoken to TAFE providers about how they dealt with disabled student and when asked why she had not contacted any non-public providers her utterly ill-informed answer was ‘private providers don’t deal with students with disabilities so there was no point in asking them’.  Now I am not saying something like that has occurred in this survey, but it would be really interesting to see if all of the parts of the sector had been able to give input and if it had covered all of the states.

Now I come to the real question I have about this paper, what is the evidence for a statement like  “Whether it was in VET pedagogy or something else, a degree or above really made a difference to things like a teacher’s professionalism, their contribution to the organisation and a deep understanding of the necessity of audit procedures.”  Is it just anecdotal or is there something more substantive.  Is it based on the response from teachers themselves saying they thought it made a difference or is there some other more shall we say robust data, or even feedback from their managers and employers about how their professionalism or contribution increased as a result of undertaking a higher degree.  I mean the cynic in me always says, if I had paid a significant sum of money for a degree and someone asked me if it was worthwhile, people are mostly going to say yes, even if it wasn’t just to appear to not appear to have made an error in judgement.

All that aside however, it is important to note that I am not against people in VET getting higher level degrees, nor am I against the concept of these degrees. I do however think that any change in policy to suggest that higher level qualifications become the standard or the entry point should be resisted wholeheartedly.  What VET needs is people who are highly experienced and appropriately qualified in their fields, who are passionate about passing that knowledge on to students and consistently ensure that they are current and well versed in industry practice.  Then we need to provide them with appropriate training qualifications to be able to effectively pass that information on and to assess the competence of students effectively.  That is what this sector needs not more people with degrees, who haven’t actually been in the industry for years because they have been to busy getting their degree.

Here’s an idea, before any more academics tell the VET sector what is good for it and that having university teaching degrees will raise the standard of teaching, how about we change university policy and force all academics who are teaching at university to have higher level teaching degrees and lets see how well that goes down.  I still remember that idiot academic last year complaining that he wasn’t being allowed to teach in the VET sector because he didn’t have a certificate IV TAE, even though he had a PhD in his field.  Just because you have  PhD in something doesn’t mean you can actually teach what you know to anyone.

Anyway that’s just my opinion.

A view from the outside – sort of.

Now that, as many of you know, I am out of the day to day business of vocational education and in a more organisational learning and development (among other things) space, I have been looking at the VET sector through a somewhat newish lens, though a lens I have admittedly looked through before and I am troubled by what I see.  Someone asked my the other day what I thought the biggest issues facing the sector were.  I started to suggest that the kinds of things people have heard me talk about at length and then it struck me that I needed to push all of that thinking away and have a fresh look at the sector as someone sitting outside of it, or at least only on the very edge and so I did and I realised something.

No one outside of the sector actually cares about what is happening in the sector.  No one really cares about the problems with the TAE, whether ASQA is doing the right thing the right way, compliance issues, what the issues with amount of training are, no one actually cares.  They only care when they go to a provider, ask for what they want, and get told they can’t have it or they can’t have it in the manner in which they want it, and even then they don’t really care as they will either except it or simply go to another provider.  And I am not just talking about business’s here, I am talking about individuals as well, and that is a very very big problem for the sector.

Yes lots of people are involved in the sector, lots of people, millions in fact gain education, training and qualifications through the VET sector in this country, and even if we discount international students and training there are massive sums of money involved and VET is a critical part of our economy, not just in terms of that money, but in terms of the generation of skills and knowledge within this country, in terms of making us as a whole, smarter, better, more skilled, and more knowledgeable.   But again, very few people outside the sector actually care.

Now to be fair this is not an active dislike of the sector, the rampant hatred of all things VET that we saw in the thick of the VET fee Help debacle has dissipated, it is simply that VET  is not on the radar of most people as something which is important, that they need to understand, or that they need to care about.  It is at best a piece towards the back of the paper to which people either respond with ‘bloody dodgy private providers’ or ‘bloody TAFE.”  The sector has unfortunately become something that people only take an interest in, when they intersect with it and then their interest is purely, for the most part, about how they get what they want from the system and once they have it the sector floats away from their lives.

We even see this when if we listen to the way the which the sector is thought about by not only those outside of it but those inside of it as well.  Principles, guidance counselors, and parents who view the sector as somewhere for those kids who aren’t going to get into university to go.  Providers, consultants and all of the other ancillary business’s around the sector itself, who see the sector as a way to make money.  Bureaucrats,  unions, governments and those in positions of power who see the sector as a means to an end, stepping stones in a career, or organisations who see the industry as nothing more than a way to train their staff for as little actual cost as possible.   Please don’t get me wrong here I am not suggesting this is the way everyone thinks, but I can tell you it is far more prevalent than you might want to think.

So why is this the case, the answer is both simple and complex.  It is simple in that there is no single connected vision for vocational education in this country, there is clear no statement about the value of vocational education.  Governments talk about how important it is, but generally only to those from the sector, and in the background keep reducing in real terms the amount of funding the sector has. It is never the center piece of discussion, jammed in between K-12 and University and seen by many nothing more than a way to appear to reduce unemployment.

There is no single driving vision, that can be clearly articulated and disseminated, talked about, and used to educate the public on the enormous value that this sector brings to this country and that is real shame.

Anyway that’s just my opinion.  Hope all of you that went had a great #2017NVC and learnt something that you can take back and make the VET sector stronger.

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.