Careers Australia in Voluntary Administration – Some comments

So just in case you haven’t heard the news today, Careers Australia was put into voluntary administration yesterday with PPB Advisory moving in as the administrators.  So as of yesterday there are 1000 staff who have been stood down and around 15,000 students who will have to organised into new courses through TDA who were Assurance Scheme for Careers.  I am going to be really blunt here.  I for one am not surprised that this has happened.  I said in a post earlier in the year when there was a range of closures of colleges which had grown large on a diet of VET Fee HELP, that as we approached the end of this financial year that we would see either the substantial contraction or closure of some of the big players.

Why has this happened?  The answer is actually very simple, as I talked about in the post mentioned above, heavy reliance on a single source of funding which can at any point be changed or removed is a recipe for disaster.  Careers Australia appear to have blamed the Federal Government and its policies around the sector, in particular the new VET student loans scheme and the governments decision not to allow Careers access to this scheme for their move into liquidation.

I have to say that I think if this is a true reflection of the rhetoric coming from Careers, then I think it is definitely stretching things a little.  Certainly it is the case that the cause of this collapse can probably be  linked to the decision by the government to change the way income contingent loans work and to deny Careers access to the new system.  However can we say that the Federal government is to blame, I think not.  In fact I actually struggling to find a scenario, except for the old, we are too big to fail, the government will have to bail us out mentality, that could have provided Careers and its management with the idea that they were ever going to be given full access to the new scheme.   I cannot see how someone within their management didn’t suggest that given the issues with the ACCC, a range of other issues, media coverage and general public sentiment, that there might be pretty good chance that the government, with its very strong position to clean up the sector, might, whether any of the issues raised about Careers were true or not, be reticent to give them access to the new scheme.  To be honest and to put in the word of Sir Humphrey Appleby, it would have been a brave and courageous decision by the minister and the department to allow them access to the scheme.

This should not be taken to suggest that I know anything about the inner workings of Careers or as to whether or not any of the allegations against them were true, or whether issues, if there were any, had not all been rectified.  It is just to say that simply from a point of view of being seen to be taking action and moving forward with the new scheme that, giving access to a provider which had been the subject of so much negative media scrutiny over the last 2 years would have undermined public perception of the scheme.  And the management of CA should have not only know that but have been prepared for it as well.  Even if they had been granted access to the new scheme this would have still seen their overall income drop by as much as two thirds, which would have had I suspect an equally devastating effect on them.  I am amazed that the management of CA appears not to have been working towards a solution or a way forward that didn’t include the VSL scheme, or maybe they did and we are seeing that in action now.  But again this is all simple speculation on my part and should not be taken to suggest anything about the mindset or plans and ideas of CA management.

It is yet another example of what happens when providers are far to heavily invested in one source of income, particularly where that source of funding is something that is controlled by the government.  Where your ability to be able to deliver the services you provide is entirely contingent on a single source of income and there are no plans or contingencies in place to react to changes in that income source there is always going to be a significant risk to continued financial sustainability.

I feel for the students and staff who have had their lives interrupted by this, however for a lot of us something like this happening has never been to far over the horizon.

Anyway that’s just my opinion.

 

Advertisements

Does Public VET mean Quality VET?

Before I start I need to make something clear, I think that a well supported public VET provider is, for the most part, a vital part of the VET landscape in this country.  There is work and projects which are done by the public provider which are either not done by non-public providers or only done by a small number of non-public providers, usually from the not for profit sector.  This piece should also not be taken to be criticism or bagging of the public provider sector, but rather a look at what seems to be a view being pushed by a range of particularly media commentators that the Public provision of VET through TAFE automatically means quality.

Firstly then a couple of facts.  The vast majority of private, again I prefer the term non-public providers, deliver high quality outcomes for their students and employers.  We can see this from NCVER data, and a range of reports from the various state and federal governments.  We can also see this from the small number of non-public providers who have closed or been closed as a result of the fall out from the VET FEE Help issues.  As I have always maintained there were about ten or so providers who were not playing the game as it should have been played so to speak.  10 out of around 4000 or about 0.25% of all providers.  Enough defending the value of non-public providers however’ what is a far more interesting phenomenon I think is the calls from various commentators, that governments should be cordoning off more funding for public providers, because, and this seems to be a common theme, public providers provider quality training.

It is important to note here that I do believe that for the most part public providers (TAFE) do provide quality training outcomes to their students and employers, however as with non-public providers I simply do not think that we can automatically assume that public means quality in all cases and in all courses.  We certainly cannot assume that public means better than non-public in all cases and in all courses.  There are numerous examples across widely varying industries of non-public providers delivering training of at least the same, if not better quality than that which is delivered by TAFE.  Just as there are examples in the opposite direction as well.  TAFE does some things very well. Non-public providers do somethings very well, and across the board there are things are probably not done as well as they could be.

Of course the point of this view is to push the agenda that because TAFE equals  quality that TAFE should get the lions share of government funding.  The interesting thing is that it already does.  The vast majority of government funding and training monies go directly to TAFE, in fact in most states the split between public and non-public when it comes to funding is about 80/20.  So somewhere in the vicinity of 20-25% of government funding goes to non-public providers, while 75-80% goes to TAFE.

So if TAFE already gets the vast majority of government funds allocated to training already,  and if across the board it really doesn’t seem to matter where a person goes to get your training done, as they are probably going to get a quality experience, which meets their needs and provides them with the outcome that they desire regardless of the choice them make, where, oh where is this view coming from.  Part of it is certainly ideological and interestingly I have no real problem with groups, particularly political parties, taking their ideological stances, I just want them to be honest about it.  I don’t care whether you are a politician, part of the education unions, an academic or a researcher, or anyone else for that matter, if you are making a stance on ideological grounds then at least be willing to tell us that.

What this sector needs going forward is not infighting between the various parties, interest groups, providers, media and others, who are whether consciously or not, promoting a particular ideology or agenda.  We need facts and informed discussions.  We need everyone to sit down, put their baggage, their ideologies, to one side, and listen to what other people are saying.  Listen, then openly talk and enter into meaningful discussions about what is best for this sector and the vital part that it plays in the future of this country.

Rebuilding VET

So  a number of people over the past few weeks have asked me about my opinions about how we can rebuild and revitalise VET in Australia.  While I have in the past spoken about what I thought might be specific changes to particular parts of the system, I have to at least some extent shied away from proclaiming my view for a future of VET.  One of the reasons for this is that, to me, a lot of what happens in this sector, a lot of what the sector does and the vast majority of the outcomes which are produced are excellent.  I am not sure that the sector needs a reimagining or wholesale reenginerring of how it operates.

If you listen to the left you will hear the constant chant of TAFE TAFE TAFE, get rid of private providers and the system will be right.  If you listen to the right, it is all about market forces, competitiveness, and the free market and here of course is the rub, they are both right and they are both wrong.  The answer lies somewhere in between.

We need a strong public provider and a strong network of private providers to make the system work effectively, more importantly though we need both groups to be treated the same and regulated the same, and not just in name only, in actual practice.

We need to recognise that trainers and assessors in this industry need to have three skill sets.  They need to have a deep understanding and relevant, up to date knowledge of their industry; they need vocational currency.  They need to have and understanding of the VET sector; how assessment processes work and what it means for someone to be competent, and they need to be good at presenting the material they are covering in an engaging and meaningful way, so that students actually learn what they need to.

We need the owners and senior managers of of all providers, be they public or private to really actually put students and their outcomes first.  Yes sustainability is vitally important, but we are in the business of education, so the actual education should be our focus, not how much money we can make, or whether or not we have the best office or the best view, or what awards we get.  The outcomes for students should be at the heart of what we do and if it isn’t we should probably get out and find another sector.

We need the regulator to actually regulate.  More than that however, we need to regulator to act fairly, consistently and in timely manner.  It is essential that providers regardless of whether they are public or private, new entrants or longtime RTOs, catering to 100 students of 10,000 students that they will be treated and assessed fairly and consistently and that breeches dealt with appropriately.

We need to government to invest in the VET system and to invest in it properly.  There is a need for sensible long term commitments to funding plans, be they direct entitlement style funding, organisational funding or contingent loan facilities.  The commitment however has to be long term and it has to address the skills and knowledge needs of this country moving forward.

Sounds really simple doesn’t it.

 

Let’s start being positive about VET

As some of you know I have been out of commission for a couple of weeks due to an injury to my hand, and during this little break from writing, I have spent a lot of time reading commentary, writings and discussions about the sector.  Something has struck me from all of this reading and it is something that really concerns me.  It seems that a lot of the commentators, industry leaders, thinkers and just people in the sector generally are spending a lot of time complaining and focusing on the negative issues which seem to be surrounding us.  Why does this concern me? Well mainly because we know that what it is we focus on and think about is what we see and what we get.  So if we continually talk about what is wrong about this sector, what needs to be fixed, and what all of the problems are, that is what we are going to see, that is going to inform our viewpoint of the sector and more importantly it is going to infect the viewpoint of others about our sector. Don’t get me wrong here, I like everyone am guilty of being critical of the sector and sometimes we do need to verbalise criticism, but too often I think this critical view takes over, so I want to try to change that a little today and see if we can’t just be positive about the sector for a while.

First off I am really proud of the sector that I work in.  I feel privileged to work in the VET sector, this is a sector that changes lives.  I was at a conference recently where a lot of people (and a lot a highly placed people) shared stories about how this sector had changed peoples lives.  Like the (youngish) grandfather who had improved his reading so much while undertaking a VET course that he was now able to read stories to his granddaughter and the massive change in the way he felt about himself that this seemingly small thing had created.  The kids from generationally  unemployed families, in deeply impoverished areas, getting apprenticeships and breaking out of the cycles that had been their lives.  People with Mental illness getting qualifications and training to help them to be able to work with others with mental illness to help those people on their own roads to recovery.

What we do in the VET sector is important!

We don’t just issue pieces of paper to people, or fill their heads with knowledge, or teach them how to perform tasks.  All of that stuff is well kind of the boring stuff of the sector, the nuts and bolts that sit underneath what it is that we really do.  We offer people the opportunity to change their lives, to have the opportunity to do things they are passionate about, to look at the world differently and explore the opportunities that are there.

VET changes lives!

I am so grateful that I have been able to work in the learning sector, be it VET or organisational learning, or professional and personal development for so many years, because it fuels that passion and that idea that what we do is important and let’s be clear it is not just important to the people we teach.  The importance of what we do if is wider than that.  We have seen recently several reports about the return on investment created by the sector, the value of international education, and the range of other important things that this sector does for the country as a whole.

So I have a little challenge for you all, Whether you are from the public sector (TAFE), a private provider, a not for profit or and enterprise RTO, let’s even if only for a little while try to focus on the great things this sector does, let’s talk about and share the good stories, the life changing moments, the things that really matter, because if we do that then we will improve the sector and the image of the sector far more than we ever could by focusing on the negatives.

 

Anyway, that’s just my opinion.

Is there a problem with VET in Schools?

We all know what VET is schools is, vocational qualifications delivered through the secondary school system, with either the school being a registered training organisation in its own right or where it is tightly partnered with another provider.  Well it appears that there may be some problems?  I say this because it seems that there are a number of investigations, research, internal and external consultations going on at the moment at various levels across the country and it seems from what I have been told by more than a few sources that the results of these investigations for want of a better is well, not great, perhaps even damming.

So what is the problem?  It seems that the numbers of students completing certificate i and ii courses through the various VETiS programs is dropping, replaced by year 11 and 12 students undertaking certificate II and IV and in some cases even higher level qualifications.  Now you might be thinking is that actually a problem, delivering the higher qualifications will give the student advantages over just having a certificate i or ii when they leave school.  Now while that might be the case if these qualifications were being delivered properly, but it seems that at least two investigations have found that that is simply not the case.  They seem to have found that these higher level (certificate III and above) programs being delivered within the school environment are being significantly dumbed down, often having very little connection to the industries they are supposed to be being trained in, insufficient workplace based learning and placement time and a lack of properly qualified trainers.  All of this is leading to students finishing year 12 with a piece of paper they think is going to help them get a job, but is really in terms of their skills and employability little more than a certificate of attendance.

Now if these rumors (and I have to stress here that no one at any of the Departments of Education has verified any of this, at least not officially) are even somewhat true, it points to some significant issues within VETiS.  I was concerned sometime ago what I noticed more and more secondary schools delivering Certificate III and above programs internally as I had always viewed the role of VETiS to be preparatory, providing year 11 and 12 students with pre-vocational, and pre-work level qualifications, those qualifications that usually sit at a certificate i and ii level.  Given the changes to a range of qualifications where work placement and more assessment criteria based on actual work have been included, it has for a while now seemed difficult to me to figure out how a secondary school RTO could be meeting all of the requirements of at least some of the programs they are delivering, at a certificate III level.  The of course seems only to increase substantially as we move up the AQF levels.  I am also entirely uncertain that whether or not the vast majority of secondary school students have the capacity to be able to successfully complete diploma level study in particular while still in school.  This should not be taken to suggest in anyway that there aren’t schools out there that are doing fantastic things for their students in the VETiS space, or that some students may have the capacity to undertake higher level studies while still in school, it is however something we need to look at very very carefully.

It is already extremely difficult for school leavers to find employment, particularly employment in areas that they actually want to work in, not preparing them properly for entry into the workforce is only going to make that situation worse.  We may think that providing a student with an ‘easy’ route to a certificate iii or higher during their time at school, particularly where that student may not be going excel in other more traditional curriculum, will assist them to find work when they leave.  It won’t.  If they are not properly competent, even if they do get a job, they will find themselves out of a job just as quickly and find getting another job in their industry much more difficult.

VETiS should be there to prepare students to move into either further study in their field or to start work and learn while working.  It does that best at least in my opinion, by providing them with those courses which prepare them, which provide them with the basics of work of their particular industry, those traditional certificate I and II level courses, not certificate III and above.

I certainly hope that the information around the VETiS sector that we are seeing is not correct, but sadly for my experience it does seem to be the case.  I think VETiS is fantastic and I would hate to see it damaged by the pursuit of extra funding and an ‘easy’ solution for some students.

Anyway that’s just my opinion

ACCC decisions, ASQA, VET FEE HELP and the end of the mega college

A few weeks ago I wrote a piece entitled Death knell of the high growth mega college looking at the significant issues that were facing a number of the most high profile mega colleges in the VET sector and suggesting that what we were seeing was in fact the last throes of the large, aggressively marketed and growth oriented private RTOs.  Yesterday we saw what is another nail in that coffin with the ACCC announcing it had accepted a court enforceable undertaking from Careers Australia regarding false or misleading representations and engagement in unconscionable conduct, in breach of the Australian Consumer Law around the marketing of its VET FEE HELP courses.  So before we look at what this means for Careers Australia and what it might mean for the sector lets have a quick look at the decision and undertaking itself.

Between 1 August 2013 and 31 March 2015, Careers Australia received and processed applications from around 40,000 students for enrolments into its VET FEE-HELP courses. Of these students, 20,242 were enrolled and incurred a debt to the Commonwealth. Careers Australia received approximately $190 million worth of payments from the Commonwealth in relation to these students. The ACCC was concerned (and Careers Australia has admitted by virtue of its undertaking) that some of its agents engaging in door-to-door marketing and telemarketing across Australia, made false or misleading representations and engaged in unconscionable conduct.

“This conduct affected some of the most vulnerable and disadvantaged groups of consumers in Australia. For example, it is unacceptable that Careers Australia allowed 80 consumers from a remote Aboriginal community in Yarrabah, Queensland to be enrolled into courses and incur debts when they were offered inducements to sign up but not alerted to the debts they would incur,” ACCC Chairman Rod Sims said.

So what does this mean for Careers Australia, well first and foremost it means that Careers Australia has undertaken to automatically cancel the enrolments of students who have not completed a unit of study, and repay the Commonwealth any amounts received as a result of those enrolments As a result of this undertaking Careers Australia has cancelled at least 12,130 of these student enrolments and either repaid or partially repaid to the Commonwealth amounts totaling at least $44.3 million.  This is a phenomenal sum both in terms of money and in terms of sheer enrollment numbers.  Sixty percent of its enrolments over 18 months up to March 2015, have been cancelled.  In addition while $44 million has been repaid the other thorn is that Careers Australia will now not be eligible for in excess of $300 million which it may have been able to claim in relation to these students.  Now let us let that sink in for a moment, it looks as if Careers Australia’s potential (and actual) cash flow has been gutted to the tune of somewhere between $50 million and $350 million depending on how they modeled future payments.  In addition to this though there may be many more cancellations and potential refunding of cash as, as part of the decision, Careers Australia will also invite other students who may have been misled to approach them should they want to have their enrolment and debt cancelled.  If even 10-15% of their other enrolled students feel they were mislead, given the dollar amounts charged for various qualifications we could see the repayment figure rapidly approach $100 million.  One could be forgiven for suggesting that White Cloud Capital who own a significant portion of the company might be feeling a little worried at the moment as might the other shareholders.  Of course being a private rather than a publicly listed company means that we won’t see a sharemarket implosion as we saw with Vocation and Australian Careers Network.

The next question is then a simple one and that is can Careers Australia survive this, and in addition to that simple question a more complex one, being, should it?  It seems certain I think that as a result of this Careers Australia will and probably must at the very least downsize and attempt to control costs and must also rethink its business model, from the ground up if it does hope to survive this.  There is a bigger question here though and that is should it survive this?  Should a company which has acknowledge that its agents engaged in unconscionable conduct be allowed to continue as a Registered Training Organisation and hold a VET FEE HELP contract or for that matter any other contract.  I mean I have worked in Yarrabah (in another life), I know first hand the conditions and levels of education and general skills and knowledge (and I mean no disrespect to the people of Yarrabah here at all) that exists there and I can tell you that without a shadow of a doubt no one with common sense, let alone a conscience could ever enter that community and think that 80 of the residents there understood what they were being signed up for.

I am struggling as I am sure many others in the sector are, with whether a company who knowingly allowed these kinds of activities to occur should be able to continue to operate in this sector. Surely this undertaking must however make ASQA as the regulator, the Federal Department of Education and even the various state training departments with whom Careers Australia has contracts, seriously consider their next actions.  It begs the question, can the Federal government do anything else other than remove Careers Australia’s VET FEE HELP contract and if that happens will we see another of the mega providers slide into administration.  If that happens I like so many others will feel deeply for both the staff and the students who are caught up the in the middle of it all.

What does this mean for the wider sector though?  It means that anyone who was using a broker or agents and who wasn’t careful around the students they enrolled in their VFH programs should be feeling a little uncomfortable at this point, particularly considering that the ACCC currently has actions around four other providers and is looking into another five.  On the other hand it is a good thing.  This rampant growth fueled by education brokerages and agents who had a sign up everybody attitude had to stop.  The damage it has done to the sector in beyond belief.  I would however also like to see the ACCC go after the brokers and agents themselves, though I acknowledge that this may be significantly more difficult.  This is however what the industry and the sector required, it required those who allowed these things to occur to be called to account so that these practices which in no way contribute to the outcomes of students, the sector, industry or employers can be stamped out and we can get back to doing what the vast majority of providers both public and non-public do and that is provide high quality training that makes a real difference in the lives of people.

Anyway that’s just my opinion.

 

On the Redesigning VET FEE-HELP Discussion Paper

So as most of you are aware the Redesigning VET FEE HELP discussion paper was released on 27 April with submissions closing on 30 June.  So what I thought I might do today is have a look through the paper and discuss some of the propositions and statements in it and then see where we land after that.

As I have said many times previously, I think income contingent loans for a vital part of the educational landscape, they allow people to study things that they want to study, some of which may not have direct correlation to employment outcomes.  They also provide an opportunity for people, who without these processes may have not been able to upskill themselves in relation to job roles then may be interested in now, or in the future.

The first part of the paper goes through the purpose and reasoning behind VFH and how and why the system was extended into the VET sector from the higher education sector.  Also interestingly I think, it points out some of the differences between the two sectors which have, at least in part have been responsible for some of the problems the income contingent loan process has had in the VET sector which didn’t occur in the higher ed sector.  These differences are things like lower barriers to entry, lower graduate pay rates, competency based rather than a graded system, lack of formal semesters, with the preference being for rolling enrollment dates and a not insignificant number of VET enrolments where the student does not intend to finish the course rather their intention is to only complete a small subset of units, which has an effect on overall completion rates.

It also makes the point that the regulatory landscape surrounding VFH is quite limiting in terms of responses.  Non-compliance with ASQA and the regulations do not have a necessary impact on the right of a provider to payment of fees, the department had only limited powers of audit and information gathering and limited capacity to take compliance action for RTOs who had appealed ASQA decisions.  As it sates in the paper ‘until January 1 2016 the only relevant consideration for determining a providers’ payments was whether or not the providers’ student had an entitlement for VFH’.  In addition it looks at the fact that there was massive growth in VFH between 2012 and 2015 with the highest grow areas being those where the students could be considered to be most at risk or vulnerable.  There was a 649% increase in indigenous enrolments, 503% increase in very remote enrolments, 181% increase for people with disabilities and 172% increase for lowest socioeconomic status quintile.  In fact the lowest increase was in the highest socioeconomic quintile.  Now while this itself is not necessarily a problematic thing as it may point to more people, who would not have usually undertaken training, entering the system, it clearly should have been a red flag given the outcomes we know have occurred.  There was also a significant increase in tuition fees from an average of $5917 for a diploma in 2012 to $14018 in 2015 with VFH loan values doubling from 2009 to 2015.  This caused a massive disparity between the cost of diplomas under VFH and price various state governments were willing to pay in terms of funding for the same diploma.  A Diploma of Salon management for example with a smart and skilled pricing of $6,330 had an average VFH price of $32,941. The other issue that sat along side this, was the issue that a great many of the qualifications with the highest levels of enrollment had little or no actual links to employment outcomes.  A prime example of this is the Diploma of Community services where there is little or no job outcome as the vast majority of employers in the sector want people with a certificate III or IV in aged care or disability or similar as these are the qualifications which are required for the vast majority of roles.  The paper then goes on to discuss a range of other issues, including the dominance of the system by a very small number of providers, before moving on to look at the current and future reforms to the system.  It does appear however, that the 2015 reforms are having an effect on VFH providers with all areas of complaints (with the exception of debt dispute, which is a lagging indicator of previous poor performance) have dropped, in most cases significantly.  It is also acknowledged in the paper the capping of enrolments at 2015 levels may have had an effect on some ethical providers, but that it was necessary to reign in the soaring costs associated with the program.

So now let’s move on and have a look at the discussion questions posed.  The first question posed is whether there are additional eligibility requirements which might be necessary for the VFH system, with an additional question around administrative complexity in relation to LLN skills for potential students.  Now I am going to be a little controversial here because I think to a large extent both of these questions can in fact be answer quite easily.  Yes there should be an additional requirement for VFH students (which should if done well solve the LLN issue) and that is at a student not be eligible for VFH unless they have already successfully completed a course of study at Certificate IV or lower.  It is important I think to remember that is would not be a course prerequisite but rather a policy setting around eligibility for the VFH loan scheme.  If you have not completed a lower level qualification then you are not eligible for a VFH loan.

In terms of the lifetime loan limit for students I see no problem with it being part of and the same as the general Higher Ed FEE HELP system, providing of course there are some other refinements to the system put into place, particularly around the rising cost to students of obtaining a Diploma.  I have on a number of occasions suggested that the government rather than limiting the loan amount or price setting (setting a price that all providers need to charge) it rather needs to simply develop and publish, and force (through its VFH contacts) all providers in all of their materials to publish, a ‘recommended’ price.  I do however think that attempting to calculate this price, factoring in mode of delivery over complicates the process without adding significant value.   With this recommended price openly published providers can then still choose to charge whatever they wish.  Those who wish to charge lower than this may justify it by them being a TAFE or a not for profit or any other number of reasons, and equally those who charged a higher fee would then need to justify why their course costs where higher.  The justification process could also be one that was part of the VFH application process as well, where providers were asked to justify why their course costs were at the level they had set them if they were significantly over or below the recommended price.  I also think the concept of linking VFH funding levels to industry need, employment or pathways to further study has value.  A priority system (similar to that used in some of the states) could then be used to determine the level of VFH funding applicable to the course.  A level one priority program would have a VFH loan rate of 100%, Level two 75%, Level three 50% for example.

It is my opinion and one which I have held for some time now, that external, third-party brokers, should simply be banned from the VET sector.  They add zero value to system and only serve to drive prices up.  All marketing should be done by the RTO themselves and directly controlled by them.

Rather than simply a VFH ombudsman a far more elegant solution would be to  appoint a VET sector ombudsman, however it is acknowledged that given the way in which various powers are spread across the states this may be significantly more difficult to achieve therefore it seems that an ombudsman to deal with VFH.  It would be my suggestion that this simply be a short-term appointment to deal with the current issues with its continued necessity being considered after changes to the system had been implemented.

I am also in favor of provider cap of some description.  A provider should on application to utilise VFH estimate the number of VFH students they will have within the next financial year.  This initial estimate should be capped at a level not exceeding 75% of their current student enrolments.  This estimate process could then simply occur each year which any increase on the previous years cap of more than 10% requiring justification as to why the number of enrollment will increase that significantly.

In terms of quality measures the links between results of ASQA audits and non-compliances and continuing VFH approval should be significantly strengthened, with higher quality standards being applied to all VFH providers through the provisions of the contractual arrangements.  This should include student completion and progression rates and additional outcome measures around employment and further study outcomes resulting from the various courses of study.

It should also be the case that with any new standards/contracts that all current providers be required to reapply for VFH status under any new system.  There should be no providers who are simply moved to the new system.  The current system should be finalised at the end of 2016 and all students either given two years from their initial enrollment date to finalise their course of study or moved onto the new system where appropriate.  In addition there should be a legislative time limit placed on all approvals (no more than 3 years) which should also be at the discretion of the minister to alter or removed as deemed  necessary on a provider by provider basis.  All providers approved to deliver under VFH should be, as with most funding contracts with the various state governments, required to report their avetmiss data on a monthly basis.

I think the current tuition assurance system is solid though there needs to be stronger links between the government and the providers of the schemes in order to ensure that students are provided with the range of protections which they require.

It is and continues to be my position that upfront payment of fees is in general a mistake and the system should be moved to a model which is more reflective of completions rather than commencements.  A fuller discussion of this can be found here.

Anyway that’s my opinion.

 

%d bloggers like this: