Let’s talk about the system before we talk about funding.

There has been a number of articles and papers popping up recently which have discussed the need to reform post secondary training and education funding in Australia.  Now while certainly I would agree that this is an issue which we need to look at, and one which requires careful consideration, I can’t help but wonder if it isn’t a little bit of the tail wagging the dog.  Bear with me while I explain.

There is always a lot of discussion about how VET in this country is funded, who should get what, should it be more competitive or less, what should be funded, the list is endless and so is the opinion and verbosity about it.  Firstly don’t get me wrong, I think that discussions around how we fund post secondary education and in particular VET in this country are vital to our ability to be able to deliver high quality educational outcomes and ensure equality of access to education in this country.  However all of this talk of funding obfuscates the real problem that underlies the entire sector and that is the question of what is the purpose of the sector and what we need to do to ensure that we have a system that best addresses that purpose.  I would hazard to guess that if we took the approach of making sure the system and purpose of the sector were aligned that we would need to spend much less time thinking about the who, what, and how of funding as hopefully the answer to these questions would be apparent as a result of how the system worked.

For quite a long time I have held the position that when we look at the VET sector, its purpose is fairly clear and that is that the purpose of Vocational education and training is to designed to deliver workplace-specific skills and knowledge to assist participants to improve their workforce participation options.  Now over the years people have suggested that this concept is to narrow and that the purpose is to increase the overall levels of education with in the country, so that we have in general a smarter better educated populous, because education and learning are ends in themselves and not simply means.  While I have some sympathy with the position and generally that education and learning are important in and of themselves, this is not and should not be the central purpose of vocational education in this country.  It is certainly not the purpose for which the vast majority of students use it for.

it is clear from years worth of data collected by NCVER and other places that more than 80% of all participants in VET are seeking to convert their participation in the sector and subsequent qualifications to improve their workforce participation levels, either through getting a job or by improving or changing the job role that they currently have.  If the vast majority of participants in the sector are seeking workforce participation improvements and the sector is, pretty much by the definition of the words themselves (Vocational, Education, Training), about delivering workplace skills, then it seems clear, at least to me, that the main purpose of the sector should be what I outlined above ‘to deliver workplace-specific skills and knowledge to assist participants to improve their workforce participation.’

Given the purpose which I have put forward this gives us a fairly solid foundation from which to commence building a system to deliver on that purpose.  I don’t propose to do all of that here and now, but I will point out a few things which instantly seem to pop out.  The first is that there must be a connection between the knowledge and skills being learnt by the participant and the role they want to utilise them in.  No point in teaching someone underwater macrame if they want to an airline pilot or teaching a prospective printer how to work a Gutenberg Press. This means that there must be an intimate connection between industry, content, delivery and assessment.  It also needs that the system needs to be agile enough to cope with rapid changes in the skills and knowledge base of particular industries.

It also means that the system must ensure the validity, particularly in terms of competency, of any qualification issued.  Participants must be able to convert their qualifications into workforce outcomes and the only way that can effectively happen is if there is robust confidence in the competency outcomes of the qualification.  If as an employer I cannot guarantee that a person a particular qualification or  a qualification from a particular provider, then I am less likely to allow the conversion of that qualification into a workforce outcome, which in turn undermines the entire system.  In fact if workforce outcomes are the primary purpose of a VET system then the ability to convert qualifications into those outcomes is the lynch pin.

As i said I am not going to try and develop and entire basis for a system here, but as i said earlier, while discussions about funding are vital, we need to ensure that we have a system that supports the purpose of what the sector is trying to do first.

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Private Equity, investment and consolidation in Vocational Education

A couple of days ago now the AFR posted an article about private equity and the Australian for profit education market, including Vocational education, in which they suggested ‘The Australian education sector is set to be the subject of a wave of consolidation led by private-equity looking to tap into its high-margins and predictable cashflow. Global strategic-advice company, EY-Parthenon, is gearing up to target the $25 billion for-profit education industry.’  The trouble is that I can’t help but think I have heard this all before.

During the middle and running through to the what was clearly inevitable end of now infamous VET Fee Help era, private equity firms, based on amazing high EBITDA margins, the lure of cashflow backed by government contracts, and an almost complete and utter misunderstanding of the VET industry in Australia, rush into the market and snatched up, partnered with or poured money into some of the biggest players in the educational market at the time all of which failed to produce the results which were way overhyped by ambitious CEOs, Managing Directors and founders looking to provide cashflow for expansion in a market which everyone, except it appears, the so call professional private equity gurus knew was a bubble soon to burst.

Now less than two years since the bubble well and truly started to burst and the demise of the vast majority of private equity backed providers, we see yet again a private equity strategy company selling the idea of investment in the Australian education business.  Admittedly EY-Parthenon and their Varun Jain and not limiting themselves to the VET market this time with their eyes on a more broad vista including early education, schools, VET and Universities. The problem for me is in statements such as such as the one where Mr Jain suggests that the fact that funding comes largely from the public sector, student fees and philanthropy is not something that he is concerned about, shows a think a deep misunderstanding of the volatility of the publicly post secondary education market in this country.  Post secondary education and particularly vocational education in this country has always been very much at the whim of the political winds and lean of whoever is currently in government.  I mean money always flows towards TAFE which of course could have more to do with gravity or perhaps more correctly inertia than anything else.  Then of course the spray which escapes from the main trickle is what is left for the non-public sector and exactly how much of a spray that is depends on some many thing that are out of the control of the operators of non-public RTOs.

So some of you are probably thinking now, why is he banging on about this.  It is simply because I am a little worried by this talking up of private equity again.  Not because I think that all education should be publicly delivered, the educational market should be as diverse as possible to allow for innovation and choice.  Nor do I care about private equity firms losing millions of dollars when the businesses they have invested in (without proper consideration most of the time in my opinion) fail.  Although I do care deeply about the effect that this has on both students and our sector workforce.  The concept of industry consolidation doesn’t present an issue for me either, as I do think the entire sector, public, private and not for profit, could do with a shake up and consolidation.

What worries me is that we have seen this before and we have seen the effects of it.  We have seen investors with little or no understanding of the education market in Australia and even less understanding of how to run an educational business, take substantial stakes in providers and because of their lack of knowledge and understanding drive their investment vehicles into practices and operations where their ability to deliver quality training and meet compliance needs are stretched to breaking point and beyond.  Roll ups, complex corporate structures, a focus on warm bodies rather than quality, all the things that force governments to enact changes to funding programs and harms the public’s view of the industry as a whole.

If you are a private equity firm (like EY-Parthenon ) please for a start do some real research, talk to people who are actually involved in the industry not just the usual crop of pundits, lobbyists, ex politicians looking a board seat and the like, because I can tell you that they knew like the rest of us about the issues around Vet Fee Help and market in general when the last crop of equity firms rushed in, they just didn’t bother to say anything.  Secondly if you are going to invest, again put people on your boards and in senior management roles who understand the market in this country and really understand the issues around training and assessment in our regulatory environment.  If you don’t then you are throwing good money after bad and damaging the industry in way you could not possibly understand.

 

Queensland VETiS and the New ATAR, a disaster waiting to happen?

So as some of you may know, I have over the years been quite critical of a range of things which occur in the VET in Schools (VETiS) space, not only in Queensland, but in most other states as well.  Things such as the the clear lack of adherence by school based RTOs to the Standards, the qualifications and depth of industry experience of trainers and assessors (particularly those who are teachers) and the types and levels of qualifications which are being delivered.

So let me be clear right from the outset where my opinion lies, anything higher than a certificate III (and if I am being completely honest even Cert III level often worries me) should not be being delivered within a schooling setting.   The concept of the delivery of Certificate IV, Diplomas and even advanced diplomas to students who have not finished their secondary education is in my opinion ridiculous and fraught with dangers.  In addition while I have nothing but the utmost respect for Teachers, just because you are a teacher does not mean that you know a dam thing about vocational education or the needs of industry in terms of training deliver and assessment, and sorry, but if you are a PE teacher who has been RPLed through a Certificate IV in Training and Assessment and  Certificate IV in Fitness so that you can deliver Certificate III qualifications to your students, unless you have a whole pile of industry experience (and I don’t mean teaching experience I mean actual experience working the industry you are training in), you ARE NOT qualified to train and assess your students and you are not complying with the Standards.

Now that I have been really clear about where I stand on this it will probably come as no surprise that I consider the Queensland curriculum and assessment authority’s (QCAA) stance on VET and the new ATAR system being introduced, as potentially incredibly damaging to the quality of training and assessment being provided to our school students, shortsighted and showing a complete lack of understanding of the VET system in this country, will have a devastating effect on the workforce participation potential and ability to undertake further training of a significant number of students, and is well frankly idiotic.

What you may well ask is happening to elicit this vitriolic response? It is actually quite simple, and revolves around the calculation of ATAR rank, and while on the surface it seems not to problematic, there is a mindset underlying it which has the potential to be incredibly damaging.  When calculating the new ATARs QTAC will calculate ATARs based on either:

  • a student’s best five General (currently Authority) subject results, as is currently the case for the OP system, or
  • a student’s best results in a combination of four General subject results, plus an applied learning subject result.

Now on the surface that seems reasonable, however as is often the case with these things the devil is in the detail and when you look further into what an applied learning subject result might be you find this;

The best result in a:

  • QCAA Applied (currently Authority-registered subject or Subject Area Syllabus subject) or
  • Certificate III or
  • Certificate IV or
  • Diploma or
  • Advanced diploma,

Did the person who came up with this concept, have even the slightest notion of what is, or should i say should be, involved in completing a Diploma of Advanced Diploma.  The QCCA is actively encouraging the delivery of programs of study which almost by definition will be rubbish, because there is simply no way in which (at least in most cases) the assessment requirements for studies at the level that they are talking about can be met within a school setting, and to think that this is possible shows an utter and shameful lack of understanding of VET and the AQF.  Further more they are encouraging the delivery of programs to students, which will make them ineligible for the vast majority of the post secondary VET funding options which are available for when they realise that their Diploma in Business is utterly worthless and will not help them to get a job. Why?  Because for the vast majority of actual funding programs, if you hold anything higher than a Certificate IV in anything you are automatically excluded. 

VETiS in Queensland is already a disaster and this will simply devalue further the qualifications which are being delivered through it more and deeply harm the outlook for students who have been sold the lie that the piece of paper they get from their school saying they are competent at a Diploma level (or really any level at the moment) will get them a job.

Is it time for capstone or endpoint independent assessment in VET?

With a number of countries including the UK moving towards using some sort of capstone or endpoint assessment to act as a final gateway for apprentices, to confirm their competence, prior to being awarded their qualification,  it seems like it may not be a bad time for the Australian VET sector to look at the concept as well.

What is an endpoint or capstone assessment then?  It is an independent assessment  of the knowledge, skills and behaviours that have been learnt throughout the apprenticeship. The purpose of which is to make sure the apprentice meets the standard set by employers and are fully competent in the occupation.  If we take the UK for example End-point assessment must be administered by an assessor from an approved, independent End-point Assessment Organisation, and not by the training provider.  It is the simple idea that at the conclusion of the apprenticeship and prior to the awarding of the qualification an independent body, not connected to the training provider or the employer, makes a final assessment of the skills and knowledge of the apprentice to ensure that they have successfully learnt the skills required for the qualification and are therefore competent to be awarded the qualification.

The first question most people as when this suggestion is bought up is Why?  Why is there the need to have a separate independent organisation certifying the competence of the student, isn’t that what the RTO (public or not) is supposed to do.  Of course the simple answer here is that under our VET system that is correct, it is the RTO who is responsible for certifying the competence of the student and awarding the qualification.  However I think given the recent issues with both public and private providers and the fact that ASQA has had to either rescind or have reassessed a substantial number of qualifications across a range of industries, it seems at least to me, that confidence in the fact that providers are actually doing enough to ensure competence may actually be a significant issue.  That those students who receive qualifications, regardless of what industry it relates to, are actually competent and have the requisite skills and knowledge they require in order to do the work which the qualification says they are able to do, is really the bedrock of our system isn’t it.  If more than 80% of people undertaking VET are doing it to improve their workforce participation, then their ability to convert that qualification into some kind of workforce outcome, along with the need for employers who employ these students on the basis of having a qualification, which indicates they possess a certain level of skills and knowledge are paramount.  In fact we have seen a number of employers now feeling that they need undertake their own testing of ‘qualified’ potential staff to ensure their competence prior to employment.  The idea of end point assessments is I think one that is certainly applicable to apprenticeships, however I also think there is certainly a useful application for them across a range of disciplines.  There would also be an interesting side benefit of a system of independent assessment and that is that it would provide substantive information to the VET regulator around the quality of graduates from different providers.  A high level of failure of students from a particular provider would be a risk indicator for the regulator to cast a closer eye over that provider.  We would I think also see that those providers who were less that scrupulous in their training and assessment practices would begin to exit the market as it would become more difficult for them to sustain their business models.

There are a range of conditions however which these kind of assessments require to meet, in order I think to be both successful and valuable.  The first is true independence, these gatekeeper organisations cannot be connected to training providers in any way.  They cannot be part of the TAFE system or linked to private providers at all, they must be truly independent organisations.  I would also suggest that along with this goes the fact that they cannot be government agencies, because, unfortunately as we know, there are often competing pressures placed upon government agencies which may make them less effective in carrying out their duties.   A couple of suggestions then spring to mind, the first of which would be to utilise the various peak bodies for different industries as a conduit to enabling this sort of assessment.  To me there may be issues here as peak bodies are often tightly linked to, and in a substantial number of instances paid for by the employers they represent.  This may produce the perception of bias or making things easier, particularly when there are shortages in the labour markets they represent.  Another possibility would be to utilise the already existing SSO’s and simply add to their duties, the development and administration of independent end point assessments.  This suggestion makes a fair bit of sense to me as there are already existing organisations in place who are tightly linked to the development of the training packages themselves and who are already funded to provide a range of VET services.  The third option would be to not utilise any existing structures and build the system from the ground up with organisations applying for and being granted a license shall we say to deliver these assessment services.  Of course stringent requirements would need to be developed to ensure that the veracity of these organisations were not subject to even the perception of bias or unethical behaviour.

I know that there will be those of you out there who will say that all this is doing is creating another layer of bureaucracy, and that what is in fact needed more high quality providers who can be trusted in their practices, and less lets get this qualification done as quickly as possible providers in the system, and to be fair you are probably right.  The problem is, that what we are doing is not working, and if we are  honest has not been working for a while now, and suggestions like removing the contestable market place or only providing government funding to public providers or more regulation and harsher penalties will not, to my mind at least, make any substantial difference.  The concept of independent final assessments may however actually revitalise the levels of confidence that everyone has in the system.  It is I think at least something we should be talking about.

 

 

 

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.

Vocational Education, Career Development and Employment

I went to a really interesting discussion hosted by ACPET last week centered on the theme, careers not courses.  As some of you may be aware this concept of career development, employment opportunity and workforce participation is a subject that I have viewed as quite important for a while now.  Too often we see post secondary graduates, whether from the VET sector or the University sector coming into the workforce either clearly not properly trained and assessed,  having not been taught particular units or subjects, or that the material they have been taught is out of date.  This therefore makes the student who was hoping that their qualification would net them a job when they were finished not actually capable of doing the role they are supposed to be trained for, yet not knowing that this is the case.  So they submit resumes and go to interviews (when they get past the resume stage) and almost never understand why they don’t get the role.  There are also a not insignificant number of people who get to the end of their study, get into the role they are trained for and find out rapidly that it is just not what they expected or what they want to do.

Of course when you start to think about this issue it becomes really obvious that there is no quick fix here.  It is caused by a number of different failures throughout the system.  The first failure point if that of the mismatch between qualifications, and the requirements of industry and employers, and this is certainly not an issue which can or will be fixed overnight.  It is also one which has a more significant effect in some industries, particularly within fast-moving industries, than in others, but given that training packages define the parameters of the training to be delivered and changing them has traditionally be a long slow process and one in which industry and employers have not stepped up as much as they could have it would seem that this issue may be difficult to address in the short-term.

There are a couple of things which I think can be done, at least more easily than reconnecting training packages and industry, and that is this idea of career development or advice and using that advice and its outcomes to inform training programs, units of competency and placements, so that it maximizes the opportunity for the student to both understand the role they are being trained for, and their ability to actually be hired and function in that role.  The question then becomes how do we achieve, how do we map qualifications, training, and student outcomes, with industry or employment need.

The first step is that people who are giving advice to potential students, particularly where those students are younger, actually need to understand both the training industry and landscape, and they need to understand the requirements of industry or the roles that they are advising people about.  The sad state of affairs is that for the most part this is not the case, at best they have one but not the other.  There are a few notable exceptions of course, but still at the moment they are exceptions nothing more.  Why? Well that is a relatively easy answer, the vast majority of people who are advising potential students are employed by job agencies, apprenticeship and traineeship providers, or educational providers (RTOs for example).  They are not in a real sense career advisers, their real role is something different, either placing people into training programs, or placing them in employment.  Their function and agendas may not be as student centric as we might like to think.  Of course as with everything I am generalising here and there are certainly, for want of a better word, advisers, who are student centric and seek to develop a relationship with the potential student which will provide that person with as good an outcomes as possible.

The other part of the equation here is the training providers.  Training providers need to understand the employment market into which their graduates will be entering.  They need to understand the skills and knowledge and the units of competency which best fit the industry or part of the industry into which the student wants to work in, and more importantly that knowledge needs to be current and accurate.  They need to understand the set of units, and the knowledge and skills which come out of those units, which will maximise the students potential to work in the area they want to.  The problem is of course that there are a lot of courses out there, particularly in the business and community services area, but in other areas as well, where the units taught and the content of those units is so generic that it virtually prepares the student for nothing at all except for a long list of rejected resumes.  One of the reasons why, in a previous role, the organisation i was with had its own RTO was to ensure that the units covered in the course, their content, how they were delivered, and what was expected during placements etc was controlled and produced graduates with the right set of skills to move directly into employment in the organisation.  We also did extensive pre-enrollment testing and discussions to ensure that the people entering the course were a good fit and were likely to complete.  Now I know that some of the apprenticeship agencies and job agencies (some of the better ones) are doing this.  Testing candidates to see how they cope with change and to look for what careers might suit them the most.  And this sort of activity is vitally important because, just because a year 12 student says he likes to play video games and wants to be a game designer, does not mean that it is the best choice for him, (the game design industry in Australia directly employs only about 900 people btw) and may actually harm his chances of getting meaningful employment or doing further training to change careers later, due to impacts upon funding.  It is really important to note here that I am not suggesting that we need to stream and railroad people out of careers that they actually wish to undertake, I am just suggesting that there a lot of people who are being trained who really don’t understand the nature of the industries or work that they are being trained for, and if they had been provided with a fuller explanation of the various careers which were available to them may have chosen a very different path.

The other thing which is important here and is which often overlooked is the fact that industry needs to come to the party as well, they need to be clear about what skills and knowledge they require of potential employees and work with providers to deliver on those skills and knowledge.

Unless we have these links between industry, providers and advisors, greater knowledge of options and the effects of various options on future choices, and truly independent advisors, it seems difficult things will improve.  What we need is an ecosystem, where the potential students are getting, timely, independent, accurate and individualised advice, which leads them to providers who create individualised learning plans for these students, based on what the student wants and what industry needs, with placements, internships and other pre-employment opportunities offers by employers to provide student with well-rounded experiences and the best possible opportunity to convert their qualification into a workforce outcome.

 

 

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.

 

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