A registration board for the VET sector?

Do we need a Trainer and Assessors registration board?

 

After my previous post and a number of comments and discussions in a variety of forums, I got to thinking about this idea of a registration board for Trainers and Assessors in the VET sector.  Now I know this idea has been floated before, and that there are several groups out there who have or are attempting, as membership organisations, to utilise this idea to lift the general level of professionalism in the industry.  But lets face facts, unless membership of an organisation is linked to some kind of regulated authority to train, then there is always going to be a systematic failure.  There are registration boards for Teachers in all of the states, statutory bodies, set up to regulate and determine who is appropriately qualified and suitable to teach in a our primary and secondary school systems,  so do we need something like that?  A single national registration board for all trainers and assessors in the VET sector.    While I think in the long-term that might be a very good idea, I think there might be an alternative which at least in the shorter term may have a significant effect on the professionalism of the industry.

A registration board for all Trainers and Assessors delivering a Training and Assessment Qualification!

So if you want to be able to train others in the Certificate IV in Training and Assessment or above or any qualification from the TAE package, you would need to be registered by a single national board which provided you with an Authority to Train.  It should like most other boards of its ilk, charge membership fees which would be used to cover the expenses of running the board, and have clearly defined membership entry and maintenance requirements.  These requirements should revolved around skills and knowledge as well as experience.  Imagine the difference that would be made overnight if the ‘TAE registration board’ required 5 years of training experience before you were able to apply for membership to allow you to deliver a TAE qualification.  Gone instantly would be the incidents of doing a weekend TAE this weekend and then teaching the same class the next weekend.  A skills and knowledge component, perhaps an exam could be added into the mix for initial registration, as well as strong on going CPD requirements including delivery thresholds, peer supervision and mentoring requirements, then add to this penalties for non-compliance including suspension and de-registration and even just at this level, directly aimed at those teaching TAE qualifications this would have a rapid and marked effect on the quality not only of the TAE suite of programs, but a knock on effect to all other qualifications as well. This added to increased regulatory pressure at an organisational level would should see the quality of the qualification and the sector lifted quickly.

Now people might argue against this proposal in a number of ways.

This is industry is already over regulated

I am not sure of this for a start, but even so the vast majority of regulation at this point in time sits at the level of the RTO.  Trainer registration sits at a personal, not organisational level.  It is something that is managed by a person for themselves.  Individuals can choose whether or not they wish to be registered and have an Authority to Train or not.  Trainers and Assessors not delivery TAE qualifications would not be required to undertake registration, although there could either initially or over time a registration process developed for those who did not deliver TAE products.

The cost of a TAE qualification would go up

Probably, but is that a bad thing?  Is a $300, 2 day, Certificate IV in Training and Assessment really worth the money it is printed on for anyone?

Who would run it

The simple solution in my mind would be the regulator (ASQA).  Given that it needs some kind of regulatory force behind it to be effective, it either needs to be the current regulatory body or some of other statutory body.  I suppose it could be an independent organisation, but issues of continuity always concern me in these cases.

It is another expense for the Trainer 

I, as I think most reputable training organisations would be more than happy to pay the registration fees and associated costs of our TAE trainers or in terms of a new employee who came with registration, renewals of the registration for as long as they worked for us.  However that aside it would be an expense, yes, but it seems one that anyone who was interested in the quality of training and assessment would be willing to pay.

 

The single most important thing about this however, is that it needs to have regulatory force, it needs to be built into the standards that Training providers delivering TAE qualification may only employ registered trainers to deliver those qualifications.  No working under supervision arrangements or anything like that, you either have the registration and the authority to train or you don’t and if you don’t you can’t be employed in a role relating to the delivery of TAE qualification.

 

Anyway that’s just my opinion.

 

 

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Fruit of the poison tree – The problem of non-competent trainers

So what happens when a trainer or assessor who is not-competent assesses someone as competent?

 

So I have been involved in a number of discussions recently about the quality of delivery and assessment of the Certificate IV in Training and Assessment and the resulting competence of ‘trainers’ as a result of that.  Now before I go any further here it is important to note that this is not just something that is occurring in the non-public sector, but across the board, we are seeing it seems just as many people coming out of TAFE lacking the skills and knowledge they should have as we are from the non-public providers.  A lot of the conversation has been around the problems of finding good, competent capable staff out of what seems to be these days an absolute tidal wave of rubbish.  People who can’t present, don’t know basic things like the principles of assessment, or how to unpack a unit of competency.  Now of course over time some of these people are going to become competent despite their original non-competence, but there still exists of course the problem that at the time the certificate was issued they weren’t competent and therefore should not have been given the qualification in the first place.

Now there has been much discussion about what should be done about this and how it can be addressed, but there seems to be a consensus that at some point the regulator must have to step in and cancel or withdraw a whole pile of qualification which were issued where they should not have been.  Now whether or not this will actually happen is certainly a matter for conjecture, however a recall of this nature would have quite a significant effect on people who had built careers on these qualifications which have been found to be soiled.  This is even more problematic for those who were actually competent in first instance but whose qualification is called into question by association or for those who have become competent since the issuance of the certificate.  Now the argument could be made that  given that they are now competent or were competent originally the withdrawal or cancellation would not prove to have an adverse effect because they  would simply need to provide evidence of that competent to acquire a ‘real’ qualification. The big question which pops up then however is who is going to pay for that. If the person in question undertook their qualification in good faith, and then at a later date the regulator removes that qualification then it would seem that either the company that issued it (which is probably then out of business) or the government should be responsible for the costs of re-assessment. Of course it could also be suggested that very few people do a 2 day certificate IV or a 5 day diploma in good faith or that they can be unaware that after a 6-12 month program where they are struggling that they are not actually competent.
On top of all of this though sits the issue of ‘Fruit of the poisonous Tree’ as they say in the US. If someone who has a qualification but who is not competent, assesses the competence of another person then it is not a reach to suggest that that persons competence and resulting qualification may also be questionable.  We have already seen a significant number of qualifications from one provider cancelled and a range of others from both public and non-public providers called into question, now not to question the competence of those people who assessed these qualifications, but it would seem to me to necessary to investigate that issue as well as the providers from which they gained their qualification.  Now let’s explore what might happen is ASQA starts to cancel, withdraw or recall certificates from even one Certificate IV TAE provider, let alone more than one.  Even if not all certificates are ‘recalled’ it throws into question the veracity of all of the qualifications issued by the provider even those non-TAE qualifications.  Further it must call into question two things,

  1. The competence of any person deemed competent from someone with a ‘recalled’ qualification
  2. The hiring and assessment practices of any providers which employed a person with a ‘recalled’ qualification

It is as I have indicated above a ‘Fruit of the poison tree’ scenario, none of the decisions about competency can be taken at face value and from there it is ‘turtles all the way down’

So what can be done about all of this, well , one solution (which will probably never happen) is to license only a very select number of providers both public and private to assess VET sector competence, rather than the almost open slather that we have at the moment and support the sector (through funding) to have everyone re-assessed. It would be a mammoth and costly task.

Another solution would be a formal licensing process for VET sector professionals assessed by an independent 3rd party with strong ongoing CPD requirements. This would also solve the problem of PD and currency for trainer and facilitators.

The other thing that sits in my head along side of all of this is the skill and knowledge sets (and qualifications) of those in education management roles an what we expect them to be. Ethical, experienced and appropriately qualified CEO’s and education managers in training providers would not allow the delivery of poor quality or substandard qualifications, and not hire non-competent people thus over time improving the quality of the training being provided and the industry as a whole.

Anyway that’s just my opinion.

 

Customisation of Learning – Connecting L&D and VET

A lot of training providers talk endlessly about their ability to customise a program to meet the needs of an organisation.  However, how many of them actually do it or do it in a way that really meets the needs of the organisation?

 

 

I think unfortunately, or fortunately for those who do, not many.  Often in the VET sector customisation means little more than choosing different electives, although not too different or there might not be someone able to train them. Unfortunately in most cases, just changing electives is not really customisation, it is far more a case of here are the options we are offering what would you like to choose. This of course is not something that is just confined to the VET sector, a great many licensed and proprietary training programs offer very little in the way of real customisation, however it is the ability to customise training to suit specific organisation and even individual need that is a strength of the VET system.

Customisation is building the training program in such a way that it achieves the goals that the organisation wants.  It is about using their documents, their policies, their procedures.  It is about building a program that produces a participant who has the skill set that the organisation requires, and who is able to utilise that skill set in their work.  The common complaint about this kind of customisation from providers is that you still have to do what the training package says, they have to be assessed on the performance criteria and you have to make sure that the skills and knowledge which are taught to the student are not so workplace specific that they are not easily transferable to other workplaces and roles.  Now of course, this is true, but I don’t think that anyone ever said that what was listed in the performance criteria was all a program could to contain.  It doesn’t say anywhere in the packages that you cannot add additional information or assessment or training.  What it says is that this set of skills and knowledge, assessed against this set of performance criteria is the evidence that is required to deem this person competent in this Unit of Competency.

The other issue that is often bought up is where there is something in the performance criteria that for whatever reason the organisation doesn’t do or does completely differently.  An example of this is a unit of competency around strength based practice in support work and counselling.  There is a process mentioned in the performance criteria which while correct and used by a lot of practitioners, is probably not used, described differently, or used differently, by equally many practitioners.  So (leaving aside questions whether or not the criteria should actually even be in the unit) often staff undertaking this unit end up being trained in something that their organisation does not use and in some cases is actively opposed to the use of.  This also then tends to mean that where that unit is an elective and can be left out it is, which may dilute the overall strength of the qualification from the organisations perspective.  It may also mean that the organisation may then have to go out and source additional training or develop it themselves, around the content which is contained in the unit.   So what does customisation look like here, for an organisation that doesn’t use the particular segment of the unit of competency, given that we know that in order to meet the performance criteria it can’t be left out, and it needs to be assessed.  Having done this on numerous occasions the answer is in general remarkably simple, do both and assess both.  Assess the accredited unit according to the performance criteria and the other according to what the organisation wants.  It is then a case of explaining to the students that while you have provided them with two options, one is the preferred method where they work now, but there are other organisations which may prefer to use the other method.  Is it a little more work?  Yes, but it will also makes the organisation much happier than saying well we have to teach them this method because that is what the training package says and then let them come up with a solution around how to train their staff in their preferred method.

Customisation is also about little things,  like making sure that when you are talking about documents and policies the examples you use are, where possible, from the organisation itself.  It is about using the language of the organisation as well, particularly if you are talking about reporting lines, hierarchies and business processes and software.  It is about sitting down with the manager, the L&D person or whoever you are working with and saying, what are the skills and knowledge you need your staff to have at the end of this and what tasks do you expect them to be able to undertake and then structuring the course around that.  Take the time to cluster and structure delivery and assessment so that it makes sense in the context of the work environment.  There is very little point in training someone in a skill they are not going to use for 6 months.  It is better to provide them with the training in proximity to when they will use the skill, to enhance the retention of the skill and knowledge.

Customisation is actually an enormous strength within our VET system.  This becomes particularly evident when it is compared to many of the other proprietary training programs that are out there, most of which can’t be changed or customised to suit particular circumstance, because the material is copyrighted and licensed and often, because of this the people delivering the training have no say in the content or its delivery.  So in order to meet the criteria of the provider that owns the program they have to deliver it in, often, a very particular manner which unless you are training large numbers of people or spending large sums of money on the training are probably not going to be altered by the program owner.  This ability to customise should not be taken to mean that we can and should ignore the rules of the VET sector, things like Volume of Learning, and the rules relating to assessment and evidence, however the space circumscribed by those rules allows us much more latitude to be able to develop and deliver a program that meets the needs of our clients than most licensed training would ever be able to do.

The real problem is that most providers seem very reluctant to do it.

Anyway that’s my opinion.

 

Paul contacted via;

Rasmussen Learning Solutions

Spectrum Training

Does our VET system work? I actually think it does.

So as most of you know I was out at the VET Reform consultations in Brisbane today.  (Thank you to Assistant Minister Birmingham, Peta, and the whole Vet Reform Taskforce crew, job well done.)  It was an interesting morning with a lot of conversation and discussion and a couple of comments and ideas actually stuck in my mind and I while I was digesting them on the way back to the office I asked myself a question.  “If I was building a national vocational education system what would it look like?”  The answer I came up with was something pretty much like what we have.  A system where the training is developed and maintained by industry bodies to meet the needs of the industries they represent.  A mix of public and non-public providers to deliver the training to meet the needs of organisations and individuals.  Government funding to assist with the priority areas for the ongoing workforce needs of the nation and a single national set of standards which governed the delivery of these qualifications by all providers.  So pretty much what we already have.

Now I am not saying that how the system operates is perfect for everyone and that there are not issues at some of the points along the way, but overall I think we have the structure right.  Not everyone agrees that the ISC’s are the right way to develop and maintain packages, a more ad hoc committee structure might work better, but I don’t think anyone is arguing that we don’t need to have the industry connection.  We are not debating the overall structure at a high level we are just debating exactly what the best way to achieve it is.  Sure there are providers and individuals (both public and non-public) out there who may not be doing the right thing, but that is an issue of governance not the structure.  Funding for programs may not always be what everyone thinks they should be, but again, that is about funding and Government priorities not structure.

We have a good, if not great system here, let’s make sure we don’t throw out the baby with the bath water.  Sure we can do things better, but is the system ever going to be perfect, no, no system ever is.  What we need to ensure is that we have a robust and sustainable system that provides the necessary outcomes for all of the stakeholders, everything else is just tinkering around the edges.

Industry Engagement in Training Package Development Discussion Paper – Some early thoughts

As most of us know the Department has released its consultation paper on the development of training packages and how packages may be developed going forward now that the ISC’s are being disbanded in the middle of next year.  I don’t intend to discuss a lot of the background and supporting discussion here suffice to say that I definitely endorse the position that ‘one of the aims of the review is to ensure more direct industry involvement in the development and review of training packages.  I want to focus on the three options put up for discussion and I guess point in direction that I am tending to lean towards.

Option 1 – Purchase training package development as the need arises: Training Development Panel

While I like the what appears to be the high level of flexibility of this approach I am concerned about a number of things, most importantly the perception that large or well-funded sectors may have much better ability to have their training packages reviewed at the expense of small or less well resourced sectors.  I am generally in favour of the technical writers being independent and without vested interest, I am not sure however about how much industry engagement is actually going to happen, how it will be handled and how it will flow through to the technical writers.

Option 2 – Industry Assigns responsibilities to preferred organisations

I like this option, it is currently the one I am leaning towards it tends in my view to represent a solid mid-point between the very open first option and the third option or what is currently the case.  In this option Industry would be given the opportunity to form committees to represent their skill needs and to develop and maintain the packages.  These committees would manage and coordinate the operation of the approach.  The committees would be the engagement point with the industries they represent and would identify the skills and needs.  They would then utilise the training development panel to take these needs and skills and codify them into training packages.  This seems to me to be the approach which best marries the needs of industry, (this model should I  think provide a high level of engagement) with development needs.  It is also less like to be effected by sector size or resources in terms of recognition of sectoral need.  In addition, without a standing edifice that we currently have with the ISC’s costs associated with development may be reduced.

Option 3 – Government contracts for Designated VET sector bodies

Isn’t this what we already have albeit with talk of reducing the number of bodies.  There would need to be substantive change in the way industry engagement is done and managed in these new bodies to make me feel comfortable with this as a preferred option.  The system is currently cumbersome and slow to react to the needs of industry and reducing the number of sector bodies would I think only increase the difficulties we currently see with the system.

So there we go.  For my mind at least and from a purely pragmatic point of view I guess Option 2 is the best option.  It seems to me to be the one that has the best ability to provide robust industry engagement, which should therefore provide us with the skills and knowledge needed for workers in the industry sector in question, both current and future requirements.  These skills and knowledge can then be developed, by the training development panel into packages with meet the standards, which can then be verified by the committee as meeting industry requirements.  It strikes me as an approach which could be very agile (in the project management sense) which should therefore return solid results for everyone.

 

Competency based, Time based or something in between?

I have been involved in a number of conversations recently about training (what a shock), but in particular about how long it takes to train some one.  The easiest answer here seems to be well as long as it takes, different people will learn at different rates so the amount of time it might take me to learn something may be radically different from the amount of time it takes you to learn the same thing.  Now essentially that is the right answer, particularly where we are talking about skills based training, if I am able to demonstrate that I can perform a skill to whatever criteria are necessary then surely I have demonstrated that I am competent and shouldn’t need to spend additional time on ‘learning’ that skill simply because it should take say 5 days to learn that skill.

I have a question though, lets take the example of making a cup of coffee.  I attend an online training course called making a cup of coffee, the course is delivered in a state of the art simulated coffee-making environment, includes a range of videos from the worlds best coffee makers and lots of reading questions to think about. Oh and there is  a ‘skills assessment’ at the end of the course where I have to make a cup of coffee in the simulated environment.  I answer a range of questions about making coffee and do a project on how coffee makers work, well to be fair my project is about how the simulated coffee maker works and my answers are largely regurgitated from the videos and printed materials and it takes me less than a day to complete.  These questions are assessed and found to be satisfactory.  I then undertake the ‘make a coffee skills assessment’ and pass with flying colours.  Am I competent?

Some people would clearly argue yes, of course I am competent I have done all that is required to show my competence in making a coffee, however what happens when I go out into the workforce with my making a coffee qualification, get  job, and find myself confronted with a coffee machine that is utterly unlike the one I have used on every previous occasion (in the simulated environment) and my consumers are much more demanding about their java than my simulated customers ever where, and struggle to manage to make a cup of coffee.  Am I still competent?

Would the situation have been any different if there was a requirement that the course took a minimum of 6 months and 100 hours of placement to complete or are we going to get exactly the same result.  Am I more likely over this extended period of time to encounter situations and equipment and people who stretch my skills then I would have been with entirely online or face to face training plus a practical skills assessment.

When we add to this the added dimension that in most cases I am not undertaking this training alone, but rather as part of a group, a group which has both widely ranging skills and abilities, including how fast they learn, how does that affect not only my competent but the competence of the other members of the group.

 

The first thing to say here is that I am not bashing online training, I like online learning and find it really useful for what it is.

What my focus here is is the question that if we are truly serious about competency based training then  surely we need to recognise that there is for the most part actually a minimum amount of time that it takes someone to become competent in a particular skill.  Now for me whether that time comes from work experience before entering training or through work placement or on the job training is unimportant, what is important for me is that there is minimum amount of time and that that minimum should be part of the recognition of competency.  If you have only ever done 40 hours of work in an aged care facility in your entire life and that was a training placement, then no matter how good the training is you have received I am going to really, really doubtful that you are actually competent across any real range of situations and environments.  There is simply not enough time for you to have experienced enough variety of situations to be able to be competent, even if you have done hours of simulated, intensive, innovatively delivered training to go along side this.  (To caveat this, of course there may be a very small range of people who after this type of training are competent, but in my opinion and experience not many)

 

We need to have a system that ensures that when someone is given a qualification that they are actually competent and one step towards achieving this seems to me to be the concept of mandating at least the level of placement hours that various qualifications need.

That’s what I think anyway.

 

ASQA Review and VET Standards Consultation paper.

Well what a big week it has been with the release of the ASQA review and the Consultation paper on VET Standards, so which one to start on that is the question as I think no matter which one I pick and what I say there are certainly going to be a percentage of people who strongly and vocally disagree with me.

ASQA Process Review

A couple of points of note I think before I start looking at the review itself, firstly ASQA is a relatively young organisation having only commenced operations on July 1, 2011 and secondly, while it is referred to the National VET regulator, everyone knows that isn’t the sole regulator and does not have responsibility for all RTO’s across the country.  So onto the review; Firstly and I am going to come straight out and say this, I don’t think there is anything damming in the review, while there were 21 findings made in the review, they can and have been broken down into six main themes and when you examine the themes, a number of them have to do with things which are not entirely in the control of ASQA itself.  So lets look at the themes;

  1. ASQA’s existing ICT systems do not facilitate the most efficient and effective business processes for the future of ASQA as a regulator. – Implementing and maintaining efficient and effective ICT systems is something that affects almost all organisation at some point in the growth, be they Government, Private or NGO’s and as stated in the report ASQA has commenced an ICT transformation program.  As one looks through the actual findings in the review 10 of these findings relate to, or will be addressed by the ICT transformation program, so in essence almost half of the findings relate to systems issues to at least some degree.  I am sure that most of us have worked in organisations where ICT systems have not been as useful as they could have been and know the frustration for both internal staff and external stakeholders and clients.
  2. ASQA is constrained by a variety of factors in the regulatory architecture. These factors drive some process inefficiencies that impact its timeliness and transparency of operations. – ASQA operates under the requirements of two separate acts ESOS and NVR, having the government harmonise these acts would assist ASQA in its operations.  Again having worked in sectors where there were multiple acts which needs to be operated under, there is always limitations and inefficiencies that occur, particularly where there is a need for staff to move between acts.  This is more an issue about the regulatory system itself than it is about ASQA, the regulatory architecture itself makes the operating environment more difficult that it needs to be.
  3. ASQA has evolved its risk model, but requires additional data about the sector and ICT capability to deliver further improvement. – I don’t think anyone would argue that ASQA’s risk model is perfect, but this is a function of lack of data and the necessity for the model to be ‘Hand Tuned.’  The lack of data about the particular industries in which various RTO’s operate and the effects that this might have on the risk profile of an RTO’s means that ASQA’s risk model focuses almost solely on the provider itself, meaning that an RTO’s operating in a high risk environment like mining, is essentially modelled in the same way as an RTO delivering retail courses.  The ‘Hand Tuning’ of the risk model seeks to address this issue, but as indicated in something which has a range of limitations and is by its very nature somewhat subjective and definitely time-consuming.  Again however this risk modelling process is something, which with additional data sets and the ability to analyse that data more effectively should be improved markedly.
  4. A lack of coordination in training package updates issued by ISCs creates unnecessary work for Providers and impacts ASQA’s operations. – Yes yes it does and the lack of coordination of training packages and the way in which they are updated have always been an issue for the sector.  There needs to be a better system for dealing with package updates which make the process simpler and more efficient for both ASQA and the RTO’s.  However is this something, the blame for which can be laid at ASQA’s feet, no probably not.
  5. A lack of guidance and clarity about the rules for Standards and training packages is creating unnecessary work for ASQA and Providers. – Again, Yes, yes it is, but as indicated in the report ASQA are not funded to provide this guidance and therefore it seems difficult to take them to task for not providing this service.
  6. Communications with Providers are not fully effective. – Hand on heart and I have said this many times before, I have always found no difficulties in communicating with ASQA, however, I also know that other people have had a range of difficulties.  What is clear is that the majority, not the vast majority, the majority of providers think that communications are clear, effective, timely and accessible.  I would also agree with the two main issues raised, that is difficulty in obtaining information about your particular case, and the redirecting to the website.

So given these themes and the findings I think what becomes clear is that as I said earlier a large proportion of the issues around ASQA relate to data and ICT issues and with the exception of theme number 6, they are issues which are not entirely within ASQA’s control and even with theme 6 most providers seemed to be satisfied with ASQA and its processes.

 

Now onto the VET Standards Consultation Paper

Now to be fair I am only going to make some cursory comments on the VET Standards consultation paper at this point and will follow this up with a more detailed analysis early next week.  However, with that being said, what are the major changes proposed in the standards.

Well the first and most striking difference is that there is only 8 Standards, however it should be noted that some of the standards have quite a large number of parts to them, in general though they seem to make sense to me and clarify some of the issues that sat around the previous standards.  On of the things I am particularly happy is the requirement for independent validation of the delivery of TAE qualifications.  It makes sense to me and is something which I think is way overdue.

So with that little comment I am going to leave the Standards for the time being to give myself time to read over them in detail and make some more in-depth commentary early next week.

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