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.

 

 

 

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VET, Learning and Development, and Personal Branding

I was prompted to thinking about the power of personal brand last week, when I was part of a discussion around the issue of training providers, and in particular RTOs using, or relying on the credentials of  people who no longer worked there (or in some cases had never worked there) in order to meet audit requirements among other things.  The discussion got me thinking about the role of personal branding for VET and L&D professionals, how developing a strong personal brand can help not only to enhance your personal opportunities but also the stature and reputation of those organisations you work and protection a strong personal brand offers from the misuse of personal credentials by employers.

I sat on a panel about personal branding, with two of the best people in L&D, namely Ryan Tracey (Ryan2point0) and Natalie Goldman (Flex Careers), a couple of years ago and I was shocked that there were so many people in the VET and L&D sectors who didn’t realise the value of developing a strong personal brand, particularly where that brand can be built and maintained in conjunction with links to strong organisational branding as well.  Unfortunately I think that a lot of people view personal branding as, simply,  a way to gain more, or better employment.  This then for people who are in roles they like with organisations that value them, tends I think to lead them to the conclusion that personal branding is not something that they really need to spend too much time considering.  Unfortunately this view only considers the range of other advantages and interesting side benefits which can occur when you develop your own personal brand.

One of the problems which can occur, and which I have seen happen to a number of good people within the sector is that without having a strong personal brand it is easy for the reputation of the last place you worked to have a significant effect on your own personal reputation and in turn you ability to acquire new roles.  Over the last few years with collapse of large players such as Vocation, ACN, and Careers Australia, and a range of smaller players as well, we have seen high quality trainers and assessors struggle to find new roles because of their association with a failed provider, or worse one that was viewed as having been less than scrupulous in its activities.  I know several people for whom it took almost 6 months to find new roles due to the stink of association shall we say.  A strong personal brand may not solve this problem entirely but it can certainly make it much easier to overcome the issues arising from association with a bad brand.

As I said however the issue of employment and employability are just the tip of the iceberg when it comes to the value that a strong personal brand and reputation can bring to someone in the VET and L&D sectors in general.  Information and connection are also key pieces of value which flow out of a strong brand and reputation.  A point that I made recently at a small training workshop on building personal brand was that, brand and reputation bring with them trust, and trust brings a willingness for people to connect and talk with you.  People will ask for opinions and advice, invite you forums and discussion, which all of which in turn, if managed well, continues to build trust, reputation, connection and brand.  In essence it gets you known to people, and getting known to people is the missing link for most people.  As a lot of people will know I am often invited to sit on consultation and advisory groups, forums and other panels and committees, and asked for formal or informal advice from range of stakeholders, all of this is the result of being known, and of people trusting my input and advice, all of this is the result of brand and reputation.

Some people may ask the question, why, why would I want to be involved in all of these things, I am happy where I am, and doing what I do.  And if that is the case then that is fantastic.  if however you feel like you want to play a greater role in the sector you are part of, have the ability to have some input and have a voice around your sector, then building your brand and the reputation and connections that brand brings is the simplest way to do that.

So how do you build your brand, how do you make yourself not just known in the sector but recognised for what you bring to the table.

Well that’s something I will discuss in another post

 

 

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.

Grassroots and start up Learning and Development

Today I thought I might give the world of Vocational Education a break and have a look at some issues that more focused around corporate learning and development and in particular early stage, or greenfields corporate learning and development. As many of you know apart from trying to run RTOs and navigate the VET sector for more than a decade, I have also been heavily involved in the world of L&D and in particular the world of shall we say grassroots L&D.  So I thought that I might share a few of the insights I have gained over that time.

Firstly what is grassroots L&D?  It’s that L&D role where in real terms you are starting from scratch.  Now this might be for a wide variety of reason, organisational restructure has centralised learning functions and created a new L&D department, L&D has been just in one part of the business and there is a need to make it organisational, the organisation is relatively young or has undergone rapid growth making L&D a focus,  or as happens in a lot of cases for some reason L&D has been badly neglected and everything has basically run down and virtually stopped.

This can be frightening place for an L&D professional to find themselves.  Usually we land in roles where there is already existing structures, where we have the foundations.  Training is being delivered, there is a team who are familiar with the business and its needs, a structure around budgets and finance, you know all of those things we expect to have in an L&D department.  Often at the grassroots level, even in a larger organisation you will find that the L&D team is a team of exactly one, You.  So on top of managing, you may also be developing and delivering training, doing the administration, implementing technologies, and on top of that trying to recruit new staff to take the load off.  The other pressure which is often present in these scenarios, is the pressure to get things up and running as soon as possible so to speak.

It is this expectation of creating something relatively quickly, which can cause heartburn for some L&D folk, primarily because we are often used to having data, strategies, platforms and frameworks already in place to allow us to move forward.  So what most people do is to dive into developing their strategy and framework, start doing TNAs, auditing compliance training and certifications, all those things that we know we have to have in order to deliver meaningful learning experiences to our staff.  This however could be a very costly mistake in terms of you longevity in the role.

Why?  Well because in most of these situations we are dealing with organisations,  managements teams and even boards who may not grasp the complexity of the L&D function.  This is of real concern when the L&D team has been created because the business has discovered a gap, or in some cases a gaping black hole which they need to address and address quickly. They often don’t have time to worry about how things are going to be evaluated for example, they just want them to work.  Getting some kind of training started in a particular area may be far more important than making sure that training is totally aligned with the business plan and strategic goals.  In these cases getting all of your ducks in a row before you start may well leave you in a situation where you find yourself having to justify your achievements. Often in these cases as well there can competing agendas across the business, particularly when L&D has become a more centralised function, instead of being within business units and under the control of Mangers or GM’s.

So what do we do, how can we get done what the business needs, or thinks it needs and still set ourselves up to be able to move forward strategically at the same time.  As many of you may already know I have been a fan of training impact maps for a very long time.  When I first saw one in Brinkerhoff’s book High Impact Learning, they struck a chord with me as a useful tool for ensuring what we are delivering meets the needs of the organisation.  They are incredibly useful in these greenfields style situations where the business wants a solution but is not sure what that solution could be.

How does this work, it’s really simple, get the business, or business unit or even the board to fill this out, with or without help from you and then use the information contained in it to create whatever intervention is necessary to meet the needs outlined.  Here is  hint though, if the business can’t fill out these sections, then training may not be the answer and you may need to have a longer conversation with people.  Another quick hint, and this is really important, resist the temptation to provide the business with ideas around measurement of success, if they don’t come up with it they won’t own it and if they don’t own it and they didn’t tell you that was what they wanted to measure, then you are potentially in for a world of hurt, when they come back and say we actually wanted to see an improvement in X why did you measure Y we don’t care about that.

Part of the trick here also is to get them to ask the right questions such as;

  • Who is the Target group for training,
  • Why are we doing this training, what result will it mean for the business
  • What are the tasks that the target group do that this training is seeking to improve
  • What are the skills and knowledge that staff need to perform these tasks
  • Which of the strategic goals of the business does this training relate to and how, and
  • How will you know if this training has been successful.

So if you can get them to fill this out properly you will have achieved a couple of quite important things, firstly as i said above you will have a nice base from which to look at what interventions you will need to develop to meet the need.  Secondly you will have started the process of the business thinking strategically about its learning and development needs, the value that training brings to the organisation and the need make sure that training that is being delivered or requested will actually meet the needs of the organisation and staff.

Now you should be up and running and can start to build and deliver things and then hopefully start work on some of the other areas which will need your attention.

Time for reflection.

Well 2017 has been a big year.  It has been a big year for me personally and professionally, moving out of the world of VET (at least directly ) and into a more traditional learning and development role.  This was a little bit of a watershed moment for the year as I hadn’t realised the extent of what could be called background stress comes hand in hand with living and breathing the running of an RTO and being neck deep in the VET sector in general.  To be back in a more traditional Learning role, even though it has a different set of challenges and stresses, does not have that ongoing, background stress that I think so many of us in the VET sector feel almost constantly.

Even though I have moved away from the day to day of the VET sector, as most of you know, I have still tried to keep my finger at least somewhat near the pulse, which surprisingly has been a little easier when away from the general hustle and bustle.  It has been a pretty big year for the sector in a lot of ways, with the end of VFH and the start of VSL and all of the issues that bought along with it, including the demise of one very big player in the field, the WhiteCloud private equity backed Careers Australia as well as a number of other providers ranging in size from large to small.  We also saw the contraction of a number of markets areas, primarily due to the caps placed on student fees through VSL. We saw a number of scandals involving TAFEs, the biggest of which has clearly been the absolute failure of TAFESA and the SA government, along with reports showing that funding for VET has not only not kept up with university and school funding but has in actual real terms gone backwards.  When we add on top of this the TAE debacle once could be forgiven for being a little pessimistic about the sector.

Unlike when I wrote a similar piece to last year and the year before, where I talked about the fact that we would see, and did, major players both private and public either leave the market or take massive regulatory hits, I don’t think we are going to see the same thing happen over the next 12 months.  I think we are going to see a sector that rallies back, a rally driven by a greater focus on the needs of industry and workforce participation outcomes, rather than student numbers and qualifications.  The gaps in the system are evident and there now exists both the opportunity and the momentum to fix them.

On a personal note my humble little blog grew in size and reach, and the number of people who I have met through it and am delighted to call my friends always amazes me.  I personally learn a lot through both writing my blog and talking with those of you who comment on it both here and in forums like linkedin, and for the most part, even where there have been disagreements, they have been cordial, well considered and thought out.  I feel honored that so many of you read this thing that I started a little over six years ago and that so many of you find it valuable, even on those days when I let fly and have a bit of a rant.

To the more than 2,500 people who follow me on a regular basis across this blog, linkedin and other forums, I appreciate each and everyone of you, you provide me with insights, knowledge and a depth of wisdom for which I am truly grateful.

So I sincerely hope that all of you, no matter what you are doing over the next few weeks, have a deeply wonderful time, a time to unwind, relax, let go of the year that was and come back next year with a renewed vigor and vitality because I for one look forward to talking to you all again.

 

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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