Rebuilding VET

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

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

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

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

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

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

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

Sounds really simple doesn’t it.


Massive changes to VET FEE Help – The King is dead, long live the king

While right at this point there has not been a complete outline of what is going to happen it is fair to say that the days of VET FEE Help are over.  The deeply flawed system which most of us have been critical of almost since its inception will be scrapped at the end of the year and replaced with a completely new system for 2017.  If you want to look at what is currently being reported about the changes you can see articles here and here.

What do we know at the moment?  Well it seems from looking through the information that I have a lot of the suggestions that myself and other have made and that I have talked about at length in previous articles (Redesigning VET and reinventing VFH) have made the cut shall we say.  Lets then look at the major changes we know about.

Everyone will have to reapply and there will be tighter conditions for entry

This had to be part of any package of reforms as far as I was concerned.  No package where currently contracted providers were simply rolled over into a new system was ever going to have legs. The old application system and criteria were systemically flawed and concentrated on the wrong metrics entirely when both determining if someone could be a provider and then managing that provider.  Making everyone reapply will almost instantly contract the number of providers because a number of current providers will simply self select out for various reasons and I am certain that the government will not accept contracts with a number of providers who may look at applying.  The idea that Relationships with industry, student completion rates, employment outcomes and a track record in education will all be assessed when deciding which colleges can access the loans program is a breath of fresh air and should have been included in the first place.

A ban on the usage of brokers and cold calling by providers

This is something that had to happen as well, not just because of what brokers have done to the system, but because cold calling random people and hard selling them a $20,000 diploma has nothing to do with educational outcomes and everything to do with making as much money as possible in the shortest period of time.  It has been my opinion for a long time now that the rise of brokerages, and providers willing to use their services, no questions asked shall we say, was the single most significant factor in the issues which arose from VFH.

A three-tiered system of loan limits will be introduced, with loans capped at $5000, $10,000 and $15,000 depending on the cost of teaching the course.

Again this is in my opinion a no-brainer.  I am yet to be convinced and a lot of people have tried, that a diploma of management is worth $10,000 plus. I think a tiered system rather than a flat cap acknowledges that different types of courses require different investments and have different costs associated with their delivery.  What this will do is reign in the costs associated with programs and bring them back to some sort of normalcy, something they haven’t had in a number of years.  Remember in some cases we saw 300-400% rises in course fees over essentially a 5 year period, with, in the vast majority of cases, no changes to costs or content, well except for having to pay a broker 25%.   UPDATE – Loan caps only apply to the amount of money which a student will be provided with by the government to ‘pay’ for their course.  Providers may charge whatever they wish for the course in question and students will be required to pay any difference between loan cap amount and course cost themselves.

Only students enrolled in courses aligned with industry needs and likely to lead to a job will be eligible for the loans.

I have said it before and I will say it again I am sure, vocational education is about employment outcomes and workforce participation and my mind has boggled at some of the courses which I have seen offered by certain providers.  I acknowledge that there are concerns around priority lists and the like, but if we are being honest here just how many personal trainers and counselors do we need to have.  This in conjunction with the tiered payments model should at least, if properly applied mean a much stronger employment outcomes for money invested in income contingent loans.

The new scheme will include tighter conditions so colleges can be paid in arrears and poor performing institutions can be suspended and have their payments cancelled.

All providers will be paid monthly in arrears based on authorised and verified student data. This is something which should have been part of the system from the word go.  Large upfront commencement payments drove the other activities which broke the system.  If there had not been such substantial almost unregulated upfront revenue a lot of the issues which occurred simply would not have happened.

The Fallout

Massive contraction at the Mega end of the market. Those providers with large exposure in their revenue streams to VFH, particularly those carrying a high level of debt which requires servicing are going to be in serious trouble as will any provider who has been used to charging $10,000 plus for a Diploma of Business, whether they are small or large.  Any provider which doesn’t have a diversified business revenue model will struggle to find their feet again and we will I think see a not insubstantial number fold or contract heavily.  If I was a provider who relied on VFH for a substantial part of my revenue, particularly if my dealings with ASQA or the Department had been anything less than favorable, I think I might be a little worried right now.

But anyway that’s just my opinion.

Let’s start being positive about VET

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

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

What we do in the VET sector is important!

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

VET changes lives!

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

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


Anyway, that’s just my opinion.

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

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

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

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

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

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

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

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

Anyway that’s just my opinion.


On the Redesigning VET FEE-HELP Discussion Paper

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

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

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

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

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

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

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

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

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

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

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

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

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

Anyway that’s my opinion.


On Industry Currency for Trainers

I came across a gem of a question today in a forum I am part of, which spiked a little thought bubble in my head about industry currency.  I did talk about this subject a little while ago but I think it is one that is worth revisting.  The statement was and I am paraphrasing slightly here – if trainers are not working directly in the industry they are training in how can they be trainers, as they don’t meet the currency requirement.  So why is this interesting, primarily because I have long thought that there are a significant number of ‘trainers’ both in the public and non-public sector for whom if the point was really pressed that currency would be a very large issue.  Why?  Well because they have not actually worked in the sector they are training in quite a number of years and have relied on going to conferences, attending PD sessions and gaining more qualifications (though this is more often than not done through RPL rather than formal study).  Now the standards (1.13) clearly say the following current industry skills directly relevant to the training and assessment being provided.  Now in their fact sheet on this standard it says, Your RTO should ideally ensure that trainers and assessors are regularly exposed to industry workplaces and that they have the ability to participate in workplace tasks, however they are clear that Delivering training and assessment in a workplace does not constitute the development of current industry skills.  Now it is the case that ASQA suggests other activities which a trainer and assessor could participate in to contribute to the demonstration of current industry skills which include:

  • Participation in relevant professional development activities: the implementation guide may provide a list of relevant industry associations. A trainer and assessor could consult with these industry associations to identify relevant development activities they could attend.
  • Participation in networks: this could include attendance at industry breakfasts, workplace health and safety meetings and discussions with employers.
  • Personal development: through reading of industry journals, with subscriptions both online and in print.
  • Undertaking accredited training: including single units of competency, skill sets and qualifications and demonstrating recent completion of a VET training product.
  • Returning to work: that is, working in the relevant industry on a part-time or casual basis.

I guess my question here is how many ‘trainers’ would if were to really dug down into it, have industry currency.  Vocational education is not like teaching, it is not just working through a curriculum (that shouldn’t be taken to in any way diminish the job that teachers actually do), there is a significant amount of technical and activity based skills and learning which are required to be passed on to students, which makes the vocational sector significantly different to the other educational sectors.  Trainers and Assessors in this sector need to have industry skills but more than that they need to have relevant and up to date industry skills, that is, industry currency.  As I said above there are a significant number of providers (both public and non-public) where trainers and assessors have not worked in their industries for many many years as they have been full-time trainers/assessors and have relied on conferences, networks, webinars etc in conjunction with RPL to keep their paper qualifications up to date.  I have to wonder however, how many of these would be able to do the jobs they are training students to do if they were dropped back into the workforce again.

I would be really interested to hear everyone thoughts on this.


Death Knell of the High Growth Mega Colleges

Vocation in Administration, Australian Careers Network in Administration, RTO services group in administrationEVOCCA, shedding staff and campuses, a small number of sackings at Careers Australia and then silence, and Ashley services group trading at way below its high water mark.  One has to ask is the time of the high growth mega provider over?  I think the answer is assuredly yes.  I also think that it will be a long time before the sharemarket sees another VET related IPO, there is a smell about them now and it is not a good one.

To be fair, there are also still some very large colleges out there, but when one looks at the other players there is a difference between a number of those that remain and those that are in various levels of trouble and this difference is growth rate and sustainability.  The bigger players who are left have had sustainable business models, have built there businesses over many years in lot of cases,  and did not expand rapidly on the back of VFH fueled enrollments.

It is highly unlikely that we will see the unbridled growth and expansion that has occurred over the last few years in the sector again anytime soon.  The market and the government have realised the issues and taken steps to stabilise the sector.  As I have said previously it was at least in some cases only the massive influx of money generated by large enrollment numbers, enormous fees and commencement payments that allow this growth to happen.  It was only pie in the sky projections, premised on the unending continuation of both funding regimes and student numbers which made some of these operations look like market darlings, when in reality as we have seen, changes in funding and student numbers, have either ground expansion to a halt or driven companies into administration.

I also think the days of the roll up company, where a parent company owns multiple providers are, if not over, very close to it.  With the regulator focusing on what have clearly become high risk indicators and lenders seemingly unwilling to back high market valuations, it seems that we will be back to mostly small to medium size operators, generally in niche or specialised markets, producing sensible and sustainable growth and profits for all of their stakeholders while at the same time producing the high quality student outcomes that the non-public VET can actually produce.

Personally I think this is a good thing, the larger you are the more difficult it is to provide high quality training to everyone, in every course, all of time.  This has long been one of the problem for the public providers, where they were to some extent expected to do just that and the variation in quality even between different faculties in the same TAFE, was sometimes astounding.  Yet the non-public side of the sector (or at least those who attempted to become mega providers) failed to see this lesson, the wider the range of programs you have the more difficult it is to ensure the right staff are in the right place, with the right qualification, at the right time, providing the right training and assessment with tools that have been properly validated.  I know, I ran an enterprise provider and L&D department that was responsible for the training needs of nearly 36,000 staff and volunteers.  Just ensuring that all of the necessary information for each student is captured is truly a nightmare of epic proportions let alone anything else.

So while I feel deeply sorry for the staff and students who have been and will continue to be effected by this correction, it was as I have said for many months now a correction which had to occur and a correction without which the VET sector both public and non-public together could not begin to move forward to actually again begin to make a difference in the lives of people who come to us.

Anyway that’s just my opinion.

One rule of some another for TAFE!

The VET sector in this country is regulated by a set of standards which are supposed to apply to all providers whether they are public, that is a TAFE or a private provider.  However after revelations this week about the Kangan Institute having left sensitive student files in an abandoned campus for

5 Years.

It is abundantly clear that all providers are not equal!

 In fact in this case if it wasn’t for the fact that the local council issued a notice to the Victoria department of education to do something about the state of the campus because local residents were scared to walk past it, the files may well have sat there forever.

This unequal treatment is clearly the case at least in Victoria at the very least, which of course has not yet managed to get its act together and hand over regulation from its state based regulator to ASQA so regulation of its providers is still provided by a body which is funded by the State government which, oh that’s right, also owns the TAFEs.  Can anyone else see problems with this because I certainly can.

For a system which is supposed to regulate all providers in the same way and according to the same standards it seems while private providers certainly are being held to account as can be seen by the list of ASQA audit decisions,  looking at the same table clearly tells us that TAFE is not being held to account in the same way.  There does not appear to be one single reference to any TAFE in Australia ever having been sanctioned by ASQA.  Now to be fair Victoria and WA  are not regulated by ASQA, but I have to say that I seriously doubt if we were to look at the audit decisions of those sate regulators that we would find any adverse decisions against TAFEs under their jurisdiction either.

Now please do not get me wrong here, I am not attempting to bag TAFE  or suggested that most of them do not do a great job, those of you who have read this blog for a while will know that I am a supporter of the public VET system.  However are we actually to believe that of all of the TAFEs, are all so perfect that there has not ever been even conditions applied to their activities by a regulator anywhere, when clearly given the revelations above and a range of other issues that have surfaced over the past few years with other public providers, this is not the case.

Now let us for a moment consider what the ramifications might have been of the Kangan Incident had rather than it being a public provider, it had been a  private provider who had left sensitive student documents strewn around an abandoned office.  I don’t think we need to consider this too deeply to say with a fair amount of certainty that if this had happened at a private provider that they would have been DEREGISTERED. 

So the question which sits in my head now is what will happen to Kangan and the staff and management responsible for this massive, ongoing, systemic failure.  My guess would be nothing.  Kangan won’t be closed, (Can’t close a TAFE that would have devastating effects on the community), the management and staff who are responsible won’t be fired (they might be lightly chastised though), the government, Kangan or anyone else involved won’t take responsibility and probably wont even acknowledge it happen or even apologise to the students whose records and personal details they treat so carelessly.  What will happen then?  There will be a review and some policies and procedures will be updated, TAFE, the Unions and maybe even the Victorian State government will come out and say that has clearly been caused by competitive funding which has stripped TAFE of the resources which it needs to operate properly and that it is all the fault of the private providers in the system.

The situation where TAFE is treated differently from all other providers, even though they are all governed by the same standards, simply because they are a government-owned entity is ridiculous and needs to stop.  If a TAFE does something worthy of deregistration it should be deregistered, or at the very least suspended from delivery of VET qualifications until it gets its act together.  If the problem is in one of its schools or campuses, or courses then stop them delivering.  It is really as simple as that.

We have a single set of regulations it is about time that everyone was actually regulated in the same way.

Anyway that’s just my opinion.

Quality Assessments in Vet – Student Assessments and Regulatory Reform

Last week I looked at the Quality Assessments in VET discussion paper that was released by the government and discussed some of the questions posed in the first half of the paper.  I also promised that I would come back and look at the second and third sections of the paper which talk about reforms to student assessments and regulatory reform.  So after spending that last week recovering from a severe chest infection here goes.

Chapter Two of the discussion paper looks at how we can assure the quality of qualifications issued to students and ensure that students who are issued with a qualification are competent.  It is of course vital that qualifications issued through the system are and can be trusted, otherwise what is the point of a nationally accredited system, we may as well just let anyone train people give them a piece of paper to say they are qualified.  As the paper rightly suggests independent validation of assessments to ensure validity and consistency of outcomes is one such way of attempting to achieve this.  There is without a doubt a need to have the outcomes of assessments validated, we should be able to say with confidence that everyone (or at least the vast majority) in Australia who has a certain qualification will be able to successfully undertake particular activities that relate to that qualification, whether it was delivered and assessed by the biggest private provider, a TAFE, or a small local provider.  The competency outcomes should always be the same.

One of the problems I think that often comes out of this discussion is one around how to make the process fair and equitable for all parties involved.  One could suggest that what is required is independent external validation of key competencies for all students prior to the issuance of a certificate.  Now while I can see the value of this in high risk areas and areas where there exist registration bodies that control who is licensed to work, there are a lot of vocational areas where the risks involved are quite low, particularly at the lower levels of qualifications and it would seem unnecessarily burdensome to have a carte blanc approach such as this.  I would however think that external validation of randomly selected participants might be useful across the board, with the percentage of participant outcomes being validated increasing as the number of graduates increased.

I also think a principles and risk based approach to validation of assessments and tools through a collaboration with industry is great start.  I know some have suggested that there is a burden here and that employers or industry groups may become reluctant to collaborate with a large number of providers.  It has also been pointed out that for providers with large scopes of delivery the process becomes almost never-ending and requires a significant staff commitment which they may not possess.  I personally think that the current requirements in The Standards for validation, if properly enforced are a sufficient base to work from.  Where there are particular concerns either around a qualification or a provider, or there is an acknowledged high risk area than additional requirements could be enforced.  The key here is of course enforcement.  There is as I have said before no point in having The Standards if they are not properly enforced.  The idea however of industry-endorsed, externally administered tests is not one that I could endorse primarily because it is something which is really outside of the philosophy of VET and the ideas of competency based training and assessment.

An argument is also often made that industry does not necessarily possess the skills to determine whether or not an assessment or tool has or will produce the right outcome.  The argument is that this is a specialist skill which is not necessarily part of the skills of an industry.  I am  not sure about this, but what Industry can do for us is tell us whether or not they feel that someone who has completed all of assessment tasks within a tool would be competent.  They can tell us in the case of particular students whether or not a judgement of competency was correct, both based on the evidence and through more practical methods.  It is industry after all who will end up employing VET graduates.

There is also  suggestion that one reason for industry satisfaction with graduates has more to do with the expectations of employers than it does with the actual competence of students.  It suggests that employers have a much higher level of expectation for say someone with a Certificate II or III than the qualification provides a graduate.  There is some validity to this argument, which suggests that employers both need to be better involved in the process of the development of qualifications, and that they need to be educated as to what should be expected of graduates at various levels.

Quickly now I want to move onto and discuss chapter 3, regulatory reforms.  I have long suggested that the regulator should be more concerned with the actual training that is being delivered and the outcomes of that training rather than just the tools, policies and materials.   Now I know that ASQA currently looks as a sample of completed assessments to ensure that a competency decision can be made from those assessments, but currently they consider or look at how those assessments were generated.  They don’t randomly visit face to face training or workplace delivery, or undertake random sampling of online delivered materials.  They don’t know if the training consists of the trainer standing at the front of the room as essentially reading the answers to everyone while they copy them into a workbook.  I firmly believe that this one single step, that is actually looking at how the training was being delivered who have a more significant effect on the quality of assessment outcomes than almost anything else suggested in these chapters.  It would also give ASQA a chance to consider the skills and quality of the trainer delivering the program and the quality of their qualification.

I think the idea of Training only RTOs is foolish and should be put out of its misery right now.


Anyway that’s my opinion.

Quality of assessments in VET Discussion paper – A discussion.

So the Federal government has just released its discussion paper on Quality Assessments in VET.  This is part of some ongoing movements around the Certificate IV in TAE and other matters that has seen the new qualification being held back while the powers that be see what they can do about the perception at least, that there is a significant problem with how assessments are being carried out in the sector.

My initial comments on this are simple.  There is nothing wrong with the Certificate IV in Training and assessment, particularly as an entry-level qualification into the sector.  The problems with assessments in my opinion have very little to do with the Qualification and a whole lot to do with;

  • Inappropriate delivery and assessment of the qualification itself by unscrupulous providers simply out for a quick buck, and
  • pressure being put on trainers and assessors to ensure that people are deemed competent, again by unscrupulous providers out for a quick buck.

The problem here is not the qualification.  The problem lies squarely at the feet of providers themselves.  If the TAE is delivered and assessed properly, and the assessment processes within providers were up to scratch then there would be no issues.  The Department, ASQA and the sector itself needs to man up and end the shonky delivery of this qualification.  We all know whose TAE qualifications aren’t worth the paper they are printed on, but no one seems to want to do anything about it,  and when someone suggests that we do, the old catch cry of not more regulation leaps out of the woodwork.


Now that I have got that out of the way let’s have a look at the questions/proposals in the first half of the discussion paper.

  1. RTO Limitations
    • Is it appropriate for large number of RTOs to deliver the TAE qualification – NO.  The TAE should be a qualification for which obtaining approval to deliver is a rigorous process, including having not just the assessment tools, and staff audited, but also to have the delivery of the program audited.  TAE should be a special scope item outside of other areas as it is the key component within the system.  The number of RTOs delivering the qualification should be reduced by ensuring that there is a heavy and continuing compliance and regulatory burden on any RTO that decides to place a TAE qualification on scope.
    • Should RTOs be restricted from issuing to their own trainers and staff – NO.  If the audit and compliance system is rigorous enough there should be no problems with issuing to internal staff.
    • Should TAE be available through RPL – YES.  There are significant number of people within this sector who are highly skilled and whom undertaking a full assessment process whenever there was a package change would be overly burdensome.  Again if the regulatory controls are right RPL is appropriate.
    • Should TAE only be delivered by practitioners with a specific period of training and assessment within the Sector – YES.  At least 2 years FTE.
    • VET trainers should have higher qualifications – YES.  Anyone training the Certificate IV TAE, should hold that qualification plus and additional higher level qualification relation to VET.
    • Should there be a practical component – YES.  There should be either a work placement (for those not currently employed) or evidence of work (for those currently employed).  It does have to be long 50-80 hours would be more than sufficient.   This would ensure that graduates had actually spent time with real students and undertaken real assessments.
    • Should participants in TAE be employed in the sector prior to entering the course – NO.  This would overly constrict entry into the sector of people who might otherwise be able to undertake a TAE course and become quality additions to the sector.
  2.  Skills and Qualifications of Trainers
    • Should a design and development unit be made a core part of the Certificate IV and would this improve outcomes – NO and NO.  Including a unit on design and development would do very little to improve student outcomes at a certificate IV level.  Design and development of assessment tools is skill which is above the AQF level of a certificate IV.  Assessment tools should not be being designed by someone who only holds the entry-level qualification unless that person has substantial experience within the sector and in relation to design and development
    • While there should be some weight given to majority considerations, these majority considerations should be tempered strongly with the views of key stakeholders (as long as those key stakeholders are chosen wisely) and the strength of the arguments made.  The idea of who are the key stakeholders for the TAE is an interesting one to ponder.  I believe there needs to some representation from the sector itself, but which must include representation from both the coal face of delivery through to RTO/provider management.  There must also be strong representation from government (The department of education) as they are the major stakeholder in this (you can disagree with me if you like).  In the long run it is the government who is the ultimate customer for the vast majority of VET work that occurs, be that through funding or loans, or special purpose project or what ever.  The system belongs to the government so it is the major stakeholder.    Now I know that there are going to be calls here for the unions (AEU etc) to be involved and the academic VET research set, but in the long run the decisions about the TAE have to be made by the sector itself and the government, others can have input and ideas and the decision should and must sit with these two groups.
  3. VET Professional association
    • Is there a need to have a national VET professional association – YES.  This to me is a no brainer, of course there should be.  Should membership be mandatory in order to work in the sector, yes, but there needs to be levels.  So the first would be an associate member shall we say which would be open to anyone who had a TAE with very little additional in the way of requirements.  From there, various level could exist depending on the experience of the person, continuing professional development, independent evaluation of their work and skills etc.  This would make it easy to delineate between those at the top of the profession and those just beginning and would also encourage the continuing improvement of skills.  There should also be categories for  Trainers/Assessors, Management, compliance etc and a person should be able to be in multiple categories.
    • The big barrier to this is of course money.  It would either need to be funded by the government or it would need to be a membership fees based process.  The problem with being funded is obvious, in that money would be need to be found somewhere.  With membership fees two things would need to happen, one, it would need to be ensured that membership was not just a you pay your money you get your piece of paper deal or there would be no point.  On the other hand the process would need to not  be overly convoluted or expensive as this may be a disincentive to gaining higher levels of membership.
  4. Activities of a VET Association
    • It needs to be a register of VET practitioners
    • Develop and implement a CPD system for the sector
    • Approve professional development activities for CPD points
    • Promote VET sector work as an attractive career path.
    • While these activities need to be coordinated at a National level, but in particular the CPD program could be achieved through existing groups and or other external structures which were approved as CPD
    • There are a number of bodies with significant sectoral membership which could be utilised.  One example would be ACPET, although this might be met with resistance from the public sector, another might be something along the lines of AITD, which is already a membership organisation for the learning and development sector and which has a significant number of VET sector members.  In addition a private sector organisation like VELG which already has a solid VET membership base may also be an option in this area.
  5. Models for a VET association
    •  I have a preference for the type B model, it is the simplest, funding can be easily accounted for, and maintenance and management of registration and CPD needs to be held centrally anyway in my opinion.
    • While model A has advantages in that it takes into account things which already exist, I think it would be too hard to manage overall and membership would not be centralised.
    • Model C is simply a registration model as far as i am concerned and would add nothing to the sector.

Well so there you have it, my thoughts on at least the first half of the paper.  I will make some comments on chapter two of the paper later in the week.

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