NSSC Position Paper on a New VET System – Part 2 The Standards

So on Tuesday I started to look at the position paper just released by the NSSC

today I want to start looking more closely at the Standards Framework which the NSSC have put forward, starting with the standards around Training and Assessment.

Standard 1 – Training and assessment strategies and practice give effect to AQF qualifications defined in the Training Package or accredited course

All of this looks great on paper,  and these comments go equally for Standard 2 as well,  but I have some issues, yet again it seems the focus is on assessment and assessment strategies, could for once actually look at how the training is delivered and the content that is being delivered.  It is not enough to say that it needs to meet AQF standards etc and then only look at the assessment tools, strategies and the qualifications of the trainers.  In reality that is not where the problem is, the problem is in what is actually being delivered to participants and how it is being delivered, until the government and the regulators actually step up to the plate and actually look at the content itself and how it is delivered and who knows and here is a radical suggestion, Auditors could actually sit in on a class or two to see what really is happening, and what the content and delivery methodologies are, instead of just looking at pieces of paper and going yep well you have ticked all of those boxes so what you deliver in to participants must be fine.

It is absolutely ridiculous in my opinion that we are supposed to have a system that regulates training providers, but which doesn’t actually look at the training that they provide.  The problem is that until we actually start doing this the system will still have the problems that currently exist.

The real kicker in this standard though and one which I and I know a large number of people involved at all levels of VET will support fully, again if properly implemented is this little gem;

Trainer/teacher and assessors delivering the minimum training and assessment qualification set by the NSSC hold at least the Diploma of Vocational Education and Training;

and all I have to say is it is about time.  It is and has always been a ludicrous situation, where someone with no training background, could  obtain the Certificate IV in Training and Assessment and the very next be training other people in the Qualification.  It made no sense and has caused no end of issues within the industry and as the NSSC paper goes on to comment in the explanation of the standards ;

a strong theme arising from consultations to date is concern with the quality of delivery of the Certificate IV in Training and Assessment, which in turn has a significant impact on the capability of vocational education and training trainers/teachers and assessors to implement quality training and assessment practices and

require a trainer/teacher delivering the TAE40110 Certificate IV in Training and Assessment to hold at least the Diploma of Vocational Education and Training 

This just makes sense, but again only if they hold RTO’s accountable for what they actually deliver and how they deliver it.

Standard 2 – AQF qualifications or statements of attainment are issued to learners assessed as meeting the competency requirements defined in the Training Package or accredited course.

My comments here are exactly the same as those above, everything talks about assessment and there is not mention of the actual training, unless we start to look at what is actually being delivered and not just the assessment tools, you know the content not just the outcome we will still have poorly trained graduates who are not actually ready for a job role in the vocation they are supposed to have been trained in.

Standard 3 – An LTO has an Accountable Education Officer, who is registered with the AVQS regulator and responsible for all training and assessment undertaken by the LTO.

I am in full support of this standard.  I know that there has been some discussion that it may add an extra layer of cost to the operations of LTO’s but I am less certain as I would suggest that most providers would currently have someone operating in that kind of role anyway, and if they don’t they probably should.  In our instance I can see that it would make no real change to our day-to-day business processes etc.  My only caveat to this is that if the Accountable Education Officer role, was a role that could not be held by someone like the CEO, Executive Officer, RTO Manager etc of the LTO.  If it is required to be a separate role, then I would be far less supportive of it as it would increase the costs without any real benefit flowing form the cost increase.

Standard 4 – LTO is accountable for and systematically monitors all training and assessment services, whether undertaken by itself or through a partnering arrangement, to ensure the achievement of quality training and assessment outcomes and compliance with all the standards.

Again from my point of view this one if a no-brainer, again as I have said before, if when they talk about training they put into place actual process and regulations around the content and delivery of training and not just of assessments   I know I sound like a broken record on this one but it really needs to happen if we are going to have a VET system we can be proud of and which provides us with the outcomes we require.

So there are my thought on the first four of the standards.  I will post some more of my views around the rest of the standards tomorrow.

Issues Paper – Review of VET regulation standards

A look at the recently released Issues paper stemming from the Review of VET regulation standards

The National Skills Standards Council (NSSC) have just released their Review of Standards for Vocational Education and Training Issues Paper, so today I thought I would have a look at the paper and some of the issues and suggested actions that it outlines.

Seven Key Issues are identified in the paper, they are;

  • The purpose of the standards
  • Quality of training and assessment
  • Engagement with industry
  • Reducing unnecessary regulatory duplication
  • Responsive regulation
  • Consistent interpretation and implementation of the standards, and
  • Transparency of the VET sector

While I am not today going to go through each of the issues in details there are some things in the paper that struck me as I read through it which I think are worth commenting on.  On page 5 of the document when discussing suggested approaches to the issue of the purpose of the standards  we find the following statement;

“It may be necessary to firstly identify what outcomes VET is trying to achieve and using this to guide the development of the standards for the regulation of VET. Consideration may also be needed to define what constitutes ‘quality’ in the context of VET and how can this inform the development of standards.”  

For me the idea that there needs to be a serious discussion about what the actual outcomes of VET should be is long overdue.  If you were to listen to some researchers, commentators and government folk you would think that the only thing which mattered was completion rates for full qualifications.  Completions is not in any way a metric that provides any real information about the importance of VET or its outcomes from either a student or industry/employer point of view, except in those areas where the qualification is linked to a licensing outcome and even then I am dubious of its validity in providing us with any real useful information.  If we are going to have a robust VET system that actually provides outcomes for both participants and employers, then stop asking the academics and researchers what the outcomes should be and ask the students and employers, at least that way it might be meaningful.

On the issue of quality training and assessment, the following rang true for me and I think will ring true for many others in the industry;

“The standards therefore need to focus on the core function of training providers – that is, the provision of quality training and assessment. Business processes to support training provider viability and sustainability, while acknowledged as important, should not overshadow the real business of VET.”

The purpose of the VET sector is to train people,  to provide quality training and assessment so that participants can have better employment outcomes as a result of the training.  To my mind the word Vocational in VET gives it away.  The business processes around the provision of training should never take precedence over the actual provision of quality training.

I was also somewhat heartened to see mention of volume of learning mentioned alongside qualification outcomes in the suggested approach;

“Develop standards to ensure RTOs have the capacity, experience and resources to provide high quality training and assessment, including Recognition of Prior Learning, meeting AQF requirements (both qualification outcomes and volume of learning) and providing access to relevant workplace training and assessment.”

The idea that there perhaps should be minimum delivery timeframes/work placements/supervision arrangements etc around the deeming of a participant competent is something that I have mentioned in other places and in principle endorse.  It has the potential to stop, the what I think is flawed and difficult to justify practice of very short delivery and placement timeframes.  In my opinion you simply can’t deem someone as competent after 5 days of face to face training and 12 hours of workplacement.  It is just not a long enough time period to ensure transfer of learning and competence across a wide enough range of scenarios.  It will also create an environment where articulation pathways with Universities may be better able to be negotiated, as the Universities will feel more comfortable that the students with VET qualifications are actually competent.

The other part of the document I found of real interest was the in the discussion around consistent interpretation of standards particularly in relation to auditors;

The VET regulator standards, in resolving issues of inconsistencies, could include standards for auditors which identify protocols and / or a code of conduct governing their work.

I think having clear guidelines, a code of conduct and a range of other protocols around the actions of auditors, how they apply the standards and what they should be looking at and for when they speak with an RTO is vital.  Without this the process of audit will be seen as something that is entirely at the whim of the auditor, rampantly inconsistent, and not producing any kind of valuable outcomes for any party.

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