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New TAEOn 1 April the Australian Industry and Skills Committee (AISC) approved what is considered "... an important update to the Training and Education (TAE) Training Package that will ensure the VET workforce has better skills in the future".

The National Regulator, ASQA, welcomed the announcement by AISC, and stated that the new Cert IV TAE "... introduces higher standards for trainers and assessors across the vocational education and training (VET) workforce". Furthermore, the Regulator stated that, "The additional unit aims to ensure trainers and assessors have a greater depth of knowledge about good assessment tools and students graduating from VET courses will be more effectively assessed as having the necessary skills and knowledge to do the job."

In this post, I will analyse the potential effect the changes included in the new Cert IV TAE may have on our trainers and assessors, and consequently on our vocational education sector.

Certificate IV in Training and Assessment is no longer compulsory for trainers and assessors

Before we analyse the changes, it's important to understand the current context for trainers and assessors. Since 1st January 2015 the TAE40110 Certificate IV in Training and Assessment (or its successor) is no longer a compulsory qualification for trainers and assessors. According to the Standards for RTOs 2015, diploma or higher qualifications in adult education are also accepted for trainers and assessors.

As the Cert IV in Training and Assessment is not compulsory if a person holds a Diploma or higher level qualification in adult education then the changes to the Cert IV TAE will have no effect.

Developing assessment tools - Back to the future

The first entry-level qualification for trainers and assessors, the BSZ40198 Certificate IV in assessment and workplace training, didn't include any unit of competency for developing assessment tools. BSZ40198 did include three units in the assessment domain that covered planning, conducting and reviewing assessment.

Developing assessment tools was included in the BSZ50198 Diploma of training and assessment systems, which had units of competency for designing and establishing an assessment system, and developing assessment procedures.

The TAA04 superseded the BSZ98 training package in 2004, and introduced the unit of competency "Develop assessment tools" as part of the 14 units of competency required to complete the new Cert IV TAA40104. Six years later, the TAE10 deleted the unit "Develop assessment tools" from the list of core units in Cert IV TAE40110, and left it at diploma level.

Today, six years later, the newly endorsed Cert IV TAE reintroduces the unit "Develop assessment tools".

There is no data publicly available to suggest the performance of trainers and assessors, or quality and compliance of RTOs was better during the 2004 – 2010 period.

Certificate IV as an entry-level qualification and trainers' career pathways

Cert IV TAE has been established as an entry-level qualification for trainers and assessors working in the vocational education and training sector. This qualification establishes the skills and knowledge required to perform the job of an entry-level trainer and assessor.

In the real world, entry-level trainers and assessors are required to use assessment tools, to plan assessments according to an established assessment plan, and to contribute to modify existing assessment tools to meet specific client's needs. But, an entry-level trainer and assessor is not responsible for developing assessment tools; that is the job of a senior trainer/assessor.

In my experience, the critical skills and knowledge that entry-level trainers and assessors must demonstrate to succeed are:

  • Understanding training packages, unpacking units of competency
  • A pedagogical repertoire for learner-centred, work-centred, and attribute-focused approach, rather than traditional pedagogies
  • Understand that the integration of learning at work is a major feature of a contemporary work environment
  • Capabilities in learning technologies
  • Capabilities as facilitator, and
  • Understanding and implementing competency-based assessment systems.

Senior trainers will pursue different career pathways. Vocational education and training is a very diverse sector that offers a broad range of job opportunities in domains such as: Instructional design, Assessment systems, Quality and compliance systems, Foundation skills, Facilitating learning, and training evaluation.

But to take on these pathways, trainers must demonstrate the entry-level skills and knowledge listed above.

Providing training in developing assessment tools to individuals that don't have significant experience in unpacking training packages or using assessment tools (with different target groups, at different AQF levels), will have very limited, if any impact.

Developing assessment tools is a sophisticated technical skill that requires other underpinning skills and knowledge in unpacking units of competency, integrating learning to workplace practices, learner-centred learning, principles of assessment, and rules of evidence. It is not an entry-level skill.

What is the performance issue that we want to solve?

According to ASQA, "... during the past three years the Regulator has identified poor assessment practices as a major issue for the sector".

ASQA is reporting performance issues, but not gaps in skills. In my opinion, we need to look at the big picture before we prescribe a specific training content solution.

Issues reported by ASQA are in relation to:

  • Not providing enough time for learners to develop skills and knowledge
  • Lack of consistency in the interpretation of training package requirements
  • Assessment not relevant to workplace practices, and
  • Poor assessment validation practices.

The next step is to analyse:

  • Why RTOs are having these performance issues
  • Why they are not providing enough time for learners to develop skills and knowledge
  • Why their trainers are not interpreting units of competency consistently
  • Why assessments are not relevant to workplace practices and conditions
  • Why validations are not working as a quality review process
  • What trainers are doing wrong or not doing, and
  • What managers and coordinators are doing wrong or not doing.

Looking into the performance issues presented by ASQA, entry-level trainers are not unpacking units of competency correctly, not engaging with industry wisely, and not understanding principles of assessments and rules of evidence to contribute to assessment validations. We don't need to include the unit of competency "Develop assessment tools" to solve this issue. The Regulator needs to ensure the units: Use training packages and accredited courses to meet client needs, Plan assessment activities and processes, and Participate in assessment validation, are delivered and assessed correctly.

Senior trainers are not developing compliant and industry relevant assessment tools. The Regulator needs to ensure the unit "Design and develop assessment tools" is delivered and assessed correctly.

Managers of RTOs are not creating and implementing systems that support effective and industry relevant training and this issue will not be solved by including a new core unit in Cert IV TAE.

What is the real issue?

I agree with the Regulator and other VET stakeholders, about the deficiencies of the system regarding a number of providers that issue qualifications based on poor quality assessment systems. But the solution is to provide support to RTOs to establish and manage quality assessment systems, which are more complex than only assessment tools.

The truth is that all issues reported by ASQA are interconnected, and if learners are not having enough time to learn, quality assessments will not have a place in that environment. I read with concern ASQA's statement about the way the Regulator will process applications for the new Cert IV TAE "... all applications for this qualification will undergo enhanced scrutiny by ASQA". I wonder what this means? Doesn't ASQA trust its own regulatory practices to assess compliance for Cert IV TAE?

The fact is that the impact of the National Regulator in the skills and knowledge of our VET workforce is not clear. In my experience working with public, enterprise, and private RTOs, a significant number of trainers and assessors don't understand the principles of assessments, don't know how to unpack a unit of competency, are not performing quality reviews to RTOs' assessment practices. However, these trainers hold the TAE40110 Certificate IV in training and assessment, and RTOs have been deemed Compliant by ASQA.

The Regulator declares that "... has been advocating for enhanced training and assessment practices in the VET sector for a number of years". However, today there are still RTOs advertising Certificate IV in TAE for $390.

Are we going to have an ROI in this new investment?

Here we go again, AISC has recommended that the COAG Industry and Skills Council consider applying the new requirements to the existing workforce; as a minimum, the existing VET workforce will be required to undertake the two additional core units contained in the new Certificate IV in Training and Assessment.

We have approximately 200,000 trainers and assessors in our system, and an upgrade of qualifications will come at a cost. If RTOs can deliver the new two units for $400, we are talking of an investment of $80,000,000. What will be the return on this investment?

If we have a system that is not providing the quality education to trainers and assessors that is required, what is going to change if we ask the same system to deliver an extra unit of competency?

Without a serious ROI study, I am afraid the return on the suggested investment will be nil. What's more, it will be very negative for the industry because there will be more evidence that the traditional approach to regulation is not working, producing more disbelief for stakeholders.

Summary

To improve assessment practices of RTOs and improve skills and knowledge of trainers and assessors we need to:

Update our regulatory framework and move to a real outcome-based regulation, where relevant industry stakeholders have a say in the registration/re-registration process
Support the National Regulator in building the required capabilities to assess compliance in a diverse and complex environment
Ensure the National Regulator provides a even-playing-field to RTOs
Identify the different issues within the assessment system, and consequently identify gaps in current workforce skills (in all AQF levels not only entry level) and update the TAE training package accordingly.
Adding a new unit of competency will make no difference to our current situation, we did that in the past and it didn't work. We need an open consultation process with the industry and create a strategic plan for the industry with a serious evaluation program that states:

  • What we want to improve
  • How we are going to measure that improvement
  • What systems metrics we are going to improve
  • What we need to do to achieve that improvement
  • How the Regulator will ensure that is done
  • What skills and knowledge are required that our current workforce doesn't have, to achieve the goal, and
  • How we are going to develop those skills.

LIVE WEBINAR - The following changes to the TAE Training Package will be discussed and explained in this webinar:

  • the qualifications
  • the units of competency
  • the skill sets
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CompliantIn 2015, RTOs were challenged by an inadequate and volatile regulatory framework and a dysfunctional VET market and during 2016, they will continue to have an unprecedented effect.

In Australia, more than 80% of the VET market is government funded, therefore, training demand is conditional on government-funded programs. But throughout these programs, the government is generally buying training seats and not training outcomes. Consequently, some training providers are selling training seats (physical or virtual seats) but not necessarily quality training services. This produces an uneven playing field in the market that generates economic pressure on those committed to quality training services.

Our regulatory framework is giving the national regulator, ASQA, the responsibility to perform a task that it is not fit for: "regulating the outcomes of training".

Let's start from the beginning. What are the outcomes of training?

For industry, the outcomes of training are about the currency, relevance and applicability of skills and knowledge gained by students, and the effect of using those skills. How can ASQA regulate or measure these outcomes? Does ASQA have the industry expertise and resources to do so?

For individuals, the outcomes of training are about using training products that will equip them with current, relevant and useful skills and knowledge to get a job, or successfully engage in further studies. Is ASQA looking at those outcomes?

ASQA continues to use a procedural-based regulatory approach, which is heavy in paper work and not an outcome-based approach. In fairness to the national regulator, the Standards for RTOs 2015, are still in many respects procedural-based, and not outcome-based as it was sold last year. For example, RTOs are required to have and implement a very prescriptive validation plan. But the RTO may have developed and implemented a "compliant" validation plan, generating records that are assessed as compliant by ASQA; however, validated assessment practices may not meet the principles of assessment. Another example is about industry engagement, RTOs are required to have a very prescriptive (in content) range of industry engagement strategies to design and improve a training product, but there are no requirements to measure the extent to which those "industry needs" are met.

Negative training results, especially but not limited to government funded training, have added extra pressure into ASQA's regulatory work. The regulator has responded by applying stronger consequences for those found non-compliant with the standards during audits, including the use of infringement notices.

RTOs must monitor compliance closely, establishing quality systems, and using quality control and assurance measures to avoid fines, sanctions, or other negative consequences. RTO managers must establish a "compliance dashboard" where evidence in real time is analysed and acted upon to ensure compliance at all times.

Areas for high priority. Having conducted more than 100 internal audits for RTOs this year alone, for Insources, we conclude that the top three areas of non-compliance were:

  1. Assessment practices
  2. Trainers and assessors' vocational competencies and industry currency, and
  3. Amount of training provided.
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asqa logoThe Australian Skills Quality Authority (ASQA) has released the findings from its VET FEE-HELP audit project.

The project was launched in April after the authority recorded an increase in the number of complaints it had received against registered training organisations (RTOs) approved to participate in the VET FEE-HELP scheme.

Chief Commissioner Chris Robinson said the number of complaints received by ASQA pointed to a potential systemic issue and, as a result, the authority undertook 21 targeted audits and interviewed more than 400 students.

"There has been a range of allegations of unethical and inappropriate action taken by training providers in relation to the VET FEE-HELP loan scheme," Mr Robinson said.

"While ASQA does not manage or administer this scheme, it is concerned with any risks which have the potential to negatively impact on the delivery of high quality training and assessment in Australian's vocational education and training (VET) sector."

Mr Robinson said eight of the 21 providers were able to demonstrate full compliance with the requirements at the conclusion of the audit, however ASQA's Commissioners had determined that the imposition of certain conditions was warranted, based on the issues examined during the audit and the commitments made by these providers to address these issues.

Six providers are still the subject of ongoing regulatory scrutiny, with ASQA still determining the outcome of the audit process for these providers.

The final seven providers were able to demonstrate full compliance with the relevant requirements at the conclusion of the audit and, as a result, ASQA does not intend to impose any additional conditions on these providers.

Mr Robinson said the authority would continue to closely monitor and target VET FEE-HELP-approved RTOs for regulatory scrutiny where complaints and other industry intelligence indicated cause for concern.

"ASQA will also enhance its cooperation and coordination with the Australian Competition and Consumer Commission, Australian consumer law agencies and the Department of Education and Training to share regulatory intelligence and coordinate regulatory action to ensure poor-quality providers are penalised to the full extent of the respective laws," he said.

"ASQA will also use the findings from its project to develop a range of communication material aimed at helping providers improve their understanding of, and compliance, with the requirements of the relevant standards and giving students relevant information and assist them to make informed decisions."

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