On 30 October 2019 the Australian Government announced $18.1 million towards the reform of ASQA to support the fair, transparent and effective regulation of the VET sector, and high-quality student outcomes. The Department of Education, Skills and Employment announced a rapid review around four areas of ASQA’s performance.
Here are my thoughts.
How can ASQA best engage with the VET sector? What strategies could be adopted by ASQA to support best practice among training providers?
Firstly, we need to have a clear understanding about the scope of engagement required. Who should ASQA engage with within the VET sector?
As the government considers the roles of ASQA as the regulator and the leading teacher regarding compliance obligations within the VET sector, ASQA must engage with all stakeholders. These include the SSOs, industry representatives, RTOs, VET trainers, instructional designers and resource developers as they have the ultimate responsibility for compliance.
The intention of the VET regulatory framework is to protect users of the VET system from poor performance, and to promote high quality training and assessment practices, but this is not only the responsibility of RTOs. Training package developers, employers, resource developers and RTOs work together to achieve high quality training and, therefore, ASQA must engage with all of them. But historically ASQA has only engaged with these stakeholders by sectors, and not as cross-sectors.
ASQA must lead cross-sector communication and provide platforms to cross-sector alignment of expectations and practices.
Here is an example of where that coordination could benefit the VET sector:
Problem: RTOs have real issues implementing training packages, due to difficulties in meeting workplace training/assessment requirements.
Solution: Employers, industry regulators, RTOs and ASQA must address these issues together, to ensure students are not disadvantaged by poor development of training packages, or industry regulations that inhibit components of the workplace training taking place.
To support best practice among training providers within the VET sector, ASQA needs to be transparent and consistent when these best practices are made public and align them to occupational standards defined in the relevant training package for that process, role or task. For example, if ASQA is considering best practices in governance and risk management, they should be aligned with the Diploma of Quality Auditing and/or other relevant qualification/skills set/unit of competency. If we are considering assessment practices, agreed best practices must be aligned with the relevant TAEASS unit of competency.
There is extensive research and industry certification in the areas of concern. Industry has adopted best practices about auditing, governance and risk management through ISO Standards (i.e. ISO 19011, ISO21001, ISO31000, ISO9001). Aligning our best practices to international and industry expectations will boost the confidence in VET performance and outcomes.
There is also extensive research in competency-based practices, competency-assessment, training evaluation methods and this should be considered when establishing best practices in these areas. Such best practices must be included/aligned in the relevant National Training Package.
ASQA must discuss best practices with developers of training packages, industry certifications, academic and RTOs, before these best practices are published.
ASQA must have a Training and Development Department within its structure to produce relevant educational programs and advice. This department must be independent from regulatory operations.
ASQA must provide feedback to developers of training packages about issues with implementing training/assessment, when appropriate.
ASQA must seek SME advice for the interpretation of valid evidence to demonstrate technical skills, when required. This agreed interpretation must be shared with RTOs and developers of training packages.
What elements of its current educative approach are the most effective? How can ASQA best help training providers to understand their obligations?
The Fact Sheets have been very effective in helping providers understand their obligations.
Again, it is very important for the regulator to properly scope the work it expects. If ASQA is expected to explain compliance obligations to training providers, tools such as Fact Sheets are very effective. The regulator should develop some “Job Aids” including checklists, templates, or general procedures to support the operations of RTOs’ staff members.
I don’t think ASQA has the capacity neither the structure to undertake any other educative roles such as developing capabilities in governance, risk management, instructional design or competency-based learning. This is not the regulator’s role.
ASQA must provide clear information about the criteria used to make audit decisions, interpretation of legislative requirements, acceptable evidence (when possible), required actions, expected data during audit.
The publication of audit reports will create a bank of cases that will support RTOs to understand ASQA’s expectations for providing transparency and accountability to the system.
What elements of ASQA’s current regulatory approach do you perceive to be working effectively? What specific areas would benefit from further attention?
The risk-based approach to audit seems to be working, however, the lack of visibility about how the risk assessment is conducted makes it very difficult to comment on this.
The most effective change in ASQA’s regulatory approach is considering the performance evidence of RTOs during audits. In other words, auditing the RTO’s practices not only the RTO’s systems. Using students’ evidence during audits has been of significant improvement.
The rectification of non-compliance by considering past and current students has been a very effective way to manage the risk associated with poor practices.
Further attention is needed in high-risk areas such as students’ participation in training, training and assessment resources, trainers’ vocational competencies and currency, and assessment evidence.
ASQA should better manage the risks associated with these areas. For example, if there is no evidence of students’ participation in training, ASQA should take immediate measures to protect students and industry.
Attention to the ratio resources/student numbers is an important factor that requires further attention. ASQA needs timely information about enrolment numbers to better manage risk.
ASQA has not responded timely to issues when RTOs have significantly increased the number of enrolments without proving they have the resources required for the number of enrolments accepted. Historical data shows that many rapidly growing RTOs end up in chaos, and students do not receive the correct training.
ASQA must put students in the centre of the regulatory work by receive more data/information about students, and not only about their satisfaction levels. ASQA should collect information about whether they learnt something new, something relevant to their jobs, whether they have been able to apply those skills in their workplace.
ASQA could even consider re-assessing students (this will require further arrangements) to confirm their competencies, when necessary.