About VET Compliance (Part Two) : An experiential – real life – case study

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copyright-symbols-and-rules-you-need-to-know-04 2015

Intellectual Property of Dr. Bruce D. Watson, DEd Melbourne and attributed authors as noted.

For Private individual use. All rights reserved.

Published: www.academia.edu

Australian Skills Quality Authority conducts a variety of VET Audits to assess providers’ new or ongoing compliance with the Standards. ASQA conducts a compliance audit if an assessment has determined there is a risk of the provider failing to comply with the relevant standards.

1. Situation Context

A specialist high end sport/fitness industry company partnered with an RTO to offer VET courses of training [Certificate II, Certificate III, Certificate IV and Diploma] directly related to the client services the company provided. VET fee help was available. The company has a philosophy of supporting training in the industry due to the expensive nature of the training and education needed. All of the specialist equipment at the company is available for use of trainees/learners onsite at the company.

The RTO partner specified the processes required that they thought would be needed to ensure that a scheduled ASQA audit would be passed in June 2015. The process was determined by a “compliance team” within the RTO, without any consultation with the trainers/staff who were requested to “do it” by end of 2014. The compliance team included several people who had worked with ASQA, i.e., expertise was brought in.

Note that two of the RTO training staff had resigned on the spot as a result of what they would be required to do.

The RTO required that the specialist high end sport/fitness industry company adhere to all of the processes the RTO compliance team had developed, particularly in view of the VET System identified high risk area., Partnerships.

Partnerships are a high priority ASQA audit area due to very poor results evident in general in RTO 3rd Party Partnerships where Standards were not being adhered to [e.g., unqualified training staff, inadequate assessment methods, inadequate records.].

2. RTO Internal Compliance Process

To internally prepare for a scheduled ASQA audit in June 2015, the RTO compliance team required the RTO and Company VET staff to produce:

  1. Course Information document – A summary of overall course for students
  2. Unit guides – For each Unit of Competency or cluster of Unit of Competencies (including a rationalisation of why Units of Competency are clustered). Written for the trainee/learner in mind, however, also the basis by which the trainer then develops the more detailed documentation for delivery of the program (i.e., Syllabus/Curriculum)
  3. Assessment Map – An extraction from the Unit of Competency of Elements, knowledge and skills mapped against all of the assessment tools – i.e., a matrix of each Assessment tool linked to each Unit of Competency Element [e.g., 1.1, 1.2]
  4. Assessment Tools – For every Unit of Competency
  5. Marking Guide and Trainee Feedback Document – The Four Pillars of Assessment need to be applied – Norm referenced tests, Interviews, Observations and Other assessment procedures (informal). Answers to Multiple Choice questions are relatively easy to document but assessment of short answer and long answer questions require more information. Trainer/Assessor Professional Judgement is crucial , however, the key things to be looked at regarding the overall intent of the Assessment Tool must be documented and matched to the Unit of Competency specifications.
  6. Delivery Plan – A description of how the course will be delivered, e.g., online, face-to-face, blended learning, hybrid learning, together with how it maps to the Assessment Tools
  7. Course Evaluation Process – A map of how the whole course will be evaluated, with continuous improvement in mind perhaps over the next 12 months – e.g., changes in delivery method, updated Training Packages.
  8. Information Guide on Evaluation – Information for use of trainers and trainees/learners

3. Issues exposed in the internal audit preparation

Training Packages and Units of Competency

  1. TAE Certificate IV in Assessment and Training is too narrow in content and skill development of trainers to meet the internal audit processes.
  2. Many Training Packages are compromises of industry needs because of differences in the same industry and they out-date quickly e.g., an Information Technology Unit of Competency in this Case Study is three years out of date in terms of where technology is now. It still refers to “command lines”. That means I.T is not being delivered to current Industry Standards because the RTOs must teach/train to the training Package. Added to this are the long lead times to get Training Packages updated due the level of specificity they require.
  3. The level of detail and industry jargon varies in different Units of Competency and Training Packages. For example, in this Case Study, the Unit of Competency for Anatomy and Physiology Range Statements say: ‘Knowledge of endocrine system’, ‘Knowledge of digestive system’, etc. hence, there is no guidance at what level the Trainer should be pegging the training to.
  4. Professional Judgement in interpreting the Range Statements for Anatomy and Physiology systems would result in the same number of different interpretations of level of understanding as the number of Trainers teaching it at different RTOs.

Professional Judgement by Trainers

  1. The crucial need for Professional Judgement by a Trainer is highlighted in assessing, for example, open ended questions. However, the audit process largely removes Professional Judgement by Trainers and the TAE Certificate IV in Assessment and Training is so minimalist in content that Professional Judgement is not developed in Trainers to a suitable level
  2. None of the RTO training staff had input to the internal audit process. There was no dialogue in which VET Practitioners/Educationists probably would have found inefficiencies and incorrect interpretations of Units of Competency. In other words, the Professional Judgement of VET staff was not used. The Compliance Management Team looked at previous compliance reports in which three auditable documents were developed. There appeared to be an executive decision without debate because “ASQA experts” were bought into the Compliance Team that 8 documents were required.
  3. There were inconsistencies of Assessment Tools provided by the RTO staff to the Company VET Educationists, some staff provided a detailed assessment tool and others a summary of an Assessment Tool.
  4. The Company VET educationists’ internal audit documentation as listed above met the timeline and requirements but the staff of the RTO did not.

The documentation and workload

  1. The Compliance Team did not take into consideration the huge amount of duplication of effort including copying and pasting Elements from existing UoC documents into the RTO required audit documentation formats. This is ridiculous and ‘busy-work’. Experienced VET Practitioners would have suggested a way of putting something ‘over the top’ of the existing Training Package document and/or attachments.

Quality Assurance/Continuous Improvement/Compliance Auditing

  1. Compliance Teams are being motivated to implement audit compliance systems that are overly complex and very detailed so that the auditors have an “easier job” – ‘tick’ and ‘flick’ on an audit checklist.
  2. The VET Quality Assurance/Continuous Improvement/Compliance Auditing process is now so detailed and bureaucratic it is overtaking the training and education agenda.
  3. The Compliance agenda has gone too far. For example, it virtually takes out of the equation the Professional Judgement of Trainers to the detriment of the VET System as a whole. The TAE Certificate IV in Assessment and Training VET Trainers are not educationists, yet they are the crucial professional link between Training Packages and the development and implementation of curriculum and delivery methods, that will pass on the Competencies specified by Industries. VET Trainers/Educationists training and Professional Judgement has been greatly minimalised.
  4. A decade ago VET Auditors were people extracted from the VET System with direct experience of it. There were ‘grey areas’ where an auditor could make a Professional Judgement that an RTO was heading in the right direction and rather than report non-compliant in some areas, discretion allowed Auditor to let the RTO fix an issue within a few days, and then have reassessment. Now this is not the case, VET Auditors of today will only report ‘Compliant’ or ‘Non-compliant’ with no professional discretion
  5. VET Audits are now being outsourced to auditing companies such as PWC and KPMG. Auditors do not generally have educationist qualifications, however, they receive in-house training on how to audit an education institution. As mentioned above, there are no grey areas The Auditor works through an audit checklist and records either ‘Compliant’ or ‘Non-compliant’ against each criteria. Almost anyone can follow a checklist, i.e., work through the list from start to finish and request to see example of policies, assessment tools, etc. But just as the TAE Certificate IV in Assessment and Training does not necessarily make a ‘good trainer’ the same applies to VET Auditors and their training.
  6. Depending on the type of VET Audit, e.g., Engagement and Participation, Eligibility, AQTF Assessment Audit, specific auditing skills would be beyond the scope of PWC/KPMG auditors so ASQA brings in experts who actually understand what they are auditing.
  7. Realistically, the VET System Continuous Improvement policy recognises that a new course is unlikely to be perfect in the first run through. It probably takes a 3 to 5 year cycle from starting a new course to being somewhat sure a training program is meeting the Standards close to perfectly. This would be the case especially where innovative learning methodologies like online materials and hybrid learning are being used.

4. Conclusions

1. What conclusions do you draw from the case study? Will you forward them to the Department of Industry as a VET Reform submission?

2. How would you suggest they should be addressed? Will you forward them to the Department of Industry as a VET Reform submission?

3. Would the issues identified be significantly addressed by using a “Capabilities Framework” instead of a “Training Package Framework”? -See:http://tinyurl.com/ltkb23g ?

As is used in the Australian Public Service: “Building capability: A framework for managing learning and development in the APS” – See: http://tinyurl.com/lwc56qx

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