Part two ” quality” – T J Ryan Foundation: Key policy issues in vocational education and training (VET)

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To rely on ‘market mechanisms through informed consumer choice’ assumes that informed consumers will choose to enrol with quality providers, meaning the rogue provider will fail to attract customers and go out of business. This is a bald assumption and no evidence of where or how this has happened to date.

On reading the actual standards they are disappointingly non-specific. It will also require assessment experts in addition to industry to properly assess outcomes.

The T. J. Ryan Foundation is a progressive think tank focusing on Queensland public policy. The aims of the Foundation are to stimulate debate on issues in Queensland public administration and to review policy directions of current and past State governments on economic, social and cultural issues.

This Foundation focuses on evidence-based policy, and provides links to a range of public accessible online resources.

The Full Report is available here: http://bit.ly/1EsKUUg

by Peter Henneken AM BBus BA FIPAA FAICD Research Associate, TJRyan Foundation

How can we ensure the quality of Vocational Education and Training outcomes?

The most recent National Agreement for Skills and Workforce Development virtually acknowledges a problem with VET quality. It says:

The parties are committed to reforms that aim to create: … (c) A high quality national training system that is centred on quality teaching and learning outcomes.

More specifically, the regulator, the Australian Skills Quality Authority (ASQA) has recently completed three reviews into the quality of provision in particular areas. The first is a report on Training for aged and community care in Australia.28 The report had its genesis in observations made by the Productivity Commission including:

  • the quality and variability of training, inc. vastly different lengths of training for the same qualification;
  • whether adequate practical work-based training was provided;
  • whether trainers and assessors had up to date industry experience; and
  • the effectiveness of regulation of training.

The key messages from the ASQA Report were:

The certificate III in Aged care remains the most common qualification for new entrants to the aged care industry. Most registered training organisations have difficulty complying with assessment requirements. Following time to rectify areas where they were not compliant, most registered training organisations became compliant with national standards. Training programs are largely too short and with insufficient time in a workplace for sufficient skills development. Changes to national standards for training organisations are required.

There are a number of other comments in the ASQA report worth recording. Of competency-based training, the Report comments:

Although competency-based training in the Australian VET system is supposed to be about the gaining of skills and competencies, and not the serving of time in a training program, the fact that so many RTO’s are offering programs of such short duration, and are struggling with assessment, means that in many cases, people are not gaining all of the required skills and competencies.

The ASQA report also discusses the unfair competition (in terms of course fees0) between Registered Training Organisations trying to provide high quality programs and those providing ‘cheap and quick’ programs:

This creates an environment in the competitive training market where there is a ‘race to the bottom’ in terms of continually reducing course fees to attract students, reducing course times to attract students and reducing training and delivery effort to cut costs. Quality and sufficient time to enable adequate instruction, learning and assessment are the ‘casualties’ in this environment.

The second ASQA report is Training for the White Card for Australia’s Construction Industry. 33 The origin of this report was stakeholder concerns about the quality and duration of training, the risk of identity fraud in online training and the general lack of workplace health and safety skills of people presenting with White Cards.34

The key messages from the report were: White Card training for the construction industry has been mandated in recognition of the high-risk nature of construction work. … Most registered training organisations have difficulty complying with assessment requirements. Following time to rectify areas where they were not compliant, over twothirds of registered training organisations became compliant with the national standards. However, all registered training organisations delivering and assessing online continued to be not compliant. Training programs delivered online are largely too short and without time in a workplace for sufficient skills development, also raising quality concerns about student identification verification. Changes to the national standards for training organisations are required.

The third ASQA report is Marketing and advertising practices of Australia’s registered training organisations. 36

This report was the result of persistent concerns and complaints about Registered Training Organisations and other bodies providing misleading information in their advertising and marketing. The report found that over half of RTOs were marketing qualifications on websites that they claimed could be achieved in unrealistically short time frames. It was also found that a significant number of unregistered training organisations were marketing nationally recognised training services.

There are a significant number of concerns expressed about training quality in a range of reports and academic papers. For example ‘Skills Australia’ in its discussion paper, Creating a future direction for Australian VET: states:

Significant issues affecting quality in the VET sector include inconsistent regulation, variable assessment practices and insufficient transparency in the system. Narrowness in the scope of performance measures and lack of data to properly asses performance are underlying weaknesses. It is currently not possible to demonstrate the public value, or the value to employers, of the breadth of activities undertake by the sector as a whole.

The Allen Consulting Group, commenting on the major concerns raised in submissions to the National Skills Standards Council (NSSC) review of the standards for the regulation of VET41 , lists the following:

  • the quality of VET teaching and the need for stronger requirements regarding teacher skills in delivery and design of training and related to this, the quality and adequacy of the Certificate IV in Training and Assessment(TAE);
  • the quality of educational design (including mode of delivery and ‘the depth and duration of training’) given its importance in shaping the learning experience; and
  • inconsistent understanding of ‘quality’, and what is expected for training to be of adequate quality, particularly with regard to the depth and duration of training.42 Following its review, the National Skills Standards Council has brought forward proposals to strengthen the regulatory framework.43

The Council nominates the most significant change as:

  • the requirement that each LTO have a registered Accountable Education Officer (AEO) to be responsible for and oversight quality so as to improve educational leadership.

The other main features of the proposals are:

  • new training providers would only be licensed initially for up to 2 years. Towards the end of this period they can then apply for a full 5 year licence;
  • training organisations that issue vocational qualifications should be called “Licensed training Organisations” (LTO);
  • less resourced LTOs should partner with better resourced organisations to improve quality;
  • standards need to be strengthened and clarified;
  • the regulatory burden on LTOs that consistently demonstrate high performance should be reduced.
  • set minimum training and assessment competency requirements of trainers/teachers and assessors;
  • improve the performance data available on LTOs.

This report was apparently not discussed at the most recent COAG Industry and Skills Council (3 April 2014). The main outcome in the quality area is outlined in the COAG Communique as:

a modern and responsive regulatory system that applies a risk-management approach and supports a competitive and well-functioning market; and informed consumers who have access to the information they need to make choices about providers and training that meets their needs.

It appears that the strengthened regulatory approach proposed by the NSSC has run up against the mantra of the new Federal Government of ‘reducing the regulatory burden’ on industry. It appears that only the risk management and improved information proposals have been taken up.

Any response to the problem of quality needs to look at the underlying causes. In my view these are:

  • a market system that encourages competition based on reduced prices and shortened programs. This is reinforced by a competency based assessment system that legitimises the reduction in length of programs;
  • reduced prices means pressure to reduce costs, in particular the costs of trainer/teachers, with the consequent result of lower qualified and experienced trainers/teachers;
  • inadequate government purchasing systems that have funded sub-standard and even “rogue” providers;
  • while improved data will help, it doesn’t necessarily follow that prospective students will act on that data. In any case it will take some time to develop reliable and valid data on providers;
  • There are not well-developed processes in VET to assess “ability to benefit” of prospective students seeking to enter particular programs. Competitive entry standards in Higher Education, while by no means perfect do address in part, this problem; and
  • The “elephant in the room” is the clear conflict of interest between Registered Training Organisations being both provider and assessor.

COAG has not addressed the main issues.

Even the NSSC report really only seeks to strengthen a system that is incapable of rigorously monitoring quality. The signature proposal to require each provider to have an Accountable Education Officer has been criticised because the an Accountable Education Officer is only required to be qualified at the diploma level.45

In July 2014 the Federal Minister for Industry, Ian Macfarlane, announced new draft standards for registered training organisations. As Macfarlane says, ‘For too long the focus of ASQA regulation has been on policing inputs, checking that boxes were ticked and that paperwork was filled in neatly – there was no real monitoring of outcomes or outputs’.

This is a significant statement and consistent with the arguments of this paper. On reading the actual standards they are disappointingly non-specific. It will also require assessment experts in addition to industry to properly assess outcomes.

Conclusions on the quality of training:

1. There is no doubt that poor quality training in VET has wasted a very substantial amount of public funds. The problem of quality has resulted in inadequate and substandard training, has tested the credibility of the system with employers and internationally, and has disappointed and exploited thousands of VET students and other participants. Low quality training is also likely to have compromised safety.

2. So what needs to be looked at? The NSSC did look at assessment systems internationally, but decided to wait for the results of COAG initiated trials of independent validation of assessment. My own conclusions are (given the implications of not progressing the assessment issue) that the trials, at a minimum need to be expedited and reviewed as a matter of urgency, so that some system of moderation of assessment or independent assessment is in place. In the meantime ASQA also needs to give priority to auditing assessment systems and, critically, outcomes. I am aware that in the electrical area there is a “capstone test”. This mainly assesses theory and safety, but should be looked at for other suitable areas.

3. I agree that there should be better information systems to guide prospective students on careers and the pathways to those careers. The information should include performance data on providers, including interactions with the regulator, completion rates, complaint levels, student satisfaction, placement into employment, facilities, etc. As noted earlier we need to be realistic that this can only be one component of a comprehensive response to quality.

To rely on ‘market mechanisms through informed consumer choice’ assumes that informed consumers will choose to enrol with quality providers, meaning the rogue provider will fail to attract customers and go out of business. This is a bald assumption and no evidence of where or how this has happened to date.

4. Given the almost universal acceptance in the schools area of the importance of teacher quality to student performance, it is surprising that there appears to be little official concern that the current arrangements in VET, are leading to pressure on teacher salaries and a concomitant impact on qualifications and teacher quality.

5. Some work needs to be done on processes, suitable for VET that can assist providers to judge the “ability to benefit” of prospective students seeking to enter various programs. The obvious starting point should be with higher level programs, where provision is more limited. In Queensland a program called ‘Skilling Solutions Queensland’ assisted prospective VET learners with career and training options and provided assessments of existing skills. Unfortunately the program was abolished by the current Queensland Government.

6. I must also commend the work undertaken by the Queensland Department to use the purchasing process to shape quality, mainly through a pre-qualification arrangement.

 

 

 

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