Ai GROUP SUBMISSION. Review of Training Packages and Accredited Courses FEBRUARY 2015

Transcription

1 Ai GROUP SUBMISSION Review of Training Packages and Accredited Courses FEBRUARY 2015

2 Contents Review of Training Packages and Accredited Courses Introduction... 4 a. How well is the system meeting the needs of industry, employers and individual students? 6 b. Do all the competencies, skills and qualifications currently included in the national system need the same level of prescription and oversight? 9 c. Are qualifications flexible enough to meet employer needs, given that they are developed against a national standard? 11 d. Is the focus on training outcomes strong enough in the training system? 12 2

3 About Australian Industry Group The Australian Industry Group (Ai Group) is a peak industry association in Australia which along with its affiliates represents the interests of more than 60,000 businesses in an expanding range of sectors including: manufacturing; engineering; construction; automotive; food; transport; information technology; telecommunications; call centres; labour hire; printing; defence; mining equipment and supplies; airlines; and other industries. The businesses which we represent employ more than one million people. Ai Group members operate small, medium and large businesses across a range of industries. Ai Group is closely affiliated with more than 50 other employer groups in Australia alone and directly manages a number of those organisations. Australian Industry Group contact for this submission Megan Lilly, Director of Education and Training Ph: mlilly@aigroup.asn.au 3

4 Introduction The Australian Industry Group (Ai Group) welcomes the opportunity to comment on Review of Training Packages and Accredited Courses Discussion Paper (the Paper). Ai Group understands that through this current consultation process, the Australian Government is seeking views on whether training packages and accredited courses are meeting the needs of industry and the economy. The Ai Group also submitted a response in December to the Government s companion paper, Industry Engagement in Training Package Development Discussion Paper: Towards a Contestable Model and recognises that any new approaches considered within the two Papers must ultimately align. The Ai Group strongly supports the COAG Industry Skills Council s 2014 objective, cited in the Paper, which aims for a national system of streamlined industry-defined qualifications that is able to respond flexibly to major national and state priorities and emerging areas of skills needs. Further, support is provided for the view that industry-defined standards need to: reflect the technical and generic skills and knowledge that are required in jobs; provide a basis for consistent assessment of competence in those skills across the training system; provide a mechanism for the national portability of those skills; and be flexible enough to cater to the needs of different individuals, employers and industries, including as these change over time. These principles should frame Australia s VET system, and guide any changes to the structure and content of training packages and accredited courses. The Paper draws attention to Australia s recognition internationally as having considerable strengths including its framework for nationally recognised and industry-informed qualifications. The Ai Group questions why alleged shifts in the economy and labour market challenge this reputation and suggests that careful consideration be given to making changes to the current system which has built this reputation. The central importance of VET to the Australian is commonly recognised. However, it should be stressed the shift in the economy around manufacturing is not simply a shift away from manufacturing and towards the service sectors as stated in the Paper. It is rather a shift in models of manufacturing, with parts of the sector actually expanding and others transforming to provide a mix of manufacturing and services. There appears to be an assumption in the Paper that change is needed to make competencies relevant to the modern economy. This is to misunderstand the nature of competencies as though they are fixed in time or not adaptable. Competencies have continued to be reviewed in the context of previous changes in the economy and occupations. Given that Australia s VET system comprises a framework of nationally recognised and industryinformed qualifications, industry is placed at the centre of the VET system and this ensures that qualifications are based on industry standards. It is our view that the tensions described in the first section of the Paper may not accurately reflect the current system. The use of the term one size 4

5 fits all for the system does not usefully describe its components and flexibility. A nationally consistent approach provides an assurance of confidence in the system and provides a necessary level of protection for those undertaking qualifications. It is our view that national consistency does co-exist with local customisation because of the considerable flexibility within training packages. A greater issue is the need for some training providers to fully utilise the flexibility within training packages to meet the differing needs of industry and employers. Addressing the four major questions posed The Ai Group s views on the broad range of issues raised within the Paper are expressed within each of the overview questions considered by the Paper (along with the more specific questions included throughout the discussion), namely: a. How well is the system meeting the needs of industry, employers and individual students? b. Do all the competencies, skills and qualifications currently included in the national system need the same level of prescription and oversight? c. Are qualifications flexible enough to meet employer needs, given that they are developed against a national standard? d. Is the focus on training outcomes strong enough in the training system? 5

6 a. How well is the system meeting the needs of industry, employers and individual students? Is there an appropriate balance between local customisation and national consistency across the different types of qualifications and accredited courses? Ai Group considers that the current architecture for training packages/accredited courses allows for an appropriate balance between local needs and national consistency across different types of qualifications and courses. The Paper makes the suggestion that the level of direction and balance could vary depending on either qualification level or industry area and does not recognise that this flexibility already exists. Currently training packages are developed to one set of standards. Many employers have employees covered by multiple training packages and those training packages are often maintained by multiple Industry Skills Councils. Currently all Industry Skills Councils refer to the same standards to develop training package documentation. Employers would find it more difficult to understand skills specified that are described using multiple approaches. The training package structure allows units of competency to be created for application across sectors and workplace contexts and promotes movement within industry and across other related industries. Packages and packaging rules, including for example core units, electives and range statements, allow for such customisation to occur, with the extent of customisation being dependent on the discussions between a training provider and individual companies as to their needs. The issuing of a qualification involves facilitating students to gain competence to the requirements of each element and performance criterion then having robust, valid assessment using the required skills and knowledge, already built into the training package, as a basis. A discussion around packaging competencies into a qualification must also consider the most important link to vocational, occupational or licensing outcomes. Care would need to be exercised with any notion of greater flexibility to ensure there is no dilution of the expected vocational outcome. It is important to acknowledge what actually differentiates a qualification from an undefined collection of units. Qualifications have an organising principle. The organising principle encapsulates the purpose and intent of the qualification. This, in turn, determines in currency for the individual in regard to the labour market or pathways to further learning. The packaging of competencies is the process whereby the organising principle of a qualification is made explicit and then codified. The packaging should also reflect an appropriate balance in the development of the skills of the individual that return both a private and public benefit. This balance will be different across different industry sectors and occupations. 6

7 Is there an appropriate balance between technical skills and knowledge and cognitive skills? Whilst the Paper raises the need for change from routine cognitive and manual skills to information processing skills and high-level cognitive and interpersonal skills, our view is that both are needed and that training packages are sufficiently flexible to achieve this. The current structure supports and enables an appropriate balance between technical skills and knowledge to complete a specific job or task and cognitive skills. These cognitive skills are built in as part of training package development, with the mix of skills guided by industry representatives, including foundation/employability skills identified by industry for specific training packages. These must then be assessed by training providers as part of the performance criteria for learners. The underpinning knowledge and skills required are spelt out in training packages and competence cannot be achieved unless these are gained. Under this system flexibility is built in it is the level of training provider understanding, delivery and assessment that is the defining factor regarding quality and the meeting of industry needs. The way to ensure that new higher level skills increasingly become part of training packages is to continue to engage industry representatives in broad consultation throughout the development and review process. Consultation currently occurs during the review of training packages thereby allowing new units that provide more emphasis on, for example, flexible workplace arrangements, digital change, diversity and ethical/socially responsible practice to be introduced. Training packages also allow for units at higher levels to be imported in order to be included for the specific training needs of individuals/employers. Is there a disconnect between the expectations of different employers adjusting to technological advances at different speeds? It is possible a disconnect between the expectations of different employers adjusting to technological advances at different speeds may exist in some circumstances, however the Ai Group does not consider this to be an issue for the structure of training packages. Should there be a one-size-fits-all approach? Characterising the current model as a one-size-fits-all approach to training package development and design does not accurately reflect the breadth of the system for training packages or the process of consultation used that allows for specific industry needs. The ability of training providers to tailor a product to satisfy the needs of employers and individuals in different industry areas and/or various qualification levels is not limited by the current approach. This can only be limited by the level of understanding of practitioners and training providers to be able to utilise relevant training packages, units and skill sets to satisfy particular needs. There would be some difficulty in determining the criteria to apply to more flexible arrangements for some industries. Such changes would also confuse situations in which more flexible arrangements are imported into qualifications that have been deemed high risk and require less flexible arrangements. 7

8 The key to flexibility is through training provider engagement with the employer or the student as appropriate. Effective engagement prevents off the shelf training plans which are less likely to adequately meet industry and individual needs. The suggestion that volume of learning requirements could be applied at the unit and/or qualification level where there is a risk of poor quality outcomes is worthy of consideration. However it appears problematic from a regulatory perspective that a volume of learning measure or range be explicitly stated in the endorsed component of either the qualification or unit of competency. This should only be applied when agreed by industry to ensure appropriate practice and outcomes are achieved as the result of a qualification. Limited application of this may go a long way to restoring confidence in the outcomes of the training system. Should all qualifications be regulated in the same way? The Paper questions consistent degrees of rigour being applied to training packages when different risk factors are associated with industries, occupations or qualifications. The Ai Group supports the uniform approach to the way qualifications are constructed and designed. National consistency is necessary for all industries and all qualifications. Anything less would be establishing a two tier system with differential status. There would be significant reduction in the confidence of training by both employers and the training participants if this were to happen. The real regulatory challenge is the regulation of VET providers. Is national consistency required for accredited courses some of which cater to niche markets? Accredited courses currently meet industry needs as indicated in the Paper. In particular, they provide a nationally recognised training option for those industry needs not yet met through training packages. Niche market accredited courses may always be needed for some specific industry areas, and the same architecture for developing these courses is important for national consistency in design, development, quality and regulatory processes. Development and accreditation of these courses must occur in consultation with training package developers and Industry Skills Councils or their successors. Accredited courses must not duplicate training package qualifications. Furthermore, a formal process should be established to allow the transitioning of accredited courses into training packages to ensure national application and consistency of outcomes. 8

9 b. Do all the competencies, skills and qualifications currently included in the national system need the same level of prescription and oversight? The view of the Ai Group is that the existing level of regulatory oversight is appropriate in order to ensure national consistency. Regulatory effort needs to be consistently applied across the training system or the standards would lose their meaning. It is considered that light touch regulation will contribute to inconsistencies in outcomes and a reduction in the confidence of the system. Whilst there may be differing levels of correlation between qualifications and employment outcomes, regulating some qualifications in different ways would undermine a nationally consistent structure and could reduce confidence in the system. The Paper suggests increased consistency and clarity in the common units across training packages, that is retain narrow occupation or industry specific qualifications but more clearly identify and develop common units. It is considered that the current system already allows for this. Are the purposes of different qualifications clear and are there consistent expectations about likely outcomes for each qualification level? Is there a lack of clarity and purpose about different types and levels of qualifications? It is the Ai Group s view that the purposes of different qualification levels are clear to industry, employers and training providers through the comprehensive AQF guidelines. We are unclear whether the questioning around consistent expectations refers to the application of the AQF, to the current arrangements for qualification endorsement and course accreditation, or to graduates having the skills to the standards expected by employers and industry. Given that we believe clear statements about industry benchmarks and workplace requirements do exist, then inconsistent expectations could only be created by inappropriate selection of qualifications as well as variable delivery of training and assessment services. From an industrial relations perspective the purpose and outcomes of different types of qualifications is extremely clear and unambiguous to industry. Multiple Awards/industrial instruments across a wide range of industry sectors directly link qualification/course outcomes to industrial outcomes. Where aligned these instruments meticulously document classification, pay and employment conditions. These arrangements are long standing and are widely understood and accepted by industry. The links between the training and industrial relations systems are highly complex. Changes to training packages or accredited courses must only be done in conjunction with the relevant industrial parties in order to ensure careful consideration of the potential industrial consequences of proposed changes. It is important that Certificates I and II remain open to being developed as broad or more narrowly focussed qualifications, according to the occupation/industry area. For example, these qualifications are at entry level and are mapped to occupations in awards for industries such as Food Processing. They are also needed as general preparatory programs in the secondary system context. Entry level training is not only delivered to secondary students and job seekers. Employers use entry level training to give their new workers induction and initial skills to apply in their workplace. 9

10 How can the needs of individuals to have transferable skills be balanced with the needs of employers for occupationally-specific skills? Workers require occupationally specific skills and broader industry skills. These different types of skills are not mutually exclusive. The training package construct is sufficiently flexible to be able to cater for both of these needs. Whilst the Paper suggests that preparatory qualifications could incorporate foundation skills, these are already built into the development process for training packages. The suggestion of tension around narrow sets of specific skills compared with transferable skills does not fully take into consideration the transferable ( soft ) skills achieved as part of gaining competence. The quality of the translation of transferable skills is dependent on the quality of delivery and assessment by training providers. What would be the advantages/disadvantages of developing new preparatory qualifications? New preparatory qualifications could have the advantage of providing a more general introduction to a broad industry area and would be particularly suitable for VET in Schools students. This concept has similarities with the Melbourne Model (University of Melbourne) in higher education where a generalist degree is undertaken prior to a more specialist degree. However, any potential implementation of this concept would require considerable care given the different entry level points across different industries. Certificate III is not the universal entry point to employment in all industries and so it would not be possible to replace all Certificate I and II qualifications. In some industry areas the Certificate II is the entry level to employment. Some examples of entry level occupations that are supported by Certificate II qualifications are trade assistant, process worker, machine operator, warehouse operator, data entry, customer service representative, desktop publisher, farm hand and horticultural worker. 10

11 c. Are qualifications flexible enough to meet employer needs, given that they are developed against a national standard? Would greater flexibility assist in the design of training courses that better meet industry, employer and individual student s needs? Suggesting targeted national coverage that tailors features of the system to meet different employer and industry needs misunderstands the system for training packages which by its very nature must apply to all industries. The design of training programs in order for the outcomes to better meet individual employer and learner needs is an issue for training providers. Do current rules about how a qualification can be constructed inhibit employers engagement by limiting their choices? The current structure and content rules provide guidance to training providers and build in considerable flexibility to training packages. Current rules about qualification construction do not inhibit employer engagement. This is an issue about the degree of flexibility of training providers rather than the product itself. Providers are able to customise in every case for employers and learners within the existing national framework. Questions about whether there is enough flexibility have arisen not because of the training packages but because training providers have not always exercised this flexibility as far as they are able in order to meet individual employer and learner needs. This flexibility may not have been utilised by training providers for a variety of reasons. Should more skill sets be formally recognised in the training system? It is considered that more skill sets should be formally recognised to meet industry and employer needs. However, Ai Group does recognise that some caution needs to be exercised in regard to whether an individual s first qualification should be a skill set, as skill sets do not have vocational outcomes, with a minimal number of exceptions (e.g. Forklift, Caren/Gantry). Further, the skill set must be able to be built on to achieve a full qualification where appropriate. However, some individuals will find a pathway to a qualification through the aggregation of a number of skill sets. The development of skill sets should reflect employer demands within various industries. Are there benefits to broad banding high level occupations? Broad banding high level occupational qualifications is not necessary given that areas of specialisation can be achieved through a selection of elective units. The desired outcome can be achieved by importing units with a focus on broad cross-disciplinary skills, such as management or supervisory skills. There also needs to be some caution around aggregating VET qualifications to provide broad skills at the expense of deep skills development, needed for occupations. 11

12 d. Is the focus on training outcomes strong enough in the training system? Should there be a stronger focus on assuring assessment demonstrates performance that meets industry and employer requirements and on strengthening assessment requirements in training packages? There is strong agreement that employers need to be assured of quality assessment that demonstrates performance. However, this will not be achieved through a change to the assessment requirements in training packages. Whilst requirements should be clear, delivery and assessment measures should not be included in training packages and accredited courses. The issue of the quality of outcomes is related to delivery and assessment by training providers. Accordingly, any corrective measures should be directed there rather than at the training package product. There is comprehensive regulation of assessment built into the Standards for Registered Training organisations (RTOs) 2015 with the critical aspects for assessment and evidence required to demonstrate competency being replaced with new assessment requirements. Industry standards have been increasingly specified in training packages over the past few years. If training providers deliver to meet client needs and measure the outcomes, then quality can be assured. Should industry have a stronger role in quality assurance of student assessment? The suggestion of a stronger role for industry in the quality assurance of student assessment needs careful consideration as to the purpose and level of involvement. There is currently much direct involvement at the individual employer/employee/qualification level which is at the most practical level to meet direct company needs. Improvement to training provider practices can assure that assessment demonstrates performance which meets industry and employer requirements. Some training providers struggle to properly assess competency as currently described in training packages and in some instances it appears that training packages are incorrectly interpreted as curriculum. The new Standards for RTOs are strengthening system inputs by ensuring assessment requirements, determined in consultation with industry, are specified for every unit of competency. Could an increased focus on improving assessment of NRT help address issues identified by some stakeholders? Training Packages include rules for assessment and it is a requirement for training providers to meet compliance against these rules. The emphasis for reform of assessment should be focused on training providers and the regulation of assessment through the VET regulator. The focus of the measures should be to ensure that training providers implement quality assessment practices in accordance with the Standards. What are the advantages/disadvantages of a greater focus by industry and the regulator on assessment against occupational standards? 12

13 Training Packages should remain focused on specifying outcomes by describing performance standards and assessment requirements. Industry can be more prescriptive about assessment evidence when appropriate, considered on a case by case basis, and only if necessary. What would an external assessment regime in the Australian VET system look like? The notion of external assessment system needs careful consideration. This is a model that is used for both higher education and senior secondary school qualifications which are curriculum-based models and so different from the VET system. An independent assessor would provide more independence and potentially validity but such an approach would also separate teaching from assessment which is not sound pedagogical practice. The notion of establishment and maintenance of a mechanism for external assessment raises a number of questions/issues around structure, expertise and funding. There is some concern that employers, their apprentices/employees and other VET students would carry the cost burden to be assessed through a user pays assessment system. The cost impost of an external assessment regime would be considerable. A cost benefit analysis would need to be conducted to determine the value of the additional benefit derived. Such an independent national body would need to include a body of personnel with a great breadth and depth of vocational knowledge and skills across industry areas. Any increased standardisation/mandated assessments could limit provider innovation, add regulatory burden and introduce challenges around gaining agreement on assessments. In any case this should not be established on the assumption that industry and employers want to be more actively engaged in this process. Industry does not necessarily need additional assessments but rather assurances that the existing assessments are properly undertaken. Is the term training packages still relevant? Whilst the term training packages is broadly understood after some years of use within the training system, it has been a source of misunderstanding. An alternative name would assist in clarifying their role and purpose. A range of alternatives have been canvassed over time. The Ai Group is supportive of rebranding the training/qualifications architecture as the Industry Skills Framework. The components of the systems, ie units of competency, accredited courses, assessment requirements, credit arrangement, pathways and packing rules could be included. Are there too many qualifications on the national register? And do you support the regular review and rationalisation of qualifications and units of competency? The Ai Group does not have evidence that the number of qualifications available on the national register causes confusion or makes it difficult to navigate the national training system. In fact, we have progressed from curriculum arrangements where we had over 16,000 accredited programs to current arrangements where there are 1,680 national qualifications. Clearly, industry has owned the issue of rationalisation and delivered a clear improvement. Scope is currently available and utilised to reduce the number of qualifications on the national register. Regular reviews of the usage of qualifications are undertaken by the current responsible bodies which can lead to the discontinuation of some qualifications. Given the widely differing training needs of industries, it is to be expected that usage of qualifications will vary considerably. Indeed, it is a sign of a responsive training system. 13

14 What changes should be considered for accredited courses? Review of Training Packages and Accredited Courses The Ai Group is concerned that accredited courses existing outside the national training system would strip portability and national recognition from individuals who complete this training, and establish them under a separate, unlinked system. The Paper suggests that accredited courses could be re-focused to address gaps in training packages. This would not be a new initiative. Accredited courses are currently developed for this purpose. What changes need to be made to packaging rules to provide the necessary flexibility? The Ai Group does not believe there is currently a case for changing the packaging rules. There is sufficient flexibility with the rules at present. This should not prevent a re-consideration of the packaging rules at regular intervals. 14

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