Review of Training Packages and Accredited Courses

Transcription

1 Submission February 2015 Review of Training Packages and Accredited Courses Submission on the Department of Industry discussion paper Contact Nigel Haywood The Resources Industry Training Council Level 10, 2 Mill Street, Perth, Western Australia Locked Bag N984, Perth WA 6844 p f w ritcwa.com.au

2 Contents About the RITC... 2 Recommendations... 2 Context... 4 Change the mix of skills included in national training packages and accredited courses... 4 Change the system architecture... 6 Change the focus of the system... 6 Responses to specific discussion questions... 7 Conclusion Page 1 of 6

3 About the RITC The Resources Industry Training Council (RITC) is a state government funded joint venture between the Chamber of Minerals and Energy of Western Australia (CME) and the Australian Petroleum Production and Exploration Association (APPEA) providing strategic advice on the workforce development needs of Western Australia s mining, oil and gas and downstream process manufacturing industries. Members of these peak organisations account for over 95 per cent of mineral and energy production in Western Australia and over 90 per cent of national oil and gas production. The Western Australian resources sector is diverse and complex, covering exploration, processing, downstream value adding and refining of over 50 different types of mineral and energy resources. In , the value of Western Australia s mineral and petroleum production was $121.6 billion, accounting for 91 per cent of the state s total merchandise exports and thus representing the majority of Western Australia s 43 per cent contribution to Australian merchandise exports. Furthermore, royalty payments to the State Government increased by 33 per cent from the financial year to reach a record $6.98 billion in Western Australia s downstream process manufacturing industry is concentrated and, like the resources sector, is diverse in nature covering activities such as basic chemical and chemical product manufacturing, polymer and rubber product manufacturing, non-metallic mineral product manufacturing and primary metal and metal product manufacturing. Combined, these industries account for around 2.5 per cent of employment in this state (2011 ABS census). Recommendations Change the mix of skills included in training packages and qualifications o An industry led or employer driven VET system will promote increased quality and also better value for the investment made by Government, industry and individuals in skilling. o It may not be possible to mandate broad banded preparatory qualifications across all industries or all training packages and this should be an issue best considered by industry in the training package development and review process. o State and Territory funding regimes which prioritises qualifications over skill sets remain a significant barrier to the further expansion of skill sets. The Commonwealth should take a leadership role in addressing this matter with state and territory skills Ministers. Change the system architecture o Training package developers should have responsibility for collecting necessary evidence to support the maintenance of qualifications on the national register and therefore in demand by industry. Standards for training package development must reflect this responsibility and also incorporate policy guidance on the issue of thin markets. o A better balance needs to be struck between flexibility in packaging rules to meet an individual employer need and the policy objective of nationally consistent and recognised qualifications to assist in labour and occupational mobility. Page 2 of 6

4 Change the focus of the system o Independent (external) validation of assessment is seen as a mechanism capable of addressing many assessment/quality issues. o The RITC does not support mandated assessment tools or capstone assessments being universally implemented across industry. Page 3 of 6

5 Context The VET system is dynamic and tasked with meeting the needs of a diverse client base including government, industry, individuals and communities. A significant risk is the system becoming all things to all people thereby losing focus and purpose. Reform agendas pursued since the 1980 s have endeavoured to make the system more client focused, efficient and effective. The focus on training package development and content comes at a critical time in the evolution of our vocational education and training system. Australia s vocational education and training system is highly regarded internationally and has a number of wellacknowledged strengths. These include the unique role of industry in driving the training package process. In a rapidly changing economic and social environment, it is acknowledged the vocational education and training system, and its products, must be fit for purpose and have the capacity to meet the demands of a modern and rapidly transforming economy. Given structural change currently being experienced in the economy, it is timely to assess the current structure of training packages to ensure they remain relevant. There is no compelling case put forward supporting the notion training packages are fundamentally broken. Within existing resourcing arrangements, it is important to ensure the model for training package development and training packages themselves are sustainable. The RITC considers the number of nationally recognised training packages and accredited courses is unsustainable. In a constrained resourcing environment, it is appropriate to consider whether each qualification should be treated the same way ie whether a one size fits all approach is practical or whether another approach needs to be adopted to govern training package qualification review processes. From an industry standpoint, the assessment process is critical to producing job-ready individuals who have the competencies and underpinning skills and knowledge to operate safely and effectively in the modern workplace. Industry confidence in assessment outcomes has been eroded due to a lack of regulatory oversight. Accordingly, the RITC believes industry is best placed to contribute directly to the assessment decision noting the final judgement will need to be made by a registered training organisation. Independent validation of assessment can play a role in increasing industry confidence in assessment outcomes as it is seen as an additional check and balance in the system. It is recognised independent validation of assessment processes have issues requiring attention cost and who pays being one such issue. The RITC considers such barriers are not insurmountable. Below are comments relating to the three themes contained in the discussion paper. Change the mix of skills included in national training packages and accredited courses Training packages stipulate the competencies necessary for individuals to work safely and productively in industry. In the resources sector, industry has expressed concerns relating to the quality of training outcomes. For industry to remain fully engaged in the nationally recognised training system, it must have a greater level of confidence in training outcomes. While this relates to a number of issues relating to training provision and regulatory regimes, training package content must have the capacity to keep pace with changes occurring in industry. In public forums, including the Perth VET Reform Taskforce consultation held in February 2015, concerns have been raised suggesting existing policy arrangements (such as those around foundation skills and the core skills framework) are increasingly crowding out technical content in training packages which effectively dilutes qualifications in the eyes of industry. Page 4 of 10

6 This is symptomatic of a system which, as indicated earlier, has become all things to all people and thereby lost focus. Inconsistency in qualifications at the same level across training packages effectively erodes industry confidence in the system and therefore the status of VET. Industry understands what a certificate III trade level qualification is, equating it to an apprenticeship which is around 3 years of on and off the job training. When industry is confronted with people who hold qualifications at the same certificate III level which have been obtained in significantly shorter time periods, questions arise as to the voracity and value of qualifications and outcomes. An industry led or employer driven VET system will promote increased quality and also better value for the investment made by Government, industry and individuals in skilling. The notion of new preparatory qualifications or broad banded qualifications at lower levels may have applicability across some industries. In Western Australia, the Construction Training Fund and Construction Training Council have been instrumental in reconceptualising pathways into the construction industry for VET in school students. This model relies on a common or broad banded certificate II qualification with pathways leading students through to a broad range of construction trade areas. This model has been embraced by industry and has resulted in significantly improved completion rates and outcomes. In contrast, the drilling industry has discreet qualifications leading to specific occupational outcomes which would make implementation of any broad banded lower level qualification not practical. This highlights it may not be possible to mandate broad banded preparatory qualifications across all industries or all training packages and this should be an issue best considered by industry in the training package development and review process. Skill sets have become increasingly desirable in the resources sector, with key drivers to their take-up being productivity effects, multi-skilling requirements, technological change including automation and efficiency. In 2013, the RITC published research into the application of skill sets in a resources sector context. This research found skill sets are an emerging intermediate product of the formal VET system, and co-exist with qualifications and units of competency. Skill sets prepare individuals to perform a specific job function, whereas qualifications prepare individuals for a broader range of functions within an occupation. Skill sets are aimed at providing specific skills to enable a job function to be performed and in a way best defined as just enough and just-in-time. Skill sets can also lead to or form the basis of full qualifications and be used as skill top ups for the already qualified, allowing individuals to transfer between job roles and even occupations. 1 In a resources sector submission to Skills Australia in 2010, the following comment was made: The current funding framework, the National Skills and Workforce Agreement, which funds for full qualifications rather than skills sets, does not meet the needs of the minerals and energy sector and disadvantages regional industry requiring non-traditional trade occupations. It must also be recognised skills sets comprising units of nationally recognised training can form the basis for forming a full qualification and any skills gained contribute to the human capital of the nation. Skill sets are a core feature of certain work and occupational roles in the resources sector, where full qualifications are a case of over-skilling [and therefore an inefficient use of government and industry training resources]. The recognition of skill sets as a subset of a nationally recognised qualification is critical. In the 1 Bowman, K Skill Sets for the Resources Sector: An exploratory study, commissioned by the Resources Industry Training Council, September Page 5 of 10

7 absence of acceptance of this principle, skill shortages will continue and a key intervention opportunity ignored. State and Territory funding regimes which prioritises qualifications over skill sets remain a significant barrier to the further expansion of skill sets. The Commonwealth should take a leadership role in addressing this matter with state and territory skills Ministers. Change the system architecture In an industry led system, nationally recognised qualifications should be a reflection of industry skill/occupational demand. Australia s current training system has mechanisms for adding qualifications and units of competence to training packages however no parallel process exists to ensure qualifications and units of competence no longer relevant are effectively removed from the national register. This is evidenced by the discussion paper s observation there are approximately 3,000 training products on the national register with 33 per cent of publicly funded qualification delivered between 2002 and 2013 having less than 50 enrolments over the period. Low numbers of enrolments do not necessarily, however, reflect qualifications not in use. The existence of thin markets may explain low levels of enrolments. This gives rise to a range of broader policy issues around how thin market areas are treated from a training package perspective. Training package developers should have responsibility for collecting necessary evidence to support the maintenance of qualifications on the national register and therefore in demand by industry. Standards for training package development must reflect this responsibility and also incorporate policy guidance on the issue of thin markets. Packaging rules applying to qualifications in training packages must have sufficient flexibility to allow individual employers to customise qualifications to suit their needs. The existence of over accredited courses on the national register is symptomatic of a failure in this regard. A better balance needs to be struck between flexibility in packaging rules to meet an individual employer need and the policy objective of nationally consistent and recognised qualifications to assist in labour and occupational mobility. Accredited courses should only exist where an identified gap exists in a training package. The plethora of accredited courses results in unnecessary complexity in the training system and additional costs to the system from a regulatory standpoint. Ideally, accredited courses should be subsumed into training packages as part of the training package development and review process. In some cases, very specific enterprise based accredited training programs and an argument may be constructed to allow these to remain outside training packages (proprietary processes/technology etc). Change the focus of the system Current VET regulatory regimes are largely process based. Implicit is the assumption if process is followed, outcomes will meet expectations. This has proven not to be the case. Greater regulatory focus needs to be on quality assuring system outcomes and not system processes. Assessment is of primary importance to industry. Significant investments have been made by industry in creating verification of competence (VoC) processes to compensate for a lack of confidence in assessment decisions made by training providers. Independent (external) validation of assessment is seen as a mechanism capable of addressing many assessment/quality issues. Concerns contained in the discussion paper are noted however the RITC considers the benefit derived from external validation of assessment (increased quality in outcomes and increased confidence in the VET system) would outweigh any costs. To address any conflict of interest issues, consideration may be Page 6 of 10

8 given to allocating responsibility for administering the validation of assessment function to the VET regulator(s). The RITC does not support mandated assessment tools or capstone assessments being universally implemented across industry. Resources sector feedback suggests use of mandated assessment tools in high risk work areas has not resulted in any improvement in outcomes or improvement in industry confidence existing arrangements for high risk work will deliver expected outcomes. Caution is expressed around the implementation of any measures relating to assessment resulting in increased VET system complexity from an external perspective. Responses to specific discussion questions Do you agree with the first principle set our above or are there important aspects to the national training system that should also be considered here? The RITC agrees with the first principle a national system of qualifications must provide a reliable signal to employers about the skills an individual has, and must be underpinned by industry-defined occupational standards. The emphasis on qualifications in this statement will have varying currency across industry areas and within individual industry areas. Employers are ultimately seeking competent people capable of performing a job role to required standards in a safe way. In some cases this may require a qualification outcome, in other cases it may be a sub-qualification which is required (a skill set, or individual competencies). The qualification lens and skill set/competency lens are fundamentally different. Current system funding regimes are largely predicated on a qualification structure. Incentives therefore exist for providers to operate in a qualifications paradigm driven by funding requirements and availability rather than units of competence or skill sets. Should there be a one size fits all approach to the development and design of training packages and accredited courses? Does this limit the ability of developers to tailor a product to satisfy the needs of employers and individuals in different industry areas and/or various qualification levels? The need for sustainability and certainty in training package development and design processes necessitates exploration of alternate approaches (including risk-based approaches) in a constrained resourcing environment. Within a given minimum standards framework, it is no longer tenable for qualifications with 100 enrolments annually to be treated in the same way as qualifications with 100,000 enrolments annually. Training package developers are currently constrained by a policy position requiring adherence to uniform standards for the development of training packages. Those qualifications specifically serving the needs of a single enterprise should not be subject to the same development a review processes as those training package qualifications servicing an entire industry. The differential approach outlined in the VET Quality Report, where higher risk qualifications and those where there is evidence of poor quality outcomes have additional delivery and assessment requirements is an approach worthy of further consideration. Providing greater specificity in high risk/poor outcome qualifications should assist training providers in achieving industry expected outcomes. Such an approach would need to preserve training provider capacity for innovation. Do you think there are benefits to officially recognising and regulating more skill sets, and if so, under what conditions? What are the highest priority skill sets for national recognition in your industry? Page 7 of 10

9 Skill sets offer employers flexibility in skilling where full qualifications are seen to provide too much training for a specific job role. Some see skill sets as mini-qualifications, tailored to a specific job or licensing requirement or as a stepping stone to mobility within a particular occupational field. From a resources sector standpoint, skill sets are beneficial and contribute towards increased productivity and support multi-skilling and the adoption of new technology and processes. Increasing the number of skill sets in training packages may have an adverse impact on complexity and appears counter to arguments put in the discussion paper about there being too many qualifications. An important consideration in pursuing a skill set agenda is flexibility. Some existing skill sets in training packages bear no resemblance to industry requirements or to identified job roles. Flexibility is critical to ensure this lack of fit does not magnify itself should decisions be made to increase the number and recognition of more skill sets in training packages. In what circumstances can the delivery of training leading to a skill set or part qualification be more beneficial than undertaking a full qualification? In a resources sector context, it is common for workers to also have assessment and coaching responsibilities in addition to their main role. For example, a haul truck operator may also have a role as an on-the-job trainer/assessor which would require the acquisition of specific skills in training and assessment. In this instance, the core role of a haul truck operator could be supported by full or partial completion of a certificate in surface extraction. The supplementary training/assessment function could best be met through completion of an assessor skill set as the person would not be required to deliver training or to develop training plans or delivery materials. In this case, completion of a full training and assessment qualification would result in over-training and acquisition of skills which would not be used in the particular job role. Should delivery measures, such as volume of learning, be included in training packages and accredited courses where there is an industry need or identified risk? How could this work in practice? From 1 January 2015, all authorised (qualification) issuing organisations are required to comply with the requirements of the Australian Qualification Framework (AQF) including the volume of learning. This measure describes how long a learner who does not hold any of the competencies identified in the relevant units of competency would take to develop all the required skills and knowledge. Although the VET regulator does not specifically audit training providers for compliance with the volume of learning measure, arrangements for delivery must support learners in achieving competence with the requirements of the relevant training package. Inclusion of the volume of learning measure is therefore likely to see compliance with the measure come within scope of VET regulator audits. This would increase the regulatory burden on training providers and would be difficult to support. Is national consistency necessary for all industries and qualifications? Do all vocational qualifications and skills need to be included in the national system? Continuation of the current one-size-fits-all regime where all nationally recognised qualifications and accredited courses are treated the same is not sustainable in the current resource constrained environment. It is recognised national consistency facilitates labour mobility, however it may also constrain flexibility at the enterprise level. Page 8 of 10

10 A case can be mounted for enterprise specific qualifications to sit outside the nationally recognised framework or for them to at least not be subject to the same review rigor as industry training package qualifications. If the system provided for a lighter touch for some nationally recognised training and a higher level of regulation for others what criteria should be applied? A framework for regulation of nationally recognised training should be risk based. Possible criteria for consideration may include: Number of enrolments in the qualification; Number of training providers registered to deliver the qualification (large numbers could lead to poor delivery practices and outcomes); Whether the qualification is related to a regulated occupation or one considered highrisk; and Feedback from the customer complaints process recently instituted by the Commonwealth. How could they be re- Do accredited courses currently meet industry needs? focussed to ensure they are responsive? According to training package policy, an accredited course would only be considered for endorsement where no existing industry training package qualification could be identified to address the specific skill requirement. Furthermore, it was agreed any accredited course outcome would be considered in the context of training package development and review processes over time, accredited courses would be subsumed into training packages. There are cases where the owners of accredited courses maintain such accreditation only to increase the marketability of their offering rather than addressing any legitimate industry skill need. Do you support the regular review and rationalisation of qualifications and units of competency? How could this best be achieved? Qualifications and units of competency should only remain on the national register where there is an identified and demonstrated industry need. This reinforces a strong requirement for the training package development process to be industry-led and for there to be robust industry engagement throughout the process. Could an increased focus on improving the assessment of nationally recognised training help address the issues previously identified by some stakeholders that the outcomes of the training system do not meet industry needs? The assessment process is seen by industry as being critical to achieving industry desired outcomes from the training system. Industry s current concerns regarding poor quality training outcomes are symptomatic of shortcomings in rigor currently applied through the VET regulatory process. Without addressing this issue (which does not automatically mean increased regulation), any strategies to increase the focus on assessment in training packages is unlikely to realise any real benefit to industry, government or individuals. What would an external assessment regime in the Australian VET system look like? Should it be applied to all nationally recognised training or would this model be more applicable to some sectors and training packages than others? How could issues such as conflict of interest and the perverse incentives for the external assessors to build a revenue stream best be addressed? Lack of separation between the training and assessment functions leaves the door open to individual trainers/assessors making poor assessment judgements. Poor outcomes or Page 9 of 10

11 completion rates could be considered as an indicator of poor quality and, by inference, a poor reflection on the skills of individual trainers. Independent or external validation of assessment is one mechanism to address this and thereby improving the reliability of assessment decisions and industry confidence in training system outcomes. The conflict of interest issue could be addressed through the external validation function forming part of the VET regulatory regime. Conclusion The RITC welcomes the opportunity to comment on proposals to reshape the content of training packages and processes which underpin their development and review. If you have any further queries regarding the above matters, please contact Nigel Haywood, Manager RITC on (08) or n.haywood@cmewa.com Authorised by Position Date Signed Nicole Roocke Deputy Chief Executive 20 February 2015 Document reference PS-RITC-Training Package Discussion Paperv0.1 Page 10 of 10