Report to the Australian National Training Authority On its High level review of Training Packages September 2003 1
This paper has been commissioned by the Australian National Training Authority (ANTA) to supplement the work of the High-level review of national Training Packages currently being conducted by ANTA. The report presents an overview of the opinions and experiences of members of the Australian Council of Private Education and Training () in working with Training Packages over the past three to four years i.e 1999-2003. This paper is particularly based on a premise expressed in a report attributed to Varghese the changing face of VET policy a State perspective and an ILO 2003 report Learning and training for work in the knowledge society namely It is widely recognized that with shifts in employment patterns and labou r markets: the individual is now the main client of the VET system, so that opportunities opened for individuals will be the main driver for maintaining the currenc y and skill and learning in the Australian workforce 2
Recommendations Recommendation 1 That the packaging rules for Training Package-based qualifications at AQF level 4 and above be redesigned so as to provide greater flexibility for private sector providers to cater for niche domestic and export markets and diverse client objectives, including the accumulation of credits towards higher education qualifications. Recommendation 2 That private sector providers be able to adopt a package plus add-ons approach to packaging their own niche market qualifications from the full range of Training Package-based qualifications and other accredited post-school qualifications in order to promote greater flexibility, innovation, diversity and responsiveness. Recommendation 3 That private sector providers be able to modify the nomenclature of Training Packagebased qualifications by using either of the following two options. Option 1 corresponds with the core plus options approach to qualifications packaging in Recommendation 1. Option 2 corresponds with the package plus add-ons approach to qualifications packaging in Recommendation 2. Recommendation 4 That a more flexible and inclusive structure be adopted for the certification of core plus options Training Package-based qualifications (see Recommendation 1). Recommendation 5 That Training Packages be renamed as Australian Vocational Standards Recommendation 6 That a "Unit s of Competency Generator " be developed Recommendation 7 That a national promotional and marketing campaign is conducted on conclusion of this high level review. 3
Purpose The purpose of this paper commissioned by the Australian National Training Authority (ANTA) is to supplement the work of the High-level review of national Training Packages currently being conducted by ANTA. The report presents an overview of the opinions and experiences of members of the Australian Council of Private Education and Training () in working with Training Packages over the past three to four years i.e 1999-2003. Introduction This paper has been developed by the Australian Council of Private Education and Training () on the basis of recent discussions with its members, reference to reports written by in relation to Training Packages in particular a report prepared for ANTA in December 2000 Enhancing creativity, flexibility and competitiveness? and reference to other work where has been involved on an individual state or National level, in particular the current work under way for ANTA Pathways for learning and skilling through the AQF. This paper is particularly based on a premise expressed in this latter report attributed to Varghese the changing face of VET policy a State perspective and an ILO 2003 report Learning and training for work in the knowledge society namely It is widely recognized that with shifts in employment patterns and labou r markets: the individual is now the main client of the VET system, so that opportunities opened for individuals will be the main driver for maintaining the currenc y and skill and learning in the Australian workforce The approach adopted in this paper has been devised to take this premise as the basis for enhancing Training Packages from the perspective of private fee-for-service providers. The approach adopted by seeks to retain the essential integrity of a national Training Package-based qualifications system, while at the same time providing registered private fee-for-service providers with greater scope to respond to individual and niche market demand and differentiate their products from those of competitors. 4
Towards these ends, seeks an approach to Training Package structure, content and implementation that gives much greater capacity to: recognise the diverse outcomes sought by fee-paying clients in domestic and export markets; promote and reward flexibility, high quality, innovation and diversity among providers and in their products; and provide simplicity, consistency, comparability and portability in the structure and range of national VET qualifications. In making this submission has addressed a range of questions raised in the terms of reference within the framework of Context Capacity of Training Packages and the current realities of implementation Enhancing the Training Package model This paper presents an integrated package of strategies which in the opinion of if fully implemented would significantly enhance the overall viability of Training Packages and enable private fee-for-service providers to meet individual and niche market demands and consequently compete more effectively in domestic and export markets. Private sector providers For the purpose of this paper, private fee for service providers are all Registered Training Organisations that are not under the management or control of a State Training Authority or State Department of Education or owned or managed by organizations that are themselves under the management or control of a State Training Authority or State Department of Education. Consequently the broad term of private fee for service provider encompasses and includes a mix of independent commercial colleges, industry or enterprise based RTO s primarily established to provide training to their own employees or potential employees, organizations that operate on a not-for- profit basis with associated tax provisions and companies operating primarily in the employment services arena providing associated training through government funding arrangements. 5
Terms of Reference Context As indicated earlier this paper is based on discussions with members which included most of the above categories of provider. From these discussions it is clear that most concern about Training Packages is being displayed by independent commercial colleges, these are private providers that are strictly fee for service businesses, mostly small in size and often owner-operated, which rely mainly on fee-paying clients, both individuals and employers. These independent commercial colleges competing in government-funded and/or privately funded training markets, and in domestic and/or export VET markets are generally small businesses working with clients (employers and employees) from small businesses and employing staff on a part-time basis who are often themselves running small businesses. It is this proximity to small business that gives the independent commercial colleges a unique and valuable insight into the operations and psyche of Australian small business. Independent commercial colleges involved in domestic markets typically service niche markets, most of which are located at AQF level 4 and above. Local fee-paying clients enrol in courses conducted by independent commercial colleges to gain a competitive edge in the labour market, and often to gain difference, individualism, personalisation and uniqueness in the products / services they purchase. Here the insight into the needs of small business are a critical determinant in the success of their operations. Consequently many independent commercial colleges in responding to the needs of small business attract clients by offering a differentiated product, usually in the form of specialised training and often with personalised approaches or other quality add-ons. Independent commercial colleges, exporting VET, deliver training primarily at AQF 5 level as it would appear that many overseas students seek diploma qualifications that provide maximum credits towards university degrees. Enrolment in AQF levels 4 and 5 are also brought about by the restrictive conditions under which visas are issued to potential students wishing to undertake qualifications at Certificate III or lower. Hence a major competitive edge of many independent commercial colleges involved in the 6
export of VET is said to relate to the number of tertiary study credits that they can provide. The perceived quality and international reputation of Australian VET qualifications are also seen to be critical determinants of client choice in export markets. As independent commercial colleges market and deliver the same training products to Australian and overseas students they draw no distinction between the national training market and global education and training markets. Within global markets, independent commercial colleges compete in a range of countries and regions, each being characterised by different value sets or socio-cultural preferences. Along with their quality of service and individualised attention, distinctive brand/product names are a key means by which many independent commercial colleges seek to differentiate themselves from their rivals in both domestic and export markets. Private VET markets, especially export markets, are highly competitive and subject to rapid and unpredictable change, all of which demand constant innovation, maximum flexibility and rapid responsiveness on the part of independent commercial colleges. As the main drivers of commercial training markets are employment trends, technological change, and socio-cultural preferences, independent commercial colleges expend considerable time, money and energy in modifying their product characteristics and marketing and service strategies so as to reflect changing demand and client preferences. Capacity of Training Packages and the current realities of implementation In 2000 private sector providers articulated numerous perspectives about Training Packages from a delivery and commercial perspective. These perspectives related to the impact of Training Packages on flexibility, quality, product differentiation and responsiveness, diversity and innovation. The issues that generated most discussion, particularly from the independent commercial college participants were: the flexibility in the structure and content of Training Packages; quality-related issues including assessment standards, capacity for quality addons, and quality assurance under the ARF; and the generic nature of the reserved qualifications nomenclature. 7
These issues have not changed over the past three years however they have been further exacerbated by the introduction of the AQTF which has seen a marked increase in the cost of compliance by private sector providers. A report released earlier this month by identifies sharply increasing compliance costs as a significant factor in the operation of independent commercial colleges that is negatively impacting on their perception of the vocational education and training system in general and Training Packages in particular. However the matter of the efficacy of AQTF is a separate issue and in this paper has not been allowed to be confused with the issues relating to Training Packages. Because of their proximity and insights into small business, independent commercial colleges experienced in the use of Training Packages are now becoming increasingly convinced that the current Training Package regime is very oriented to the needs and operational arrangements of big business and government with little cognizance, understanding or appreciation of the needs or operational arrangements of small business. Independent commercial colleges still argue that flexibility in both the content and construct of Training Packages, needed by small business, could be improved if they were more adequately consulted during the developmental phase. Lack of consultation is not only attributed to a failure by government and federal and state education agencies to recognise that commercial training provision, particularly that of the independent commercial colleges, is a major domestic and export industry in its own right one that is larger and economically more significant than many industries represented by existing national ITABs or some of the proposed Industry Skills Councils, but also to a failure to recognise the contribution that could be made by members to ensuring the needs of small business are better met. High among concerns of independent commercial colleges is still the impact that Training Packages are having on the quality of training and the reputation of Australian VET qualifications. All Training Package users agreed that some Training Packages are experiencing highly variable standards of training delivery and assessment due to the combination of: overly general competency standards that are ambiguous and open to loose interpretation by different RTOs; and 8
the lack of appropriate protocols and objective criteria to guide assessment in a consistent manner between RTOs. This variability cannot and should not be confused with flexibility or market differentiation, in the opinion of many members it is contributing to a lowering of credibility of Australian VET qualifications both locally and overseas. It is also seen that currently many of the quality issues arising from Training Packages are compounded by the practice of RTOs issuing graduates with identical qualifications, regardless of variations in the quality and standard of training delivery and assessment. There is also broad based perception that the nominal hours approach to competencybased assessment has encouraged cost cutting to be achieved by substituting face-toface tuition with self paced or self-directed study, with negative implications for the quality of learning. Such practices, in their opinion of members have allowed low quality operators not bound by the Code of Ethics to maximize their own cost efficiencies or to maximize benefits to employers primarily interested in gaining Commonwealth Government employment incentives. The generic titles of Training Package-based qualifications are still identified as a major constraint on the capacity of independent commercial colleges to differentiate their products in domestic and especially export markets. It is argued that individual and niche marketing requires flexibility in the naming of products, not just in product content and delivery modes. Moreover to those colleges currently unable to signal product differences to prospective clients, the reserved qualifications nomenclature is seen as an additional disincentive for them to customise and incorporate quality addons in Training Package-based products. Independent commercial colleges involved in the discussions pointed out that neither of their main competitors in export markets - overseas providers and Australian universities - are required to comply with such restrictive marketing regulations. Not only are many of the reserved titles for Training Package-based qualifications perceived to be unattractive to overseas students and prospective employers in their home countries, but also certificates with graded levels and advanced diplomas have little if any international recognition. 9
Many independent commercial colleges in response to these concerns have actively supported the introduction of the associate degree into the AQF as an exclusively higher education qualification. These colleges see that the initial expense and rigours of the higher education accreditation system is a well worthwhile long-term investment. Whilst many colleges privately indicate in principle support for the concept of the associate degree simultaneously being a higher education and vocational education and training qualification many are fearful that such an approach will incur the counterproductive heavy hand of Training Package rules. An additional expressed concern of some independent commercial colleges was that the work-based assessment requirements in Training Packages restricts their ability to meet the needs of: individual clients who have no access to workplaces, particularly, international students, new job seekers, the unemployed and people living in geographically remote areas; and domestic and overseas clients seeking management-related competencies in certain industries and occupations. A particular concern expressed by Ms Jocelyn Broadbent, Director of the Gold Coast Aviation Centre relates to the nexus between Training Package qualifications and licensing when she writes Many students find that accessing a course for licensing through a certificate course or diploma course is confusing and sheds doubt on course content. Having a course with two names is confusing and hard to sell particularly to students who have a cultural suspicion of what is being sold to them. I.e it s called a certificate IV in Aviation but you will get a licence to work as well. Sorry you can t get a visa for a licence only Enhancing the Training Package model In the 2000 report Enhancing creativity, flexibility and competitiveness? proposed six primary recommendations for enhancing the Training Package framework as well as a number of additional recommendations. Some good work has been done over the past three years in relation to some of the additional recommendations but little cognizance has been given by ANTA to the five of the six primary recommendations. From the discussions with current members four of the original recommendations still have a high degree of currency and are relevant to this 10
paper. The four recommendations as originally presented are listed below. However some of the original implementation strategies have been modified to be more in accordance with the experience gained over the past three years by members. Recommendation 1 It is recommended that: The packaging rules for Training Package-based qualifications at AQF level 4 and above be redesigned so as to provide greater flexibility for private sector providers to cater for niche domestic and export markets and diverse client objectives, including the accumulation of credits towards degree-level qualifications. Under this arrangement, all RTOs would be required to deliver and assess training leading to nationally recognised qualifications at AQF levels 1-3 inclusive in accordance with national Training Package policy, packaging rules and implementation guidelines, as modified in the light of other recommendations below. At AQF level 4 and above however, Training Package-based qualifications should be restructured to facilitate a core plus options approach to the packaging of units of competency from Training Packages and/or other individually accredited units, including appropriate units from associate degrees/ degrees. At these levels, qualifications should be designed in accordance with the following packaging requirements: Qualification level Packaging requirements Certificate IV (AQF 4) Deliver a defined minimum number of core units of competency; and Add an additional specified number units at AQF level 4 or above from the same or different Training Packages and/or individually accredited units, including appropriate units from associate degrees/ degrees. Diploma (AQF 5) Deliver a defined minimum number of core units of competency; and Add an additional specified number units at AQF level 5 or above from the same or different Training Packages and/or individually accredited units, including appropriate units from associate degrees/ degrees. Advanced Diploma (AQF 6) Deliver a defined minimum number of core units of competency; and Add an additional specified number units at AQF level 6 or above from the same or different Training Packages and/or individually accredited units, including appropriate units from associate degrees/ degrees. 11
Under a core plus options arrangement, the defined minimum number of core units of competency should comprise no more than 75 per cent of the total number of units of competency in each Training Package-based qualification. Where independent commercial colleges identify a unit of competency that does not presently exist, and for which demand in domestic and/or export markets can be demonstrated, they should be permitted to submit such units for individual accreditation by the appropriate recognition authority. In cases where units of study from degree-level courses are included, colleges should be required to provide evidence that they are recognised by the relevant university as a legitimate provider of such units, and that students will receive the specified credits on completion of the qualification. Under a core plus options arrangement, independent commercial colleges should be permitted to customise the qualifications titles according to the guidelines specified in Recommendation 3. Certification requirements associated with this approach are identified in Recommendation 4. Recommendation 2 It is recommended that: Private sector providers be able to adopt a package plus add-ons approach to packaging their own niche market qualifications from the full range of Training Package-based qualifications and other accredited post-school qualifications in order to promote greater flexibility, innovation, diversity and responsiveness. Under this arrangement, independent commercial colleges would be permitted to develop recognised training products for domestic and export markets that comprise component 1 plus various mixes of the other the components a, b, c as follows: 1. At least one or more Training Package-based qualifications at AQF levels 1-5 in combination with: a. industry-recognised certificates (eg. first aid, computer packages); and/or b. units/modules/subjects from degree-level courses accredited by Australian universities; and/or c. other accredited post-school qualifications. 12
Under this arrangement, independent commercial colleges would be permitted to devise distinctive titles for their qualifications, as specified in Recommendation 3. In such cases, the whole qualification would not be recognised as a national qualification in itself, although the constituent parts that conformed to Training Package requirements would lead to the award of the relevant national qualification(s) and be recognised under Mutual Recognition arrangements. Provided such qualifications contained at least one whole Training Package-based qualification, they should be included on the National Training Information System to enable private sector providers to promote them to fee-paying clients, and to have them listed them on the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) for delivery in export markets. Independent commercial colleges who include additional components, such as industryrecognised certificates and/or accredited degree-level units/modules/subjects, in such qualifications should be required to provide evidence from the relevant accreditation authority that they are recognised providers of the additional components, and that graduates will be certified accordingly and/or receive the specified credits towards subsequent qualifications. Colleges should be required to list each individual component of such qualifications in their marketing materials and provider-issued certificates, and to indicate clearly which components are recognised by government and/or other relevant accreditation authorities. Such an approach would allow Australian independent commercial colleges to compete more effectively with their overseas competitors, such as those from New Zealand who are permitted to develop and market their own unique qualifications in this manner. 13
Recommendation 3 It is recommended that: Private sector providers be able to modify the nomenclature of Training Package-based qualifications by using either of the following two options. Option 1 corresponds with the core plus options approach to qualifications packaging in Recommendation 1. Option 2 corresponds with the package plus add-ons approach to qualifications packaging in Recommendation 2. Option 1: Under this option, independent commercial colleges who adopt the core plus options approach to qualifications packaging would be permitted to add their own customised secondary title in brackets after the approved primary title of the base national qualification, according to the following formula: Certificate IV in Industry/Occupation (discrete emphasis according to units added) Such an approach would enable providers to identify the particular speciality of their qualification, as reflected in the: additional units of competency imported from one or more other Training Packages; and/or individually accredited units of competency, including units of study that have been imported from appropriate associate degree/degree-level courses. Under this approach, colleges would also be permitted to develop, advertise, deliver and award Training Package-based qualifications at AQF level 4 and above with combinations of generic primary titles and customised secondary titles, such as: Certificate IV in Tourism (Tour Boat Operator) ; and Diploma of Finance (Share Trading) ; and Advanced Diploma in Business (E-commerce). 14
Course information issued to prospective clients would list all the core and non-core units of competency, together with the base national qualification(s) from which they were sourced. Certification requirements associated with this approach are identified in Recommendation 4. Option 2: Under this option, independent commercial colleges who adopt the package plus addons approach to qualifications packaging would be permitted to use a fully customised qualifications title for trading and certification purposes, in conjunction with the full AQF national qualifications title(s) and other accredited qualifications and units of study. For example, the Bruny Island Maritime College (BIMC) could develop, promote and deliver its own unique qualification as follows: Bruny Island MC Diploma in International Maritime Management Qualifications and credits awarded on successful completion of the course: Bruny Island MC Diploma in Maritime Management AQF Certificate IV in Transport and Distribution (Maritime Operations) AQF Certificate IV in Business (Compliance Management) Associate Degree in International legal Systems (60 credit points) Prior to trading with customised qualifications titles in accordance with Option 1 or 2, RTOs should be required to register them with the relevant State/Territory Training or Recognition Authorities, and then have them included on the CRICOS for trading in export markets. State/Territory Training and Recognition Authorities should ensure that the customised qualifications titles, and related advertising and promotional materials, comply with the AQTF standards and where applicable the ESOS national code. As shown in the example above, customised qualifications titles should be accompanied by the approved AQF national qualification title in full, in addition to other accredited components, in all advertising and promotional materials, and on credentials issued to graduates. 15
Recommendation 4 It is recommended that: A more flexible and inclusive structure be adopted for the certification of core plus options Training Package-based qualifications (see Recommendation 1). This recommendation is included to create an incentive for independent commercial colleges to further innovate and respond to individual and niche market demand by including quality add-ons in their commercial offerings. Colleges who adopt the core plus options approach to qualifications packaging should be permitted to issue a single certificate incorporating the core and additional or adjunct units of competency from other Training Packages (for which separate Statements of Attainment are currently issued) and/or other individually accredited units of competency and/or other industry-recognised certificates and/or units of study from other post-school qualifications, such as university degrees. The new single certificate should comprise two main parts as follows: Core units of competency: to record assessment outcomes against the core units of competency taken from the base national Training Package qualification; and Adjunct units of competency and/or other individually accredited components: to record assessment outcomes against the additional non-core units of competency from the same or other Training Package-based qualifications and/or other individually accredited units of competency and/or degree-level units/modules/subjects recognised by Australian universities for credit transfer purposes. A single certificate issued along these lines would not only satisfy industry requirements for a nationally consistent qualifications system, but it would also enable providers to respond to the diverse preferences and objectives of fee-paying clients in domestic and export markets. Such an approach would also promote increased product differentiation and market competition on the basis of price and quality. 16
This recommendation should be implemented in conjunction with Recommendation 1 and the proposed modifications to the existing reserved nomenclature for Training Package-based qualifications in Recommendation 3. This would ensure that independent commercial colleges are more able to signal differences in product content and post-course outcomes to prospective clients in domestic and export markets. Recommendation 5 It is recommended that: Training Packages be renamed as Australian Vocational Standards In the experience of members there has been confusion amongst some potential or newer education and training practitioners and Industry about the nature and the content of Training Package. Many potential independent commercial colleges initially look to or expect Training Packages to include curriculum, training information/programs or subject matter content within the Training Package and are often surprised and disappointed by the lack of such information. understands that Training Packages are in the true sense a specification of vocational standards. It is therefore recommended that to overcome the level of confusion that they be renamed to Australian Vocational Standards. Recommendation 6 It is recommended that: That a "Unit s of Competency Generator " be developed ANTA has recently released a research project undertaken conjointly by a number National Industry Training Advisory Bodies (ITABs) relating to Shared Technologies. The report notes a high degree of commonality that is likely to increase across Training Packages that use similar technologies. ANTA has also undertaken considerable work on 17
the issue of employability skills, which stresses the needs for a more consistent approach to some of the generic cross industry skills. It seems appropriate to members that given a growing number of units of competency are likely to reside in many Training Packages that it might be more useful for ANTA to direct that all ITABs/ISCs involved in Training Package development contribute to the development of a "Units of Competency Generator" along the lines of the Resource generator. The Generator would hold all such units of competency and developers would draw required units of competency down from the generator, to construct qualifications for their Australian Vocational Standards. The advantages of this approach is that it would reduce duplication of like units of competency, improve consistency of funding for same outcomes across packages, improve efficacy of delivery and assessment, and reduce the probability of big business silo mentalities emerging. Such a model would also support earlier recommendations in this paper. Recommendation 7 It is recommended that: A national promotional and marketing campaign is conducted on conclusion of this high level review. Not withstanding the concern about rising costs of compliance, in the past year has conducted a very successful program in Victoria in relation to developing greater awareness and understanding of the AQTF. It was clear from these workshops that the opportunity for sharing of information, advice and experience of working in the VET sector was very much valued by members. members acknowledged the program as contributing significantly to their understanding of the AQTF and to ensuring a greater degree of compliance. It is consequently recommended that when this high level review of Training Packages is completed that ANTA introduce a national promotional and marketing campaign to ensure that all in the VET system are aware of any new directions. 18
For and on behalf of National Board September 2003 19