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Training Product Reform

Template for submissions to Training Product Reform

Key consultation areas

The Department of Education and Training (the department) seeks stakeholder input on the paper Training Product Reform: what is the case for change? which proposes enhancements to the design of training products in vocational education and training (VET) to ensure they support skills development into the future. The paper Training Product Reform: Issues for Discussion provides further detail and sets a framework for public consultation. These papers are both available at www.education.gov.au/VET-consultation.

How to provide feedback

Stakeholder consultations begin with the public release of Training Product Reform: what is the case for change? in December 2017 and continue through to March 2018.

Respondents may provide feedback on some or all of the paper’s themes. To assist with the compilation and analysis of the views of all stakeholders, respondents are encouraged to provide feedback via this preferred submission template. Submissions in alternative formats will also be accepted.

All submissions should be emailed to [email protected].

All submissions will be made publicly available on the department’s website, unless respondents direct otherwise. Terms and conditions for public submissions are available on the department’s website at www.education.gov.au/terms-and-conditions-public-submissions-department-education.

How feedback will inform policy decisions

Stakeholder responses to the discussion questions will form the basis for the Training Product Reform Joint Working Party’s report to COAG Industry and Skills Council on training product reform.



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Submissions that do not meet web accessibility requirements may not be published. Further information on Australian Government web accessibility requirements is available at www.australia.gov.au/accessibility.

If you do not want your submission published on the department’s website or otherwise be made publicly available, please advise the department upon making your submission, otherwise all submissions may be published.



Theme 1 discussion questions: The case for change

What are the skills, knowledge and abilities that make workers more adaptable and resilient to future workforce changes?

How well placed are training products to respond to future workforce demands and skill requirements?

What barriers are there which could prevent training products from meeting future workforce needs?

Will the design changes proposed improve the ability for training products to respond to future workforce demands and skill requirements?

Are the terms ‘training packages’ and ‘training products’ fit for purpose? Do they appropriately describe this fundamental VET system infrastructure?

How strongly has the case for change been made by the paper Training Product Reform – what is the case for change? Does it need refining in particular areas?

COMMENT:

(1) Workers must be adaptable and resilient to a changing economy. To achieve this they will need both skills that are likely to be required in the future, as well as skills to handle change itself.

Research has identified the types of skills that are both necessary now and will retain or increase their importance in the future. For example, work from the Foundation for Young Australians and the Mitchell Institute has identified skills like problem solving, critical thinking, creativity and communication as holding or increasing their importance in the future world of work. This is in part due to the inherent adaptability of these skills.

Industry still recognises that technical skills are important, and they are concerned with the next generation of technical skills and how they will be supported, not replaced, by the ‘enterprise’ skills above. Consequently, next generation technical skills emerging from new technology will likely replace or add to existing technical skills.

With respect to adapting to change itself, the focus should be more on attributes than skills and knowledge. Resilience and learning agility have been identified by industries as keys to constantly remaining relevant. There is significant debate about whether these skills can be, or should be, taught in formal training.

(2, 3 and 4) Training products are well placed to meet the skills needs outlined above, particularly with respect to enterprise skills and emerging technical skills. We should focus on taking full advantage of training products by embarking on a structural and cultural shift away from the traditional rigidity of qualifications towards the responsiveness and fluidity of units or skills sets.

Furthermore, reviewing training packages will have to be undertaken in a fundamentally different way. Training Packages cannot be iteratively adjusted but rather should be fundamentally overhauled where industry is willing and the skills needs require it.Currently, the Business Services and ICT Industry Reference Committees are considering major changes to the architecture of their respective training packages. This will likely result in a decrease in the number of qualifications and an increased use of skills sets and specialisations.



They are doing this for two reasons: to improve industry understanding of the qualifications and units, and to make the training packages easily adaptable to their fast changing industries.

This is a challenge for the VET Sector. Such an approach will not suit every industry and traditions, conventions, training package standards and the administrative burden of non- equivalence will create significant resistance.

(5) On balance, the names ‘training packages’ or ‘training products’ are not in themselves an impediment to meeting the needs of the economy. Some industries do not understand what a training package is which can make engagement difficult. On occasion they are also confused by curriculum. Replacing the name, however, will not improve this situation. Changing the name to “industry standards”, as is sometimes put forward, will replace the current confusion with different misunderstandings.

The current names are well known in the VET Sector. They have been trained as part of the Certificate IV Training and Assessment for some time and changing their name would cause additional confusion in the VET sector.

In short, it is our submission that name change(s) will not result in a commensurate benefit and that effort and resources would be better invested on other parts of the reform agenda.

(6) The case for change provides a useful account of the pressures on training products and illuminates some of the key issues to be considered in charting a path to change. Together with the submissions following these questions, it will provide a significant body of evidence on which to make decisions about future reform.



Theme 2 discussion questions: Qualification design – Inclusion of foundation skills and future work skills

Should future skills and foundation skills form part of all qualifications?

How much prescription should there be to accommodate different learner cohorts?

Can the current format of units of competency effectively support the learning and assessment of future work skills and foundation skills? Would changes be needed?

How could training products specify the assessment of these skills even if a learner’s qualification does not include specific units of competency in these skills?

What additional skills and knowledge should be incorporated in future work skills which are not currently encapsulated by employability skills? Does the term ‘future work skills’ convey the intent of these skills or should employability skills be broadened to include these additional skills?

Does the current VET workforce have the skills to deliver these units? What, if any, upskilling would be required?

COMMENT:

(7) There is overwhelming support from industry for workers to have skills that might be variously described as foundation, enterprise, future or employability skills.

With respect to LLN skills (commonly referred to as Foundation Skills), there is wide recognition that without these, little else is possible. Current mechanisms, if correctly applied, should identify and appropriately address LLN requirements in qualifications. Consultations on the review of the Foundation Skills Training Package found significant under-use of FSK units in the context of technical training (i.e. training in qualifications from other training packages). Changes to the FSK Training Package will improve this situation but systemic changes to funding and trainer capability would also assist.

With respect to employability or enterprise skills, these are skills that are required now and are becoming increasingly important due to the changing nature of work. They are skills that can be contextualised to different industry requirements. Currently, these skills exist in various forms in multiple training packages and current efforts to support the creation of common units should help improve the portability and recognition of these skills across industries.

With respect to emerging technical skills, which could be considered future skills, the nascent methodology for including these in training packages is sound. Emerging skills needs are identified in Industry Skills Forecasts and where future skills needs apply across multiple industry sectors, cross sectoral projects are undertaken. The cross sector projects on skills like Cyber Security and Automation help to develop the “technical” skills of the future in a way that makes them broadly applicable.

(8) At present there are processes in place requiring training products to be, so far as is practical, accommodating of different learner cohorts.

Fundamentally, industry demands optimising the potential number of participants so as not to exclude potential sources of skilled workers and RTOs demand the same so as not to exclude potential sources of students.



More directly, the equity element of the quality assurance process for training products demands the needs of different learner cohorts be factored into training package reviews.



The Standards for Registered Training Organisations requires that trainers use reasonable adjustments in their training and assessment strategies to ensure that training products meet the needs of learners.

Improving the application of current rules and obligations is likely to be a more fruitful place to drive improvement than embedding any new rules within the training package system.

(9 and 10) The current structure of units of competency does not inhibit the delivery of future skills or foundation skills. Industry and RTOs have argued that the current practice of not including range statements has made units difficult to contextualise. It is argued this may inhibit the delivery of units that require high levels of contextualisation like cross-cutting units.

We would further caution against changing the structure of units of competency given they were only recently changed. Notwithstanding their merits these changes have caused significant fatigue in industry and the VET Sector.

The current mechanism for including foundation skills in units of competency is the obvious solution to include future work skills if a policy decision is made to do so. Industry has responded well to the inclusion of reasonable detail in the foundation skills section of units and broadening this section’s scope may be worthwhile. It should be noted, LLN skills that are currently included in this section have a strong anchor framework to reference (the Australian Core Skill Framework) where future skills may not have such a framework to add additional context or reference outside of the content within the units.

(11) See answer to question 1.

(12) It is highly unlikely that units of the nature described in this section would be effectively implemented without some work being undertaken to increase the capability of the VET workforce.

As evidence for this, our consultations on Foundation Skills Training Package found that there was a concern over the capability of the VET workforce to effectively deliver FSK units. There was a concurrent Commonwealth Government funded project undertaken with a view to establishing an LLN Practitioner Framework to determine the kinds of skills that are required to effectively train these units.

Further, it was consistently submitted that the Certificate IV Training and Assessment is only designed to give trainers the ability to identify LLN issues and requires an individual to seek external assistance in addressing LLN needs. Consequently, the testimony of those consulted was that practitioners prefer to shy away from embedding FSK units in other qualifications because it is too onerous or complicated. The fact they are not being used in other qualifications is supported by unit usage numbers.

A similar issue is a key risk for other cross cutting units including potential ‘future skills’ units. If the skills being taught are not an area of expertise of the trainer, if they receive little or no attention in the Certificate IV Training and Assessment and if funding is not sufficient to properly support the cross cutting units being embedded into qualifications (as opposed to being taught stand-alone) then the units will simply not be used.

Potential solutions include, delivery only being undertaken by practitioners with certain skills (i.e. establishing assessor requirements), embedding skills in the Certificate IV Training and Assessment to enable all trainers to effectively train these units or to fund appropriately so units can be delivered in a “dual trainer model” that allows for specialist assistance to support the delivery of the units. All of these have complex funding or implementation considerations.



Theme 3 discussion questions: Qualification design – Technical skills

Should technical units have a greater focus on underpinning knowledge and theory?

How should underpinning knowledge and theory be assessed?

Is the language used to differentiate the components of competence appropriate, or is there other language or terms that better differentiate knowledge and skill?

Is there a need to assess technical skills differently in high risk sectors? If so, how?

How could skill sets or accredited courses assist in providing specific technical skills required for the workplace?

COMMENT:

(13) There can be no blanket rule for the inclusion or otherwise of “underpinning” knowledge or theory into a unit of competency. It is logical that if you were to include in the unit itself all of the preceding knowledge required to undertake a unit, as you worked your way up in complexity the units would become increasingly large.

As a rule of thumb, units that are likely to be used as entry level units have greater scope to include underpinning knowledge within the unit. For those units likely to be used (on their own or in qualifications) for the improvement of skills for established workers, there is greater scope to use pre-requisites or entry requirements to serve this purpose.

(14) Pursuant to the above, training products are the appropriate place to determine to what extent underpinning knowledge should be assessed and, through the knowledge evidence, articulate how it should be demonstrated. RTOs should also, consistent with their obligations to the student, determine whether the students existing knowledge is such that the RTO believes, in good faith, they are reasonably likely to satisfy the requirements to complete the course in which they are enrolling.

(15) In our view the rules and language used to differentiate components of competence are appropriate.

(16) Where the risk of injury, physical or otherwise, is heightened it is likely that assessment requirements will be less open to interpretation and more onerous. Where possible, training products should allow for contextualisation and innovation, however, in instances where the downside risk is too great, it is better to err on the side of prescriptive assessment requirements.

(17) Skill sets and accredited courses enhance the ability of the training system to deliver technical skills particularly where those skills are for the purposes of further learning for established workers. Skill sets enable this cohort to have minimal time away from their jobs and get the skills they need without the need to satisfy the requirements of a full qualification. Accredited courses assist in providing niche skills that IRCs may not deem sufficient to warrant a training product. Skill sets and accredited courses may have some benefit for learners entering the workforce, however, full, training package qualifications usually have greater utility.



Theme 4 discussion questions: Qualification design – Broadening the vocational outcome

Theme 4 discussion questions: Qualification design – Broadening the vocational outcome

What types of jobs require targeted qualifications? Could these jobs be better served by broader qualifications?

Would the needs of learners be better met by qualifications that have a targeted or broader outcome? Why?

Would the needs of industry be better met by qualifications that have a targeted or broader outcome? Why?

If qualifications are matched to a broader range of occupational outcomes, what models will support effective upskilling or retraining?

COMMENT:

(18-20) As a general rule there are too many qualifications, their outcomes are too specific for the modern working environment and their packaging rules too prescriptive to allow further flexibility. Generally, the needs of industry and learners would be better served by having fewer qualifications and those qualifications having greater flexibility to allow students to choose their own path. This also gives industry a chance to focus on fewer, more relevant qualifications.

For example, rather than having multiple qualifications at the same AQF level in the same training package, having a single qualification with the ability to specialise through dedicated streams is a better approach.

Having said that, where an occupation has very strict requirements, including but not limited to, licencing requirements, it may be necessary to remain more targeted. Often, however, requirements of licencing authorities are restricted to particular units or groups of units and not full qualifications.

(21) Similar to the philosophy outlined elsewhere in this submission. Broad qualifications at entry levels articulating into targeted skills sets at higher levels is a model advocated for by a number of industries.

There may be scope to progress this approach to a point where if an individual undertakes multiple skill sets building on their initial qualification, this may form recognition as a higher level qualification.



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Theme 5 discussion questions: Qualification design – Structure of core and elective units

Should the design of qualifications specify a minimum number/proportion of core units or a minimum number/proportion of elective units? Should this vary between qualification level or by industry, or should it be consistent?

Should qualifications specify a minimum number of the different types of units (technical, foundation, future skills)?

Should there be a minimum number of units which should be included from other training packages?

If the current flexibility is retained, what other mechanisms could be put in place to assist employers to understand the specific skills which learners have gained through their qualification?

Could greater use of specialisations within qualifications achieve a better balance of flexibility and consistency?

COMMENT:

(22) We have not received any feedback that would indicate abolishing packaging rules (stated in the first part of this question as “minimum numbers” and “proportions”.) While arguing for retaining packaging rules, it has been routinely stated that they are overly proscriptive. Across our industries there is not a consensus, or single approach, to what packaging rules should consist of and therefore we would recommend not introducing blanket minimum numbers or other one-size-fits-all rules.

(23) Qualifications should use groupings, core units, elective units and groups within the elective bank, to stipulate the mix of skills an individual should attain while providing flexibility within each of those categories. Further, and particularly useful for technical skills, the use of streams within elective banks can help differentiate between different sub-groups of technical skills.

(24) At the moment, the training package policy prescribes flexibility. It is our submission that industries should be able to import units from other training packages but not be forced to do so. If there are obvious units to include in a given qualification, they can be included in the elective banks through importation. If the industry wants to give students the freedom of “loose electives” they should be able to do that as well.

(25 and 26) As mentioned before, the better use of specialist elective streams in broader qualifications is a way of helping employers understand the employment outcomes from a given qualification while allowing the student greater flexibility in their own learning.



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Theme 6 discussion questions – Qualification design – Training packages

Are ‘training packages’ useful for determining training needs?

Does the system require additional flexibility to enable different ways of grouping qualifications?

COMMENT:

(27) Training packages are an effective mechanism for determining training needs. Efforts should be dedicated to improving their effectiveness such as increasing the utilisation of skills sets and individual units of competency, as well as improving the process through which training packages are updated.

(28) As mentioned in other sections, the ability of an individual to build their own qualification in a manner that suits their own career path is paramount. At present qualifications are too rigid and qualification names and outcomes are too narrow for the modern economy.

One potential remedy is the use of skill sets as building blocks across the system. Over time they would build towards recognition as a qualification, or an improvement in the level of qualification attained.

This system may limit the number of redundant units individuals undertake and satisfy industry’s demand for shorter, sharper training directly related to employment needs.



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Theme 7 discussion questions: Qualification design – Increasing the use of common units of competency

What are the benefits or disadvantages promoting the use of common units?

What barriers are currently in the system which prevent the adoption of current units?

What would be suitable criteria for determining whether a learning requirement can be met by a common unit of competency?

Are there other mechanisms (e.g. implementation guides, companion volumes) that would overcome potential disadvantages of common units of competency and promote wider adoption?

COMMENT:

(29, 30) A clear benefit of creating common units is to establish cross industry standards for skills that are both portable and will be required in the multiple jobs across multiple industries one will have over the course of their career.

The existing situation has similar skills delivered in iteratively different ways across different industry training packages. Consequently, these skills are trained in a way that erodes their portability (because they are too industry specific), or they are not in fact industry specific and therefore the presence of multiple versions of these skills causes duplication and obsolescence.

Skills for Australia has recently written draft units for ‘teamwork’ and ‘communication’ skills. This process has highlighted obvious challenges.

Firstly, these kinds of units require significant contextualisation. The unit cannot, by its nature, be prescriptive and therefore relies on the quality of the trainer to deliver it in the context of the skill set or qualification that the student is undertaking. The capability of the VET workforce to effectively contextualise units was routinely questioned in our consultations.

These types of units are also most effective when not trained in isolation. It is highly unlikely that a student would undertake a qualification consisting only of these broad skills. As a result, these units would have to sit in come kind of bank, or a Training Package that enables people to choose from an array of units and import them. The Foundation Skills Training Package has acted in this manner for some time and it has faced issues with usage of the units in the context of other technical training. This, to some extent, is because trainers and assessors do not know of the units or do not feel confident in using the units. This lack of confidence may be in part because the ability to contextualise the content is not a strength for the trainer. Funding for FSK units was also an issue commonly raised.

There is a current discussion paper being prepared on who should ‘own’ the teamwork and communication units, how a ‘bank’ would operate within the current training package policy and what mechanism the AISC or other group could use to promote their use. These questions must be resolved satisfactorily and we continue to contribute our views to this discussion.

(31, 32) A common unit of competency should receive no different treatment than any other unit of competency with respect to the requirements of the unit. In crafting the elements, performance criteria, and evidence requirements consideration must be given to the broad applicability of the skill and therefore covering off on a range of different sub-



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skills that may be required. For example, in the ‘communication’ units, the draft unit contained specific types of communication that had to be covered as part of the unit.

Implementation Guides would be useful in so far as they could provide additional contextualisation or case studies that assist trainers to deliver the units. However, the development of these units may also be supported by more intensive stakeholder engagement or materials over and above the usual collateral released as part of a training package update.



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Theme 8 discussion questions: Skill sets

What factors contribute to the use of skill sets by your organisation?

Should skill sets have a stronger link to the qualification?

Could skill sets be used as specialisation within a qualification? What would be the advantages and/or disadvantages?

Should skill sets for introductory level students, especially those without a school certificate, be only available after a student has already undertaken a qualification that includes foundation and future work skills?

Is there a better way to ensure skill sets meet the needs of industry and students?

COMMENT:

(33) Is not applicable for our organisation at this time.

(34) Unequivocally yes. Skill sets should be the building blocks of which qualifications are built. At the moment, skill sets are collections of units classified as such for a range of different reasons including licensing and regulation, or to better brand a particular subordinate set of skills.

A collection of skill sets should form a qualification and for this to occur there would need to be a fundamental review of packaging rules for qualifications as well as the current configuration of skill sets. (35) This scenario would enable the testamur to better demonstrate what skills have been demonstrated in the particular qualification by highlighting the component skill sets. In this way skill sets may act like specialisations.

(36) As previously mentioned, skill sets are more valuable for individuals seeking to upskill. The reason for this is that their base of post-school learning is strong (through doing a full qualification) and they are incrementally adding to those skills. It also suits the way in which this cohort is likely to learn. They are already in the workforce and therefore are unlikely to undertake a full qualification because of the time commitment and the fact they do not need that level of learning to achieve their learning objectives.

This does not mean that skill sets on their own are not suitable for entry level workers. In fact, if a recognised skill set is sufficient to get someone into a job quicker than this can be a positive thing. However, more caution should be exercised because a skill set on its own will likely be insufficient to sustain a student through their entire career. Therefore, considerations like a student’s training entitlement should be factored in. While they may leave their initial training with a skill set, they should be able to return and complete their qualification as a minimum.


Training Product ReformTheme 9 discussion questions: Accredited courses

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Theme 9 discussion questions: Accredited courses

Do you (or your organisation) use accredited courses? What is the primary benefit to you (or your organisation)?

Should there be tighter guidelines around what types of courses should be accredited? If so, what should they be?

COMMENT:

(38) SFA is involved in the provision of letters of support to be attached to course owners’ applications for course accreditation. These applications are submitted to the relevant regulator.

These letters of support confirm the SFA’s satisfaction that proposed accredited courses fulfil two requirements: First, that the proposed course does not duplicate, by title or coverage, the outcomes of an endorsed Training Package qualification and second, that the proposed course meets an established industry, enterprise, education, legislative or community need.

(39) SFA has previously submitted concerns regarding the current process for accrediting a course. While respecting the role of accredited courses in the system as mentioned elsewhere in this paper, we submitted three key areas that require consideration to tighten the current process:

- Clarity about what is meant by key words like “duplication” and “industry need”. For example, to what extent must a proposed accredited qualification differ from an existing training package qualification? Or, what proportion of units can be imported from training packages compared with the number of unique units?

- Low thresholds for compliance with course accreditation process and policy. The aforementioned lack of clarity may result in lower thresholds being applied in assessing compliance. For example, it could be argued that an accredited course similar to an existing qualification is still compliant where only a few units have been substituted.Similarly, an accredited course might be deemed to meet an industry need, on a broad interpretation of the term, with only limited endorsement from industry.

- Consideration should be given to the commercial interests of course owners and to the motivations for submitting an accredited course. There is a distinct commercial advantage to owning an accredited course particularly in relation to retaining intellectual property and being able to name the course to position it in the market. This in itself is not an issue, however, it can, if the system settings are not appropriate, lead to the submission of accredited courses for commercial reasons, not to improve skills outcomes.

There has been a suggestion that one response to this situation may be to make intellectual property available for every accredited course, however this would disadvantage those who have invested reasonable resources into producing an accredited course for an appropriate purpose.

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