VET
John Dawkins
partnering with a licensed training organisation, which seems a sensible strategy for those providers struggling with the mounting costs of meeting regulatory requirements. Unfortunately, while this novel proposal is floated in the paper it is not explained in any detail.
One proposal described in some detail is that providers appoint an accountable education officer to be responsible for all training and assessment undertaken by the licensed training organisation( LTO). Dawkins believed this appointment would enable providers to take more responsibility for their own regulation:
“[ With ] the creation of the accountable education officer, hopefully there will be more in the way of self-regulation within the organisations themselves, and we hope that over time ASQA will feel sufficiently comfortable to allow the LTOs … a greater ability to make decisions without detailed reference to ASQA.”
The accountable education officer will reduce some of the workload for ASQA and will spare quality providers from excessive auditing.
“ In a context where the LTOs will be more assiduously regulating themselves … through the agency of the accountable education office who will have to sign off to ASQA about what’ s happening from a training and assessment point of view, there’ s an opportunity here for ASQA to continue to do audits from time to time, but I think there’ s an opportunity for them to take a less intrusive approach to the better performing LTOs,” Dawkins said.
Dawkins said the overall proposed approach would be supportive of quality providers; it was about“ how we can ensure that the better performers can operate effectively in a new regulatory environment”. He hoped the preferred approach recommended in the position paper would be seen as efficient and effective, not intrusive:“ I certainly hope it’ s not seen as … a more heavy-handed approach. It’ s … intended to give ASQA additional tools to be more effective.”
Uncomfortable aspects However, the good impressions of the NSSC position paper are slightly dented by a closer examination of three aspects of the paper, in addition to the point mentioned above about the vague invitation for some providers to relinquish their independence and partner licensed training organisations.
First, the paper clarifies that accountable education officers only require a diploma, and yet, as Dawkins noted, these pivotal people need to be“ capable of making the judgments about the quality of the provision and the quality of the assessment and indeed the quality of the teaching and training workforce for which they are responsible”.
Additionally, Dawkins viewed these people sitting at the top of the pyramid, above the teachers and those who train the teachers:“ At the top of that … pyramid is the accountable education officer who will be the one accountable to the regulator for … the quality of the teaching and assessment within that organisation”. Imagine the public reaction if the top educator in a child care centre, a school or a university only held a diploma. A diploma level qualification for the accountable education officer deserves a rethink.
Second, the position paper largely absolves governments of the damage done to VET quality by rogue providers funded by those governments.
Instead, the paper identifies three factors contributing to concerns about the quality of VET qualifications: poor quality providers, lack of information about providers and the growth of the training provider market.
Yet much of the poor behavior of providers exposed in recent times has related to governments inadvertently funding rogue providers. Before blaming providers for the damage to the reputation of the VET sector, those government funding regimes based on market design need to be overhauled.
The NSSC paper ignores the flaws of the market design school; a school which has been exposed over the last twelve months as ideological and not evidence based. The major flawed premise of market design is that adequate public good safeguards are in place in VET for the introduction of a widespread student entitlement system and full scale competition for government funds between public and private providers. Third, and straight from the discredited school of market design, the position paper extols the virtue of a free market for VET providers, as a core way of controlling RTO behaviour:
“ A key element of the proposed system is to support a shift towards a more responsive regulatory model, one which utilises a range of regulatory tools and strategies to ensure quality training and assessment delivery by RTOs. This is not just about a VET regulator ensuring compliance against the standards, but also enabling‘ softer’ regulatory mechanisms or controls to influence RTO behaviour( e. g. market mechanisms through informed consumer choice; and rigorous internal controls and quality assurance mechanisms of the provider).”
To rely on“ market mechanisms through informed consumer choice” assumes that informed consumers will choose to enroll with quality providers, meaning the rogue providers will fail to attract customers and go out of business. This is a bald assumption and no evidence is provided of where or how this has happened to date.
The good impressions and high hopes of the NSSC position paper are further dented by a paper released in February 2013 by the NSW Department of Education and Communities,‘ Smart and Skilled: Draft Quality Framework’.
This paper announced that the NSW government is setting up its own quality framework, in parallel with and based on a memorandum of understanding with ASQA, to foster“ coordinated audit and monitoring arrangements” with ASQA.
The draft NSW framework is based on nine loosely described principles – for example,“ Consumer protection: clear avenue for consumer protection” – that could create confusion and additional workloads for all providers, just as the NSSC is predicting a lighter regulatory burden for quality providers.
Taking into account that WA and Victorian regulators are currently operating under the previous national system, the Australian Quality Training Framework, not the current VET Quality Framework, and those state governments have not indicated whether they will support the NSSC position paper, this decision by NSW to construct its own quality framework is another jarring note for those people hoping the NSSC will help bring about a truly national system entitled the Australian Vocational Qualification System.
The NSSC proposals will be tabled with all ministers in June 2013, but Dawkins cautioned that the Council of Ministers may or may not have the appetite to discuss this matter:“ It’ ll be up to the appetite of the various governments as to whether they want to deliberate on this at their meeting.”
To avoid disappointment, those VET people who were enthused by their first reading of the NSSC position paper may be well advised to scale back their expectations. n
Dr John Mitchell is a VET researcher and consultant www. jma. com. au
www. campusreview. com. au April 2013 | 37