ASQA went through a significant transformation of its regulatory approach during 2016, and it is fair to say that the changes are promising.
The dimensions of the VFH debacle, embarrassed the whole system, and certainly opened a debate about the ROI on the regulator's performance during its first five years of existence. So far, ASQA hasn't been the catalyst expected for the VET sector.
To be fair with the regulator's team, the structure of the VET sector has not supported ASQA to achieve its mandate.
Perhaps the first mistake was to assume the market could sort out product quality issues, but the reality has shown that the market hasn't been able to decipher a training sector where both "good" and "dodgy" providers operate under the same label of Nationally Recognised Training (NRT).
At the age of five, ASQA now knows our sector, and the current approach seems to have a strong basis on that knowledge.
I refuse to call our system a failure, that would be an untruthful diagnosis and unfair, as many RTOs provide high-quality work. The vocational education and training sector generates hundreds of thousands of good stories every year, stories about individuals developing talent and opening the doors to employment and social inclusion for many.
What are the system's issues then? Dysfunction. A couple of years ago, a Minister referred to the VET sector as "convoluted and dysfunctional", a very accurate diagnosis.
Vocational Education and Training requires:
- Industry relevant training
- Educational pathways for learners
- Regulation of RTOs
There is no strategic vision for the VET sector, no connection among the five areas listed above.
Funding is not connected with industry or learners' needs. The government only buys seats and not outcomes, there is no ROI study available for any funding model, or training package; what we have are cost analyses. But a cost analysis cannot connect resources used with outcomes, and cannot be used to evaluate results later.
Relevance of training outcomes are not connected to industry. The government has mandated SSOs with the creation of training packages, but SSOs don't participate either in the regulation of training delivery, or the evaluation of outcomes. Today nobody is accountable for the effectiveness of training packages; we only have entities accountable for writing training packages.
Until we fix these dysfunctional issues, we are not going to get an effective, efficient, and high-quality VET sector, and these incongruences will continue to depreciate the NRT brand.
Why ASQA's new audit model can help us to improve the situation
Firstly, the regulator is now better integrating the principles of quality audits into its own approach.
It is difficult to perform an audit against the Standards for RTOs 2015 and apply the principles of outcome focus, simply because the Standards have a rather procedural focus, and the whole VET Quality Framework lacks benchmarks for training outcomes.
In fact, the Standards for RTOs 2015, are more suitable for an accreditation system, and not to manage the operations of RTOs. But ASQA is trying to do the best with what it has available by:
- Looking at the application of Standards from the "students' experience" perspective, and
- Collecting evidence from different sources.
The different phases of the student experience will help the regulator to confirm whether certain outcomes have been achieved. For example, by asking students whether they received the information and support needed to make an informed decision prior to commencing training, the regulator will gather relevant evidence about the outcome of the RTO's marketing and enrolment process. Asking students and trainers whether they think the amount of training was about right, ASQA will collect relevant information about the suitability of the amount of training from the key stakeholders: trainers and students.
The Standards for RTOs define requirements for some core functions that training providers must execute, but these functions are organised and listed by content domain, and not in the order they are performed. Basically, every Standard for Quality Management Systems, including ISO 9001, are written the same way.
The effect that ASQA's new approach should have is primarily moving the focus of regulatory audits away from paperwork and towards outcomes. This approach will allow those hundreds of high-quality RTOs, to maintain compliance without increasing administrative costs in useless paperwork, and concentrate on quality training delivery and assessment. In other words there is a better alignment with compliance and quality.
Secondly, ASQA's next important step is collecting evidence from different sources; initially this will be fundamentally from students and trainers.
I honestly think ASQA's new approach will help to maximise benefits from current regulations and arrangements, and I would like to make a few recommendations:
- Publish all audit reports. By publishing audit reports, the regulator will promote transparency. This will help to moderate audit criteria, promote accountability within the sector, and constitute great reference and educational material.
- Regulate number of students per RTO. ASQA should regulate the number of students enrolled for a period. RTOs should have, as part of their registration, an approval for a specific number of students and they should only be allowed to increase this number if they can demonstrate access to the resources required. This will provide assurance that RTOs have the resources, and not only the strategies, to deliver the courses to the students enrolled.
- Include industry representatives in audits. Current arrangements keep training packages and training delivery on parallel paths, totally isolated from each other. SSOs and IRCs do not always have direct representation from those who set industry standards. Therefore, their potential contribution to measuring whether students have met occupational industry standards is unlikely. ASQA needs to identify industry representatives that can support auditors to measure outcomes in relation to meeting occupational industry standards.
- Regulate employers. ASQA should regulate employers for the delivery of apprenticeships and traineeships. The on-the-job supervision of apprentices is a critical component of their training, but employers are not properly audited against their responsibilities as per the apprenticeship contract. This will help to improve the training received on-the-job.
- Reform (improve) the VET Quality Framework and Training Packages. But that is a topic for another post.