Submission to the Education and Science Committee on the Industry Training
and Apprenticeship Amendment Bill
Hairdressing New Zealand registered as NZ Hairdressing Industry Training
Organisation Inc. (HITO)
Dr Flora Gilkison, HITO Independent Chairperson on behalf of the HITO Board
Rationale for Change
Prior to 1992 work-based training was through the apprenticeship system. While the
philosophy of the apprenticeship system was supported the reality was that the
system had become inflexible and highly regulated. In essence it was a time
serving model for trainees exiting the school system.
The key aspect to apprenticeship training is on-job skills learning and off-job
theoretical learning to reinforce and integrate with the newly developed skills. Prior
to 1992 this integration had become poorly connected. New industries were finding
it difficult to break into the apprenticeship model. The funding for off job training to
polytechnics was deemed insufficient and the polytechnics who set the curriculum
through their guilds. These were at times not teaching up-to-date material that the
industry wanted. Also at this time the development of NZQA National Qualifications
Framework where unit standards were introduced and on job training assessments
could now count towards a National Qualification was added to the mix.
In summary the system in 1992 was seen as no longer fit for purpose and a change
was required. The new Industry Training Act was designed to allow a new industry
training system to be:
• be industry-led
• be founded on competency-based training
• provide flexibility for employers and unions
• allow expansion that would include new areas of training.
1
In part the Act was successful for Industry Training but the funding mechanisms
between the Industry Training Organisations and the Providers, both polytechnics
now called ITPs and the plethora of PTEs which had developed, meant constant
niggle between the ITOs and the providers because of poor non-integrated funding
policies which to this day drives perverse behaviours. The industry-led aspiration of
the government in the 1990s had somehow been subsumed between the ITOs and
the providers. The upshot has been that there was a large number of ITOs
registered who developed the national qualifications. Separate to this the providers,
in order to maximise funding were enabled by NZQA to develop an overabundance
of qualifications all feeding the one industry. This has led to confusion in the market
place, funding incentives which have led to perverse behaviours and many trainees
signed up for a qualification who is not achieving the rate of unit standards expected
from the system.
In 2002 the ITOs were mandated to perform a leadership role. This created some
challenges as it was not clearly defined exactly what was expected other than a
requirement for a Strategic Training Plan. Due to the lack of clarification this role
was not always seen as being well done but also at this time there was a push back
from some TEOs suggesting that ITOs were not representing the needs of their
sector. For some industries it was difficult to define the current and future skills
needs especially where the majority of the businesses were small with less than 10
employees with limited business analysis. While this is planned to change in the
Bill, there will remain the same difficulty for SMEs to provide a leadership voice and
will continue to look to their ITO for leadership, advocacy and representation.
HITO, despite all these issues has managed to stay well engaged with their
industry, managed contracts with providers despite the extensive number of
qualifications developed by providers to maximise poorly developed funding policy
and have very engaged trainees. However HITO’s Board does agree that there is a
need for refinement of industry training. So just as in 1992 it was time for a change
over 20 years later it is time for another change. HITO is basically supportive of the
proposed Industry Training and Apprenticeship Amendment Bill but wishes to draw
attention to some aspects of the Bill.
HITO’s specific comments on the Bill relate to:
1. Endorsement of the role NZQA will undertake, in so far as ensuring quality
assurance requirements are consistently applied throughout the country whether
through an ITO, PTE or ITP. The concern is that the legislation is not sufficiently
2
specific e.g. New Section 11B which includes an obligation of an ITO to comply with
any condition of recognition and the quality assurance requirement prescribed by
NZQA. HITO would like further clarification of this clause whereby the word
nationally is added in “comply with any nationally prescribed quality assurance
requirements “. This would have the effect of giving consistency between all
providers and the ITOs as the concern is that NZQA may develop quality assurance
standards for ITOs which do not align with other quality assurance standards for
providers. Since ITOs are dependent on providers maintaining quality standards,
e.g. ensuring credits are registered with NZQA in a timely manner as the ITO’s TEC
funding is dependent on this. Non-aligned quality assurance standards may cause
the same issues that are currently in the system and again drive perverse behaviour
and conflict. This is unnecessary but poor Bill drafting can have these unintended
consequences.
2. In new section 13 B – Qualification Authority may prescribe quality assurance
requirement Rules made under section 253 (1)(ga) of the Education Act, quality
assurance requirements for ITOs may include, without limitation, requirements
relating to –
the quality of the management, operation and governance of ITOs
HITO’s view is that the inclusion of the word governance is a step too far.
Governance must comply with the law and NZQA is established as the quality
assurance setting body and therefore the governance of HITO must comply with
these requirements. The addition of governance into this clause in the Bill is
extreme and may have unforeseen consequences as the manner of how NZQA may
construe and define governance and their role is not sufficiently defined. The
removal of that word is the best option, NZQA is still empowered but the governance
of ITO’s is not compromised.
3. While the payment of fees from the ITO to NZQA to support NZQA with its new
quality assurance requirements are understandable the legislation again goes too
far in making an annual fee (11F Annual Fee) as well as fees for quality assurance
compliance monitoring. The latter should be the only fee required. However if the
insistence is to keep both fees then the addition of a requirement for NZQA to follow
the Auditor-General’s good practice guide on fee-setting by public sector
organisations should be added.
4. 13A Additional functions of the Qualifications Authority – these are agreed with as
the current environment has been scarred by poorly performing ITOs and has meant
that well performing ITOs such as HITO have not had the recognition deserved. One
area of concern with this additional function relates to the previous concern whereby
NZQA must ensure similar or nationally consistent quality assurance expectations
across all areas of learning. If the NZQA develops inconsistent policies – which it
has done in the past – then problems may arise again.
3
5. 11A Persons other than industry training organisation may receive funding for
industry training
The Commission may enter into funding agreements under this section providing for
any person (other than industry training organisation)
HITO does not agree with the inclusion of other apprenticeship trainers as further
defined in this section. The landscape is littered with providers and to add more into
the mix does not make sense. New PTEs can already be established but there are
strict guidelines for this. To enact industry to provide its own training is in our view
short-sighted. While HITO notes this is a particular philosophy we are against this
and not at all for our own protection. HITO stands tall in its own recognition and
support by their industries and the training standards it achieves. HITO's view is
that there are already good pathways for trainees to gain the training they require,
albeit some further refinement for consistent quality assurance is required. What the
enactment of this clause may do in the future is to allow further dilution of training
whereby trainees are confused by the competition in the market place and the public
resources for trainees becomes too stretched. Quality should be the marker and the
addition of yet more funding agreements into the market will again provide the
wrong drivers to industry with the impact being directly on poorer outcomes for
trainees and their expectations of employment.
HITO recommends that if this function is to remain in the new act the quality
assurance process is strengthened and the monitoring requirements are further
developed. The other aspect is that the Bill should include some provision that the
“Persons other than industry training organisations” must have an established
recognised cohort of employees or it may be that inadvertently quasi PTEs become
established. Marketing is a powerful influencer on young people’s choice of training
and career and without strong guidelines on what or who this particular part of the
Bill is designed for may have definite poor outcomes for young people searching for
the right career and training. We have seen far too many young people burdened
with student loans and yet no qualifications and resources just wasted. New
Zealand’s future development is too important to allow this to occur again.
6. 13C Apprenticeship training redefined part (d) (ii) a person or an organisation that
receives funding under a funding agreement. Again we urge that the Bill must be
stronger in its detail on how these proposed new trainers must have very specific
quality assurances practices established. Currently this is not enunciated strongly
enough in the Bill
Otherwise HITO is supportive of the Industry Training Federation Submission.
4