Quality of assessment in
vocational education
and training
Mr Patrick Reid
Leading Age Services Australia CEO
02 6230 1676
The voice of aged care
www.
Leading Age Services Australia
P: 02 6230 1676 | F: 02 6230 7085 | E: info@lasa.asn.au
First Floor, Andrew Arcade, 42 Giles Street, Kingston ACT 2604
PO Box 4774, Kingston ACT 2604
ABN: 7115 6349 594
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Leading Age Services Australia (LASA)
Leading Age Services Australia (LASA) is the peak body for service providers of retirement living,
home care, and residential aged care. LASA is committed to improved standards, equality and
efficiency throughout the industry; helping older Australians to live well. LASA advocates for the
health, community and accommodation needs of older Australians, working with government and
other stakeholders to advance the interests of all age service providers, and through them, the
interests of older Australians.
LASA represents private, church, charitable and community care organisations, which gives it the
unique ability to provide a comprehensive view on behalf of the aged care industry to enable all
Australians to have access to, and choice of, high quality age services. To assist in achieving this,
LASA pursues relevant issues with robustness and vigour in order to maintain and enhance age care
services throughout Australia.
LASA has a number of offices across Australia allowing it to focus on State and Territory specific
considerations and concerns, as well as at a national level. Together LASA presents a strong, unified
voice on behalf of the industry to Government and other stakeholders.
LASA has two Registered Training Organisations, one in Victoria, the other in Queensland.
Thank you for the opportunity to comment on the Quality of assessment in vocational education and
training – Discussion Paper. Should you have any questions regarding this submission, please don’t
hesitate to contact Ms Tina Ison on 07 3725 5555.
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Leading Age Services Australia (LASA) .................................................................................................... 2
Introduction ............................................................................................................................................ 4
1.
RTO limitations ........................................................................................................................... 4
2.
Skills and qualifications of trainers and assessors ..................................................................... 7
3.
Benefits and purpose of a VET professional association ........................................................... 7
4.
Potential activities of a VET professional association ................................................................ 8
5.
Models for a VET professional association ................................................................................ 9
6.
Capability framework ............................................................................................................... 10
7.
Increasing industry confidence ................................................................................................ 11
8.
The role of industry in assessment .......................................................................................... 12
9.
Specific models......................................................................................................................... 13
10.
Industry expectations and graduate capabilities ..................................................................... 14
11.
Evidence of assessment and graduate competency ................................................................ 15
12.
Enforcement............................................................................................................................. 17
13.
Cancellation and reassessment................................................................................................ 18
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Introduction
Leading Age Services Australia (LASA) thanks you for the opportunity to comment on the Quality of
assessment in vocational education and training – Discussion Paper. LASA is a strong advocate of
enhancing innovation in education and training to support a workforce providing care and services
that are accessible and sustainable, whilst still maintaining safeguards in quality and focuses on
continuous improvement.
1. RTO limitations
Is it appropriate for relatively large numbers of RTOs to deliver TAE qualifications or
skill sets? Should the number be reduced to a targeted number of RTOs focussing on
high-quality provision?
It would be entirely appropriate to have numerous Registered Training Organisations (RTOs) if the
training and assessment could be guaranteed to be of high quality. This is not the case in the current
Vocational Education and Training (VET) system. Smaller RTOs which deliver specialised training have
the Training and Education (TAE) qualification on scope, and it is argued that every industry requires
competent trainers and assessors. Whilst an RTO may be specialised and expert in their industries
requirements, they fail to be experts in the delivery and assessment of training and education.
A possible solution to this issue is to conduct an immediate audit (which could be completed via a
desktop audit initially) of the training and assessment strategies employed by RTOs to deliver this
qualification. RTOs who fail to demonstrate compliance with the volume of learning requirements
for new entrants into the profession should be investigated. It would be of relevance to target those
RTOs who purport to deliver qualifications in a weekend/ week and advertise that all assessment is
completed during the training delivery.
Further, the delivery of courses completely on-line raises the question of how participants learn the
art of training. How can an assessor assess delivery to an individual or a group without having
observed the learner?
Should RTOs be restricted from issuing TAE qualifications or skill sets to their own
trainers and assessors?
LASA supports the premise that RTOs should be restricted from issuing TAE qualifications or skill sets
to their own trainers and assessors. There are a plethora of RTOs delivering this qualification, and
there is no reason why this couldn’t be implemented. A possible solution would be an Australian
Skills Quality Authority (ASQA) directive/ notification to all RTOs with the TAE qualification on scope.
However, ASQA would need to consider the legal implications for enforcement.
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Are TAE qualifications and skill sets so significant that evidence of competence should
not - or cannot - be appropriately demonstrated via recognition of prior learning?
 Is recognition of prior learning for TAE qualifications or skill sets granted with sufficient
rigour to ensure the quality of student assessment? Should the practice be restricted?
LASA suggests RPL should be able to be granted for trainers and assessors who are current in the
profession. There are many RTOs who apply rigour to the RPL process and it would be unfair to see
those RTOs disadvantaged. It would further be onerous on experienced and competent trainers and
assessors to continuously complete full qualifications.
Where the current system fails is in the application of the RPL process. The VET sector has become
an expert at ‘mapping’, which has led to the mapping of BSZ to TAA, and then TAA to TAE which in
effect could see trainers having completed no additional professional development in this area for
greater than 10 years. A possible solution would be clearly defined assessment requirements in the
Training Package with tangible outcomes to be demonstrated. The VET sector needs to get back to
quantifying outcomes. For example, “the learner must be able to demonstrate XX hours of delivery”.
In commenting on RPL in general, there needs to be a significant shift in how this is taught in the TAE
qualification. Many trainers who hold this qualification have no idea or concept of how RPL is to be
applied. A further solution to this issue would be the implementation of a professional body
(discussed in Q3) to allow competent trainers and assessors a formal, independent avenue to
demonstrate currency.
Are there opportunities to improve the assessment skills of the VET workforce
through changes to the delivery and assessment of TAE qualifications and skill sets?
 Should TAE qualifications and skill sets only be delivered by VET practitioners who can
demonstrate a specific period of training and/or assessing employment history in the VET
sector?
There are many improvements that could be made, relatively simply. LASA queries what happened
to the minimum of five years’ experience before a person could train any qualification? Accepted
best practice was always a trainer/ assessor had to hold qualifications equal to or higher than what
they were delivering/ assessing, be current (worked within the industry within the last two years)
and had demonstrated at least five years’ experience in the industry. Those rules applied for every
qualification from Cert II to Advanced Diploma and across all industries. Unfortunately, these best
practice guidelines are not implemented in all RTOs.
The Standards for RTOs 2015 1.13-1.16 only partly addresses these basic principles. Clause 1.13 a)
identifies that the trainer/ assessor must at least hold the qualification to the level. Clause 1.13 b)
does not define currency therefore this is open to interpretation. Further clause 1.13 c) again does
not define currency. There is no mention of experience in an industry of a nominated amount of
years before being able to train/ assess a qualification.
A possible solution would be defining a period of time practicing in the industry, for example, 3 or 5
years. This would ensure that trainers/ assessors are at least able to deliver and assess within their
vocation. In terms of the TAE, this would improve the relevance and validity of assessment as well as
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the overall understanding of the VET sector. Some trainers, while skilled in their vocation, are not
necessarily fully cognisant of the intricacies of VET and the assessment systems (including RPL).
The approach to the VET system at the moment is to leave it up to the RTO to determine their
compliance with the Standards deliberately being written, it seems, with flexibility in mind. The
current system is a result of this change. It is assumed that RTOs appreciate this approach to
compliance. It is clearly not working and not sustainable. To underpin the system with quality,
perhaps quality trainers and assessors need to be defined.
 What circumstances would support a change requiring some VET trainers and assessors
to hold university-level or higher-level VET qualifications, for example, practitioners
delivering and assessing TAE qualifications and skill sets?
These circumstances would result in an ailing VET system; which is what we have currently. It is
highly appropriate to expect trainers to have a higher level qualification in order to deliver
specialised training. The Cert IV TAE and Diploma are examples of where this rule should apply.
 Should the TAE Certificate IV and/or Diploma require a practical component? If so, how
long should the practical component be?
These qualifications do have a practical component (if taught properly) at the moment. For example,
if an RTO unpacked the training package correctly in the Cert IV TAE the learner must demonstrate
three sessions of at least 40 minutes of delivery to a group, at least two sessions of 30 minutes for
one-on-one workplace training, participate in at least two validations, complete a 15 minute skill
session for a group. It is the application of the learning and assessment which lets these qualification
down. Again, it confounds LASA how these qualifications can be delivered and assessed fully on-line.
 Should entrants to the TAE Diploma be required to demonstrate employment history in
the VET industry before being issued with the qualification? Would this condition help to
improve the relevance and validity of assessment? How long would this period of time
be?
To strengthen the TAE Diploma, there clearly needs definition around experience. The easiest way to
implement this would be to define an amount of hours of delivery/ assessment in a core unit of
competency. Possible examples include:





the learner must provide evidence of:
o timetables,
o training plans or attendance sheets totalling 70 hours of facilitation,
lesson plans totalling 30 hours,
evaluation forms from 5 sessions,
completed training needs analysis, and
evidence of assessment at least 20 candidates from a total of 10 or more units of competency.
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2. Skills and qualifications of trainers and assessors
Should the TAE Certificate IV be changed to a core unit on the design and
development of assessment tools? How would this improve assessment outcomes for
students?

Should the core unit be the existing TAEASS502B Design and develop assessment tools
unit of competency? Are there alternative approaches, such as developing a new unit on
the design and development of assessment tools?

Is the TAEASS502B Design and develop assessment tools unit of competency a specialist
unit that should only sit at the diploma-level on the basis the Certificate IV is currently
designed for delivery to new entrants seeking to be trainers and assessors?
LASA suggests there is no need to develop another unit of competency. The existing unit of
competency needs to be strengthened in terms of quantifying the evidence, however do not require
a full re-write.
TAEASS502B is more aligned to the AQF Diploma level. Most trainers and assessors do not write
assessment tools and instruments. It is however argued, that these skills give a VET trainer the
context of assessment and the skills to unpack a unit of competency. At the Certificate IV level of
TAE the main skill required is the ability to contextualise assessment to the cohort of learners. To
competently undertake this task (and still meet the assessment requirements of a unit) it is
recommended that this unit remain in the Certificate IV.
In the case of making any updates to the TAE, is it appropriate to form judgements
based on majority considerations? Or is it too risky to do so? Is it a better basis for
decision makers to give strong weight to key stakeholders and the nature of the
argument put forward?
Unfortunately many stakeholders have a vested interest in the design of training packages. Decisions
should be based solely on the best interest of the VET sector and improving current standards. Key
stakeholders would need to be defined before further comment could be made.
3. Benefits and purpose of a VET professional association
Is there a need to establish a national professional association for Australia’s VET
system?
 Specifically, is there a clear role for Australian governments in assisting the development
of professional skills of the VET workforce by funding a professional association?
LASA strongly believes there should be a body developed as a VET professional association but it
should be co-designed with industry. Such a body could be similar to registering bodies such as the
Australian Health Practitioner Regulation Agency (AHPRA) which is the organisation responsible for
the implementation of the National Registration and Accreditation Scheme across Australia for
health practitioners.
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What are the barriers to establishing a national professional association? How could
these be overcome?
The barriers that exist will be with stakeholder interests which are not always aligned to the best
interests of the VET sector. To overcome this, government and industry would need to manage the
process. It may be useful to examine other such registering bodies to ensure consistency and to
learn from how they were implemented.
What would be the most useful guiding purpose of a national professional
association?
Recognition of trainers/assessors as a profession. Identifying, through eligibility and continued
professional development, trainers/assessors who are current in their profession. Providing
industries, those that undertake qualifications and the community generally, with confidence that
those who are registered with such an association uphold the requirements for membership and
demonstrate consistency across the industry.
LASA currently has feedback from its members that there is a significant lack of confidence in some
RTOs who produce people with qualification that are not suitable for the workforce needs of the
industry, where some graduates are not ‘work ready’ and require significant additional training to
provide safe, quality care and services to older Australians.
Registration to such an association for trainers should therefore be mandatory.
4. Potential activities of a VET professional association
What activities would be most beneficial for a national professional association to
undertake?
For example, would it:
 coordinate, approve or design professional development programs
There are numerous programs already existing that could be utilised by a professional association.
 develop capability frameworks
Yes. Refer to the Australian Aged Care Leadership Capability Framework (2014) for an excellent
model.
 positively promote the profession of VET trainers and assessors as an employment
destination and career path to attract professionals
Yes.
 act as an advocate and voice for VET trainers and assessors
This could be difficult to implement if the association is government funded, however such an
activity could be pursued.
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 interact with industry to respond to their emerging needs
LASA considers that this activity may not be required as it is the responsibility of the Australian
Industry and Skills Committee (AISC) and Skills Service Organisation (SSO).
 register VET practitioners?
This would be the primary function, to ensure:




compliance to professional standards,
determine eligibility for membership,
determine a nominated number of hours of professional development required per year
(suggest at least 10 - 20 hours), and
define professional development for trainers/assessors.
What advantages would there be to conducting these activities at a national level
rather than through existing professional development undertaken through
membership of existing groups, or that which is currently organised by RTOs?
The advantage of conducting these activities at a national level would be to ensure consistency
across the industry which would cross state boundaries. It would also support industry, sector and
community confidence.
Are there any existing organisations that could fulfil this role?
No, not specifically. There are a number of professional associations; however for consistency a new
government led, industry co-designed approach could be adopted.
5. Models for a VET professional association
Which of the suggested models for a VET professional association would be
considered most preferrable and viable in the current VET environment? Model A,B or
C?
All models presented have merit, advantage and disadvantages. Model B represents a single VET
professional association, endorsed to undertake a range of functions including the development of
professional standards and a capability framework, and design and promotion of professional
development and practice, though without government structure may lack authority.
In seeking feedback from the LASA RTOs, LASA found that Model C, proposing that state and
territory school teacher registration extend from the schools sector to the VET sector may be a
model to support. However, under this model as proposed, VET trainers and assessors would
register with the teacher registration body relevant to the jurisdiction in which their RTO operates.
This would cause jurisdictional boundaries whereby VET sector ‘teachers’ may not be able to
practice outside of their jurisdiction. LASA would seek that a national approach be implemented.
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What value would a VET professional association, or associations, add to the VET
sector?
The value would be the recognition of trainers and assessors as a profession. The model would add
validity around the currency of trainers and assessors which is not open for interpretation at the RTO
level. This model, structured with defined eligibility and defined professional development
requirements for individuals, could lead to a higher standard of trainers/assessors within the VET
sector and as described above provide industry and community confidence.
What mechanism would sustain a professional association, for example, membership
fees from individuals or RTOs?
Membership fees would need to be reasonable and should be at the individual level. It should be the
responsibility of the individual to demonstrate nominated number of hours of professional
development each year to maintain currency.
Should VET teacher and trainer membership with a professional association be
mandatory or voluntary?
Membership to a professional association or authority should be mandatory. The sector needs a
change in its approach to this issue and allowing voluntary participation will not raise the quality of
the profession nor confidence in the system.
6. Capability framework
What can be learnt or applied from the capability frameworks that have been
developed or are currently being developed?

Is there an opportunity to make better use of these frameworks, irrespective of
proposals to develop a professional association?
The Australian Aged Care Leadership Capability Framework (2014) is an example of how industry and
government can partner to develop an industry-led capability framework. The framework describes
the knowledge, skills and abilities required by leaders across Aged Care. Peak bodies, including LASA,
in collaboration with the former Industry Skills Council, defined leaders and leadership and
examined the application against levels of leadership. The benefits of the Capability Framework
include:








identifying common and transferable aspects of leadership within or outside Aged Care
supporting effective recruitment strategies and pathways from outside Aged Care
benchmarking professional standards
enabling the design of leadership development initiatives that address Aged Care
requirements and acknowledge the Aged Care context
promoting the development of a skilled, flexible and mobile leadership cohort
expediting leadership-related development processes including performance reviews,
recruitment and succession planning
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
increasing access to leadership qualifications
This model could be used as the foundation of a capability framework for trainers/assessors.
Specifically, describing the knowledge, skills and abilities of trainers/assessors.
In the future, if a professional body is not implemented, this work could be undertaken by the SSO’s.
7. Increasing industry confidence
Are there alternative approaches not covered in this discussion paper on how industry
can increase engagement with the conduct of assessment, but not specifically the
validation?
Industry needs to clearly define the practical component of qualifications within the VET sector. This
work was previously undertaken by the Industry Skills Councils (ISC) in collaboration with industry.
Going forward, the work will now be driven by the Industry Reference Committees (IRC) set up
under the AISC supported by the SSOs. It should be noted that industry already contributes to the
VET sector through many avenues. The Standards for RTOs 2015 clause 1.5 and 1.6 clearly states
that RTOs should have processes in place for industry engagement which should be validated
through ASQA audits.
Are there other ways to ensure industry confidence in assessment without requiring
independent validation of assessment? For example, are industry-endorsed, externally
administered tests a practical alternative to ensure that VET graduates are
competent?
 What would be the benefits and drawbacks in requiring such tests? Under what
circumstances would they be mandated, for example, for particular student cohorts?
Should these be specified in training products?
 Who should regulate the tests?
 Should such a test be a pass/fail dichotomy, or would it be more important to use the test
to identify gap training?
 Is the concept of an externally administered test, such as a test required before receiving
a qualification, inconsistent with the premise of a competency based VET system?
 Should the results of tests be made public at the RTO level?
In general, industry confidence in the VET sector, and specifically around assessment, differs. This is
largely driven by the inconsistency of what competency means. In Australia we have the Australian
Qualifications Framework (AQF) and a National Recognised Qualification system, therefore
industries expectations are that if a person graduates from any RTO, the graduate should have
identified skills, knowledge and abilities. This is not the case, and places unnecessary expectations
on workplaces to fill the gap in the graduate’s abilities. The main victim of the system is not just
industry, but rather the learner who can be deemed unemployable even with the necessary ‘piece of
paper’.
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The above suggestion of an independent test adds another layer to an already over-complicated
system and it is argued that this would not ‘fix’ the issues within the sector. Any such burden would
need to be independently funded as RTOs would not be able to incur further administration costs.
This suggestion glosses over the underlying problems and would not be necessary if the problems
are addressed. That is, national consistency in competency for a specific qualification. This can only
be driven by industries requirements and should be clearly defined in training packages around
‘time’ (discussed in section 11).
8. The role of industry in assessment
What role should industry, for example, employers and industry organisations, play in
validation of assessment? Does the varied interpretation of ‘industry’ inhibit a proper
appreciation of the topic and should it be defined? If so, who would best define
‘industry’ when considering the practice of validating assessment?
There are many definitions of industry of which vary. For the purpose of the VET system, industry
could be simply defined employers of graduates. They are, in effect, the end-user of the product.
Industry has a significant role to play in validation.
It should be noted that this function is not funded.
Do employers or industry groups have the skills required to fulfil this role in validating
assessment? Is assessment such a specialised skill that industry and employers either
do not want to get involved or should not get involved?
Industry groups would not necessarily have the skills to conduct validation independently, however
should be supported by VET experts. Direct engagement with industry is critical. If the training
package had clearly documented guidelines (which should have been determined by industry in the
first instance), industries role therefore should only be ensuring the application of the training
package is consistent and is meeting the workplace’s needs. The technical aspects, such as mapping
assessment against the unit of competency should remain with the VET sector (or RTO). The
industries role should be to validate the assessment tools and instruments to ensure that are what
employers need ‘on the ground’.
Is there a need to build industry capacity and capability regarding involvement with
training and assessment? If so, how might this be done?
It would be advantageous to all for a half day program to be developed and rolled out on ‘Industries
role in the VET sector’. Remembering that they are not the VET experts, there is no need to
complicate the process with jargon and the technical aspects of validation. It could simply by
outlining the importance of industry expertise, how they can contribute to the VET system and
provision of key contacts for feedback. Feedback from industry could be directly provided to the
newly formed IRCs. Peak bodies would be well equipped to lead this process. The benefit would be a
cohort of industry representatives capable and confident to contribute to the process and
participate effectively in any validation process with any RTO.
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How can we ensure engagement with industry is appropriately targeted so it does not
add undue burden and is targeted to those within industry with appropriate expertise
required for validation of assessment?
This question could be directed to the new IRCs for comment and recommendations. A peak body
could also play a vital role in connecting industry with the VET system.
9. Specific models
How can independent validation be best applied to avoid a ‘one size fits all’ approach?
For example should independent validation of assessment be triggered by:
 improving RTO practice, for example, through a principles based model and best practice
guide to support the VET workforce in identifying the most appropriate technique to
validate assessment
 mandatory requirement to lift quality in specific instances, for example, where a
qualification is identified as high-risk
 funding requirement, for example, independent validation of assessment could become a
requirement for RTOs seeking to access government funding.
LASA would be supportive any of the three suggestions for independent validation. There would
need to be consideration of how to fund this activity if it is over and above current processes.
Should there be an increased role for external assessment by industry, and in which
situations?
 For example, should it be mandatory for certain industries where there is a concern for
public safety if a learner is incorrectly deemed competent?
Again, LASA would be supportive of such a measure. However, any measure should not create a
further burden on industry, therefore consideration should be given to funding such a strategy.
External assessment may increase industry’s confidence in the sector, however would need to be
properly funded and administered.
A concern for public safety (and the associated risk) could very well be the benchmark for
determining which qualifications should be categorised as high-risk and indeed inform the definition
of high-risk qualifications. Coupled with categorising high-risk environments where there is a
potential risk to the learner.
It should be noted that, in some cases, industry already contributes significantly to the VET system
and student outcomes through existing participation in IRCs, Workforce Councils and Committees.
Moreover, industry supports work placement and contributes to the learning of practical tasks in
real work environments.
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If independent validation of assessment is to be risk-based, then what factors should
be considered in the assessment of risk, for example, public safety, RTO profile,
student cohort?
The assessment should only be determined on risk. There would need to be approval from industry
to have qualifications categorised as high-risk. Industry would need to be consulted and an issues
paper drafted outlining advantages and disadvantages before any such decision could be made. The
resourcing and implementation of such strategies would need to be considered further.
Should high-risk student cohorts be required to undergo independent reassessment
of industry-agreed sets of competencies before being issued with their qualifications?
 For example, particular qualifications; students undertaking qualifications with RTOs with
high levels of non-compliance; or that conduct assessment wholly online or on-the-job; or
in areas of public safety.
LASA does not see a need for this double work. If the assessment process was robust in the first
place, this would not be necessary.
Would the burden be too great if independent reassessments were required for an
entire student cohort, and should independent reassessment apply to a sample of
students instead? If so, how could such a sample be chosen?
As discussed above LASA disagrees with this concept.
Who would be most appropriate to oversee the reassessment of qualifications?
 For example, could existing regulators or other organisations (such as firms that specialise
in assessing students) take on this role?
As discussed above LASA disagrees with this concept.
10.
Industry expectations and graduate capabilities
Is there a role for Government or industry to develop resources outlining VET
graduate expectations for particular training products? If so, who should take this
work forward?
 Do higher order issues need to be resolved regarding terminology such as ‘competent’
(as assessed against the training product) and ‘job ready’ (ready to undertake all aspects
of a particular job)? Is there a common understanding of VET system outcomes?
LASA suggests there is not a common understanding in industry or the VET system in relation to job
readiness and competent. These are terms and concepts not understood by both industry and the
VET sector. Resources outlining VET graduate expectations for a particular training product would
clarify this confusion, however is this not what training packages are for? The intent of training
packages is to articulate job skills, knowledge and abilities aligned to job outcomes which, in effect,
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outlines what a VET graduate should look like for a particular job role. It could be argued that a more
appropriate term is skills ready, however the sector already has enough definitions and jargon.
The common understanding of outcomes should be directly linked to the training package.
11.
Evidence of assessment and graduate competency
Should the Standards for RTOs be revised to include strengthened and more specific
rules around the conduct of and evidence to support assessment? Which elements
that have a clear link to quality of student outcomes need to be strengthened?
The Standards are clear around the evidence to support assessment, in particular section 1.1 – 1.4.
Which leads to the question of what is perceived the real and underlying problem of the VET system.
The main issue is the RTO determining ‘the amount of training’, which is what is stated in the
Standards. The underpinning notion is that RTOs should comply with the AQF at all times, which
therefore gives the power of regulation back to ASQA. Unfortunately, it appears that ASQA does not
regulate compliance with the AQF. If this was the case, weekend diplomas would have been
eradicated. In defence of ASQA, RTOs have become adept at manipulating the volume of learning to
suit commercial practices as opposed to a genuine commitment to learning for job outcomes.
Currently, the AQF is perceived and implemented as just a framework, and until it is used as the
foundation for compliance, the VET system will continue to decrease in quality and create a
workforce that is not skilled to cope with future workplace demands.
The VET sector over the past decade has argued against ‘time’ and ‘quantity’ in relation to setting
benchmarks for work placement and volume of tasks to be completed before becoming competent
and as a result, training packages have systematically become vague. It was successfully argued that
competency can be determined, irrespective of where the learner gained their skills and knowledge.
This definition should be applied primarily for students undertaking an RPL assessment. New
workers to an industry and job role, should have clearly defined outcomes that need to be met, as
determined by industry. ASQA would therefore have the ability to take action against RTOs that
could not demonstrate that their learners, for example, did not undertake work placement. It is
perplexing how students are awarded qualifications in the VET sector without ever having
participated in a workplace. Simulations are an important tool, however only form part of a quality
learning experience.
If the VET sector quantified assessment requirements in terms of quantity (something tangible that
could be measured), many of the issues facing the sector would be alleviated and would assist the
regulator in compliance. For example, in the new Certificate III in Individual Support, a core unit
cannot be awarded without having completed work placement. Previously, the aged care industry
was inundated with graduates who had never been in an aged care facility or worked with an older
person. Yet, graduates could be awarded the Certificate III in Aged Care. Industry, supported by the
former ISC, mandated the hours of placement against a core unit of competency. Whilst this
measure was not supported unanimously throughout industry, due to an increase in demand back
on industry for placement, it was determined that this measure had to be taken to improve the
quality of the assessment process.
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If all qualifications determined against a core unit of competency, a defined amount of work
placement and defined the number of times a task had to be undertaken competently, this would
solve the majority of issues the sector is facing. For example, the learner must demonstrate personal
care on a defined number of residents.
Currently the system supports the issuing of a diploma after two days of study (and it’s advertised no
previous experience necessary) and issues a qualification without any practical experience. The
current system fails the industries in which it is meant to be preparing a workforce for. There is a
need to get back to basics to ensure a graduate is fully qualified and work ready.
Government, through its open competition policies, has forced the sector to a ‘race to the bottom’.
To elaborate, by driving down the cost of training, the VET sector has RTOs offering Certificate III’s
for $9.00, however no supervised work placement can occur for this price. It would more than likely
be totally delivered on-line, with the student left to organise their own placement.
For real change to occur, with the inclusion of prescribed work placement, funding needs to support
quality training and assessment. It is unrealistic to expect industry to completely supervise novice
students (particularly in an aged care environment). RTOs should be funded and supported to
include workplace supervision (or clinical placement) to allow for workplace learning and workplace
assessment and observations to occur.
On an aside, industry will largely determine which RTOs they will support for placement etc. It is up
to the RTO to work with industry to determine the best possible programs to suit the learner and the
workplace.
Would a more prescriptive condition of registration, such as a requirement for RTOs
to retain all assessment samples for a longer period, improve the quality of
assessment?
Assessments should be kept for a minimum of the registration period e.g. five years. An RTO can
produce sound assessment items at audit if the RTO has only been required to demonstrate
compliance for 12 months. This measure should be adopted as best practice however is unlikely to
produce the result of quality assessment if the other measures discussed above are not
implemented.
How could the focus of regulation move to evaluating assessment outputs, such as
samples of students’ assessment pieces, without incurring excessive costs or imposing
excessive burden on RTOs?
 Is ASQA the appropriate regulator to oversee this function, or are there better placed
agencies such as firms that specialise in assessing students?
The regulation of assessment should remain with ASQA.
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Are there other mechanisms that you would like to see added to the regulatory
framework to prevent poor assessment? For example, should training-only RTOs be
recognised as a formal part of the regulatory framework?
LASA contends there would be no need for training-only RTOs if the assessment requirements were
non-negotiable and consistently implemented.
12.
Enforcement
How could the focus of regulation move to evaluating assessment outputs?
The focus of regulation at present is squarely on assessment. Outputs can only be measured by
industry feedback.
On another issue, it would be advantageous to all industries if the same focus on learning could be
applied. The VET sector seems to be focussed only on assessment and compliance. What has
happened to learning? Should we not apply the same rigour to the students learning experience? It
would seem the VET system has lost the art of teaching.
Which additional regulatory enforcement options should be considered in dealing
with RTOs providing inadequate assessment? For example, should the regulator have
an explicit administrative power to require a RTO to arrange and fund external
reassessment, or should additional civil penalty provisions be created?
LASA supports both suggestions. It is preferred that strategies be implemented such as described
above on a case by case scenario. It would be unfair, unjust and unreasonable to implement some of
the strategies discussed in this paper to all RTOs.
To what extent should the characteristics of the RTO influence the response? Should
the size of the RTO or the number of students involved matter?
LASA suggests that the size of an RTO is irrelevant. Learning should be of a consistently high level
whether the RTO has 100 or 1000 students. The determining factor should be based on past
performance and non-compliances of the RTO.
Given the need to balance procedural fairness with swift and effective enforcement
action, what methods should be available to the regulator to manage RTOs that are
repeatedly non-compliant with assessment requirements? How could such repeat
offenders be defined?
Like any other ‘certification type’ activity LASA suggests that all RTOs must comply with a set of
standards. Where there is non-compliance found then the regulator should have the power to
suspend all or some activities depending on the seriousness of the breach. A risk approach must be
considered.
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What role should regulators have in communicating their activities and findings? Does
current regulatory practice provide adequate transparency and disclosure, or are
there other approaches that should be taken?
LASA is supportive of the current ASQA communication practices.
13.
Cancellation and reassessment
Where inadequate assessment has occurred, should the power to cancel
qualifications be exercised more frequently than it has in the past? What factors
should affect this decision (for example, potential impact on public safety) and how
should they be balanced?
This strategy would need to be carefully considered. If an RTO was found to be in serious breach,
immediate action should be taken to remove current students, provide gap training for previous
study and support the student through a transition to another RTO. High-risk qualifications,
discussed previously, would be the logical starting point for this type of strategy. However, the
learner becomes the victim of the VET system. Who will fund a student’s reassessment and
potentially a student’s learning for gap training?
Should a scheme for the reassessment of students be implemented?
If so:
 Are there any situations where a student should not be offered the chance to be
reassessed, for example, student fraud?
 Should there be a time period after which ASQA should not move to cancel an individual’s
qualification? Noting potential public and other safety issues, should a decision to cancel
consider whether or not the person involved is reliant on the qualification for their
current employment?
 Who should bear the cost of reassessment and any gap training found to be necessary? If
the cost is to be recovered from the RTO, should this be pursued regardless of the RTOs
financial viability?
 Who should deliver the reassessment? Are there any circumstances in which it would be
appropriate for the original RTO to undertake the reassessment?
 What should the qualifications be for those doing the reassessment, and what industry
experience and currency would they need? To what extent should ASQA, industry or
employers be directly involved in the reassessment process?
Student fraud should be determined as gross misconduct and there should be a clear policy and
procedure at the RTO level in dealing with such events.
Cancelling an individual’s qualification is serious and should be based on significant evidence of noncompliance. Other strategies should be implemented before such action is taken. Time is irrelevant;
the impact on the learner is what should be considered first and foremost.
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The offending RTO should fund any reassessment. If the RTO is no longer financially viable,
government may need to support the process. It would be extremely unfair to expect the individual
to incur the cost.
If the breaches were significant enough to warrant the cancelling of qualifications, the offending RTO
should absolutely not have anything else further to do with the process.
Reassessment should be conducted by another RTO with the qualification on scope by competent
and current trainers/assessors.
Should a tuition assurance fund be set up to further protect students in Australia’s
VET sector, particularly in the context of any scheme of reassessment or cancellation
of qualifications? Should membership be mandatory for all RTOs? Who should
operate such a fund, and who should bear the cost of its operation?
LASA supports this strategy noting it would need to be mandatory; possibly funded by a joint
contribution from government and membership fees.
What linkages with income support eligibility should apply for graduates impacted by
any recall of qualifications?
If a graduate was the victim of a qualification recall; and the qualification was a pre-requisite for
their current employment, consideration would need to be given as to how this person was to be
supported both by the workplace and financially through government until such a time that they
could be re-trained.