The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42
Submission to
The Australian Senate
In response to:
The Inquiry into the Operation, Regulation and Funding of Private Vocational Education and
Training (VET) Providers in Australia.
13 February 2015
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© E-Oz Energy Skills Australia 2015

The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42
Introduction
E-Oz Energy Skills Australia (E-Oz) is the Industry Skills Council (ISC) for ElectroComms and Energy
Utilities industries - the Energy Sector. In consultation with Industry, industry regulators, VET regulators, registered training organisations (RTOs) and Commonwealth, State and Territory government agencies, E-Oz develops and maintains a suite of four nationally endorsed Training
Packages which cover the Electrotechnology, Electricity Supply (Transmission, Distribution and Rail),
Electricity Generation and Gas Transmission and Distribution sectors.
To carry out this work E-Oz provides services to industry and other stakeholders to develop, manage and maintain 121 endorsed qualifications from AQF level 1 to AQF level 6 and the 1121 individual industry developed units of competency which comprise these qualifications. E-Oz also manages the
527 units imported into the qualifications it manages from other Training Packages.
Engagement with All categories of Registered Training Organisations
The characteristics of the industries E-Oz covers include:
 high levels of regulation and licencing to ensure public, individual and asset safety

Mandated compliance with technical standards; and

The need to address low volume, technical specialisations in essential services and high risk work.
These characteristics mean that the Industry and E-Oz as its Skills Council must engage with all classes of Registered Training Organisations (RTOs) including large publicly and privately owned
RTOs offering a range of qualifications, Enterprise RTOs operated by Energy Networks delivering skills for their own workforce and small specialist private RTOs providing a limited range, of sometimes unique and highly valuable skills.
Private RTOs operating servicing the Energy Sector vary in both size (number of enrolments) and coverage (number of qualifications). However the majority of these operate mainly within the sector with some offering training in allied trades.
It should not be assumed that RTOs with limited enrolments and/or limited units or qualifications on their scope of registration are of lesser quality. In the energy sector some such organisations have very high reputations nationally and in some cases internationally.
Funding Models and Competition
Since the inception of Training Packages, training delivery has been an increasingly competitive market and the various funding models implemented by State and Territory governments from time to time combined with various initiatives by the Commonwealth have had a strong influence on the development of private RTOs.
The majority of training provision in the Energy Sector industries is via Australian apprenticeships for trade qualification which are jointly funded and managed by Commonwealth and State and Territory government.
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© E-Oz Energy Skills Australia 2015

The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42
Other training is funded by various mechanisms including individual or enterprise purchase, traineeships, cadetships, State/Territory based training entitlements and joint government/enterprise funding via schemes such as the National Workforce Development Fund and more recently VET Fee Help and the Industry Skills Fund.
Supply and demand shifts combined with the various funding initiatives and cost price pressure have increased competition in the VET market place, particularly in the face of ongoing reductions in direct funding of public RTOs. In most jurisdictions competition between public and private providers in direct and on equal terms.
State and Territory governments are increasing applying scarce resources to the targeted funding of priority qualifications including those where skill shortages have been identified, leaving other qualifications to be funded by individual and/or enterprise expense.
This means that RTOs are increasingly attuned to seeking efficiencies and maximising returns and also to developing market strategies to deliver training which is no longer publicly funded.
Accompanying these changes there has also been ongoing amendments to Training Package components, increased flexibility in qualification design and review and codification of VET regulatory frameworks with the aim of improving the quality and consistency of delivery and services to students and industry.
Engagement with Registered Training Organisations
E-Oz engages with Registered Training Organisations of all type across of its activities including the development and continuous improvement of Training Package components, the support of Training
Implementation and the provision of advice to stakeholders including government agencies, employers, industry and regulators, industry associations and individuals and their families on
Training Package and training services matters. E-Oz provides stakeholders with generic information and also with specific advice in response to specific enquiries.
This places E-Oz in a somewhat unique position as it receives requests for information and advice on training and Training Package matters from a wide variety of stakeholders and is able to either develop specific advice, refer to other information sources or direct the enquiry to a third party.
In addition to direct engagement with RTOs on Training Package development and maintenance issues, stakeholder engagement to support Training Packages and assist with their implementation involves a range of activities which lead to contact with RTOs, including:

Advice to industry and individuals on training providers able to deliver specific units, Skill
Sets and/or qualifications

Advice to industry regulators on compliance issues and interpretation of Training Package and related matters such as Trainer/Assessor competency requirements for a given unit or qualification.

Advice to VET regulators on the interpretation of Training Packages in relation to RTO compliance, resources, Trainer/Assessor competency requirements and assessment tools and evidence requirements
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© E-Oz Energy Skills Australia 2015

The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42

Referral of industry stakeholders, regulators and individuals seeking to resolve issues with
RTOS to relevant authorities/agencies.
E-Oz has positive engagement with many RTOs servicing the industry including private or enterprise operated RTOs, both directly and via various industry or VET focussed organisations including:

National and jurisdictional based Industry peak bodies

State and Territory Industry Training Advisory bodies

Training Package implementation workshops

State and Territory Industry Working Groups

RTO Associations such as: o The Victoria Electrotechnology Senate o The Australia and New Zealand Electrotechnology Training Alliance (ANZETA)
The issues raised below are not intended to indicate widespread malpractice or low quality but to highlight areas where there has been persistent feedback over time about training provision in to the sector.
Issues and Trends
Generally RTOs servicing the Energy Sector industries have responded well to the changes in the VET landscape outlined above.
Whilst there is no significant evidence of the types of exploitation of funding entitlements recently documented in the press across training provision in the energy sector, individuals, industry stakeholders and industry regulators have raised concerns about the practices of some RTOs and other organisations operating in the VET market.

Issuing of statements of completion rather than Statements of Attainment
Under the Australian Qualification Framework, RTOs are permitted to issue statements of attainment for individual units, Skills Sets or partially completed qualification.
In the Energy Sector there is some evidence that some private providers have been enrolling students in units, skill sets or qualification and only providing classroom based/theory training and ignoring the requirement for evidence of work performance needed to issue competency in the units in which the student is enrolled.
Typically these participants receive a certificate of completion of attendance which does not meet
AQF requirements and attest to competency. Participants seeking jobs or credit against other units or qualifications on the basis of these statements of completion are disappointed and frustrated when they become aware that the training they have been given is incomplete and therefore not recognised.
Industry stakeholders and individuals regularly raise cases of this sort with the ISC and in the majority of these private RTOs are involved.
In some cases industry enterprises and/or individuals have referred these matters to VET regulators.
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© E-Oz Energy Skills Australia 2015

The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42
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Enrolments in qualifications with no prospect of completion
In a similar way to the issue of statements of completion, there is some evidence of the enrolment of students where the participant has no prospect of completion.
An informed provider and student should be aware of the requirements for qualification completion and this situation should seldom arise. However E-Oz is aware of situations where enrolments have been taken when it is clear that the prospective student will not be able to complete due to:

Not meeting or being able to meet pre-requisite requirements

Not being employed in the industry or not able to meet work performance requirements

Not being able to meet regulatory or licencing requirements.
Where these cases have become known E-Oz has referred participants and/or their employees to appropriate regulators.

Non RTO brokerages
Another recent trend which has concerned industry participants, industry regulators and individuals is the emergence of non-RTO training and assessment brokerages.
These private companies are not RTOs but actively promote skills recognitions services often with guarantees of qualification outcomes in very short periods of 14 days.
The model is usually based on up-front ‘assessment’ of the customer’s knowledge, skills and experience and an alliance with an RTO to provide Recognition of Prior Learning (RPL) services on the basis of the initial assessment.
E-Oz has had reports of very poor practices from these organisations and industry regulators have expressed concerns at the processes involved and the capacity of graduates of these to competently perform licenced electrical work.
Where complainants have sufficient evidence they have been referred to ASQA as the VET regulator to have the activities of these organisations and associated RTOs investigated for compliance.
The ability of these organisations to remain unregulated and to rapidly re-invent themselves when their practices are exposed is of concern to industry, regulators and reputable RTOs.

RTO promotional activities and qualification requirements and duration
Concerns have been raised with the ISC about the promotional activities and of some RTOs particularly in relation to the accurate description of qualification requirements and the duration of training programs to meet these.
Regulators, industry enterprises and individuals have raised matters of significant disparity amounting many weeks or months between RTOs offering training programs in the same qualification.
It should be noted that on some occasions the fees for shorter programs are as high or in some cases higher than those of RTOs offering longer duration programs in the same qualification.
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© E-Oz Energy Skills Australia 2015

The operation, regulation and funding of private vocational education and training (VET) providers in Australia
Submission 42
With regard to accurate descriptions of qualifications this often relates to incomplete or inaccurate information regarding pre-requisites, employment and work performance requirements which in some cases attend other issues raised above.
Recommendations
Whilst industry is generally comfortable with the levels of compliance of most RTOs servicing the sector, the high risk nature of work in the energy sector which can impact individuals, enterprises, communities and in worst cases have economy wide impacts means that the highest level of quality and industry confidence in training and assessment of competency must be maintained.
A significant issue in the VET sector is information about quality and quality indicators in a commercially competitive environment. Quality indicators in other education sectors are available and well understood by the consumers.
The VET sector has clearly defined standards expressed via the units of competency and qualifications endorsed in Training Packages. However it is apparent that quality delivery and quality indicators are poorly communicated and understood by consumers including industry enterprises.
In addition to any recommended review of funding models, compliance with VET regulations and the implementation of Training Packages to achieve registration, there should be an emphasis on the establishment of benchmarks for quality outcomes based on the moderation of assessments within and between RTOs combined with industry and regulator feedback.
Establishing such quality indicators based not only on inputs but also taking into account the output from training and assessment via moderation and benchmarking will enable industry enterprises and individuals to make better choices of training provider and induce lower performing RTOs, whether publicly or privately held, to provide a high quality service in a competitive market.
© E-Oz Energy Skills Australia 2015
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