North Coast TAFE
Institute Council
Institute Council Secretariat
Institute Office, Hindman Street
PO Box 528 Port Macquarie
NSW 2444
p: (02) 6586 2219
f: (02) 6586 2344
The North Coast TAFE Institute Council welcomes the opportunity to provide the attached response on
selected recommendations in the report “A Shared Responsibility - Apprenticeship Reform”. Our response
endorses the Expert Panel’s call for a simpler system which better supports employers and apprentices and
more strategically targets government incentives. It also highlights those recommendations that have
potential to adversely affect regional areas and SMEs and suggests some alternative ways forward.
The Council is an independent advisory body for TAFE services in the North Coast region of NSW. The
Council advises the management team and Minister on aligning TAFE services with the skill needs of
regional industries, communities, disadvantaged groups, other education sectors and stakeholders and
comprises 13 industry and community members and the Institute Director as an ex-officio member.
Our input to this consultation is informed by Council’s knowledge of TAFE’s extensive delivery of on and offthe-job training services for apprenticeships and traineeships in and beyond our region, and by intelligence
from our industry, community, student and staff constituencies. But, just as TAFE is a comprehensive
education and training provider that is more than just an RTO, our input provides much more than an RTO
perspective. The Council includes members with experience in apprenticeships and traineeships as
employers, HR professionals and group training provider for industries as diverse as resources, children
services, aged care, meat processing, construction and transport, metals, manufacturing, electrical, local
government, finance and customer service, hospitality and administration.
Our input is shaped also by our view that current arrangements and some of the report’s recommendations
often overlook the needs of SME employers, apprentices, trainees, RTOs and other service providers in rural
and regional areas – needs that reflect size, capacity, dispersal and distance, thin markets, regional skills
needs and other local factors that may not be visible in broad brush state and national trends or in planned
responses to them.
Our members also bring to this exercise their experiences, not only in the North Coast, but from the Hunter
and other NSW regional areas, Western Sydney and SE Queensland. Therefore we provide the attached
comments and suggested improvements for the system in the hope that they might assist in designing new
arrangements that are responsive and flexible enough for the varied needs of enterprises, communities and
service providers in metropolitan and non-metropolitan areas.
On behalf of the Council, I welcome the opportunity for this input to the apprenticeship reform process and
would be pleased to arrange for these matters to be discussed further with our members. I can be
contacted on 0400 441 976 or via the Council’s Executive Officer, Joy Corben on 65862215.
Yours sincerely
Warren Grimshaw AM
Chair, North Coast TAFE Institute Council
8 April 2011
North Coast TAFE Institute Council
A Shared Responsibility - Apprenticeships for the 21st century: Response to
selected questions on the Expert Panel’s final report
Support required by apprentice/trainees or employers before, at commencement, or while
progressing through a traineeship.
1. A distributed, locally responsive, easily accessible support service is needed at all stages of the process.
Efforts to drive competition and efficiency in the current system have created conditions encouraging
multiple intermediaries to compete unproductively to deliver minimal support services into regions
where they have a limited, if any, physical presence or long term experience or commitment. This
undermines the quality of support, customer service and communication for all players in the system.
2. Though financial incentives information is well-promulgated, there is evidence that the system is so
multi-layered and dispersed that most employers are not aware of other useful support services and
tools funded by the Commonwealth and States to support apprentice and trainee progression and
completion. Providing a single, visible, genuine local one-stop shop (see point 3 in the section below)
would lead to better communication and cost-effective services and provide a base from which quality
mentoring and support for employers and apprentices could be delivered.
More harmonised and less confusing regulatory, support and mentoring arrangements
1. We agree with the Expert Panel’s finding that the system is too complex and confusing and its
identification of some areas requiring attention. These include the need for harmonisation of
arrangements between States and use of common terminology. A return to the distinction between
“apprenticeships” and “traineeships” and ceasing use of the term “Australian Apprenticeships” would
be a very easy and welcome first step.
2. We support national harmonisation of regulation and standards for the system, consistent with activity
underway in legislation and regulation across a broad range of areas impacting on industry and
employment. We see that an ongoing collaborative national mechanism will be necessary to achieve.
However, if the role of a “national custodian” was to develop and enforce a single regulatory system ,
this could work against the simpler, more flexible system needed to respond quickly to changing
enterprise, industry and regional needs and to interact with state-based industry frameworks and
awards.
3. The provision of AAC services requires attention. In some of our regional towns three or four AAC
providers have a physical presence. In others there is none. There can be role confusion where some
have related training services arms and consistent feedback from employers that the process is
complex and cluttered. Simplicity, transparency and “shared responsibility” may be served better by
the Commonwealth either:


Contracting State industry training service agencies to provide a simple, single state-wide AAC
service alongside their other industry advice, support and regulatory roles; or
Establishing a fully on-line service for those AAC services that are mainly administrative in nature,
similar to that provided by the ATO for tax returns, complemented by a phone hotline help desk
service for those needing personal assistance.
Either option (or a combination) would remove one layer from the system and should provide synergies
and some cost-savings that could be redirected to higher priorities in the system.
4. We would have liked to have seen more attention in the report to Group Training. GTOs achieve well
above State and National apprenticeship completion rates and actually supply much of the “after sign
up” advice and support that is part of the AAC arrangements. If GTOs were paid for these services and
passed those savings onto employers both apprentice numbers and completions would increase.
In a tight fiscal environment, how should Government target assistance to the Australian
Apprenticeship System to support a skilled economy – ensuring apprenticeships and
traineeships are affordable and a truly shared responsibility?
1. We caution against a broad-brush national industry sector approach in targeting or tightening employer
and training incentives. There can be significant differences between regions in the skill needs that are
of vital economic importance. For example, in addition to the trade skill shortages being experienced
nationally, our region has ongoing needs for new entrant trainees in areas such as aged care, meat
processing, dairying, production horticulture and accommodation and hospitality services, areas that
may not meet any new test of “national economic significance” for targeting apprentice and
traineeship incentives. However, they are vital regional industries and employer incentives are essential
to the apprentice/trainee employment capacity of small regional enterprises in these sectors, and in
other sectors such as construction, engineering, children’s services, retail and business services. A
regionally responsive approach to targeted funding for training places is equally vital (see point 4).
2. Inequities in rural, regional and disadvantaged areas – and between industries experiencing a higher
level of need - will become more entrenched unless the incentive regime is redesigned to direct
resources to those that need it most and away from those who have a capacity to take more
responsibility. The Expert Panel’s report and previous reviews could have given more consideration to
the question of how large companies might take on a greater burden of cost. However, very large
companies and their in-house RTOs have much more capacity to absorb reductions in apprentice and
trainee incentives without undermining their capacity to employ, train or support apprentices and
trainees. Similarly, whilst acknowledging trades skill shortages in the resources sector, we hear of large
companies in the sector paying well above award wages to apprentices and tradespeople, exacerbating
the problems that regional SMEs here and elsewhere have in attracting and retaining trade apprentices
3. National and multi-national companies make a major contribution to our national and regional
economies so any reduction in apprentice and trainee incentives would need to be carefully worked
through. However, if large enterprises were able to take on more responsibility, resources could be
directed to support better wage subsidies for smaller and regional enterprises with less capacity and to
provide them and their apprentices/trainees with the better support services to improve quality and
completions. Arguably large enterprises have much greater capacity to provide these support services
in-house through their supervisory structure and training and development units.
4. Despite high levels of unemployment in rural and regional areas, many experience ongoing or cyclical
shortages of trades and other skilled staff. Whilst PPP and critical skills funding has sought to address
this issue, central planning of such programs often leads to a mismatch between program priorities and
regional SME skills needs, for both new entrants and existing workers. Industry and trade skill shortage
cycles can also differ between regions. For these reasons we have significant reservations about the
Expert Panel’s suggestion for Government support for apprentices and trainees to be re-focussed on a
set of national priority occupations, and suggest instead that priorities be identified collaboratively by
industry, training and economic development stakeholders at a regional level. The Regional
Development Australia network may be well placed to facilitate this process.
5. The system needs to provide incentives for players to work strategically and collaboratively with
others with a long term interest in the ongoing supply of apprentices and other skilled labour in
the region. Funding reform in both the VET and job services markets would assist. A good start
would be some guaranteed growth funding for TAFE, the public provider uniquely equipped to
support sustained regional collaborative efforts, rather than rely primarily on competitive
mechanisms to achieve growth and short term fixes. Tendering guidelines for employment and
training market intermediaries could also require them to commit a % of their revenue to
collaborative initiatives with industry bodies, enterprise clusters, group training and RTOs. These
approaches could stimulate new pre-apprenticeship, apprentice and trainee opportunities in areas
aligned with regional skills needs and support better outcomes and completions.
RTOs, governments, industry organisations and employers working better together to
deliver high quality on and off-the-job-training
1. The Expert Panel’s call for better and more integrated on and off-the-job training and support to
improve quality and completions is welcome. However, the proposed accreditation scheme for
employers would be a considerable burden that would discourage micro, small and medium enterprises
from employing apprentices and trainees. SMEs are major employers of apprentices and trainees
Australia-wide and our regional employers are mostly in this category. For similar reasons we agreed
with the Government’s early decision to reject the proposed Employer Contribution Scheme, which
SMEs could not have absorbed.
2. We support the need that the panel identified to redirect resources to provide more frequent and
structured support for apprentices, trainees and their SME employers and see this as a value-added
service that they could purchase from their RTO or Group Training Company. We disagree that this
should be resourced from an across-the-board redirection of incentive payments, and have identified
above some alternatives: i.e. synergies/savings from contracting State training agencies to integrate
AAC services into regulatory services and/or moving some administrative services online; reducing
apprentice/trainee wage subsidies for large companies with capacity to pay; reductions in subsidies for
large enterprise RTOs; redirecting some AAC funding to subsidising GTC mentoring and support services
to make GTCs (with their proven higher completion outcomes) a more cost-attractive option for
employers.
3. Our regional employers would echo the strong support that the Expert Panel heard for a return to more
Government support for institutional pre-apprenticeship programs to achieve job readiness. Though
recent NCVER research suggests minimal difference in completion of apprenticeships for those who
have or haven’t completed a pre-apprenticeship program, they are nevertheless invaluable in preemployment preparation, screening and decision-making and creating apprentices who can be safe and
productive from day one.
Pre-apprenticeship programs are a particularly valuable support for small enterprises, especially in
regional areas, that are limited in their on-job training capacity, and also for ensuring a continuing
supply of partially trained apprentices during times of cyclical downturns in the construction and other
industries, to fill the gap when employers do not have enough work to take on apprentices. They are
also critical in engaging and supporting the disadvantaged and those most disconnected from
educational and employment opportunities in the system (see next section).
4. Some traineeship and apprenticeship areas, especially in service industries, are highly suited to a
complete on-the-job arrangement supported by in-house or mobile trainers and assessors and North
Coast TAFE successfully supports such arrangements both within the region and for some state and
national business clients, as do other high quality RTOs. However, providing accredited training
completely on-the-job lowers the entry threshold for RTOs into new regions and program areas leading,
at times, to unproductive competition in thin markets and doubtful quality in some RTOs. We suggest
that this is a high risk area that the new VET national regulatory arrangements could pay some
attention to.
5. Quality training for apprentices and trainees in “traditional trades” is often less suited to a total on-thejob model and is best supported by commitment to a more equal sharing of responsibility for training
between RTOs and employers. We have been particularly pleased to see the development of an
exemplary shared responsibility model involving North Coast TAFE partnering with the heavy vehicle
industry, to respond to a need identified in a community forum facilitated by our Institute Council
several years ago. TAFE and a regional heavy vehicle enterprise that identified the need collaborated in
developing and engaging other enterprises in the model.
Apprentices who previously needed to travel to another region to access expensive, specialist TAFE
heavy vehicle training facilities in a block release arrangement, now undertake their first year day
release off-the-job training at their local campus with other automotive apprentices and complete the
remaining two years of training on-the-job supported by a mobile TAFE teacher and workplace
mentors. In this model the RTO takes responsibility for the staff, facilities, equipment and consumables
needed for the initial training of the apprentice in the basic technical and generic competencies, a
responsibility that many employers and workplace supervisors cannot allocate sufficient time or
resources for. The success of the model equally relies on industry taking responsibility for providing upto-date facilities, equipment and consumables and, most essentially, the committed workplace mentors
needed to ensure high quality, enterprise-relevant training in the second and third years.
How should disadvantaged individuals be supported to engage in apprenticeships and
traineeships?
1. A common impediment to engagement of those from rural areas and other disadvantaged backgrounds
is a mismatch between the level of job-ready knowledge and skills sought by apprentice/trainee
employers and the basic knowledge and skills of the potential trainee/apprentice. Pre-apprenticeship
options are particularly suited for those from disadvantaged backgrounds who may have limited
industry knowledge or connections or need to develop LLN skills in an applied context.
2. Experience in our region shows that outcomes for disadvantaged individuals are enhanced when JSAs,
AACs and GTCs are willing to purchase an integrated, personalised VET support service for specific
clients, or where market intermediaries fund additional pre-vocational training places that help prepare
youth-at-risk or displaced workers to become job-ready for local enterprises with potential apprentices
or trainees opportunities. Revised contracting arrangements for such market intermediaries could
include incentives and accountabilities to collaborate as funding partners with RTOs to engage and
support disadvantaged clients to become successful apprentices and trainees.
3. A recent NVEAC Briefing on Foundations Skills and the Industry Skills Council’s No More Excuses report
noted there is variable quality in the capability of some RTOs and VET practitioners in developing and
supporting foundation skills. We suggest that any proposed national standards for the apprenticeship
and traineeship system emphasise that State and Territory user choice tendering arrangements require
that RTOs provide evidence of capability in the area of foundation skills. There may also be a need to
re-examine how funding is provided for WELL and other LLN programs and for developing VET
workforce capability in this area.
4. As a more innovative and pro-active measure, approved provider arrangements could be established
to direct funding to training providers, such as TAFE, who have a proven capacity to provide effective
“one-stop shop” support services to disadvantaged apprentices and trainees, including youth at risk,
indigenous students and those with learning and other disabilities. This approach would support a more
comprehensive, personalised service at commencement and to continue the extra support as the
apprentice/trainee progresses to completion.
Alternatively, revised arrangements could shift to a targeted apprentice entitlement model, where the
individual has a “support services account.”
What are the barriers to widespread adoption of competency-based progression in apprenticeships and
traineeship and how can these barriers be overcome?
1. We have discussed this matter several times in our Institute Council meetings. The issues are complex
due to the many and competing needs and priorities of all players in the system - employers,
apprentices, RTOs, intermediaries and funding bodies. The major area of difference seems not so much
about competency based progression as a concept, but rather that it is being used solely to fast-track
apprenticeship and traineeship completion. While this may be attractive financially for apprentices,
trainees, RTOs and funding bodies, many employers feel that they only start to get a return on the
investment, especially for apprentices, towards the end of the training period.
2. At the level of the individual arrangement, the only way to work through this fundamental difference is
for the RTO, the employer and the apprentice/trainee to communicate more clearly at commencement
and during progression about their respective needs and expectations and the implications of early sign
off units of competency or the whole qualification. The revised AAC arrangements would have an
important role in facilitating this communication. At the system level, there may be ways that incentive
mechanisms could be adjusted to balance these competing priorities.
3. This is also an area that could be advanced through revisiting, yet again, what evidence of competency
means for all parties. Our advice is that employers are concerned not only about financial implications
of an early completion but that their apprentice or trainee can do, reflect on, integrate and
continuously improve on the skills specified in the units of competency comprising the qualification,
and can do so over a sustained period in the workplace. Achieving this calls for attention to developing
the required underpinning knowledge, a reflective approach to teaching, learning and assessment and,
not least, time. This could mean raising the quality bar for all RTOs.