INDUSTRY TRAINING REVIEW:
Summary of submissions received
on the Consultation Document Proposal to improve the
performance of the Government’s
investment in industry training
1
Table of contents
Table of contents ....................................................................................................................... 2
1. Introduction and background ................................................................................................. 3
2. ITO functions and roles .......................................................................................................... 8
QUESTION 1 Arranging training and clarifying expectations.............................................. 9
QUESTION 3 Increasing expectations of completions ...................................................... 16
QUESTION 4 Skills leadership ........................................................................................... 22
3. Apprenticeships and traineeships: definitions and funding ................................................. 30
QUESTION 5 Higher subsidies for apprenticeships ........................................................ 31
QUESTION 6 Extending apprenticeship support .............................................................. 37
QUESTION 7 Options for apprenticeship co-ordination fee.............................................. 40
4. Industry training at higher levels and transferability across sectors .................................... 46
QUESTION 8 Increasing training at levels 5 and 6 ............................................................ 46
QUESTION 9 Transferring between tertiary sectors .......................................................... 50
5. Quality assurance ................................................................................................................ 55
QUESTION 2 Standard settings ........................................................................................ 56
QUESTION 10 External moderation and managing consistency of graduate outcomes .. 61
QUESTION 11 Quality assurance settings ........................................................................ 67
Appendix: Submissions received ............................................... Error! Bookmark not defined.
2
1. Introduction and background
1.
On 1 August 2012, as part of the ongoing policy review of industry training, a
consultation proposal was circulated for public comment. The proposal:

clarified the roles of Industry Training Organisations (ITOs)

increased the performance expected from ITOs

linked industry training to employment and education work-streams to
strengthen the dynamics between education, employment and industry

enabled learners to transition more easily between employment based
and other types of training.
To guide feedback the consultation paper asked submitters 11 specific questions
about the proposed changes to industry training.
2.
We have grouped the proposed changes in the consultation document into the
following areas:

ITO functions and roles

apprenticeships and traineeships: definitions and funding

industry training at higher levels and transferability across sectors

quality assurance.
The remaining sections of this report briefly outline the proposals in each area
and summarise the feedback.
3.
Consultation closed on Wednesday, 12 September 2012. A total of 332
submissions were received from:

187 employers (189 submissions)

54 industry associations

23 ITOs (including the Industry Training Federation)

25 tertiary providers (including peak bodies)

9 independent Modern Apprenticeship Coordinators (MACs)

32 other submitters.
Overall summary of responses
4.
Responses to the consultation document generally supported the proposals.
3
5.
The proposal outlining options for the apprenticeship coordination fee was the
most contentious. Most independent MACs were strongly against both proposals
to change the funding rates. The MACs contend the proposed changes would
give ITOs a monopoly of modern apprenticeship coordination and eliminate
independent MACs.
6.
The proposal to open up skills leadership to non-ITO organisations also caused
some controversy. Most employers’ submissions were against this proposal,
while there was only mixed support from industry associations. However, this
may have been because the intent of the question was misinterpreted by some
submitters as removing the skills leadership function from ITOs, whereas the
purpose of the proposal was to open up skills leadership to other organisations.
7.
Some of the issues raised, such as implementing a working group on the
governance of ITOs, were outside the scope of the proposals in the consultation
document.
8.
Although we endeavour to provide some evidence of the number of submitters
supporting different proposals or voicing the same argument, some caution
needs to be taken in interpreting these numbers. Many responders made
submissions on one or two proposals only, so the number of responders on
many proposals is smaller than the number of non-responders. In addition, of the
189 submissions from employers, 130 came from Competenz-linked employers.
Most of these employers made submissions on a standard form letter provided
by Competenz. The views of Competenz-linked employers may not be
representative of the employers’ views more generally.
Employers
9.
Responses were received from a wide variety of employers ranging from large
employers with more than 600 employees, to small-owner operators. Employers
who responded operate in a variety of industries including construction, care,
dairy, energy, engineering, food, maritime, service, tourism, and hospitality.
10. In general, employers supported the proposals. However, they detailed the
following areas of concern:

the importance of aligning training with industry requirements

the lack of recognition of the in-kind costs employers bear in training

the importance of retaining current levels of funding for levels 2 and 3 as
employers were concerned focus on higher-level qualifications may
marginalise foundation levels
Industry Associations
11. There were 54 industry association submissions.
12. Industry associations support ITOs retaining arranging training. They state strong
support for ITOs being responsive to industry and being recognised and
incentivised for this.
13. Industry associations support increased completion targets. However, they were
concerned higher completions should not be at the expense of lower level
4
qualifications. They stressed it was important levels 1-3 qualifications retain their
importance and that there will be no decrease in quantity or funding of these.
Moreover, the measures adopted for measuring completions should be linked to
industry.
14. Industry associations expressed mixed feedback on the skills leadership function
proposal. Some support the proposal to make skills leadership more industry
focused, while others think ITOs should retain this role or advocate a
combination of industry and ITO responsibility for skills leadership.
15. There is widespread support for introducing a higher apprenticeship subsidy rate.
Industry associations also strongly support extending apprenticeship support to
all apprentices, but this should be balanced with protecting youth involvement in
the scheme.
16. Industry associations were split over whether they favoured an incorporated
apprenticeship co-ordination fee or a separate fee. An incorporated fee is seen
as easy to administer and more cost effective, but there is a concern how this
would affect transparency and independent MACs.
17. Industry associations generally support allowing a greater volume of industry
training at levels 5 and 6 and increased transferability for learners.
18. Industry associations hold a range of views on how external moderation should
be conducted and how to manage the consistency of graduate outcomes. In
general, industry associations agree that the whole training system is dependent
on high quality, consistent moderation and the moderation system must therefore
be simple, robust and reliable. There is also general support for a common
currency of learning and skills.
Industry Training Organisations
19. There are 23 ITO submissions. ITOs are generally supportive of the overall
direction of the proposed changes.
20. The main points ITOs raised include:

ITOs strongly support themselves retaining the functions of arranging
training and setting standards.

ITOs strongly indicate that they do not wish to lose the skills leadership
role. They want to remain involved in this role, either in partnership with
industry or retaining complete responsibility for this function.

ITOs want to ensure that any changes in completion targets are industryled and meet industry needs. They suggest flexibility of targets to take
into account the realities of industry work flow including different learning
situations and learner groups.

ITOs support increased funding for industry training. They also strongly
support developing a simple, clear definition of what an apprenticeship is.

ITOs are generally supportive of increasing provision at levels 5 and 6.
However, many question why a cap is needed, at all.
5

ITOs are generally supportive of recognising completions for learners
who transfer between tertiary sectors. However, many ask how this will
work in practice.

ITOs agreed that consistency in qualification outcomes in individual
standards is important and that at least some external moderation needs
to be retained to ensure industry confidence in the system. However,
there were a range of views on how external moderation should be
conducted and how to manage the consistency of graduate outcomes.
There was also general support for a common currency of learning and
skills.
Tertiary Providers
21. There were 25 submissions from tertiary providers.
22. Providers maintain there is the need for a clear distinction between what
constitutes ‘arranging’ and ‘delivering’ training. They were concerned that ITOs
circumvent the rules restricting them from delivering training.
23. There was mixed feedback on whether ITOs should retain their role as standard
setters because of the conflict of interest between ITOs not only setting
standards, but also arranging training.
24. Providers generally supported the other proposals. They support a review of unit
standards and suggest uptake of unit standards is currently limited by factors
such as unit standards being too task specific or detailed. A common currency
was also widely supported as this would benefit employers by ensuring more
accurate expectations of what an employee can bring to the workplace.
Independent Modern Apprenticeship Coordinators
25. Nine independent modern apprenticeship
submissions on the consultation document.
coordinators
(MACs)
made
26. The greatest concerns of the MACs were with the proposal 7, options for the
apprenticeship coordination fee. Most MACs rejected both options proposed, as
they considered this would give ITOs a monopoly of modern apprenticeship
coordination and eliminate independent MACs. They argued this proposal was
inadequate given the poor performance of many ITOs and previous
accountability concerns over their performance.
27. Responses to other questions also reflected independent MACs concerns over
poor performance and accountability of ITOs. In the view of many MACs, ITOs
focus on minimising cost and maximising revenue, rather than on supporting
quality training. Given the poor past performance of ITOs some MACs
questioned whether ITOs should retain their arranging training role. Although
there was some support for additional funding of apprenticeships, there was also
concern over how of this funding would be spent by ITOs.
Other submitters
28. There were 32 submissions from other organisations or individuals. These came
from a wide variety of submitters, including central and local government
6
agencies, consultants, unions, Crown entities, and private individuals. Eight of
these submissions primarily address training for emergency management
personnel.
29. There are few over-arching themes from submitters in this category. However,
many submitters did indicate their overall support for the directions outlined in the
proposals. One theme that did emerge across questions was the value placed on
training at levels 1-2. There is strong support for ensuring that any changes to
the current system do not undermine provision and quality at this level.
Emergency management
30. There are serious concerns about whether the proposals meet the needs of a
coordinated emergency management sector. Submitters stated that the
proposals do not take into account that in emergency management the majority
of trainees are volunteers and their service provides a public good to the
community. The aim and types of training are also different compared to
workplace training generally is the focus of training is not to increase productivity,
but to ensure they are ready for action in the event of an emergency.
31. Several of the submitters support Emergency Management Qualifications’
(EMQUAL) proposal for the creation of standard setting bodies alongside ITOs.
These bodies would align training standards, but have no responsibility for
arranging and delivering training. Seven submitters support EMQUAL as the best
organisation for this role.
7
2. ITO functions and roles
Proposals
ITOs focus on providing excellent service and support to employers and trainees.
Higher expectations of qualification and programme completions for ITOs.
Industry will be responsible for communicating skill needs to Government, with
support from the Ministry of Business, Innovation and Employment (MBIE) and the
Tertiary Education Commission (TEC).
Overall
32. Most submitters agree with clarifying expectations of service to employers and
trainees of ITOs. It is felt this would help to improve the consistency of
performance and accountability.
33. In general, submitters support ITOs retaining their function of arranging training.
ITOs are seen as best placed to arrange training due to their industry focus and
institutional knowledge.
34. Providers and employers commented that the main risks of this proposal relate to
the variability of service between ITOs and the extent of ITO coverage across
industries and geographical locations. Some MACs questioned whether ITOs
should retain their function of arranging training given their previous poor
performance.
35. ITOs claim that defining too narrowly services and support could stifle innovation
and flexibility.
36. A higher completion expectation for ITOs is also well supported. Submitters state
that this would provide many benefits including improving returns on investments
in industry training, increasing skill levels and encouraging improved cooperation
between ITOs and tertiary providers.
37. Industry associations, employers, tertiary providers and ITOs all express concern
that an emphasis on higher-level qualifications might marginalise levels 1 and 2
qualifications. Moreover, employers and industry associations commented that
focusing on completions might lead to too much emphasis on qualifications
rather than skills that add value. Another risk identified by independent MACs is
that this might result in ITOs ‘dumbing down’ qualifications to achieve
completions and too much emphasis on short-term targets.
38. There was a lack of consensus on the proposal to open up skills leadership to
non-ITO organisations. On the one hand, some said this would improve links
between industry and Government and make training more relevant.
Independent MACs thought this would lead to improvements in skills leadership.
On the other hand, most submitters are concerned over how small businesses or
certain sectors would have a voice in this process and how this would be
implemented. Many submitters feel ITOs are better placed to continue to
represent industry, rather than industry providing skills leadership. ITOs and
8
industry associations note the skills leadership role is neither well-defined nor
funded.
QUESTION 1 ARRANGING TRAINING AND CLARIFYING EXPECTATIONS
In your view, what are the benefits and risks for employers and trainees in
your industry of retaining the arranging training role of ITOs and clarifying
expectations of service to employers and trainees?
Employers
39. The majority of submitters, 160 of the 188 employer submissions, support their
ITO and note the value ITOs bring to business. Reasons for this support include:
connections between ITOs and individual businesses; cost efficient and effective
service provision; and active engagement with employers in facilitating training
opportunities.
We value the roles ITOs have in arranging industry training and ensuring a high quality of
delivery is adhered to for both on- and off-job learning within the industries we operate in.
We strongly value the trainee/apprentice coordination service provided by ITOs which
provides effective direction and monitoring for our learners at this level. Downer New
Zealand
40. ITOs’ collaborative approach is valued by a wide range of employers, including
members from the engineering and food industries, particularly when arranging
on-the-job training. Employers emphasise the importance of on-site, employerled training, as it is efficient, convenient and well-aligned to job requirements.
Employers also collaborate with ITOs to develop learning materials.
Working with our ITO, Careerforce, we carry out on-the-job training. We are pleased the
consultation document endorses the arranging training function of the ITO, as this is what
works best for our sector. TerraNova Homes and Care Ltd
We have written our own learning and assessment material which has been moderated
by the Skills Organization (previously ETITO). Spotless Facility Services
41. The main concern about ITOs arranging training is the potential for misalignment
between the training provided and industry requirements. In the building industry,
the cost and quality of the theoretical components of training are poorly regarded
because of the perceived lack of outcomes that result. For trades, employers
emphasised that training must be practical and suit the learning styles of tradespeople.
Carpentry is a hands-on career and must be taken and taught that way. BB
Construction
Most of the time these young students are not “academics” but are hands-on physical
workers who learn by doing. Jackson Engineering
42. Another criticism levelled at ITOs and training providers is that they are
motivated by financial gain, and in some instances this is attributed to their
funding structure. In one submission, the ITO is seen as complicating the
9
employer/employee relationship. In another, the role of arranging training is seen
as unnecessary given the employer could do this.
43. Employers asked for greater and clearer expectations for the service ITOs
deliver and for increased ITO accountability. Employers of all sizes believe ITOs
should facilitate improved communication from training providers in regards to
trainees’ progress. Garrison Security said they “seldom get feedback on a tech’s
progress”. Downer New Zealand also called for improved transparency and
measurement of trainees’ progress.
44. Nine employers reported a negative experience with their ITO, and some
employers said service delivery was non-existent.
The maritime industry ITO, being Competenz by default, provides little or no proactive
advice to maritime employers of SOLAS ships or for that matter to trainees. KiwiRail
Interislander
Industry Associations
45. Industry associations support ITOs retaining the arranging training role. Twentyeight submitters support retention; only one does not support retention. Industry
associations stated that ITOs are well placed to undertake this role and that most
ITOs are doing a good job of this currently. Associations also say that this role is
complementary to the standard setting role. ITOs are seen as the most effective
and cost efficient way of delivering this role. Any transfer is seen as problematic.
We see major issues with transferring to anyone else. We are the sole industry body in
the Fitness industry, and we fully recognise this role is the domain of the ITO (not us).
Fitness New Zealand
46. There is concern that increasing standardisation may decrease ITOs’ flexibility
and innovation in meeting needs or force them to provide services that are not
needed.
We are well served by and fully engaged by our ITO (Competenz) and … arranging
training and their moderating the trainee through their learning is best handled by them.
Fire Protection Association
47. Associations acknowledge that some sectors have received variable service from
ITOs. It is also noted that, the ITO is the only route into industry training in some
sectors. Other associations expressed their confusion at what an ITO’s current
role actually is. They suggested that there needs to be a clear definition around
what services and support ITOs must provide. This would improve achievement.
48. Industry associations stated that ITOs provide consistent information, service
and support, and can be a one-stop-shop for meeting training needs. Industry
associations also noted the importance of ITO work with schools, and the need
for this to be valued and funded. Several associations noted that they want the
flexibility of on-job/off-job training maintained and that the current ITO model
does this well. ITOs are also seen as a good way of increasing levels of
engagement in training by employers and trainees in the workplace. The
ITOs should retain the process of arranging training in collaboration with industry and
according to the specific needs of the employers and trainees in each sub-sector of the
industry. Cement and Concrete Association of New Zealand
10
Having the ITO act in a coordinating role is desirable as the diverse skill sets required by
a modern productive export sector is much more challenging and sophisticated than
when ITOs originally came into existence. Pipfruit New Zealand
49. There is also support for the proposal because industry associations believe it
would remove ambiguity between arranging and delivering training. In
consequence, there would be a clearer delineation between ITOs and tertiary
providers, which would decrease confusion, conflict and competition between the
two groups. Dairy NZ said it would be more valuable if ITOs had the broader
mandate of recruiting trainees for the tertiary education system as a whole
(polytechnic, university or industry training path) and place trainees where they
are best suited. There is some support for limiting ITOs’ ability to deliver training.
50. Several industry associations stated that they want a simplified ITO sector with
reduced duplication and waste. However, there was also concern expressed
about forced amalgamations.
51. Some associations support extending ITO services to employers as well as
employees as this would provide benefits across the whole workforce.
Employers need to be upskilled as well as employees. Employers should be able to
access Government funded industry training. This would create benefits for employees
as well as the businesses. This is particularly important for our smaller owner-manager
operations. Horticulture New Zealand
52. Some associations suggested that Government should incentivise and recognise
ITOs to respond to industry. They stated that there needs to be a match between
government expectations and ensuring ITOs do activities valued by employers. If
ITO priorities are Government-led there may need to be specific funding for
responding to Government.
53. There is support for retaining employer choice in who to use for training,
including the option for the employer to provide theory, or off-job training, on site.
There is also support for ITOs having the option to contract an expert, rather than
a tertiary provider, for off-job training.
54. Some associations want to see ITOs continue to develop learning materials
where ITOs are producing high-quality materials. They support funding for
learning material development. However, ITOs should not be able to dictate the
learning materials for other programs, even when these other programs use ITO
developed unit standards.
55. One industry association asked for flexibility around how this role is performed
and by whom. One association suggested that this function be opened up to
more training providers, giving industries more options to access training.
We would take the view that this should not be an ‘either or’ situation but rather an option
for industry to decide….those industries that are dominated by SMEs, the challenge of
individual firms making the arrangements will often prove to be too demanding. In other
cases, large employers may be best placed to make these decisions. Flexibility is the key
factor here. NZ Shipping Federation
56. Some associations expressed concern that ITOs can be out of touch with
industry needs. They are also, at times, seen as being slow to address evolving
skills requirements. Additionally, ITOs are sometimes seen as prioritising off-job
training at the expense of the on-job training preferred by employers. One
11
association noted that the ITO has not done well with their industry to date. This
is largely because they have replicated training and qualifications that industry
have developed, rather than building on and supporting industry work.
Risk that the ITO is not always in touch with industry requirements and/or expectations in
terms of training. Institute of Quarrying New Zealand
57. Hospitality New Zealand expresses concern about the suitability for small and
medium sized enterprises (SMEs) of the current ITO model and its funding
arrangements.
The current funding arrangements make it incredibly difficult for SMEs to engage in
structured training which delivers national qualifications. That does not mean that the
SMEs do not undertake training….What they do not train to is national standards
delivered by the ITO. They will be far more likely to do so if the size of the training was
more appropriate to the needs of industry, rather than the arbitrary dictates of TEC.
Hospitality New Zealand
58. One industry association considers that the ITOs system has major weaknesses.
In particular, the ability of ITOs to address high-level technical skills provision in
rapidly changing industries is weak. As skill needs outpace the capability of the
current workforce, there is a breakdown in the system that expects the trainee to
become the trainer when they qualify as a competent tradesperson.
59. A number of industry associations suggested the establishment of an
implementation working group to ensure any changes promote performance
improvement at a lesser cost. This group would include members from industry.
An implementation working group be established and include members from industry
(employers and employees) and others to ensure that change promotes performance
and responsiveness to industry needs and preference at the lowest possible of
administrative and compliance costs. Business NZ
Industry Training Organisations
60. There is general support among ITOs for retaining the arranging training role.
Twenty of 23 submitters support retention. ITOs describe themselves as offering
continuity, consistency, quality, tailoring, context-specific knowledge, affordability
and accessibility. They see themselves as being the most appropriate
organisations to arrange training and meet industry needs. This role and the
standard setting role are seen as being intertwined. The importance of on-job
training and support for trainees and employers, and the general support for the
ITO sector from employers and trainees is reaffirmed.
Cost effective solution for our sectors that is affordable and accessible. Aviation,
Tourism and Travel Training Organisation (ATTTO)
Arranging workplace-based training with employers is critical for Careerforce and for the
success of our trainees. Careerforce
61. Four ITOs support the clarification of ITOs’ support role and the clarification of
the definition of arranging training. ITOs feel that these clarifications, along with
increased funding, will decrease the ambiguity between arranging and delivering
training, and well therefore decrease tension with tertiary providers. One ITO
suggested that these changes would offer increased opportunities for
collaboration between ITOs and others in education.
12
62. Five ITOs also identified a need for improved consistency and increased
expectations for ITOs from both Government and employers. In particular, they
support working more closely with, and greater accountability to, industry to
ensure industry needs are being met.
ITOs should be responsible for establishing and negotiating transparent service
expectations for their employers and learners, because they understand the nature of
their industries and employer/learner needs. This ensures their accountability and
commitment to achieving agreed training outcomes. NZ Motor Industry Training
Organisation (MITO)
There must be a match between ensuring ITOs undertake activities that employers value
and Government expectations through investment plan guidance. Forest Industry
Training and Education Council (FITEC)
63. The Industry Training Federation (ITF), the peak body for ITOs, and some ITOs
called for a principles-based approach to outline Government’s expectations of
trainees and employers, which would enable increased ITO flexibility to meet
industry needs. Such flexibility might include the ability to contract the most
appropriate provider, not necessarily a tertiary provider, for delivery. InfraTrain
suggest an annual customer satisfaction measure for ITOs. This could be used
by the Tertiary Education Commission (TEC) to measure industry engagement
and could be used as a funding measure alongside completion rates.
64. The Plumbing, Gasfitting, Drainlaying and Roofing Industry Training Organisation
(PGDR ITO) states that the support function should be adequately funded, as it
is crucial for trainee progression. Increased costs for off-job training have limited
provision of on-job learning support. Clear expectations of services would help
determine appropriate funding levels for service functions and performance
management of the ITO.
65. New Zealand Hairdressing Industry Training Organisation (HITO) supports the
proposals to provide feedback on trainees’ progress and training and mentoring
of workplace trainers. They comment that having a funding stream and clear
academic outcomes for the latter would be valuable. Service Industries Training
Alliance (SITA) stated that they often receive feedback that tutors are ill-prepared
for their role.
66. Two ITOs are concerned that a tight definition of the ITO role could stifle
innovation and flexibility. Competenz is concerned that increased monitoring of
ITOs could increase the cost to Government. ATTTO is concerned that the new
definitions could increase tension between ITOs and providers.
67. There is support for the ITF proposal to establish a Vocational Education and
Training (VET) working party to work through the suggested changes with many
ITOs indicating they would like to be part of such a process. Competenz also
suggests a strategy and vision for the overall VET Sector be developed. The
Communications and Media Industry Training Organisation (CMITO) state that it
is important that TEC, the New Zealand Qualifications Authority (NZQA), Ministry
of Education (MoE) and Ministry of Business Innovation and Employment (MBIE)
adopt an all-of-Government approach to industry training.
68. Two ITOs comment on the importance of getting SMEs involved in the training
process and the difficulties in ensuring this under current funding. The ITOs
describe how they are currently offering non-credentialed training to SMEs to
engage and support them to progress to national qualifications.
13
69. Some ITOs comment on employer experience within the ITO process. The
Building and Construction Industry Training Organisation (BCITO) says that
employers are opposed to an off-site theory/practice split. Electricity Supply
Industry Training Organisation (ESITO) supports employers having the right to
choose providers independently of the ITO. CMITO supports company-wide
training plans for large companies.
70. ITO mergers received some comment. Competenz supports the idea of fewer
ITOs and for current ITOs to be rationally grouped together. InfraTrain supports
ITO mergers that are based on industry need. For example, InfraTrain would
support a broad-based infrastructure ITO.
71. The Skills Organisation (TSO) asked whether the requirement to have a union
representative on the ITO board has been superseded by how ITOs have
developed and whether this requirement could be removed from legislation.
72. EMQUAL states it has serious concerns about the proposals. It states that many
of the recommendations are inappropriate for organisations setting standards
across sectors where public good is the focus rather than increased productivity.
EMQUAL wishes to cease being an ITO and become simply a standard setting
body.
Tertiary Providers
73. Feedback on ITOs retaining their arranging training role was mixed. Some
training providers, such as Jupiter Training Resources, which is a trainer within
the food and manufacturing industry, strongly support the role of its ITO. Other
providers question the quality of ITOs in training arranged by ITOs. Some
providers make the point that ITOs prioritise revenue generation and sales over
the quality of training. The hairdressing department of Waiariki Institute of
Technology notes that once a trainee is placed with an employer by a
salesperson of HITO, there are no qualified subject specialists from HITO setting
up training plans to suit trainee and employer needs.
ITOs receive one (main) stream of funding and split this between internal (standard
setting, quality management, leadership, etc) roles and the purchasing of training and
assessment from external agents (PTEs, etc). In our experience, they will always service
their internal needs first. Tectra
74. There was general consensus among providers that there should be a clearer
boundary between arranging and delivering training. The New Zealand
Association of Private Education Providers (NZAPEP), the Waikato Institute for
Leisure and Sport Studies (WISS), and Training Systems and Solutions make
the point that competition between ITOs and tertiary providers has created
tension and hindered outcomes and this is due to the blurred boundary between
arranging and delivering training. Independent Tertiary Institutions (ITI) contends
there are a number of instances of “industry assessors” being used by ITOs to
circumvent the ban on delivering training. Seven providers thought performance
would improve if ITOs focus more on what they do best, arranging training.
Is not the development of learning materials, supporting apprentices, and assessing
apprentices actually the delivery of training? Unitec
14
75. ITI questions whether a clearer definition between arranging and delivering
training will make a difference, as ITOs simply ignore the restrictions on
delivering training.
Independent Modern Apprenticeship Coordinators
76. Independent MACs were vocal in their criticism of the quality of training that ITOs
arrange. In a similar fashion to providers, they are concerned that a focus on
profitability and minimising costs comes at the expense of the quality of training.
Competenz’s main engineering certificate (Mechanical engineering general engineering;
nominally 270 credits) was at inception roughly one third night-class, one third blockcourse and the rest workplace assessed. Currently 197 credits are workplace assessed
(employer delivered) and around 80 are off job delivered. The ITO therefore is only
“arranging” about 30% of the whole cert. Whangarei Education and Business
Services
The ITO double fees justifying it by claiming they will provide all manner of additional
services some of which their staff can’t provide because they are not trade qualified or
don’t have the necessary trade experience or knowledge, and much of this additional
compulsory service is of little, if any, use to us. Southern Group Training Trust
77. MACs question whether ITOs should retain their arranging training role given
their poor communication with relevant stakeholders, disorganisation and general
ineffectiveness in arranging high quality training. MACs claim ITOs usually
arrange training at their convenience and the timing of training is sometimes
inconvenient for the apprentice and out of synch with industry labour demands.
A painting MA [Modern Apprentice] being scheduled to attend the only relevant block
course at CPIT [Christchurch Polytechnic Institute of Technology] only to have the MA
turn up and be told it had been cancelled. The ITO forgot to let the employer or the
apprentice know, and the MA had travelled to Christchurch to attend it. The same MA is
now scheduled to attend his final block course which has foolishly been scheduled for
early December, a prime time for painters to be out on the job…while we raised our
concern about the timing with the ITO it was ignored. 1 Smart Careers and Southern
Group Training Trust
This year while we had advised that there would be at least 24 new first year engineering
apprentices the ITO saw fit to provide only three Training Manuals which meant the first
evening class was a waste of time and effort for all those involved, some of whom travel
two hours return to attend. Smart Careers and Southern Group Training Trust
78. Despite these problems with poor performance, Southern Group concedes the
arranging training role of ITOs might have to continue because the geographic
isolation of trainees and the range of trainees’ needs make it necessary.
Other submitters
79. Only fourteen submitters commented on this question. Several submitters noted
that ITOs are best placed to continue in this role, as the current system works
well. Increased clarity for employers and trainees about what is expected is
welcomed. One submitter hopes that new expectations will be developed with
ITOs and industry bodies and be evidence-based. They also note that new
definitions, in terms of what support should be provided to learners, would be
1
This happened under Creative Trades, a poorly performing ITO that is now defunct.
15
useful to any organisation that includes a work-based component in their
qualification.
ITOs are the best organisations to arrange training as they have the contacts with industry
and can broker where training should best take place to meet an employer’s needs. NQF
Solutions
80. One submitter suggests that the role needs to be strengthened to complement
the sector. Another submitter commented that the ITOs are currently
underfunded to perform tasks associated with this role.
81. Three submissions from unions note that there could be greater specification and
guidance around this role, while still allowing for a degree of diversity in how
ITOs meet these goals. One submitter stated that there is a need for a
mechanism to clarify the distinction between arranging and delivering training.
They added that ITOs should not deliver courses and instead remain focused on
their core roles.
82. One submitter notes that it is important not to mistake the voice of the ITO for the
voice of industry. They are concerned that industry voice will be subsumed as
ITOs fight for survival in any amalgamations.
‘Industry view’, is not synonymous or representative of ITO views. Plant & Food
Research
83. The Tertiary Education Union comments that ITOs should work more closely with
ITPs and other providers to meet this role. It suggests that ITOs should not direct
how and what is taught, but focus on standard setting and moderation. It states
that a distinction between theory and practice is unhelpful. It also comments that
ultimately ITOs and providers have the same goals meeting industry and
learners’ needs, and the economic goals of the country.
84. Two submitters support the establishment of an implementation working group
and signalled their willingness to be involved in it.
QUESTION 3 INCREASING EXPECTATIONS OF COMPLETIONS
What are the benefits and risks for employers and trainees in your industry of
increasing the expectations for ITOs of qualification and programme
completions?
Employers
85. The majority of employers did not comment on this proposal. Those that did
recognise that qualification completions are important, both for trainees and
employers. Completions are one way to improve the returns on investment of
industry training for the Government and employers.
86. The benefits of qualification completion for trainees were widely acknowledged
including trainee confidence, an increased likelihood of pursuing further training
and higher skill levels. However, submitters commented that it is important that
learners develop commercial competence and the quality of qualifications is
maintained.
16
87. Employers commented that a close partnership is required between employers,
ITOs, training providers and trainees to facilitate successful completions.
Employers acknowledge that there has been success in increasing completion
rates in recent years.
With the help of our ITO, Careerforce, we are achieving more training completions than
ever before. Presbyterian Support South Canterbury
88. However, a large employer said that the increased onus for completions has
fallen on industry, rather than ITOs even though ITO funding has increased.
89. The timing of provision was identified as important to supporting qualification
completions. Skyline Enterprises and Framework suggested courses should be
timed to suit job or industry requirements, rather than scheduling in accordance
with the academic year. Additionally, employers suggested that there needs to
be improved recognition of changing labour demands such as seasonal work in
the dairy industry. It was noted changing labour demands can affect the incentive
and availability of workers to train. To mitigate this, one employer said funding
needs to be committed over a five year time period.
Comments from some industries in the Ministry review suggests that ITOs and industry
have difficulty dealing with the impacts of seasonal peaks and troughs because trainees
are not always available to progress and be assessed against the competency
requirements. Although we operate within a seasonal industry, it would appear that the
TEC operational policy settings should offer sufficient flexibility for trainees to be put “on
hold” to mitigate duration issues. Fonterra
90. Some employers argue poor qualification completions is the result of funding
settings. They claim too much emphasis is placed on course enrolments, rather
than course completions. Also, funding for training organisations recognises the
number of courses on offer and their duration instead of the trainees’ skills.
91. There is a concern that training organisations focus on providing courses that are
profitable, rather than what trainees or industry require. Qualifications must
reflect employment opportunity, for the trainee’s benefit as much as that of
industry.
92. Increased completion targets may be above industry or trainee needs and a
widespread concern is that trainees who have only completed low level courses
may be excluded from funding. These trainees have skills that are valuable to
industry. In this vein, one employer called for fewer rules around qualification
completions.
93. There was little feedback on the sharing of standards. However, cost efficiency
was welcomed and some employers anticipated using ITO standards.
Submitters identified a risk that inconsistency may result if tertiary providers and
other ITOs use ITO standards without using standardised learning materials
developed by the same ITO who set the standard. Two employers added that
ongoing support for adequate literacy and numeracy is important.
94. Two employers said the availability of resources and training providers can inhibit
progress, and another called for ITOs to address the lack of training providers
outside the main centres.
95. In the experience of the regulated maritime industry, training and certification is
mandatory to employment so completion rates are very high. Two employers
17
suggested funding be paid per trainee rather than per qualification, and another
stressed that the primary purpose of the MAC should be qualification completion.
Industry Associations
96. Industry Associations are supportive of increasing expectations for ITOs of
qualification and programme completion. Twenty-four of thirty-nine associations
who answered this question agreed with this proposal. Industry Associations
stated that this proposal would maintain and enhance completion rates and raise
skill level and performance over time.
97. Some associations stated that meeting revised goals will require adequate
resourcing and incentives. A focus on outcomes instead of inputs is seen as
valuable, but it was suggested that it may be helpful to focus on smaller units
rather than whole qualifications. Targets need to be set at an appropriate level.
98. There is concern that higher completions should not be at the expense of lower
level qualifications. Level 2 skills are viewed as particularly valuable. This is
because they provide foundation skills, pathways and transitions, an entry point
for unskilled workers, and access to literacy and numeracy skills. One
association stated that they strongly supported achievement-based funding, but
only with mandated pre-requisites in lower level skills including literacy and
numeracy.
While EMA supports the need for a higher skilled workforce, it feels equal emphasis
should be placed on the value to industry of level 3 and 4 qualifications as they contribute
significantly to productivity improvement, innovation and provide employees with lifelong
skills. Employers and Manufacturers Association (EMA)
99. There is also concern that an emphasis on quality should not be lost in favour of
quantity. All qualifications must remain high quality.
Performance linked funding can drive achievement but can also drive standards
downwards. Past unethical activity reflects a tendency for organisations to act primarily for
their own survival, not necessarily in the best interests of trainees or the industries they
are supposed to serve. In principle trainees should be pushed to complete, but not at the
expense of standards. New Zealand Outdoor Instructors Association (NZOIA)
100. Additionally, there is a view that the circumstances of industry may have to be
accommodated and that any system must firmly reflect industry and business
need. Different industries have different needs and these will change over time
so the system cannot be too inflexible.
The completion targets for industry training will have to be tempered with the realities
around commodity markets and business priorities. Forest Owners Association (FOA)
101. There is concern that these targets may influence ITOs to see themselves as
responsible to Government rather than industry. There is also support for the
idea that quantitative measures should be linked to industry and not compared
with other types of providers. Some industry associations expressed concern
about how completions will be measured. There is concern that certain industries
could be disadvantaged because of the nature of the work cycle. It is noted
training cycles based on calendar years, rather than work cycles may
disadvantage the trainees.
18
102. Some associations stated that completions are not an end in themselves. It is
more important that employer and trainee are getting what they need. Outcomes
should be tailored to industry needs, rather than simply ensuring high completion
rates.
It is important that we don’t fall into the trap that completions become an end in
themselves. There are many cases when trainees (and employers) may regard
completions of qualifications as unnecessary….The principle measure of success in this
regard should not be whether or not a particular box (e.g completions) is ticked but rather
are the trainee and employer getting what they need? NZ Shipping Federation
103. Various associations noted that Government needed to realise that there were
many reasons for non-completion. Those listed included a transient workforce,
people only undertaking training to meet regulatory requirements, and the
qualification not being fit for purpose. One association noted that cutting funding
should not be the only incentive and that there may be more effective ways to
incentivise completions. They suggest that funding could be based on the
number of unit standards completed rather than an “all-or-nothing” approach.
They also suggest a staggered funding approach where funding is received at
various points in the apprentice’s training journey.
104. There is support for further consideration of how people in vocational training get
their qualifications to ensure training models reflect workplace reality.
…thought needs to be given to how apprentices attain their standards. As this may not be
a straight line process the funding mechanism will need to align so as to not disadvantage
either the ITO or apprentice. Registered Master Builders Federation
There needs to be short course off job training to provide key technical skills that cannot
be attained in the workplace. Courses must be modular to provide the trainee with the
specific skills and the employers with productivity gains and value. Modular courses can
staircase to qualifications. Pipfruit New Zealand
105. Some industry associations noted that a major risk is over or under qualifying the
employee pool. There should be a close match between skill levels and the
labour market. One association suggested that it may be necessary to incentivise
completing higher level qualifications if these are not directly job related.
We are concerned to ensure that there is a good match between the skills levels acquired
through vocational training and those required in the labour market. A responsive
vocational system should enable improved matching… Business NZ
Industry Training Organisations
106. Twelve of twenty-three ITOs agree with the proposal to increase expectations for
ITOs around qualification and programme completions. The benefits are seen as:

better support for trainees

better results monitoring

the creation of clear pathways for learners

better value for money

increased numbers of qualified people
19

meeting industry requirements for increased completions

improved educational performance.
107. Five ITOs noted that there may need to be some flexibility in the targets to reflect
the realities of work flow and industry training itself. This includes addressing
different learning situations and learner groups. This is especially the case if any
comparison with institution-based providers is to be attempted. For industry to
buy-in to targets there may need to be incentives to complete higher
qualifications, which are not directly job related.
The ITF believes that Government’s focus on progression to higher qualification levels
needs to be balanced with the realities of training at different levels and across different
industries. ITF
The very different (compared to institutional education) circumstances and requirements
of industry training must be fully taken into account, including seasonal employment and
impacts of commodity market trends. FITEC
There needs to be a degree of flexibility to enable trainees at all levels to have their
needs met, which reflects the complexity and nature of the environments and
circumstances in which our trainees learn. InfraTrain
108. There is concern from four ITOs that higher level qualifications should not be
pursued at the cost of lower level training including literacy and numeracy
training. Entry level qualifications should still be funded as on-job learning and
pathways from levels 2 to 4 should be encouraged. Competenz suggested that
too much emphasis on completion at higher levels might devalue level 2 and 3
qualifications.
109. Five ITOs stated that completion and progression should not be ends in
themselves. These measures could over-emphasise complete qualifications at
the expense of usefulness to the sector and learner. This model does not value
employment and skill utilisation outcomes. ITOs should not be judged solely on
academic outcomes as competence involves learning, practice and experience.
There is a risk that quantity is valued over quality.
Achieving the qualification or completing the programme becomes more important than
spending the time learning and applying the learning in a way that benefits both the
learner and the business. ATTTO
110. There is concern about how completions would be measured. BCITO suggest
that the targets should be based on numbers enrolling, not the numbers in
training. Three ITOs suggested that completion rates and progression should be
negotiated with each ITO to reflect the diversity of sectors. Two ITOs also noted
that staircasing through different qualifications is not necessarily linear. People
should be able to access qualifications at the level that is needed. TSO
suggested rewards linked to performance above a base level and relative
improvement over time. Not reflecting the different starting points of sectors in
training could, over time, reduce some sub-sector and sector access to training.
111. EMQUAL suggested they won’t be able to meet Government requirements and
performance criteria for future funding because their trainees are largely
volunteers. Additionally, the 40 credit requirement for funding as well as the
expected credit and qualification completion rates poses significant barriers to
20
volunteer engagement with higher levels of training. This will in turn impact the
quality and coordination of emergency management.
Tertiary Providers
112. Overall, providers support higher expectations of qualification and programme
completions for ITOs. Three submissions stated that a benefit of this proposal
would be more qualified staff with greater skills. However, this may also result in
staff retention issues as better qualified staff may be more likely to leave.
113. Blueprint for Learning proposed key performance indicators should be set and
related to funding to facilitate completions.
114. NZAPEP and WILSS thought more focus on completions would force ITOs to
work with providers, rather than compete.
115. The School of Applied Technology for the Bay of Plenty Polytechnic emphasised
that completion rates must be coupled with transparency and accountability by
the ITOs. They also stressed that the quantity of completions gained must not be
to the detriment of quality.
116. Another risk identified was that a focus on completions might result in
marginalisation of learners at lower levels. It was also possible that ITOs may
pass on the increased onus for completions to employers.
Independent Modern Apprenticeship Coordinators
117. Regent Training Centre agreed that more emphasis on completions would lead
to more qualified staff with greater skills. They see this as having a positive
impact on productivity, rising returns on investment for taxpayers and increasing
consistency. However, they also pointed out there is the potential for ITOs to
‘fudge’ results or ‘dumb down’ qualifications.
118. Southern Group Training Trust stated that the content, timing and quality of
qualifications must reflect the needs of industry and not be influenced by the
ITOs short-term performance pressures.
119. MACs generally made the point that if focus on ITO completions came at the
expense of non-ITO MACs this could be detrimental to outcomes as non-ITO
MACs typically have better completion rates. To support their submissions,
some independent MACs included letters of support from employers and
apprentices supporting the retention of their services.
By not engaging independent Modern Apprenticeship Coordinators, this could be
detrimental to levels of support and ultimately completion rates. Regent Training Centre
Ltd
Given the choice we would prefer to retain the services of our Modern Apprentice
Coordinator…[ITOs] have a poor track record in delivering service directly to industry, and
have a record of charging for service they do not deliver. Amtec Engineering
My Modern Apprentice Coordinator is trade qualified, understands what it is like being an
apprentice, knows the apprenticeship training system very well, and is there to support me
when I need it, not when it suits him. Apprentice
21
120. The joint submission by Smart Careers and Southern Group Training Trust noted
there could be multiple reasons for non-completion unrelated to performance
concerns such as relevance of courses to industry, the difficulties created by
challenging economic conditions and levels of numeracy and literacy at the
beginning of courses.
Other submitters
121. Fourteen submitters commented directly on this proposal. One submitter
supported an emphasis on performance.
It’s time ITOs caught up with the rest of the sector. PTEs and more recently polytechnics
have been living in the performance world for some time. Plant and Food Research
122. Three submitters commented that improving completions was good, but that
Government should be careful not to introduce perverse incentives that
prioritised numbers completing over quality of graduates.
123. Two submitters suggested that there was a need to consider pathways from
completion. These should include progression onto level 5 and progression into
further tertiary training.
124. Three submitters commented that completion targets should be varied by sector
and learner to take into account different settings and training histories. One
submitter noted the need for shorter and more specific qualifications. One
submitter noted that this proposal would make it harder to reach SMEs.
One size does not fit all however the Government as the predominant funder must
ensure NZ is getting value for money. Private Individual 5
125. Another submitter commented that the value of level 2 and 3 qualifications
should not be lost in pursuing this proposal.
126. Three submitters from unions stated that they accepted the need for increased
completions and noted the progress that has been made towards this aim.
However, they expressed concern that the proposal may exclude “marginal” or
“risky” trainees. They suggested that this will have negative economic and social
outcomes and lead to greater exclusion from training. They also stressed the
need for a more strategic view of medium term requirements rather than simply
one based on completion targets.
QUESTION 4 SKILLS LEADERSHIP
What are the benefits and risks for employers and trainees in your industry of
transferring the skills leadership function to industry?
Employers
127. Many employers disagreed with this proposal. However, the strength of this
opposition is mitigated by two factors. First, although 115 submitters disagreed
with the proposal, 105 of these submissions came from Competenz linked
employers, most of who made submissions on a standard form provided by
Competenz. Second, the intent of the question may have been misinterpreted by
some employers as the proposal never intended to remove ITOs from the skills
leadership function, only to open up skills leadership to other organisations.
22
128. The main reasons employers gave for opposing this proposal are:

ITOs are best placed to communicate with Government on behalf of the
industry as a whole

different business ability to engage with Government

many businesses don’t have an industry association to represent them

large players may dominate communication with Government

inconsistent and incomplete skill needs analysis

SMEs lack the resources, time and leadership to effectively identify and
quantify upcoming skill shortages.
Industry Associations were not established, nor are they funded, to do the in-depth
analysis required to offer sound advice on skills needs. It would be too easy for the
loudest voice, or the largest voice, to capture the process leaving the bulk of enterprises,
the SMEs, with no avenue to reach government. ITOs have contact with a large number
of enterprises and are best placed to represent our skill needs. WYMA Engineering NZ
Ltd
129. Downer New Zealand recognise that ITOs are currently undertaking leadership
and skills initiatives at the broader industry level, saying:
…ESITO do valuable work promoting vocational career pathways to school students and
under-represented groups in our industry, namely women, Maori and Pacific people. We
see value in this offering (and don’t have the resource to do this ourselves or collaborate
with industry)… Downer New Zealand
130. In contrast, however, Restaurant Brands New Zealand Ltd, KiwiRail Interislander,
and Fonterra, three large employers, were all supportive of industry
communicating directly with Government. They suggested this offers:

increased authority and responsibility to industry to champion their skill
needs

a better understanding by Government of industry relevant training
approaches

improved alignment of the training sector with industry requirements

more relevant assessment.
It is important industry provides the areas of skill shortages, this would remove training
institutions providing courses where minimal or no employment opportunities exist.
Contact Energy/Mighty River Power
Our industry must take the initiative back from the training organisations and become
central players in the process of determining the training and assessment outcomes of
our staff. KiwiRail Interislander
131. This proposal would allow ITOs to focus more on standard-setting and arranging
training. It would give a clearer role definition to ITOs and ITOs could focus more
on the training needs of industry, rather than overall educational objectives. One
23
employer is pleased that a path for communication when their ITO does not
perform will be opened up.
132. Submitters suggested that industry may choose to delegate a leadership function
to ITOs if there is no other obvious leader. It is also suggested that ITOs might
set up industry discussion groups to communicate with Government and facilitate
investment in labour market research capability. Some submitters noted that
ITOs are owned by industry so direct involvement already exists.
Industry Associations
133. Industry associations are divided over opening up the skills leadership function to
industry. Eighteen agreed with the proposal and sixteen disagreed.
134. There is some confusion over what the skills leadership role actually is and there
was a suggestion that it requires better definition from both Government and
industry. Some associations feel the current system has had mixed results.
Industry associations commented that any process should be industry-led, rather
than being driven by Government.
135. Some associations are strongly supportive of industry-led skills leadership.
These associations stated that ITOs’ current skills leadership role is not
sufficiently industry facing. ITOs make decisions about training structures and
provision based on their own needs and the needs of providers, rather than
consulting with industry.
136. Other associations commented that industry want intimate involvement with the
development of standards that demonstrate competence in the workforce and
this proposal would reinforce the importance of industry. This proposal would
also better align industry directions with Government investment leading to a
focus on the sharper end of commercial need. Industry associations stated that
successful transfer will require closer alignment of policy across Government.
Industry have businesses to run but are very interested in ensuring we are involved in
having our needs heard directly and not via any ‘filtering’ systems. Waikato Engineering
Careers Association (WECA)
137. Some associations suggested that Government is currently difficult for small
industries to negotiate and this proposal should improve this. It would also serve
to remove duplication between industry and ITO work that currently occurs. One
association stated that they want the same level of engagement with TEC and
MBIE as they currently have with ITOs. Other associations suggested that
industry will need funding to undertake this role. The level of funding would be
dependent on the level of involvement required from industry.
138. There are questions raised by associations about how industry consultation
would actually function in practice. One association questioned whether
Government is open to industry needs given that there is conflict with ITOs on
National Qualification Framework (NQF) processes and qualifications.
The details of how this will work are quite sketchy with more clarification needed. Print
NZ
139. Some industry associations commented that industry should be tasked with
identifying its own training needs and then working with ITOs to meet them.
24
Industry, through their advisory group, can independently determine its training needs
and then work together with the ITO to agree on how and what training will be delivered.
The ITO needs to be seen as an agent for industry, acting on their behalf in its
interactions with TEC and NZQA. Scaffolding Access and Rigging NZ (SARNZ)
140. Industry associations view themselves as critical to the successful
implementation of this proposal. In some cases, associations see themselves as
more representative and better versed in the skills requirements of the sector
than ITOs.
141. Some industry associations stated that industry groups should be involved with
skills leadership, but ITOs should not be precluded from participating. Others
indicated that they would like to communicate skills needs in conjunction with
their ITO. Others suggested that ITO involvement should be optional for industry.
One association suggested that ITOs should be monitored to ensure they are
undertaking sufficient industry consultation. One association stated that TEC
should ensure that ITOs are delivering the skills leadership role and hold them
contractually accountable for this.
We have long been of the opinion that leadership needed to come from industry and that
whilst the ITO has a role to play, they should be a participant – not a leader. Master
Plumbers, Gasfitters & Drainlayers NZ
142. Several industry associations commented that ITOs should retain their skills
leadership role, arguing that ITOs are best placed to investigate future skill
requirements, are well placed to communicate with Government and are
experienced, effective and efficient at this role. They also suggested that
removing the skills leadership role removes ITOs from engaging with the sector.
The proposed changes are an unnecessary lengthening of the industry training supply
chain. Northland Wood Council
CETANZ see this proposal as a huge step backwards. We would prefer that ITOs
continue to carry out this function as they are experienced and currently perform this task
well. Civil Engineering Testing Association of New Zealand (CETANZ)
We think transferring leadership to industry is a very dangerous and counterproductive
suggestion…. As an industry organisation, we are part owner of the ITO and therefore
we already have a direct involvement in skills leadership through the ITO. There seems
no reason to change this system that is working for us. Fitness New Zealand
143. Three associations stated that industry will expect ITOs to continue this role.
The Associations operating in this sector believe they have ownership of the ITO and will
continue to expect the ITO to provide a leadership role in the labour market and skills
needs of the hospitality industry. Hospitality New Zealand
There is considerable concern from associations about how any new process
would capture all industry voices adequately and fairly. Associations identified
risks around:

capacity of industry

businesses’ desire to have this role

financial costs for industry
25

‘large budgets’ and ‘loud voices’ dominating consultation

industry fragmentation making concerted engagement hard

variable quality of skills intelligence produced, particularly on long term
skill requirements

possibility that the proposal may transfer rather than resolve problems
identified with skills leadership.
One association asked what the consequences would be if no industry skills
leadership occurred. There is particular uneasiness about how SMEs would
engage with Government.
We are concerned that if industry is at all fragmented then problems will arise that will
impact standard setting, arranging training, and increase cost to industry as a result. The
Electrical Contractors Association of New Zealand (ECANZ)
144. There was also some discussion of how MBIE, TEC and other Government
agencies would build their own capability and capacity to undertake formal and
robust dialogue with industry.
Industry Training Organisations
145. ITOs generally agree that greater involvement between Government and industry
is desirable. However, how this will be managed is questioned by a number of
them.
146. ITOs stated that improved links between Government and industry would benefit
all stakeholders in industry training and indicate that skills leadership is being
taken seriously. There is a need for a clear mechanism for industry to
communicate skills needs to all those with an interest in skills and industry
training. ITOs are aware that direct consultation is already taking place in some
sectors and attempts to extend and systemise this would benefit industry. ITOs
also see that this proposal may also clarify and refine the definition of skills
leadership.
147. ITOs identified a number of barriers to achieving the transfer of skills leadership.
Eight ITOs expressed concern about the capacity and capability of SMEs to
engage in skills leadership. They identified SMEs as tending to lack resources
and be highly fragmented. It is suggested that ITOs coordinate these disparate
voices.
It is believed that without using JITO as a conduit, the small size of the sectors and
fragmentation of businesses, possibly due to the large number of SMEs, skill leadership
for them may be a “non event”. Joinery Industry Training Organisation (JITO)
148. A number of other barriers were also identified including:

Government being unable to replicate the penetration into industry that
ITOs have

the lack of clear definition of skills leadership

industry participation requiring funding
26

the potential for decreased collaboration between ITOs, sectors and
providers

the muddying of where the key responsibility for skills leadership lies;
difficulty in mobilising leadership and difficulty in developing processes to
ensure skills needs are adequately conveyed

identifying representative voices within an industry or sector; a potential
lack of flexibility and responsiveness to meet industry requirements

difficulties for industry in conveying skill need clearly

how ITOs would access skill needs information to inform standards and
qualification development.
149. ITOs stated that they should not be precluded from the skill leadership process.
Four ITOs said that ITOs have a role to play and this should be recognised,
funded and harnessed. They commented that industry is unlikely to take the lead
in skills leadership and will look to ITOs to do this. The New Zealand Industry
Training Organisation (NZITO) suggested that it may be desirable to allow
industry to delegate this role to the ITO if there is no industry led coordination
available. InfraTrain stated that industry associations and ITOs should
collaborate in the skills leadership role.
The ITF is committed to working with MBIE, industry and other organisations to develop
and implement an approach to industry skills leadership that represents value for money
for both Government and industry; facilitates representative and industry-led discussions
between Government and industry; and that recognises the skills leadership that ITOs
will provide their industries through their arranging-training and standard setting
functions. ITF
150. Five ITOs suggested that the skills leadership role of ITOs should be retained.
They see removing it as being at odds with the strengthening of other areas of
ITOs’ responsibilities. They also see losing responsibility for skills leadership as
reducing ITOs ability to respond quickly to industry skill need. HITO suggested
that retention should come with clear guidelines about the necessity for industry
liaison and consultation. Six ITOs stated they will continue their skills leadership
support irrespective of where responsibility for it ends up as it is necessary for
other roles and it is what industry wants. Three ITOs stated that this will result in
duplication of effort as ITOs will still be required to undertake skills analysis.
151. NZITO said that it is presumptuous of ITOs to assume that they are skill leaders
for industry. They also suggested that Government’s abilities to access data and
analyse labour and economic data at a macro level are important components of
its participation. Careerforce queried whether the skills leadership role would be
a conflict of interest for ITOs who work with Government contracts. ATTTO
commented that removing this role would free ITOs to concentrate on their
standard setting and arranging training roles. Three ITOs stated that it is crucial
that skills leadership is driven by industry rather than Government.
152. Two ITOs are concerned about ensuring ITO work that has been undertaken in
the secondary-tertiary transition space is not lost.
27
Tertiary Providers
153. Providers welcome this proposal. Four providers suggest that this will increase
the voice of industry and in doing so ensure training is more relevant. Tectra
suggests closer involvement in skills leadership by industry could assist
productivity as there would be a close relationship between the skills required to
be developed and training.
154. Another benefit identified was to reduce conflict of interest for ITOs from their
roles in skills leadership and arranging training.
155. There were important issues raised about how this proposal would work in
practice and what the future role of ITOs in skills leadership would be. One of the
main concerns was that it might be difficult for small organisations or sectors to
be heard if skills leadership is “industry led”. Five providers specified that industry
associations were not established or funded to perform skills leadership.
However, another provider stated there are 70 industry associations in New
Zealand and these organisations provide a coordinated communication path.
Eight providers also felt that ITOs were better set-up to reflect all the voices of
industry and skill needs, rather than industry representatives.
156. The Waikato School of Hairdressing raised the concern that industry led skills
leadership might lead to too much focus on individual business interests, rather
than system wide concerns.
157. Providers suggest broad consultation was necessary for this proposal to work in
practice given the lack of detail over how industry-led skills leadership would be
implemented.
Independent Modern Apprenticeship Coordinators
158. Most independent MACs were supportive of this proposal. Some MACs viewed
this as a better approach to skills leadership than the status quo due to problems
with ITOs connectedness to industry.
159. Advantages of opening up skills leadership to other participants included more
transparency and accountability for ITOs from industry, enabling ITOs to focus
more on their core roles of arranging training and standard setting, and lower
costs.
160. Whether this worked in practice, however, did depend very much on broad
consultation prior to implementation.
161. The main concerns raised by MACs were the costs and time this would take for
industry to perform this function and uncertainties regarding how industry
leadership would be facilitated. Indeed, the prominence of industry in this
process could be reduced if this significantly increases training costs or involves
a large time commitment.
Other submitters
162. Fifteen submitters commented directly on this proposal. Four submitters noted
that the role is currently ill-defined and a clearer definition would be helpful. The
New Zealand Council of Trade Unions (NZCTU) commented that there is a risk
28
that skills leadership will “fall between the stones” and that an already inadequate
situation will not be improved. They stated that a template around the questions
that a strategic approach to skills must address should be developed. They also
stated that some ITOs remain well placed to carry out this role.
163. Three submitters advocated ITOs retaining the skills leadership function with
appropriate reporting and monitoring work carried out annually to ensure that it is
being done well. One submitter noted that a well-run ITO would do this anyway.
One submitter noted that ITOs are not separate to industry, but a part of it so
ITOs working with Government is industry working with Government. Two
submitters noted that whatever happens some of the skills leadership role is tied
to the standard setting function and would remain within ITOs’ sphere. Three
submitters commented that any transfer would be inefficient, complicate the
system and have limited impact on the workload of ITOs.
The industry needs to dictate what is best for their sector, however with so many different
focuses within each industry we believe ITOs are well placed to take on that function on
behalf of industry. Competency International
When the ITO system of consultation with the industry and the ITOs are accountable to
their industry the present system works well. Governments only role should be to fund
and audit ITOs to insure they are working and listening to their industry trainers.
Gisborne Development
164. Two submitters stated that ITOs are used to addressing the strategic challenges
of industry. They commented that ITOs have experience in industry and
education. In consequence, they can think strategically about issues facing
industry and how skills can address those issues. On the other hand, it was
argued industry bodies are much more likely to focus on immediate need. One
submitter noted that it was possible that this would lead to skills needs of certain
jobs being more narrowly defined and therefore decrease the range of skills a
trainee learns. However, submitters also noted ITOs do not have a monopoly on
this and it may be necessary to get other stakeholders, including providers,
involved.
165. Three submitters identified issues around SME capability and capacity to engage
with the proposed process. They identified the risk that smaller or more specialist
employer voices could be lost. One suggested that MBIE and TEC would need
significantly increased capability and capacity to engage meaningfully with all
industry bodies. Another submitter stated that it would be interesting to see
whether industry bothered engaging in the process. One submitter asked “why
does the Government want this information and what will they do with it?”.
166. Two submitters from unions noted that this proposal will need an “all-ofGovernment approach”, not just vague expectations. This will include roles in
resourcing, consolidation of expertise and methodology of strategic leadership.
They also noted that TEC and MoE have a role in ensuring cooperation across
the VET sector and that there must be clear lines of communication for all
stakeholders. They suggested that the Minister should meet with all stakeholders
regularly. They asked for more detail on proposed Government support for the
implementation of this proposal. They noted that any definition of industry must
include organisations representing the workforce.
29
3. Apprenticeships and traineeships: definitions and
funding
Proposals
A more sustainable funding regime that increases the subsidy rate for traineeships
and introduces a higher subsidy rate for apprenticeships.
Amalgamating all apprenticeships into the Modern Apprenticeship Scheme to enable
the same level of support to be available for all apprentices, regardless of age.
Consider whether to incorporate the modern apprenticeship coordinator fee into the
training rate for apprentices or keep it as a separate fee.
Overall
167. There is widespread support among most submitters for a higher subsidy rate for
apprentices and for amalgamating all apprenticeships into the modern
apprenticeship scheme.
168. The higher subsidy rate would encourage the uptake of more apprenticeships
and recognise the higher costs of apprenticeship training. ITOs also suggested a
higher rate could possibly decrease tensions between ITOs and providers as this
would be mutually beneficial to both groups. However, some MACs questioned
whether higher funding rates would necessarily lead to more apprentices.
169. One problem in increasing subsidies for apprenticeships, according to industry
associations and ITOs, would be that it might devalue traineeships by creating a
two-tier system with apprenticeships more highly valued than traineeships.
170. Even more important were issues around how to define an apprenticeship. ITOs
and providers think this should include competency and theoretical knowledge as
a core competency, while employers thought it was impractical to define
apprenticeships solely by the number of credits. In addition, employers and ITOs
suggested that employer in-kind contribution to the cost of training should be
recognised.
171. As with the higher subsidy rate, extending equal support to all age ranges would
encourage more apprentices. This proposal would also increase flexibility and
perhaps positively impact on completions due to higher quality staff as this would
grant equal support to more mature trainees who are often regarded by
employers as more reliable.
172. The main risks identified by submitters in extending support were the reduced
opportunity for youth and that it may penalise seasonal industries.
173. For the modern apprenticeship coordination fee, there is more support for
incorporating the fee into the apprenticeship rate over having two separate fees.
In general, most of the different groups supported the first option, as it was
considered a simpler system, with lower costs. However, MACs were strongly
30
opposed to both options on the basis that it would provide ITOs a monopoly over
modern apprenticeship coordination, which would eliminate independent MACs.
174. There is some concern among employers, providers, MACS and other submitters
that ITOs would use these funds for their own purposes, rather than on training.
QUESTION 5 HIGHER SUBSIDIES FOR APPRENTICESHIPS
What are the benefits and risks for employers and trainees in your industry of
introducing a higher subsidy rate for apprenticeship training?
Employers
175. This proposal is widely supported; only four submitters expressed negative or
neutral views. Employers stated that the cost of training apprentices is high and
they believe that they would benefit from a higher subsidy rate.
A first year apprentice cost can include the following – four weeks holiday pay,
approximately one week sick leave, three weeks trade school, Competenz [ITO] fees [of]
about $1,000. A second year apprentice usually costs about the same as a first year but
they start to break even. Third and fourth year apprentices then start to be productive.
These costs do not include the cost of our time that we invest in training apprentices on
the job. WM Ross Engineering Ltd
The cost to train an apprentice can be very high and any proposal to reduce costs and
duplication, and provide extra funding, would be welcomed if it meant more money was
available to support companies to take on apprentices. SEC Group Ltd
176. Employers support increased subsidy rates because apprenticeships have
higher costs than traineeships, require substantially more theoretical knowledge
and are highly valued by employers. The proposal would support New Zealand’s
production of high-quality trades-people. In turn, this would support succession
planning and reach segments of the population with historically low achievement
rates.
Investment in trades and training apprentices is vital for the future of the development of
trade skills and industry in NZ. IVE Group Ltd
Succession planning within roading is difficult for all companies. It is evident a 15 to 20
year gap has emerged, and encouraging our young people to join the industry training
towards qualifications, which provide a variety of lifelong skill opportunities is crucial. Our
industry encourages youth to work for us, an area of society which lacks recruitment
opportunity in many other areas. Higgins Group Holdings Ltd
177. Employers want funding focussed on training provision, not on ITOs overheads.
They are also concerned higher funding for apprenticeships might incentivise
training providers to rebrand training schemes lacking industry relevance as
apprenticeships to increase their revenues.
…ensure all apprentice funding is directed in a way that drives industry outcomes
(productivity, safety, effectiveness) and not as an incentive to establish sub-standard
training institutions seeking a revenue stream… Genesis Energy
178. Some employers say that it is impractical to distinguish funding rates through
credits and instead industry conditions should be used to guide funding levels.
Downer New Zealand requested consistent subsidy rates across ITOs because
they are confusing and at times out of proportion.
31
Industry Associations
179. Industry associations are largely supportive of introducing a higher subsidy rate
for apprenticeship training. Twenty-four submitters agree with the proposal and
one disagrees.
180. In general, associations see improved funding as positive, offering better support
to apprentices and incentivising faster completions. They also suggested that the
increase might incentivise uptake of apprenticeships. However, a higher subsidy
must come with targets and be used to improve training outcomes.
This proposal is welcome. It will encourage the revitalisation of this important mode of
training. NZ Shipping Federation
181. There is concern from industry associations about the two-tiered funding system
and a perceived decrease in levels of funding for trainees. They stated that the
support needs of trainees are not less than apprentices and that decreasing
funding for traineeships devalues them. There should instead be equal service to
all regardless of the qualification being undertaken. They suggested complexity
of qualification delivery, in the form of a high level of theory or off-job training, not
its size should dictate funding. Some industry associations stated that this
proposal is a limited change, which is not flexible enough to meet the often
changing needs of different industries. It is also suggested that a higher subsidy
rate does not meet the needs of vocational occupations. One industry
association expressed concern that the increased funding targets off-job
providers.
We do not support any system that de-values the learning path of some trainees. CCANZ
would prefer to see a system that strives to provide equal service levels to all trainees
regardless of the qualification being pursued. Cement and Concrete Association of
New Zealand (CCANZ)
182. There is also concern expressed by industry associations around the definition of
an apprenticeship. They suggested industry should determine any definitions
used. This is an area that several industry associations suggested could be
addressed by the proposed implementation working group. Industry associations
are particularly concerned that their current qualifications will not meet the credit
threshold for apprenticeships and would lose funding.
We are concerned with the proposed definitions of “trainee” and “apprentice” and want
these definitions to have meaning for industry. Industry should be able to determine the
level and length of training as required as part of the traineeship and as part of an
apprenticeship. To have meaning for industry there needs to be mechanisms for industry
input to define “traineeship” and “apprenticeship”. Business NZ
This definition needs to be flexible enough to cater for the needs of different sectors in
our industry – and for other industries. CMITO
The definition of an apprenticeship needs careful consideration. It needs to incorporate
competency of practical skills built up over time, theoretical knowledge as well as the
basics of English and maths. Without a clear definition there is a real risk of devaluing the
Apprenticeship brand. The Institute of Refrigeration, Heating and Air Conditioning
Engineers (IRHACE)
183. Industry associations stated that they do not want the credit limit for
apprenticeships altered dramatically and that there needs to be clarity and
consultation around qualifications credit requirements. They stated that one size
32
will not fit all. Some associations stated that 200 credits is too many for an
apprenticeship. One Association suggested that 140 credits might be appropriate
as it equals two years on-the-job study.
184. There is concern from industry associations that this proposal would lead to
higher level training being preferred over level 2, both in funding and quantity of
courses. They consider level 2 training must be protected as it provides an entry
point for unskilled workers, foundation skills, pathways and transitions. Level 2
qualifications are valued by many employers because they increase the
productivity of employees.
185. Some industry associations also commented that the real costs of training to
industry should be reflected in the funding model. They suggested that a 30
percent contribution on a higher subsidy would be onerous unless ‘in kind’
contributions are recognised.
Cash contribution to NZQA based training is only part of the equation and the 30% cash
cost expected is not taking into account the true investment made. There is no
discussion here on contribution such as intellectual property, use of equipment, and
manager’s time in workplace training that industry, firms and trainees/apprentices make.
Horticulture NZ
There is a sense in the consultation document that the government is seeking to extract
100% of the outcome in return for its investment without sufficient consideration of what
industry should have returned to it. Construction Industry Council (CIC)
186. Several industry associations suggested that where a person trains should not
impact funding. Industry training should receive funding based on a formula
similar to institutional training. They stated that a graduate who meets industry
expectations is the most important factor, not where that graduate trained. One
association called for an integrated VET system with neutral funding.
An apprenticeship is an apprentice, and we assume that they will be funded equally
under these proposals whether enrolled with a tertiary provider or in a training agreement
with an ITO. CIC
187. There is also support for a differentiated funding system within the
apprenticeship system. This would implement a higher rate targeted at specific
sectors and specific professions that are important to New Zealand’s economy or
that are more expensive to deliver.
Industry Training Organisations
188. ITOs largely support a higher subsidy rate for apprenticeship training. Sixteen out
of twenty-three submitters agree with the proposal. ITOs identified the following
benefits of this proposal:

increase uptake of apprenticeships

enable ITOs to better support apprentices

improve engagement with employers and learners

encourage employers to commit to high quality/high cost training
33

more adequately reflect the higher level of theory and on-job and/or offjob learning required in these qualifications

enable them to better investigate options for training and fund more offjob training.
189. Two ITOs note that this model would not work in all sectors and that it could
devalue traineeships and penalise those sectors without apprenticeship routes.
ATTTO commented that longer qualifications are not necessarily better. They
suggested apprenticeships and traineeships should both be funded adequately
to meet the support needs of learners. SITA expressed concern that a focus on
apprenticeships could make qualifications too academic for some industries.
Traineeships could be viewed as “second-rate”. ATTTO
190. There is widespread interest in ensuring that a simple, clear definition of an
apprenticeship is developed. Fourteen submitters commented on this. Three
ITOs stated that the definition of an apprenticeship should be flexible and could
be industry specific, but should not be solely based on length of time served.
ITOs consider that the definition should include competency and theoretical
knowledge. Six ITOs advocate the Government taking a principles-based
approach, rather than a rules/credit based approach to differentiate
apprenticeships and traineeships. This would provide flexibility in meeting
industry and learners needs.
The Skills Organisation believes that a simple definition of an apprenticeship is desirable,
and recommends that any programme of over 100-150 credits at level 4 or higher be
classed as an ‘apprenticeship’, and attract a higher funding rate. TSO
The definition should be flexible enough to cater for the needs of various sectors and
industries…. to include the modular or pathways approach to apprenticeship. CMITO
We believe that the definition of an apprentice and associated support provided should
be flexible and meet a need rather than basing support on ‘time served’ in a qualification.
The definition of apprenticeships and the related funding rate therefore need to be based
on learner support requirements rather than an arbitrary credit level. ITF
191. Four ITOs rejected a potential 200 credit based definition. There was concern
current apprenticeships would lose funding if this model was adopted. A 120 to
140 credit structure was preferred. It was suggested that this was one area the
proposed VET working group could consider. Three ITOs asked for the 70 credit
per year limit to be reviewed and removed if possible.
192. Four ITOs advocate that employers’ “in kind costs” be included as part of the
employer’s contribution to the costs of training. HITO asked whether the 30
percent industry cost would be a percentage of the incorporated MAC fee
amount. They suggested that if this was the case the cost could prevent industry
recruiting an increased number of apprentices. The Hospitality Standards
Institute also recommended the establishment of a single fund for all apprentices.
The income generated from this proposed fund by its users could be counted as
part of the employer contribution.
193. Four ITOs asked for funding to be allocated on an identical basis to tertiary
providers.
34
An apprentice is an apprentice, and we assume that they will be funded equally under
these proposals whether enrolled with a tertiary provider or in a training agreement
arrangement by an ITO. BCITO
194. Three ITOs suggested that there needed to be a funding review to make it more
sustainable and to better recognise the ITO role. FITEC asked for a simple
transparent system. The Extractive Industry Training Organisation (EXITO)
suggested a differentiated funding rate based on industry. This would take into
account relative skill levels and capital costs of different industries. EXITO state
that they are finding it hard to attract high-quality trainers with the necessary
industry skills at the current funding rate.
195. TSO stated that the existing single, low rate had contributed to some undesirable
practices and that a new higher rate would improve quality of services. The
Primary Industries Training Organisation (PRITO) stated it would make funding
more equitable compared to Student Achievement Component (SAC) funded
qualifications. Three ITOs stated that higher funding rates would decrease
tensions between ITOs and providers as the funding increase would be mutually
beneficial. TSO support having two funding rates. Some ITOs state that there
needed to be clear detail around what the new rates would actually be in order
for them to comment fully.
196. Eight ITOs stressed the importance of funding at levels 1-3 and that the value of
these qualifications should not be undermined. Many jobs peak at this level of
skill and there is high industry demand for these qualifications. InfraTrain
suggested funding be increased at all levels. CMITO, the Communications and
Media ITO, suggested level 2 have the same funding as level 3.
Tertiary Providers
197. Providers are generally supportive of the proposal to introduce a higher subsidy
rate for apprenticeship training.
198. Providers suggested advantages could include recognising the higher costs of
apprenticeship training, incentivising more apprenticeships, increasing the focus
of ITOs on outcomes and greater accountability.
199. Waiariki identified two possible risks of increasing apprenticeship funding.
Trainees could be put under pressure to complete before they are ready and a
higher rate may not be passed on to the person doing the training.
200. Other issues were definitions of apprenticeship and a lack of recognition by the
Government of the in-kind costs of training. Tectra also make the point that
pastoral care is more expensive than off-site theoretical training.
[We] urge the Government to better recognise the true cost of training to industry. A 30%
contribution based on cash alone ignores the cost of time, materials and facilities – the
classroom and the teachers – that we provide to learners. ATC Professional
Independent Modern Apprenticeship Coordinators
201. The response to this proposal from independent MACs was more mixed. While
generally supportive there were divergent views over whether this would lead to
greater uptake of apprenticeships and some concern over the allocation of the
extra funding.
35
202. Smart Careers and the Southern Group Training Trust said increasing funding of
apprenticeships would not increase the uptake of apprentices. They suggested
the money would be better invested in Gateway or Secondary Tertiary Alignment
Resource (STAR) programmes. Southern Group also questioned the rationale
behind additional funding for apprentices. They said ITOs are already paid more
for an apprentice than for a trainee because an apprentice trains to level 4,
compared to a trainee that studies up to level 2. Therefore, apprentices attract
funding for a longer period.
203. Whangarei Education and Business Services were concerned that any additional
funding might go directly to the ITOs without being used for training purposes.
In the fourth year (where there is no off job training to do) the apprentice subsidises the
ITO by the full $1065 (including GST) per year. Whangarei Education and Business
Services
204. Smart Careers and the Southern Group Training Trust raised other issues
including the alignment of funding to the length of apprenticeships which vary
between different industries, the national significance of the skills being studied
and problems relating to the variability in quality of distance learning. They
suggested funding for ITPs, who provide the theoretical training, should be
increased.
Other submitters
205. Fifteen submitters commented directly on the proposal for increased funding for
apprenticeships. Three submitters support increasing the funding.
206. Three submitters from unions asked for clarification around the definition of an
apprenticeship, one suggested:
That the definition of an apprenticeship is flexible enough to take into account the shift
away from traditional “time served” measures of apprenticeships to achieving the
required skill level and competence that are needed by industry. New Zealand
Engineering, Printing and Manufacturing Union
207. One submitter said they support the formal distinction between apprenticeship
and traineeship as this offers clarity around the purpose of different programmes.
Consequently, the submitter thought there would be better differentiation of
support and outcomes. This would support better understanding of the system by
stakeholders.
208. One submitter stated that increased funding should have measurable value for
trainees and employers. Two submitters from unions noted that increased
funding would hopefully drive more off-job training that meets learners’ needs.
Another submitter expressed concern that the money will not benefit learners,
but rather be lost in ITO overheads. One submitter proposed a cash incentive to
employers to take on an apprentice. Another submitter stated funding measures
should be applicable to all providers. One submitter stated apprenticeship uptake
is restrained not through cost, but as a result of the ability to find the combination
of a willing and able candidate, an accessible off-job trainer and a competent onjob assessor.
209. Six submitters stated that increased funding at higher levels should not be at the
cost of level 1-3 provision. They commented that they do not want improved
36
apprenticeship provision at the cost of devaluing the importance of achievement
at foundation levels. They suggested that this proposal would risk excluding
certain groups, particularly those with historically low achievement. Rural Women
New Zealand (RWNZ) state that they had concerns that the aged care industry
will be disadvantaged because they do not have apprentices.
210. Submitters from unions raised a number of concerns. They noted that the
implication of the proposed scheme would be fewer learners in industry training
with higher Standard Training Measure (STM) funding and at a higher level of
qualification. They asked how this helps other Government targets around
achievement, especially Māori and Pacific achievement. They expressed
concern about split rates for traineeships and apprenticeships. Unions asked
whether the traineeship rate would also be increasing and noted that all rates
should lift as improved pastoral care is needed at all levels. Two submitters from
unions asked whether this model recognised how learners actually progress
through qualifications; they noted that learners may not necessarily progress in a
straight line upwards. One union submitter asked about what happens in sectors
that do not use an apprenticeship model.
QUESTION 6
EXTENDING APPRENTICESHIP SUPPORT
What are the benefits and risks for employers and trainees in your industry of
extending apprenticeship support to all apprentices, regardless of age?
Employers
211. The response to this proposal was unanimous: give equal support to apprentices
regardless of age.
212. Mature trainees are described as willing, focussed and more likely to have basic
skills and valuable life experience. Gravure Packaging said they have had “great
success” with trainees that are over 21 years old. Some industries comprise a
wide age range, and this may encourage employers to take on more apprentices.
This proposal would recognise the large proportion of trainees who leave school
and focus on getting a job prior to moving into a trade level qualification.
people who have failed in their early years develop better and become more settled when
in their early to mid 20’s. Active Refrigeration Ltd
213. Some employers noted a need for improved funding of older trainees. Five
employers said they have had a total of eight apprentices that were too old to be
eligible for the Modern Apprenticeship scheme.
214. This proposal may help address issues raised by New Zealand’s aging
population. It would enable all workers to pursue higher learning and this
supports employers’ retention of staff. Genesis Energy believes this proposal
would provide an opportunity for staff to retrain into new careers and would align
the skill set of existing employees to the needs of the business.
Industry Associations
215. There is strong support for extending apprenticeship support to all apprentices,
regardless of age. Thirty-three submitters support the proposal and one
submitter opposes it. Industry associations stated that the proposal would see all
37
apprentices treated equally and receiving similar support. It would also allow
employers to recruit from a wider pool. They suggested that this proposal may
improve completion rates.
Good idea. We have people of all ages entering our industries and needing training, and
our industry desires attracting individuals that are looking for second or subsequent
careers. Fitness New Zealand
It’s important to treat all apprentices equally. Print NZ
216. Some industry associations expressed concern that the proposal might have a
negative impact on youth employment. There is particular concern about how to
reach those not in education, employment or training (NEETs). Some
associations suggested that younger apprentices need more support. They
suggest a targeted approach that would support groups with historically low
engagement and people with special needs. Another suggested raising the
eligibility age for Modern Apprentices to 24. One industry association hopes that
this would mean that the term ‘Modern Apprenticeships’ would become obsolete
in favour of simply apprenticeships.
Industry Training Organisations
217. There is widespread support for this proposal: twenty submitters support the
proposal. Eight ITOs stated that the proposal would provide equal opportunity
and support for all apprentices. Two ITOs believe the proposal would reduce
duplicated costs. The proposal is seen as being able to create a simplified
system with increased flexibility. Competenz suggested that it would remove
tension between MACs and ITOs. PrITO suggested the proposal would
particularly benefit those with difficulty in literacy and numeracy. Two ITOs stated
that the proposal would improve achievement and completion rates.
EXITO endorses the proposed amalgamation of all apprenticeships into the Modern
Apprenticeship scheme on the basis that all trainees who need additional support should
be entitled to receive it. EXITO
All apprentices who deserve additional support should be given it regardless of age.
ESITO
218. The proposal is seen as being good for industry. EXITO said that employers like
the current support given through MACs. Additionally, this proposal would benefit
industries that cannot employ younger people because of risk or statutory
requirements. PGDR ITO comment that it would provide additional support to
level 4 and 5 trainees doing qualifications with major theory components.
219. Competenz are concerned that the proposal may risk discouraging young people
from taking up apprenticeships. NZITO commented that young people still need
these opportunities. FITEC also suggested that it may make NEETs harder to
reach. However, TSO state that apprenticeships would likely continue to be
focused on young people. ATTTO are concerned that this proposal might lead to
added strain on resources.
Tertiary Providers
220. On the whole, providers support this proposal.
38
221. Providers felt extending support would be a good thing because it improves
support for trainees, encourages employers to employ mature people without
industry experience and facilitates new career pathways within industry as well
as attracting people from other backgrounds.
For the trainee knowing the additional training and support are available will have a
positive impact on an older but very capable generation to try something new whilst
maintaining an income, contributing to industry and the economic health of the country.
Tectra
If people decide to have a change of career or return to work after having a family or
illness then an apprenticeship will allow them to do this as they can earn whilst they learn
and not incur a huge student debt. Waiariki Institute of Technology
222. This proposal, however, does not come without risks. According to Waiariki, the
risk to employers is that mature apprentices may have greater non-work
responsibilities increasing the difficulty in attending training outside of work
hours, while the risk to trainees is that there are fewer apprenticeships for the
young as industry prefers to take on more mature trainees due to their lower risk.
223. The Bay of Plenty Polytechnic also makes the point that a one size fits all
approach to funding disregards the “need aspect” of funding.
Independent Modern Apprenticeship Coordinators
224. Independent MACs were also positive about this proposal. Regent Training
Centre noted that this would allow more staff to participate in industry training
and could also have a positive impact on completion rates. The various letters of
support from employers and apprentices submitted by MACs also supported this
proposal.
225. The only concern raised by MACs about this proposal was that it might lead to
ITOs becoming the sole providers of modern apprenticeships.
Other submitters
226. Fifteen submitters commented on this proposal directly. All of them favour it.
Submitters noted that this proposal would:

improve equity and offer equal opportunities to all

entrench the idea of life-long learning

provide a more flexible workforce

increase consistency of outcomes and improve completion rates

decrease duplication of work undertaken by ITOs and MACs

streamline administration and provide greater transparency.
227. Two submitters noted that much of their current workforce misses out on Modern
Apprenticeship opportunities due to age. One submitter noted that the rising age
of school leavers is reducing the pool of candidates for Modern Apprenticeships.
39
One submitter suggested that older apprentices are more likely to complete their
training.
228. One submitter expressed concern that people aged under 21 years may receive
less support than currently. Submitters are concerned that this proposal might
penalise industries where there is no apprenticeship model and also industries
where trainees are seasonal and therefore are more transient in their study
pattern. One submitter expressed concern that the economy will not be able to
support jobs for an increased number of graduate apprentices. Another submitter
commented that the selection of modern apprentices needs to be more carefully
considered.
One of the main issues is selection of apprentices. You need to get the match right and if
employers have issues with this they need assistance and advice….Personality traits and
relevant work experience are important in selecting who should go where. Private
Individual 3
QUESTION 7
OPTIONS FOR APPRENTICESHIP CO-ORDINATION FEE
Which of these two options for the apprenticeship co-ordination fee is more
likely to result in better service to employers and apprentices and why?
1. The coordination fee is incorporated into the apprenticeship rate.
2. The coordination fee is not incorporated into the apprenticeship rate, and
ITOs are given responsibility for managing apprenticeship coordination
contracts.
Employers
229. An incorporated fee is supported by 76 employers, 65 of these are aligned with
Competenz. An incorporated fee is seen as simpler, more cost efficient and
easier to administer. Several employers noted their support of Competenz, and
said this ITO has a track record of effective apprentice coordination. Two
employers name the same coordinator from this ITO because he does a “great”
and “fantastic” job.
230. Employers’ rationale for supporting an incorporated fund, particularly those
aligned with Competenz, is that it will free up more money for them to take on
more apprentices, but this was not stated as an outcome of the proposal.
If putting all of the modern apprenticeship money into one fund means that more money is
available to support companies and apprentices, then I fully support this option. I am
supportive of our ITO, Competenz, they are working well with our company and are
providing us with the support that I and the apprentices need. Gillies Metaltech Ltd
I support the “one fund” approach so that more money will be available to help companies
take on apprentices. Ensign Engineering Services Ltd
231. The same 76 respondents do not want a second person to coordinate with their
apprentice. This is because it risks duplication and adds down time and
confusion for the trainee.
40
There is no point having two people coming to visit our apprentices, it is unnecessary
duplication. We find it easier to only have to deal with one person for our needs.
Goodmans
232. A further 44 submitters, also all members of Competenz, did not explicitly say
they want an incorporated fee. They are, however, supportive of their ITO. They
also said they want only one point of contact for their apprentice, for the same
reasons given above.
233. A further 49 respondents did not comment on the proposal. These employers are
equally divided between Careerforce, Competenz and unknown ITOs. Four
employers believe the status quo works well.
234. Large employers do not clearly support one option or the other. Four support a
separate fee and six support an incorporated fee.
235. A separate fee is supported by 11 employers. One employer states this approach
would increase communication. Other employers said this approach would lead
to better coordination by the ITO and more accountability for individual
apprentices. They suggested that separate funding may benefit smaller
employers. They also noted that a separate fee is less likely to be swallowed in
ITO overheads.
A separate payment will force co-ordinations to be measured and ensure they are carried
out at regular intervals. As a consequence this process will provide an auditable trail
where documentation with an apprentice signature demonstrates coordination has taken
place. Contact Energy/Mighty River Power
Industry Associations
236. Industry associations are split over whether they favour an incorporated
apprenticeship co-ordination fee or a separate fee. Eighteen submissions
support an incorporated fee, while four support a separate fee.
237. There is general agreement that ITOs should have the responsibility for
managing apprenticeship coordination funding. However, there is some support
for tying this funding to performance. Any performance measure could include
recruiting, retention, completion and offer some incentives for attracting nontraditional learners or those with specific support needs. These incentives should
go to those who hold the decision making power to implement change.
238. One association asked that the MAC role not be held by the ITO and suggested
that independent MACs could lead to higher completion rates.
We would support ITOs taking primary responsibility for modern apprenticeship as
ultimately their performance is measured on the achievements of all trainees. Motor
Trade Association (MTA)
239. An incorporated fee is seen as easy to administer and cost effective by the
associations that supported it. Some associations suggested that it would offer a
simplified funding structure for apprenticeships that would reduce waste and
duplication. This proposal is also seen as offering improved flexibility for ITOs to
meet industry needs most appropriately. One association stated that this process
must be transparent.
41
240. A separate fee is seen as offering greater transparency and specifically funding
the co-ordination role by the Associations that support it. Comment made that
there are currently some very good MACs and that industry do not want to lose
them through funding being swallowed by general ITO budgets. Those that
oppose a separate fee see it as expensive, unnecessarily complex and confusing
for employers.
241. One association asked for achievement based funding of MACs to incentivise
completions. Another asked for staggered funding to reward recruitment,
retention and completion independently. One association suggested that
Government funding for MACs and off-job training be paid directly to the
providers rather than being routed through ITOs. Another suggested making use
of the ITO optional with an annual sign up and the ability to opt out if ITOs do not
meet current industry needs.
242. Several associations commented that this was an organisational matter for ITOs
and would have little impact on industry.
243. Dairy NZ called for a full system review and said that the proposed changes are
too minor.
Industry Training Organisations
244. The majority of ITO submitters favour an incorporated fee. Fourteen submitters
support this option. Four ITOs commented that it is simple, reduces duplicated
costs and provides better value for money for Government. Three ITOs stated
that it could decrease administration costs for ITOs, industry and TEC. Two ITOs
see this option aligning accountability for qualification completion with funding.
Two ITOs stated that it would allow for better systemised coordination and
management of contracts and outcomes. Competenz said it would offer
consistent support to learners.
Simple is good. Competenz
It is less complex to incorporate the MAC fee into the training rate. Plastics and
Materials Processing Industry Training Organisation (PaMPITO)
One fee would be easier and straightforward to administer, and not something employers
should notice InfraTrain
245. PGDR ITO support having a separate fee. They commented that this would allow
funding at appropriate levels based on number of apprentices receiving
additional support. It would also be simpler to administer contracts with MACs
contracted by ITOs.
246. Five ITOs, such as TSO, want to retain the ability to contract out Modern
Apprenticeship coordination.
The ITF favours the ability of ITOs to contract and harness the skills and innovative
approach of these organisations and people [MACs] where they are in the best interests
of the learner, employer and industry. ITF
247. Some ITOs are ambivalent. TSO state they have no firm views either way as
ITOs have accountability for completions under either proposal. Instead, they
focus on the importance of appropriate ITO/MAC contracting arrangements. NZ
42
Marine commented the change would have little effect for either ITOS or MACs.
PGDR ITO stated either system is workable.
248. Some ITOs offered suggestions for how apprenticeships could be funded. PrITO
stated that the whole MAC service fee needs to be reviewed. InfraTrain suggest
prioritising funding for qualifications that are linked to key Government and
industry objectives. ITF suggest that the coordination fee should be paid as a
‘per credit’ STM rate rather than the current flat per person rate. Hospitality
Standards Institute (HSI) suggested that the fee should be paid on the basis of
outcomes not number of people enrolled. Plastics and Materials Processing
Industry Training Organisation (PaMPITO) stated that non-ITO MAC
arrangements should be ended, and sought clarification as to the exact
requirements of the coordination role.
Tertiary Providers
249. The feedback from providers was mixed on the two different funding options
proposed. Training Systems and Solutions Ltd, for example, thought
incorporating the fee was the best option as it would be simpler to manage, while
Tectra wanted the fees to remain separate as this would allow the services of
independent MACs to be retained, which they valued.
250. Providers were most concerned that effectively handling ITOs a monopoly of
modern apprenticeship coordination might lead to suboptimal outcomes. CPIT
identified two risks in particular. First, effective apprenticeship coordination under
both options would be reliant on high performing ITOs. Second, the proposed
changes would prevent providers from supporting apprentices in the workplace.
Tectra noted in their submission that there needed to be a clear separation of
funding for provision from internal ITO functions. This necessity would only
increase if ITOs receive extra funding.
Independent Modern Apprenticeship Coordinators
251. Most independent MACs were strongly against both proposals to change the
funding rates. The MACs contend the proposed changes would give ITOs a
monopoly of modern apprenticeship coordination and eliminate independent
MACs.
We don’t agree with either option as it seems to exclude independent MACs from the
funding. This contradicts proposal 4 which states ITOs should focus on their core roles
that industry value most-standard setting and arranging training. Regent Training Centre
Ltd
252. MACs question the proposed approaches to funding given the previously
substandard performance of ITOs. MACs doubt whether ITOs have the capability
to effectively manage apprentice coordination due to their poor track record of
monitoring progress and completion rates.
ITOs do not appear to be in any fit state to manage exclusively the system with any
degree of accuracy…We have, for example, identified MAs as being recorded as still
active when we have repeatedly, over a period of 12 months, reported them as
completed/terminated. Smart Careers and Southern Group Training Trust
It seems absolutely wrong that these ITOs are now being rewarded for their bad
behaviour when we have been absolutely exemplary and done everything by the book. I
43
can provide letters of support from many employers attesting to our services and the fact
that they do not wish to return to an ITO monopoly. Job Finders
253. They also raise doubts whether there will be sufficient accountability to ensure
that funds received by ITOs will be spent on training, rather than other purposes.
Funds given to ITOs for an ostensible purpose once added to the “consolidated fund” of
running the ITO will disappear forever…Whangarei Education and Business Services
254. MACs claim they perform better than ITOs in modern apprenticeship
coordination. This view is backed up by letters of support from 67 employers and
74 apprentices.
255. The letters of support claim proposals under question seven would produce
inferior apprentice coordination through ITOs replacing MACs as apprenticeship
coordinators for the following reasons:

ITOs provide services internally

ITOs have a poor performance track record

MACs are located closer to the trainees and have proven capability,

MACs are independent of ITOs and keep them accountable.
My Modern Apprentice Coordinator is trade qualified, understands what it is like being an
apprentice, knows the apprenticeship training system very well, and is there to support
me when I need it, not when it suits him. Apprentice
Given the choice we would prefer to retain the services of our Modern Apprentice
Coordinator…[ITOs] have a poor track record in delivering service directly to industry, and
have a record of charging for service they do not deliver. Amtec Engineering
256. Other comments include that funding should be allocated per trainee and that on
site/employer training should be subsidised.
Other submitters
257. Eleven submitters commented directly on this proposal. Five submitters support
incorporation of the fee and five submitters support separation of the fee. One
submitter noted that the critical factor is the employer knowing who is responsible
for managing the training process. They added that the payment structure should
not impact service level.
258. Five submitters support incorporation as it would be easier to manage, result in
less administration and be more transparent. They noted that this would require
robust quality assurance especially in the case of extensive contracting out of
this responsibility.
259. Two submitters stated that separation of the fee would increase accountability for
the coordination role and completions.
260. Three submitters are concerned that independent MACs would be lost under the
proposal and stated that they should be different from the ITO. They added that
the funds should be ring-fenced for the purpose of apprenticeship coordination.
44
261. One submitter stated that ITOs have monopolised apprenticeships, industry
training and standard setting and the proposal to incorporate the fee would
further produce an anti-competitive environment as the ITO would have control of
all funding.
Modern apprenticeship co-ordination is ‘unique and essential’ in providing a level of ‘trust
and access to industry expertise’. Plant and Food Research
There are many benefits but I question the motives of an ITO wishing to be the only
supplier of Modern Apprenticeship support. Private Individual 4
45
4. Industry training at higher levels and transferability
across sectors
Proposals
Raising the current 10% restriction on training at levels 5 and 6.
Remove disincentives to transferring between industry training and provider
courses by recognising continuation of a qualification across subsectors as a
positive outcome.
Overall
262. Submitters are supportive of raising the current 10% restriction on training at
levels five and six. In fact, many submitters state that this proposal does not go
far enough as there should be no cap on training at these levels. This is due to
the impacts of raising skill levels on higher-level qualifications.
263. Employers, ITOs and other contributors note that more training at the higher
levels would increase skill sets, which in turn would assist productivity and
meeting future challenges. They also noted that this encourages more training
and better pathways.
264. The most common concern in raising limits on training at the higher levels is that
this should not come at the expense of training at levels 2 and 3.
265. There is also consensus that recognising completions for transferring learners is
important. It is recognised this has many advantages including increased
flexibility and completions, as well as less waste of funding and learning.
266. The main issues revolving around transferability concern monitoring. Employers
are concerned that this might increase their costs, while ITOs noted that it is
difficult to monitor learning acquired in multiple settings.
QUESTION 8 INCREASING TRAINING AT LEVELS 5 AND 6
What are the benefits and risks for employers and trainees in your industry of
allowing a greater volume of industry training at levels 5 and 6?
Employers
267. Twenty employers are in support of an increased volume of industry training at
levels 5 and 6. A total of 138 submissions did not comment on this proposal, of
these 116 are members of Competenz. Several employers commented that a
greater volume of training at these higher levels would be beneficial as this
training develops skills in demand such as management capability.
268. Employers welcome the development of career pathways in their industries and
said higher learning supports staff retention and development. The benefits of
allowing a greater volume of industry training at levels 5 and 6 would be higher
46
levels of skill among technical staff and improved management capability which
would increase productivity. There would also be a range of personal benefits
for trainees including increased confidence and self esteem as a result of better
job performance. One employer noted that more theoretical training postapprenticeship addresses the gap between trades people and tertiary-qualified
employees.
It helps to increase management capability in the print and packaging industries and to
ensure a higher level of technical skills amongst technical staff. Broderick Printing and
Design Ltd
269. A total of 23 respondents emphasise the importance of funding at levels 1 to 4,
saying it is imperative that funding at lower levels is not reduced. Specifically,
levels 2 and 3 were mentioned by 10 employers from the care and food
industries as being integral to their organisation.
Our caregivers are mostly trained with level 2 (43 credits) and level 3 national
certificates…It is vital that the funding rates for entry level qualifications are maintained.
The Ultimate Care Group Ltd
270. Employers note that any increase in training at levels 5 and 6 needs to take into
account differences between industries and their differing funding requirements.
One employer said that the electricity industry would benefit from a removal of
the cap altogether. There is concern that higher-level funding may be allocated to
industries that do not require it. Dairy NZ suggested allowing more autonomy for
ITOs to allocate funding across different levels.
271. One employer wants the capability to train and assess at levels 5 and 6. This is
because on-site training at this level benefits both industry and the trainee.
272. Two employers do not believe the funding will increase the numbers that pursue
further training.
Industry Associations
273. There is general support for allowing a greater volume of industry training at
levels 5 and 6 from industry associations. Twenty-nine submitters agree with the
proposal; two submitters disagree.
274. Those associations that support the proposal stated that it would be good for
industry, as it would increase flexibility to meet higher level skill needs and would
mean that certain areas of industry would find it easier to train staff. Associations
also stated that there would be career progression benefits to the learner. Some
associations also commented that this proposal would combat significant unmet
demand for graduates at levels 5 and 6. Much of the need for skills at levels 5
and 6 is in the areas of management, leadership and human resource
management.
We know that there significant unfilled demand for graduates at Levels 5 and 6 and that
demand will continue to increase as the high technology sector builds through the
Advanced Technology Institute’s activities. The Institute of Professional Engineers
New Zealand (IPENZ)
275. Associations also noted that there would also be flow-on benefits for lower-level
study. Trained managers would be more likely to train their staff and to value the
benefits of skills and training in their staff. This would result in improved
47
completions. Greater volumes of higher-level training would support employers to
keep pace with technological developments and encourage innovation. This will
assist industry with future challenges, including the aging workforce.
DairyNZ has indicated to government and the ITO that it wishes to shift emphasis to
level 5 of the NZQF. We see two main benefits in this shift in emphasis: firstly, our
research indicates that improved management capability is strongly correlated with
increased productivity in the dairy industry and as we have a low base of management
capability there are significant gains to be had by incentivising improved management
capability through higher uptake of production management and business management
diplomas; secondly, we believe managers that are more highly educated themselves are
more likely to value training of their staff and therefore are more likely to support their
staff through training. We therefore would expect to lift participation and completion
rates of lower level trainees once we have raised the level of competency of our
managers. Dairy NZ
276. Some associations commented that the restrictions provide no benefit and that
provision should be driven by industry needs rather than what they saw as an
arbitrary Government cap. Many questioned the need for any cap.
We see little benefit in having restrictions at any level. The key criteria should be whether
or not the system is delivering benefits to industry and trainees. It is difficult to see how
placing restrictions can do this. NZ Shipping Federation
277. One association suggested that this proposal may encourage ITOs to compete
with other established industry qualification schemes and could lead to
duplicated qualifications resulting in confusion for employers. One association
suggested that the ITO system may not be the best vehicle for delivering higherlevel training.
278. There is also concern that the proposal may impact on funding and levels of
provision at levels 1 to 4. Many associations stated that there is no current need
for skills at levels 5 and 6 in their industries and that they need to continue to
build a qualified workforce at levels 2 and 3. There is concern that the proposal
may limit choice and decrease ITO responsiveness to changing industry needs
and priorities. There is concern that this proposal may over-qualify the workforce
in some industries. This may lead to highly qualified people leaving New Zealand
for better opportunities overseas.
Industry Training Organisations
279. There is strong support for increasing the volume of trainees at levels 5 and 6
from ITO submitters. Eighteen submitters support this proposal. Four ITOs state
that there is increasing demand from industry for higher-level skills and that this
proposal would better equip ITOs to meet their demand for training at this level.
Four ITOs stated that the proposal supports higher-level pathways. NZ Marine
suggested that increased targets will encourage graduates to stay in training and
to stay connected to their industries. HITO stated that it will increase uptake at
this level. TSO said it will help meet Government skills targets. It also supports
the greater freedom to design programmes and services at this level. InfraTrain
suggested that the Christchurch rebuild may drive skill need at this level.
...supports pathways to higher achievement which in turn aids productivity within technical
and management roles. ATTTO
48
280. ITOs are concerned by the cap on provision at this level. Five ITOs stated that
there is no need for a cap, as need will drive provision. Two ITOs said that
arbitrary limits are inconsistent with government policy. Five ITOs stated that
lifting the level does not go far enough and that, instead, it should be flexible and
driven by industry skill needs rather than Government targets. TSO suggested
that a 20% should be the starting point rather than the end point. HITO
suggested that if the cap is reached it should be reconsidered. Competenz stated
that any cap should be implemented at sector rather than ITO level.
The need and rationale for a cap on training at Levels 5 and 6 is not clear….We
recommend that there is no cap applied and that the arranging of training above Level 4 is
flexible and driven by industry. PrITO
No funding cap be applied to level 5&6 programmes. Market forces will determine the
volumes of training at higher levels. If industry requires skills at level 5 & 6 then
programmes at these levels should also be eligible for funding. PaMPITO
281. Three ITOs also expressed concerns that provision at levels 5 and 6 should not
at be at the expense of provision at levels 2 and 3.
Tertiary Providers
282. Providers are generally supportive of the proposal to raise the current restriction
on training at levels 5 and 6.
283. Providers stated that the proposal will result in more workers with greater skill
levels thereby increasing productivity. Providers also noted this will allow them to
respond to industry requirements. This proposal would support continuous
professional development and career pathways as well as improving the
incentives for ITOs and senior managers to up-skill workers.
Capping training at 10% of total does not allow providers to be flexible and responsive to
industry or sector requirements, and provides an artificial barrier to training. Blueprint for
Learning
This provides for a more complete pathway and options for continuous professional
development. Training Systems and Solutions Ltd
284. ITI suggest this proposal would also support the Government’s Better Public
Services targets, but doubt whether lifting the cap would increase participation
and completion in higher-level training.
285. The Bay of Plenty Polytechnic outlines the following risks of this proposal:
Risks – assumption that the ITOs are best positioned to support the ‘train the trainer’
model with on site managers & supervisors (from an educational capability/expertise
standpoint). Much of this is done quite effectively within current delivery structures. If
the 10% cap is raised, providers will still play a role in training (based on current/likely
future qualification structure), so could see a sub-contracting arrangement which may
not be best use of funding. Bay of Plenty Polytechnic
286. More broadly, five submitters expressed concern that levels 1 to 4 will be
overlooked. More emphasis on higher-level qualifications might result in
marginalisation of learners at levels 2 and 3. It was noted that lower-level
qualifications are vital to business and trainee development.
49
Level 2 and 3 qualifications contribute significantly to the productivity of the businesses
we are working with, and the reality is that for many, a qualification at this level is a huge
achievement. ACT Safety Ltd
Independent Modern Apprenticeship Coordinators
287. Independent MACs agreed with this proposal.
288. In a similar fashion to the providers, Regent Training Centre believe this would
be beneficial for productivity by raising skill levels of workers, while Whangarei
Business and Education Services noted this will help to address current skill
shortages.
Other submitters
289. Thirteen submitters commented on this question directly.
290. One submitter stated that this would produce a more skilled workforce. Some
submitters stated there is a real need for qualifications at levels 5 and 6 in their
industries while other submitters indicated there is only low-level need for
qualifications at higher levels. Three submitters from unions support a rise in the
level allowed to 15-20% as this would allow flexibility and would be of clear value
to workers.
291. The Tertiary Education Union believes that it will be necessary to recognise the
need for strong partnering between ITOs and ITPs and other providers to
delivery courses at this level. It said that it has strong reservations about the
capacity of workplace training to deliver robust level 5 and 6 qualifications.
However, one submitter is concerned that this proposal may result in the
duplication of courses already delivered by other providers and that this may lead
ITOs to disengage with other providers in the sector.
292. Four submitters commented that this proposal should not be implemented at the
expense of levels 2 and 3 training. One submitter commented that industry
needs people with a range of skills to perform the tasks that need to be done.
They added that over-qualification leads to worker dissatisfaction.
As long as this does not detract from encouraging all support staff to engage in training at
a level where they can achieve successfully (e.g. levels 2 and 3). Age Concern New
Zealand
293. One submitter said that there should be no arbitrary cap on provision. Industry
need should drive the provision of training at all levels.
QUESTION 9 TRANSFERRING BETWEEN TERTIARY SECTORS
What are the benefits and risks of recognising completions for learners who
transfer between tertiary sectors?
Employers
294. Eighteen percent of employers commented on this proposal; 31 favourably and
three express mixed views. Large employers responded more widely. Their
response was similar to all employers with 15 out of 18 generally supportive.
50
295. Employers stated that the benefits for trainees would be having their prior
training recognised, and that they would more likely to complete qualifications
and complete higher levels of qualifications. One employer noted that trainees
could switch to apprenticeships.
296. Transferability supports greater flow of talent between industries and sub sectors
and encourages skill transfer. One employer noted that transferability would align
with NZQA objectives, and another suggested transferability would be enhanced
by outcomes of the Targeted Review of Qualifications (TRoQ).
A basic premise of the NZQA system was for learners to build there [sic] skills and
knowledge over time, and that this learning could come from a number of appropriately
recognized providers. Framework
297. One employer describes the status quo as legalising an effective monopoly.
The unit standard should not be held back until all the theory training is completed as it
currently occurs with some technical institutes. The current actions by these technical
institutes are not in the best interest of the apprentice to gain employment. Aspec
Construction
298. Employers called for clear guidelines for transferability. They emphasised that
they require accurate records of what the employee has learnt during their
training as part of a qualification record. Two employers suggested unit
standards should be logged with NZQA as they are attained and that NZQA
should cross match standards across tertiary providers. One employer suggests
transferability is best suited to generic courses.
299. One employer stated that there is an increased likelihood of losing trainees partway through training.
Industry Associations
300. Industry associations generally support recognising completions for learners who
transfer between tertiary sectors. Twenty-six submitters support this proposal.
Several associations indicated that this is not currently an issue in their sectors.
301. Industry associations stated that this proposal would be good for both industry
and trainees. Several associations indicated that transferability already happens
in their sectors. Some associations suggested that wider implementation would
allow increased flexibility and mobility for trainees and that it would improve
retention and completion. They suggested it would enable industry to maintain
capability through low cycles and open up sectors to wider employment pools.
They stated that the proposal would encourage life-long learning. Furthermore,
associations stated that it would not penalise providers or ITOs for things that are
outside their control. They suggested that funding needs to follow the learner
when they transfer.
The flexibility put forward by this proposal is a good example of how the tertiary sector
can be more responsive to the changing needs of industry. Horticulture New Zealand
When business conditions are tight, some earn-as-you-learn trainees are let go, but these
conditions are often cyclical and therefore temporary. These trainees should not
experience barriers to continuing training…When business conditions pick up and
demand for labour and skills increases there should be little barrier for trainees in other
parts of the tertiary sector to transfer to the earn-as-you-learn environment. Dairy NZ
51
302. Some industry associations stated that this proposal fits with and would be
enhanced by TRoQ. Others commented that it would be difficult to assess
progress without unit standards, which they see as endangered by the TRoQ
process.
303. There is some concern that this would promote skills development in simulated
environments. Many associations are strongly opposed to allowing qualifications
with no practical work-based component. Some associations do not support
apprentices transferring to a provider to complete their apprenticeship. There is
also concern about how industry timeframes and provider timeframes may mesh
and whether this potentially would make transfer difficult.
…any such system that enables transfer must be done with Industry approval and not
upset the current system that enables employers to be a very strong part of the
development of early training on the job. ECANZ
…it needs to be recognised that on-the-job learning cannot be simulated at a provider and
we therefore do not support the transfer of apprentices to providers to complete their
apprenticeship. Bakery Industry Association of New Zealand (BIANZ)
304. Some associations stated that design and implementation of the proposal is vital.
They said that collaboration across the tertiary sector would be necessary and
commented that there is a need for well-integrated data systems otherwise any
system will be difficult to manage.
Industry Training Organisations
305. There is strong support from ITOs for recognising completions of learners who
transfer between the tertiary sectors. Eighteen submitters support this proposal.
Two ITOs noted that it was not a major issue in their sectors.
306. Three ITOs stated that the proposal would increase flexibility for, and remove
disincentives to, trainees moving across qualifications and providers. The
proposal would put learners’ needs at the forefront. Four ITOs stated that this
proposal would ensure that providers and ITOs are not penalised for things that
they cannot control. TSO suggested the proposal could improve outcomes,
improve service quality and allow flexible and innovative solutions to meet skills
needs, for example, in the Christchurch rebuild. Two ITOs stated it would
increase collaboration between ITOs and providers. ATTTO suggested it would
reduce the waste of funding and learning that currently occurs when a student
transfers. Careerforce stated that this ensures all tertiary education providers
who have contributed to a learner are recognised.
Removing disincentives to move would retain learners in the VET sector and result in a
training environment that is more responsive to changing needs of employers, workers
and students. ITF
Support the recognition of transfers because often events in trainees’ lives that interrupt
their training are beyond a provider or ITOs control. PaMPITO
307. ITOs are concerned about how the proposal will work in practice, that is, how
learning would be recorded so that learners could transfer easily. Two ITOs
stated that it is currently relatively easy to go from a tertiary provider to on-job
provision, but the reverse is not true due to ITO flexibility. Increased provider
flexibility and collaboration across the tertiary provision sector is likely to be
needed. Three ITOs stated that transferability might be more difficult in the
52
current NZQA and TRoQ environment. They also suggested that moving subsectors was likely to be difficult under TRoQ. MITO suggested that it may be
difficult to monitor vocational learning acquired in multiple settings. Four ITOs
commented that any system must be unit/assessment standards-based to
ensure transferability. HSI suggested the use of an ePortfolio across providers.
The aim is admirable and we support it – if it can be made to work. Competenz
The ability to transfer between providers and workplaces is important. There is a
disconnect between TEC/NZQA and MOE around the currency that will be used for this to
work. If unit standards are not used in qualifications what then is actually recorded on the
trainee’s Record of Achievement? HSI
308. Four ITOs stated that if the proposal were to be successful it would require the
development of well-integrated systems for tracking learners and their learning.
Tertiary Providers
309. Overall, providers who commented on this issue supported the proposal.
310. Providers stated the benefits of transferability are that it would:

respond to trainees’ changing life circumstances or employment
situations

increase completion rates

respond to industries’ changing labour demands, for example, as a result
of an economic downturn

improve career pathways within industry

allow multi-qualified staff to contribute to industry

recognise that learning and assessment can take place in multiple
contexts

reduce tension between on- and off-job training.
Employers can take on apprentices part way through training when they have learnt the
basic skills and are of some use to them. Trainees can go into employment sooner if they
can transfer their learning from full time training into an apprenticeship. Wairariki
Institute of Technology
When the economic situation dips there is a significant dropping of apprentices as
industry reduces staff. This leads to a lack of qualified trade’s[sic]people when the
economy recovers. By enabling a trainee to complete through a tertiary provider a pool of
qualified people is ready. Christchurch Polytechnic Institute of Technology (CPIT)
311. Providers noted more accurate tracking of trainees’ progress will be required if
the proposal is to be successful. The Bay of Plenty Polytechnic said the variety of
ITOs’ trainee tracking methods would inhibit implementation of this proposal. It
53
also asked how funding would be affected if a trainee left part-way through their
qualification.
Independent Modern Apprenticeship Coordinators
312. Independent MACs were also supportive of this proposal with Southern Group
Training Trust and Regent Training Centre noting that advantages included:

supporting the primary purpose of pre-trade courses

ensuring ITPs and EPIs are not negatively affected by positive outcomes,
such as a trainee on a pre-trade course moving into an apprenticeship.
313. Whangarei Business and Education Services stated that the benefits was
numerous and this proposal would be important in increasing responsiveness to
changing labour market demands.
314. There were, however, some concerns with this proposal.
315. Regent Training Centre contended that the risk of the proposal was that ITOs
would be less accountable. Apprentice retention rates could fall if the ITO sees
returning to polytechnic as a positive outcome when employment is the aim.
According to Regent, this would be a backward step for industry.
316. Whangarei Business and Education Services were concerned that cross
crediting arrangements could be “time consuming, costly and ineffective”.
In some cases even within the same industry, transferring between disciplines results in
trainees having to go back to “year one” because their units already achieved on NZQA
for one qualification are not compatible with the units required for the new intended
certificate. Whangarei Education and Business Services
Other submitters
317. Fourteen submitters addressed this proposal directly. Some stated that this is
already happening in their industries.
318. Most submitters reacted favourably. Submitters stated that the change was long
overdue and that the skills and knowledge gained are what is important, not
where they were gained. Others said that the proposal provides transparency for
employers and reassurance for learners that their learning will be valued and
recognised. It also reflects the current job market and peoples’ geographic
transiency. Four submitters stated that this did not penalise ITOs or providers for
things outside their control.
319. Two submitters stated that there are practical issues around funding incentives
for providers to enable this proposal to succeed. One submitter suggested that
some units may need to become more relevant.
54
5. Quality assurance
Proposal
ITOs focus on the standard setting function for their respective industries.
Lead qualification developers will manage the process for assuring the consistency
of graduate outcomes.
Review of unit standard quality assurance settings will be undertaken with the view
that unit standards will be flexible and able to be contextualised to different settings.
Overall
320. There is widespread support for ITOs focusing on the standard setting function
for their respective industries. In their development of standards, ITOs are
generally regarded as being highly capable at coordinating industries and
employers. However, some providers and MACs noted one of the problems is
that a conflict of interest arises from ITOs not only setting standards, but also
arranging training.
321. Some submitters noted that there are opportunities to improve the current
arrangements by:





linking standard setting to compliance
involving the standard setter in quality assurance
ensuring funding is available
improving the performance of ITOs
placing more emphasis on developing and updating unit standards.
322. There is some concern that the use of common standards may not meet the
needs of particular industries and that standards may not able to be
contextualised or made relevant. One submitter did not want the use of ITO
training materials to be made compulsory. Another submitter noted that ITOs use
the standard setting role to control rather than encourage delivery.
323. While there is support for more and better moderation, there are various
suggestions for who should undertake the role, what should happen and how it
should be funded. There is support for qualification developers, ITOs, tertiary
providers, an independent inspectorate, or NZQA undertaking the role.
324. There need to be objective benchmarks rather than subjective assessment.
There are a range of views about what should be moderated, including that:

all unit standards should be looked at,

unit standards in critical areas should be looked at,

sampling of unit standards, or
55

unit standards should be looked at when risk is identified.
325. Moderation and consistency need to be funded, possibly through the credit
rebate, a levy, or reporting fees to NZQA. There are concerns, employers have
to bear increased costs.
326. Comment was made about the TROQ. Some submitters support the TROQ
process because it will rationalise unit standards, reduce duplication of
qualifications and focus on learner outcomes.
327. There are concerns about how quality and consistency within and across unit
standards will be handled and funded. Standard setting should be connected to
the national quality assurance processes with a focus on quality and consistency
of qualifications. Unit standards should focus on learning outcomes. Credit
values may need to be revised to ensure they are appropriate. Further
clarification about standard setting, including the relationship between unit
standards and TROQ, was raised by some stakeholders.
328. Some submitters support unit standards as a common currency while others do
not. There was a concern that there could be a proliferation of programmes and
unit standards. One submitter considers that all programmes should use unit
standards. There were also comments about the need for workplace-based
training, as well as the place of simulated situations. One submitter considers
that the length of time (one year) to change qualification content is too long.
329. Further work could be done to strengthen NZQA’s quality assurance processes
relating to employers and trainees. There is a question about how NZQA could
approve programmes without industry-endorsed expertise.
QUESTION 2 STANDARD SETTING
In your view, what are the benefits and risks for employers and trainees in
your industry of retaining ITOs’ standard setting function and allowing tertiary
providers and other ITOs to use ITO-developed standards more freely?
Employers
330. The bulk of submissions, 145 or almost 80%, did not comment specifically on this
proposal. Of those that did, 29 employers are broadly supportive of the proposal.
Those that support the status quo describe this as a useful mechanism
necessitated by the fragmented training industry and the number of employers.
ITOs are well placed to coordinate diverse employers, set standards and
qualifications based on industry needs. Employers suggest that ITOs do this well.
Twelve of the eighteen large employers supported this proposal. However, they
stated that industry involvement is required to ensure relevance of standards.
The ITO is proactive in setting the relevant standards within the industry and continue to
develop and review these. APN Print NZ
The requirement for sector employers to have a significant say in the setting of standards
with the ITO. PSC Enliven.
331. Large employers noted that sharing ITO developed standards would improve
cost efficiency, drive standardisation and help create generic standards that
56
apply across industries. In addition, this approach may support employers’ use of
training materials from multiple ITOs.
Highly collaborative practices leading to common tools would also suitably lower costs to
the ITO (and by extension industry) through mitigating the risk of high costs caused by
moderation across a large range of resources. Fonterra
Our industry has several skills common to others eg. petrochemical. If the standards exist
it would be more efficient to adopt them than develop and moderate our own. Contact
Energy/Mighty River Power
332. Downer New Zealand stated there is a risk that ITO standard setting and sharing
could cause duplication. They also noted industry may lack a central point of
contact. Another employer stated that they do not want ITOs to impose the use
of their training documents and trainers.
333. The ten employers that do not support this proposal describe ineffective services
from their ITO negatively impacting trainees and employers. They restate the
concern that training providers pursue commercial interests at the expense of
trainee and industry requirements. KiwiRail Interislander offers their experience
as an example. It stated that Competenz is the ITO for the maritime industry and
the statutory training provided by it is, in some instances, twice as long and costs
twice as much as qualifications that meet international requirements. KiwiRail
Interislander is therefore critical of a funding structure that prioritises the number
of courses on offer and said a proliferation of courses have resulted. Many of
these courses are irrelevant for trainees, are not linked to employment
opportunity and not aligned with industry needs.
The lack of any meaningful ITO has led to the training organizations setting the course
duration and content…The training provider is funded on course content and duration and
even basic training for ab-initio seafarer is overly complex and time consuming against
worldwide standards. KiwiRail Interislander
Industry Associations
334. Industry associations generally support the proposal for ITOs to retain their
standard setting function. Twenty-nine submitters agree with this proposal.
Associations strongly support industry having the right to clearly specify
standards within qualifications. They stated that this proposal puts industry,
through ITOs, at the heart of standard setting and quality assurance. ITOs
should design qualifications with and for industry and should be required to
consult widely with industry in fulfilling this role. This gives industry confidence in
the qualifications. Some associations noted that TRoQ should ensure high
quality consultation occurs. Several associations said that ITOs currently perform
this role well and that this is the role industry values most.
Proposal 2 would indicate Government’s wish for industry to define its training needs and
we fully support this approach. Print NZ
The NZMPTA supports initiatives to focus ITOs on the roles industry values most, the
setting of standards in concert with industry and arranging the training. NZMPTA
ITOs must work closely with industry to ensure the outcome of these standards meets the
needs of a number of parties – the employer, apprentice, regulator etc, and that they can
be realistically delivered by the training provider. Master Plumbers, Gasfitters &
Drainlayers NZ
57
335. Some associations stated that industry should determine skills need and that
these should then be conveyed to ITOs who set standards and ensure that these
are coordinated with NZQA and NZQF. One association suggested that ITOs
and industry should share the standard-setting role. Some associations
commented that industries may wish to undertake this role themselves and this
should be an option. In particular, there is concern from industries with well
established industry qualifications that ITOs were duplicating qualifications
leading to confusion for employers and to decreased credibility for all
qualifications.
Skills Active has been a follower, not a leader, in terms of standards setting; it has
consistently duplicated the standards set by others and represented those on the NQF
(we acknowledge this may not be the case in other industries served by Skills Active). Its
standard setting work has blurred the picture for employers and trainees leaving
significant parts of the sector confused; this has been unhelpful, not constructive. The
standards set by Skills Active have at times been woefully low; in particular we have
challenged their minimal requirements for people to become assessors and lack of
‘policing’ to ensure even the low standards are being adhered to. Past experience has
been that their standards are used far too freely and this has resulted in a lack of
credibility. New Zealand Outdoor Instructors Association
On the matter of ITOs using each other’s standards, there is little doubt that the present
‘exclusive’ nature of standard ‘ownership’ has contributed to widespread duplication.
This is a matter that should be addressed in the context of the Targeted Review of
Qualifications. New Zealand Shipping Federation
336. Several associations support ITO-developed standards being used more freely.
They noted that TRoQ addresses shared unit standards and should facilitate this
process. They stated that this would improve consistency of delivery and
outcomes. Associations also commented that increased contextualisation by
providers would provide better potential for programmes to adapt to the
increasingly fast pace of industry’s changing needs. This would make
programmes more attractive to employees and increase uptake.
…supports the move toward a smaller number of standards delivered in context over the
proliferation of situation-specific standards. Where possible, CCANZ supports the use and
re-use of standards to ensure consistency. CCANZ
ITO developed standards, (if the development is government funded), should be available
for use by all, including other ITO’s, providers and employers. There should be no
ownership, just a responsibility to maintain by the developing industry and ITO. ECANZ
337. Some associations identified a possible risk if industry standards are used too
widely that they may lose their industry-specific meaning and may cease being
used by employers. Additionally, there is a risk that consistency and quality of
achievement may be compromised with increased contextualisation. Guarding
against this will require robust moderation and quality assurance.
Giving in to desires to genericise specific sector skills has a danger of creating
meaningless qualifications that industry no longer values or relates to. Association of
Wall and Ceiling Industries (AWCI)
338. One association stated that although ITOs understand the match between
industry needs and NZQA rules, sometimes ITOs are forced to make changes to
qualifications to meet NZQA requirements. Often, industry does not understand
the rationale for these changes. It was also noted that there is rigidity and
inflexibility in the current system where ITOs coverage intersects. One
58
association said that standards are not rigorously enforced and that ITOs should
take stronger measures.
Industry Training Organisations
339. There is strong support for retaining the standard setting role from ITO
submitters. Nineteen submitters support this proposal. Six submitters stated that
ITOs are best placed to hold this role because of their strong industry links. Nine
ITOs commented that industries see this as a critical ITO function. This is
because it ensures that qualifications reflect changing skills needs of sectors,
contextualise learning, and offer cost effectiveness, ultimately resulting in
employees with broad-based skills.
340. There was a range of comment on the standard setting role. Two ITOs stated
that ITOs must be the lead developer for all vocational qualifications. Four ITOs
commented that ITOs as the standard setter must be involved in all quality
assurance. FITEC suggest that standard setting should be linked with
compliance. Four ITOs stated that the standard setting role needs further
definition and enhancement. Two ITOs said TRoQ should help address this.
ATTTO suggested that ITOs should act as a bridge between sectors and VET
providers. Competenz commented that ITOs should be funded separately for this
role.
341. Two ITOs stated that while it is acceptable for providers to contextualise
standards, learners must earn competence according to prevailing industry
expectations. TSO support the separation between the standards setting role
and offering optional learning and assessment materials. However, BCITO stated
that it is its experience that providers want to use ITO generated material, rather
than developing their own. BCITO also suggested that the ability to contextualise
standards may not aid the adoption of common standards, rather it may retard it.
NZITO stated that there are differences between skills learned on-job and those
learned in a classroom setting, especially in high capital expenditure based
industries. There therefore needs to be a separation between unit standards
developed for industry specific skills versus institutional learning environments.
342. PGDR ITO commented that in principle ITO developed standards should be
freely available. However, this is complicated by licensing requirements in
industries that are heavily regulated. In this case, it may be necessary for the ITO
to develop common learning and assessment materials to help achieve national
consistency.
343. Four ITOs expressed concern about NZQA and the TRoQ process and how this
could impact on the standard setting function. In particular, there is concern that
the needs of industry may be lost in the process. There is also a concern that
TRoQ favours providers over ITOs. Two ITOs suggested that NZQA need to
develop flexibility in their processes around unit standard development to enable
ITOs to work more effectively, efficiently and speedily to meet industry needs.
TSO also suggested that the interface around NZQA/ITOs/MoE needs to be
recognised and enhanced, especially around qualifications expiring.
344. ATTTO suggested there is a risk that ITOs may view themselves as ‘the voice’ of
the sector.
59
Tertiary Providers
345. There was mixed feedback on this question. Some providers supported ITOs
retaining their standard setting function. Blueprint for learning said ITOs should
focus on standard setting. They argue support from ITOs to ensure standards
are met allows providers to provide training flexibility and efficiency. Tectra
maintained ITOs should act as coordinators of standard setting with cooperation
from providers. The TRoQ process was described by Tectra as an excellent
example of how ITOs can coordinate without owning the process. The
qualifications developed through the TRoQ process were described as
appropriate to industry and trainers.
346. Other providers are opposed to ITOs retaining the standard setting function. Four
providers stated that ITOs retaining the standard setting function creates a
conflict of interest for ITOs and can lead to misuse of power. It can result in ITOs
and providers being in competition for the same funding. There was concern
ITOs use their standard setting role to control, rather than encourage training
delivery. Unitec and Manukau Institute of Technology claim ITOs set standards
to benefit their training methods and generate revenue. They suggested the
NZQA is better suited to standard setting and ITOs should become just training
providers. Despite this tension, the CEOs of the Metro ITPs, the NZITP, and the
ITF submitted collaboratively suggesting a VET working party.
The ITO’s should not be both a Training Provider and a Standard setting Organisation. If it
does then a continuation of the past misuse of its privileged position as a standard setter
will continue, whereby it sets the standards which benefits their training methods and
makes it difficult for competitor providers such as tertiary institutions. Manukau Institute
of Technology
347. Providers were largely supportive of the proposal to use ITO developed
standards more freely. It was noted by one provider that standards are a public
good. Some providers suggested the proposal would offer employers greater
choice, as providers can better tailor courses to meet skills needs in a variety of
settings. However, it was emphasised by some that adoption of ITO materials
should be optional and not a mandatory requirement.
Independent Modern Apprenticeship Coordinators
348. Independent MACs feedback on this proposal was similar to other providers in
that the value of ITOs in standard-setting was acknowledged by some, but there
were also concerns about the performance of ITOs in this context. Southern
Group Training, for example, stated they valued the role of ITOs as standard
setters in consultation with industry. However, they were concerned there were
flaws in the consultation process with industry to ensure qualifications were
relevant and questioned the quality of materials ITOs developed for training
purposes.
349. MACs strongly supported providers being able to use ITO developed standards
more freely. Whangarei Business and Education Services noted there were
several possible benefits of this including:

potential standardisation and sharing of best practice

the possibility of lower prices through increased competition between
ITOs and training providers
60

greater choices for employers.
Other submitters
350. Fifteen submitters addressed this proposal directly. Fourteen submitters support
the proposal. One submitter stated that ITOs have mostly done this well. Two
submitters stated that ITOs should retain this role because they are a single
recognised body that is in and of the respective sectors and can therefore
adequately reflect that sector’s skills needs.
This function lies at the heart of ITO’s role in our VET system (and that of comparable
international bodies) Ako Aotearoa: The National Centre for Tertiary Teaching
Excellence
351. Five submitters stated that they support more flexible use of ITO developed
standards as learning occurs best when contextualised to a learners needs.
However, they noted quality assurance is an important consideration. One
submitter strongly supports TRoQ. Another submitter stated that delivery of
training must be moderated and that providers should not be able to deliver
training if they did not agree to ITO moderation. One submitter stated that
standards would only be used more freely in the short term. Long term, in a
competitive environment, providers would seek a point of difference and develop
their own materials and certification.
352. One submitter suggested that some providers do not currently believe in the
academic rigour and industry relevance of ITO developed qualifications. This has
led to them developing their own qualifications. A closer model of collaborative
working should address this.
QUESTION 10 EXTERNAL MODERATION AND MANAGING CONSISTENCY OF GRADUATE
OUTCOMES
How should external moderation and managing consistency of graduate
outcomes be conducted and funded to ensure learners are consistently
competent while minimising compliance costs and enhancing collaboration
across tertiary sectors?
Employers
353. Less than 20% of employers’ submissions responded to this proposal. Overall no
single view dominates about how to conduct moderation. However, employers
agree that there should be no additional fees imposed for auditing levies.
354. Employers acknowledge the importance of moderation and consistent graduate
outcomes. They noted that poor outcomes can result from quality failures;
examples given include ‘leaky homes’ and the CTV building collapse. Employers
stated qualification developers must be monitored closely by industry and it was
important to have competent moderators.
355. Five employers said industry should be involved in moderation through ITOs and
one employer believes ITOs should be funded accordingly. Another employer
61
suggested separate funding for external moderation of unit standard assessment
and for management of consistent graduate outcomes.
356. Other suggestions for moderation included:

using industry’s technical advisors as moderators

the provider of the training providing assessment

using an independent Government entity similar to ERO.
357. Suggestions for managing consistency of graduate outcomes include:

break down qualifications to elementary level unit standards

focus funding on high risk, industry-critical standard assessment

redistribute credit rebates from other standards to support the
management of consistent graduate outcomes

greater input from NZQA.
NZQA must actively assess the learning standards which providers state their
programmes achieve. Gravure Packaging Ltd
358. Contact Energy/Mighty River Power asked for increased collaboration and
communication between industry and the NZQA, saying
Industry must identify what the content should be, assist with the delivery of the training
and be able to moderate the outcomes, to give it credibility. NZQA needs to have
assurance from Industry that skill identification is current and correct and Industry needs
assurance from NZQA that assessment is at the standard that industry requires. Currently
we see little dialogue between parties involved.
359. Some employers also noted courses should not be assessed by individual skills,
but on the basis of the whole course. In addition, there was some concern that
moderators should be independent of qualification developers to ensure quality
outcomes and that consistency was limited to only the ‘critical’ elements of
trades.
Industry Associations
360. Industry associations presented a range of views around how external
moderation and managing consistency of graduate outcomes should be
conducted and funded. Several associations asked for more information on this
proposal. Industry associations generally agree that the whole training system is
dependent on high quality, consistent moderation and the moderation system
must therefore be simple, robust and reliable. Employers must have confidence
that all graduates from the same qualification are equal and there must be limited
local variation in outcomes. Some associations stated that moderation should be
funded.
Funding should be directly available for moderation activities to ensure compliance and
maintain skill standards and educational outcomes. Pine Manufacturers Association
62
361. Some associations expressed concern at the proposal to only moderate “critical”
skill standards.
We believe that if the word “critical” is narrowly defined, then this will be detrimental to the
productivity and skills of workers in our industries. Fitness New Zealand
362. Several associations suggested that ITOs are best placed to have a moderation
role. This is because it best sits with the qualification developer. They stated that
the current system works well.
A system with strong moderation to ensure consistency of graduate outcomes is best
owned by the ITO who leads our industry qualifications. NZ Heavy Engineering
Research Association
363. Some associations want clearer accountability around how ITOs manage
moderation to ensure it meets industry needs. One association suggested more
effort should be put into moderation and this should be incentivised with
increased funding. Associations stated that moderation should not be diluted for
ITO or provider convenience. One association suggested a stakeholder survey to
measure ITOs’ and training providers’ performance in managing moderation
processes, as part of the feedback loop with MBIE and TEC. Another association
called for moderation to be evaluated across the whole industry training system.
364. There is also some support for moderation being undertaken through
collaboration between ITOs and industry organisations/associations. One
association suggested the sector body alone should undertake moderation.
Several associations stated that it is essential that training in their sectors is
moderated by a skilled person from the sector and independently audited.
Moderators should be nominated by an industry group or advisory group
independent of ITOs and providers. This way there is no funding incentive for the
moderator in their decision making and they are not captured by either ITP or
ITO priorities. The cost of this should be split between Government and industry.
Collaborate with the industry organisations/associations as industry is ultimately the end
user of the training and the good and not so good will soon be identified. Institute of
Quarrying New Zealand
It is essential our members are able to have input on the design of the assessment and
moderation processes NZ Heavy Engineering Research Association
365. Some associations stated that ITOs must manage the process for ensuring
assessment outcomes are consistent and meet the standards required by
industry. They stated that ensuring consistency of training is very important in
minimising variance in training outcomes. Some associations commented that
managing consistency of graduate outcomes should be funded.
366. There is no general agreement on how moderation and managing consistency of
graduate outcomes should be funded. There is support from associations for
moderation and managing consistency of graduate outcomes to be funded
through retention of the current credit rebate. One association suggested a flat
levy that would be paid to qualification setters to fund this. The qualification
setters would then be responsible for, and accountable to, industry and
Government for the spending of it. This would ensure transparency. However,
some associations stated that they did not want this function to be funded
through a levy. Other associations stated that ITOs funding for moderation and
consistency activities should be separate from funding for the arranging training
63
function. Associations stated that compliance costs should be minimised so that
employers do not face increased costs. This is particularly important at levels 2
and 3.
Industry Training Organisations
367. There is a range of views from ITOs on how external moderation and managing
consistency of graduate outcomes should be conducted and funded. Five ITOs
are interested in further information on this proposal, particularly some cost
modelling around the various options. It is generally agreed that consistency in
qualification outcomes and in assessment of individual standards is important
and that at least some external moderation needs to be retained to ensure
industry confidence in the system.
368. Six ITOs stated that if ITOs are responsible for standard setting they should also
have responsibilities for quality assurance regardless of who developed
particular qualifications. However, they are concerned that it was unclear how
this would happen. They also suggested that if programmes are not developed
with industry this could lead to problems such as qualifications not being relevant
to workplace competence. Therefore, it is vital that industry is involved in
programme approval and quality assurance via ITOs. One ITO and the ITF
suggested that ITOs be funded to manage quality assurance through a credit
rebate based on usage.
the ITF strongly believes that ITOs need to be responsible for and funded for moderation
and managing consistency of qualifications, we believe there is a lack of guidelines
around how qualification developers will monitor the outcome of their qualification. ITF
PaMPITO believes that ITOs as standard setters have the responsibility for managing
consistency of graduate outcomes. Further clarification is sought on the mechanism
proposed. PaMPITO
369. Seven ITOs view moderation and consistency of graduates as distinct processes
that should be funded as such. The two functions may be funded through
different mechanisms.
Moderation and quality assurance activities should be funded as separate activities, with
the retention of the credit rebate for external moderation of unit standard asessment and
some funding redistributed to manage consistency of graduate outcomes. MITO
370. Four ITOs stated that ITOs need to be confident that all graduates coming out of
the same qualification are equal. Two ITOs suggested that graduate outcomes
could be assessed by comparing final assessments across providers instead of
at an individual level. SITA suggested that graduate consistency could be
managed by sampling a range of programme owners and organisations with
consent to assess. SITA expressed concern that programmes developed outside
an industry developed unit standard model may lack validity and rigour when
managing consistency of outcomes. Competenz stated that an external
consistency panel, funded by a levy, should be established. They stated that this
would ensure consistent application of standards and allow good practice to be
shared. Three ITOs suggested that funding for consistency should come from a
separate levy.
ITOs need to provide employers with confidence that the same qualifications, although
gained through different programmes and pathways, have comparable skills and
knowledge and that these align well to job roles in industry. PrITO
64
371. FITEC stated that ITOs should do external moderation across all qualifications
and that moderation should be funded. ESITO said that unit and assessment
standards are both good measures and that industry should decide which
measure is used when. Two ITOs support external moderation against clear,
accessible measures, potentially as part of the NQF. ESITO suggested that
providers with moderation systems should only be moderated by the ITO where
failures become apparent. EXITO suggested that ITOs should also be required to
develop best practice with NZQA and other standard setters.
372. Four ITOs stated that unit standards should be individually moderated and
funding retained for this. They stated that any other alternative is impractical.
This is because it would be logistically difficult to agree who decides if a unit is
critical. There is also concern that if a unit was not deemed critical it would not be
moderated and this in turn would lead to a decline in quality and consistency and
the undermining of the concept of generic standards.
We hold some concerns that quality control will be limited to what the proposal states as
being ‘skills critical to an occupation as identified by industry’. Whilst we consider all
outcomes critical, we would need to understand how critical skills will be identified and
whether the exclusion of non-critical skills in moderation would undermine quality control.
NZITO
373. Two ITOs support external moderation only of standards relating to skills critical
to an occupation as defined by industry. This would manage consistency and
align with the value placed by industry on standards setting. They stated that it is
the simplest of the options and its focus on specific, critical standards would give
real and transparent consistency. They stated it was less clear how the other
options would achieve consistency.
374. EXITO stated that if unit standards were not compulsory it will present a
considerable moderation challenge. They also suggested that there could well be
difficulties if ITOs and providers tried to agree on qualifications that adequately
suit both learning contexts. MITO stated that wider use of ITO unit standards
would ensure increased consistency of outcomes. However, it would also
increase moderation costs as moderation would take place across a broader
range of assessment materials. Competenz stated that unit standards should be
generic where possible and these should be moderated by NZQA. Other units
would be industry owned, developed and moderated.
375. Some ITOs raised concerns around quality generally:

Four ITOs asked for a review of the way qualification developers interact
with NZQA. They also stated that NZQA quality assurance needs to be
reviewed

ATTTO asked whether delivery of training should be moderated in
addition to assessments

CMITO does not agree with the use of the term “graduate outcome” as its
meaning seems unclear

Competenz expressed concern that moderation costs could be increased
if moderation had to occur across a broader range of trainers.
376. Two ITOs suggested retention of the current credit rebate. Additionally, PGDR
ITO stated that it is important that funding matches the need for external
65
moderation and that there should not be any cross subsidisation. Two ITOs
stated that the current moderation process is costly and a review of that is
welcomed.
Tertiary Providers
377. Submissions from tertiary education providers address how external moderation
and managing the consistency of graduate outcomes should be conducted and
funded.
378. NZAPEP maintained the lead developers of qualification should manage the
process for assuring consistency of graduate outcomes. Blueprint for Learning,
noted that in order for assessments to be credible qualification developers should
be independent from ITOs.
379. The independence of external moderation was an area of concern for some
submitters. The Bay of Plenty Polytechnic questioned who was providing quality
control on the external moderation that ITOs provide. Unitech and the Manukau
Institute of Technology stated that ITOs should not internally moderate their own
quality and then externally moderate other providers. They argued that ITOs
should be externally moderated themselves.
If an ITO is assessing, as well as moderating providers, a) how is that fair, and b) who
would moderate ITO assessment practices? Bay of Plenty Polytechnic
380. The submission by the Metro ITPs, NZITP and the ITF emphasised that it was
vital for coherent and common quality assurance standards and processes to
apply across the system. The problem in this respect, they pointed out, was how
to fund moderation as the cost of this could be fairly high in order to achieve
national consistency of moderation.
381. Some providers proposed solutions to this problem. Training Systems and
Solutions advocated for an independent inspectorate who would visit providers to
observe delivery and conduct assessment. These independent inspectors would
be managed by industry through funding from a per credit fee. CPIT claimed
moderation should be delegated to tertiary providers as there were already
established processes in the tertiary sector to ensure high-quality moderation.
The ITP sector CEOs contended that NZQA play a role in moderation to ensure
greater consistency because of the different stakeholders involved and resulting
variability between sectors.
Independent Modern Apprenticeship Coordinators
382. In a similar fashion to providers, independent MACs were also concerned with
the independence of external moderation.
383. Smart Careers and Southern Group Training Trust were concerned that ITOs
moderating their own assessments creates a conflict of interest and inconsistent
moderation outcomes. Southern Group Training Trust in a separate submission
argued that moderation by ITOs should be optional as employers may prefer
industry-based assessors. The use of trade qualified workplace assessors
moderated by the ITO worked well in ensuring consistency. Southern Group said
this approach worked better than using an ITO assessor because ITO assessors
lack trade qualifications and experience.
66
384. MACs were also critical of the quality of assessments. Southern Group claimed
assessments have become increasingly open and flexible resulting in greater
inconsistency. Regent Training Centre maintained assessment results must be
checked for accuracy in order to prevent self-interest of training providers.
385. Quality could be improved, according to Whangarei education and business
services, by requiring a final external exam that is the final qualification and
assessing previous units on the ”say so” of fellow tradesmen, supervisors or
employers. Southern Group suggested moderation should not only be of critical
skills, but be expanded to all skills relevant to the qualification as only by doing
this do you capture skills necessary to “the essence” of particular trades.
Other submitters
386. Thirteen submitters directly addressed this question. One submitter asked for
more detail on the proposals.
387. Two submitters stated the current system works well. They stressed the need for
external moderation. They also stated that the ITO should constantly improve
and update its moderation processes. One submitter stated that the system
needs to be simple, clear and verifiable. Another submitter stated that
moderation within industry and across providers is needed to ensure the
competence of all graduates. This will require collaboration across tertiary
sectors.
388. One submitter noted that they have experienced inconsistencies with the ITO
system of moderation. Another submitter stated that moderation and consistency
should be owned by the standard setter. One submitter stated that the focus
should be more on the front end of the process and focus on assessment
delivery and resource development. One submitter supported the focus on key
competencies.
389. Two submitters support moderation of all unit standards. They questioned who
would decide what a “critical” skill is.
It would be far more robust having moderation done on all unit outcomes as who decides
what’s valuable or not, this would be far more consistent for a good outcome worthy of a
National Certificate. Private individual 1
390. Two submitters from unions stated that they do not want extensive changes to
the moderation process nor to have external moderation diminished. They want
all standards moderated, as this is important for credibility. They also support the
status quo with an emphasis on high quality standards and the retention of the
credit rebate. However, they did not support the introduction of a levy.
QUESTION 11 QUALITY ASSURANCE SETTING
Will NZQA reviewing its quality assurance settings for unit standards
incentivise greater uptake of unit standards in providers? What other issues
disincentivise the adoption of unit standards? Do you agree that vocational
education and training should have a common currency for learning and
skills?
67
Employers
391. Employers regard NZQA unit standards as an effective form of moderation and
support their continued use. However, a review is welcomed on the basis that:
Too many unit standards on the framework have led to many being undervalued. More
rigorous reviews of these will raise the value of them. Downer New Zealand
The proliferation of health and safety unit standards is given as an example.
392. An employer in the care industry supports having an increased ability to
contextualise unit standards because many of their staff work and train in
geographically isolated locations. In more technical or ‘hard-skill’ industries
however, consistency and standards are paramount. Two employers therefore
stated that unit standards must underpin all qualifications as an indicator of
competency; Scotty’s Construction suggested a national curriculum and Garrison
Security advocated a standard exam.
393. Employers stated that the main benefits of a common currency are that it clarifies
employers’ expectations of apprentices’ needs and capabilities, and it supports
employees’ transferability. The ‘one standard’ approach is more efficient.
However, at the moment, resources, training approaches and standards, vary
across tertiary training providers. Employers do not want more inconsistency as
a result of the proposal and are concerned that the ability to contextualise unit
standards will give further license to training providers to produce inconsistent
skill standards.
There are too many variations on how the unit standards are achieved… Atkin
Construction
The current situation still allows unit standards to be taught in a variety of settings – on
job, off job, online, correspondence, night classes, block courses. Don’t change
something that is not broken. Wood Robson Ltd
394. Employers said that there is a need to distinguish between generic and industryspecific unit standards in developing a common currency. Foodstuffs support the
concept of a common currency for learning and skills at the lower end of
vocational training (levels 1 to 4). Two employers suggested industry should
work with ITOs to identify which unit standards are applicable across which
industries. Training packages can then be developed to suit individual industries
using common unit standards.
The ITO’s and other providers need to focus on core skills first and then deal with
developing unit standards for the industry specific skills. Gravure Packaging Ltd
395. Employers noted that one disincentive to the uptake of unit standards is the way
assessment timetable requirements are currently structured. One employer said
the rule that one credit has to be reported in the first month of training is
impractical given they conduct integrated assessments covering a range of unit
standards.
396. Other disincentives to the uptake of unit standards are:

time is required outside of work hours

the travel time for trainees who live in remote areas
68

unit standards are too task-specific and should be required to include
‘real world’ job experience

A confusing variety of training programmes

delays accessing quality training providers

no recognition of prior learning or current competency

administration is not user-friendly

moderation and quality assessment processes

merging of ITOs

cost and availability of technical resources for an adequate review and
update

TRoQ de-emphasises unit standards.
Industry Associations
397. Industry associations generally see quality assurance as important. One
association stated that quality assurance was not currently a problem for them,
but that simplicity is the most important factor in any system going forward. Some
associations commented that rationalised unit standards, reduced duplication
and focus on learner outcomes, where feasible, is positive. Some stated that
TRoQ will aid this. Other associations want consistent use of unit standards
across all forms of delivery. This is because industry has had input into designing
unit standards and therefore understand them. There is strong support from
associations for ensuring consistent quality outcomes of unit standards. One
association commented that unit standards must have the same outcomes in all
cases if used more widely than by the originating ITO.
Need to ensure delivery and assessment of standards is consistent and meets quality
assurance expectations. Northland Wood Council
398. There is a belief that industry-specific components in qualifications should not be
removed entirely as this would decrease employer confidence and qualification
uptake. It is stated that it should not be necessary for all unit standards to be
shared.
Should the targeted and mandated review processes currently under way genericise [sic]
the Interior Systems qualifications to a point where they become virtually unrecognisable
by stripping out the industry-specific components, it is likely to be to the detriment of the
industry which would no longer have any assurance that specific training needs were
being met. AWCI
However, care is required during this process to maintain industry technical and critical
skills standards. Horticulture NZ
399. Some associations suggested that unit standards need to be strengthened and
fine tuned. Unit standards should be:

more robust and flexible
69

more focused on learning outcomes

more customisable for industry need

more fit for their purpose.
Some associations stated that unit standards must ensure that graduates
demonstrate commercial competence in the areas covered by their qualifications.
That is, verify that a graduate can perform a specified task unsupervised, to a
quality finish and in an appropriate time frame. There was some concern that
industry training could become too academically focused. Some associations
contend that qualifications need to be practical and work as a cohesive whole
and that sometimes unit standards make this difficult. There is also support from
associations for flexible vocational pathways. One association commented that
there should be flexibility to pick units from across the framework.
400. Some associations strongly oppose simulated training. This is because simulated
training does not ensure that employers know that all people with the same
qualification have received equivalent training and experience, including on-site
experience.
Under the proposed changes anyone could run a training course and issue a carpentry
certificate to a person who has no onsite experience and gained all their knowledge in a
classroom situation only. The Association is adamant that substantial onsite experience
during training in carpentry is an essential part of a tradesperson’s qualification which will
be recognised and accepted by the industry. Marlborough Registered Master Builders’
Association
401. There is strong support for a common currency across vocational education and
training. Some associations stated that it makes qualifications recognisable and
understandable for employers and learners. They suggested that it would also
improve uptake. There is support from some industry associations for using unit
standards as the common currency. Some are, however, concerned that TRoQ
made use of unit standards as common currency problematic. One association
stated that it is essential for NZQA to work more closely with industry to support
the development of a common currency.
We do support a common currency of skill recognition as this makes it easy for employers
to easily understand the skills an employee brings to the work place. It is also of obvious
benefit to employees to have a common system that recognises their skill. The New
Zealand Manufacturers and Exporters Association NZMEA
Unit standards should be the unit of currency from school to provider to industry training.
A common currency allows the transferability of skills and allows learners to build on their
skills base throughout their lives. And, a common currency gives employers the surety
that competent means competent. Baking Industry Association of New Zealand
We believe that NZQA should be required to consult with industry to ensure qualifications
and programmes are fit for purpose, meet the needs of industry and provide the ‘common
currency’ envisaged in the discussion paper. Registered Master Builders Association
402. Some associations stated that they do not believe that unit standards in their
current form should be the common currency for learning and skills. This is
because they are fragmented learning and any currency should be seen in the
context of a whole qualification. Additionally, unit standards are not the only way
of measuring competence. One association commented that unit standards had
added confusion in their sector by replicating existing industry qualifications.
70
Another association suggested using assessment standards as the common
currency. One association suggested using New Zealand qualifications as the
common currency and stated that this would mean that the use of unit standards
would be at industry discretion.
403. One association stated that quality assurance settings won’t drive change.
Another association identified three factors affecting the uptake of qualifications
and unit standards: price and funding to buy at that price, contractual
requirements, and literacy and numeracy barriers. One association was
concerned that quality assurance may become too driven by providers and the
international education market at the expense of domestic industry.
It appears that the providers has an undue influence in qualifications size and content.
This influence has been dictated by providers’ wish to meet an international education
export market. Hospitality New Zealand
Industry Training Organisations
404. There is considerable disagreement among ITOs in relation to unit standards and
how they should be implemented and more specifically about the value of the
TRoQ process. There is general agreement that the concept of a common
currency is worthwhile.
405. Several ITOs support robust, flexible and relevant unit standards, which maintain
industry involvement. NZITO stated that non industry-specific, portable skills can
and should be codified in common unit standards and then contextualised for
industry purposes. However, several ITOs noted that it is important to retain the
balance between generality and specificity. Unit standards must not be so
generic as to have no industry relevance. Certain skills are critical to certain
industries and those industries should be able to determine what these standards
contain. However, the ability for providers to contextualise is good. Unit
standards should be flexible where possible and able to be assessed in a range
of settings. However, it is critical that ITOs retain moderation of all standards.
406. BCITO stated that unit standards encompass commercial competence, that is,
performing a task repeatedly to a high standard under work conditions. It would
be very concerned if that was lost.
407. TSO stated that unit standards currently constrain ITOs developing fit-forpurpose standards and statement of outcomes. They stated unit standard as a
term should be phased out and replaced by the terms skills standard or
assessment standard.
408. Two ITOs stated that TRoQ would rationalise unit standards, reduce duplication
and focus on learner outcomes. It would see everyone working for the same
outcome. Four ITOs particularly welcomed the emphasis on learner outcomes.
Two ITOs suggested that TRoQ should be strengthened and needs of industry
able to determine outcomes. Two ITOs stated that TRoQ recognises industry
involvement in qualification development. In particular, they support the
Vocational Pathways model.
409. Three ITOs stated that TRoQ was making the use of unit standards more
problematic, stating that there is a disconnect between these proposals and
TRoQ. There is concern that non-unit standard outcomes would not be
documented on a learner’s record of achievement. NZITO said that this is a
71
significant structural change for NZQA and providers. Thus, it will need careful
management and may require some reversal of TRoQ outcomes.
Alignment of NZQA policy, especially around the Targeted Review of Qualifications and
the requirement for qualifications to be non-unit standard based in some instances would
be a potential barrier to this proposal. NZITO
Consideration should be given to making unit standards and off-job or on-job assessment,
when industry determines this is necessary, as compulsory for all providers delivering
qualifications ESITO
410. ITOs list a number of concerns around how unit standards are currently being
handled:

HSI stated that if unit standards were lost, this would dilute the influence
of industry in linking skill standards to qualifications and graduate
outcomes.

CMITO stated that it dislikes the process that has been used to
rationalise qualifications, as it ignores industry, and does not want it
applied to unit standards. Instead, NZQA should clearly outline its
requirements and let industries use these as it goes through qualification
and unit standard review. NZQA and TEC processes should align with
industry requirements and be easy to administer from an ITO perspective.

Three ITOs asked how NZQA would approve programmes without using
industry endorsed expertise to ensure it delivers identified outcomes and
questioned whether this would just be replicating the work undertaken to
develop unit standards if they did use such expertise.

Two ITOs were also concerned that TRoQ risks encouraging a
proliferation of programmes delivering the same qualification and
additional costs associated with vetting multiple delivery methods.

SITA stated that there could be confusion if ITOs use different criteria for
developing and assessing qualifications to ITPs and PTEs. ATTTO stated
that all trainers in the VET sector should use the same system for funding
and performance measures as this would reduce funding confusion.
411. Two ITOs stated that quality assurance needs to be reviewed with a view to
developing clear guidelines for lead qualification developers on how the
outcomes of qualifications will be monitored. Two ITOs stated that NZQA quality
processes need to be improved for employers and trainees. Additionally, funding
for all quality assurance functions should be assessed to ensure it is appropriate.
412. There is strong opposition to many skills being learned in simulated
environments. Two ITOs suggested that on-job and off-job skill acquisition are
not the same, even if they appear to be. PaMPITO stated that skill standards
should be learned and assessed in suitable settings. They commented that there
needs to be a balance with on-the-job needs so that qualifications retain their
work focus. Two ITOs stated that industry should be able to specify the context
of assessment for industry specific skills. InfraTrain stated that practical skills
must be assessed in a practical setting.
413. Two ITOs stated that a common currency is good practice. Eight ITOs support
unit/assessment standards being the common currency across the vocational
72
training sector and applied in different settings. PrITO also support the use of unit
standards in sub-degree level programmes to continue common currency idea.
EXITO suggested that unit standards should be incentivised to become the
common currency. BCITO stated that the common currency is good in theory,
but hard to implement practically in the current environment. They asked about
how consistency will be established and maintained.
414. Three ITOs said current measures are unlikely to be successful in encouraging
uptake of unit standards unless they are more closely aligned with NZQA policy.
415. Many ITOs supported the establishment of a working group.
The ITF recommends that NZQA establish a working group consisting of industry, ITOs
and providers to evaluate NZQA policy around unit/assessment standards being
component parts of qualifications and to incentivise use of unit/assessment standards
across the VET sector. ITF
Tertiary Providers
416. Providers support a review of unit standards. Indeed, the ITP sector CEOs
observed that a review of unit standards was vital for preserving the integrity of
the standard-setting process.
417. Different providers highlighted problems with unit standards. Waiariki Institute of
Technology and the Waikato School of Hairdressing note that unit standards
become quickly outdated, are too restrictive and inflexible. The Bay of Plenty
Polytechnic said unit standards are too task-specific and detailed resulting in
them being unsuitable for many trainees.
418. In order to incentivise greater uptake, the ITP sector CEOs suggest NZQA needs
to focus on skill outcomes that are adaptable. This theme of greater flexibility as
a solution to many of the unit standards problems was taken up by other
submitters. Tectra maintain that greater flexibility is required of NZQA in standard
delivery and interpretation. Another submitter, who wishes to remain anonymous,
pointed out that it was necessary to consider how students needing a common
skill across a range of situations will be catered for alongside those operating in
only one context.
419. Ten providers support a common currency. Eight providers see benefit for
employers of more accurate expectations of what an employee can bring to the
workplace. Three providers described transferability as essential. To be valued,
however, this must be collaboratively developed and focus on learning
outcomes.
Independent Modern Apprenticeship Coordinators
420. Only a few independent MACs commented on this proposal. The main problems
identified with unit standards by Southern Group Training Trust, Regent Training
Centre and Whangarei Business and Education Services was the duplication of
unit standards, lack of resources and variability between standards.
421. Southern Group suggested unit standards could be improved by having greater
industry involvement in the development of standards, more careful writing of
each unit standard and narrower delivery methods. They also noted that mature
workers who are unfamiliar with unit standards require additional support.
73
Whangarei Business and Education Services suggested that unit standards
could be improved by having generic unit standards which were distinct from
industry specific standards.
Other submitters
422. Thirteen submitters commented directly on this proposal. There were few
common themes.
423. Three submitters stated that industry must be involved in determining the criteria
for unit standards. The development of these must not be Government-led. One
submitter stated that achievement of a unit standard should genuinely reflect the
capability of a learner to use relevant skills in an authentic setting. Three
submitters support more flexible unit standards that could be taught and
assessed in a variety of settings.
424. Four submitters are opposed to simulated training, stating practical skills must be
learned on site. This is because simulated training does not faithfully recreate the
workplace situations in which skills will be used.
425. One submitter suggested three things that would improve unit standard uptake:
revising settings for course approvals, actual need in the workplace for unit
standards based education, and a common understanding of what is being
provided. Another submitter suggested better recognition of prior learning would
encourage people to continue study. One submitter suggested that a common
currency would encourage uptake.
426. One submitter stated that alignment between ITO quality processes and NZQA
and ITP quality processes is very important for maximising employer and
learners’ experiences. The Tertiary Education Union called for a review of tertiary
sector quality assurance overall.
427. Another submitter supports the NZQA review, stating this should be done in
concert with all users. The basis for the review should be what best suits the
learner, not what best suits ITOs or providers. Two submitters expressed
concern that there was a mismatch between TRoQ and the use of unit standards
as a common currency. Two submitters stated that ITOs should be properly
resourced to promote and implement vocational pathways.
428. One submitter suggested a move from task-based standards to skills-based
standards. Another submitter stated that assessment and unit standards both
have a place within the qualifications framework. One submitter stated that
standards should reflect new qualifications outcomes and not remain at the subtask level.
429. One submitter does not support the use of unit standards as a common currency.
This is because unit standards are too fragmented and specific.
74
Appendix: Submissions received
ORGANISATION
ABBREVIATION
TYPE
Abel Engineering
Abel Engineering
Employer
Active Refrigeration Ltd
Active Refrigeration Ltd
Employer
AdMark Visual Imaging Ltd
AdMark Visual Imaging Ltd
Employer
Advanced Engineering Solutions
Advanced Engineering
Employer
AF Southgate & Sons
AF Southgate & Sons
Employer
AFS Total Fire Protection Ltd
AFS Total Fire Protection
Employer
Air Fluid Otago
Air Fluid Otago
Employer
Airtech NZ Limited
Airtech NZ Limited
Employer
AJ Grant Engineering
AJ Grant Engineering
Employer
Alan Poulsen Ltd
Alan Poulsen Ltd
Employer
Aldridge Hydraulics Ltd
Aldridge Hydraulics
Employer
Alert Engineering Ltd
Alert Engineering Ltd
Employer
Alliance Group
Alliance Group
Employer
Alloy Yachts
Alloy Yachts
Employer
Alteration Specialists
Alteration Specialists
Employer
Amcor Packaging NZ Ltd
Amcor Packaging
Employer
AMT Mechanical Services Ltd
AMT Mechanical Services
Employer
Andrew Lawson Builder
Andrew Lawson Builder
Employer
Angus Robertson Mechanical
Angus Robertson Mechanical
Employer
Anzco Food, Green Island
Anzco Food, Green Island
Employer
APN Print NZ
APN Print
Employer
Aspec Construction
Aspec Construction
Employer
ATI Engineering Ltd
ATI Engineering
Employer
Atkin Construction
Atkin Construction
Employer
ATNZ
ATNZ
Employer
AW Fraser Ltd
AW Fraser Ltd
Employer
BB Construction
BB Construction
Employer
Begg Security Group Ltd
Begg Security Group Ltd
Employer
Bennetts Plumbers 1979 Ltd
Bennetts Plumbers 1979 Ltd
Employer
Bleeker & Weith
Bleeker & Weith
Employer
Broderick Printing and Design Ltd
Employer
BUPA Care Services
Broderick Printing And Design
Ltd
BUPA
Canterbury Steel Structures Ltd
Canterbury Steel Structures
Employer
CCT
CCT
Employer
Chillzone Ltd
Chillzone Ltd
Employer
Christchurch Steel Ltd
Christchurch Steel
Employer
Chubb
Chubb
Employer
CMP Rangitikei Limited
CMP Rangitikei Limited
Employer
Coastal Welders
Coastal Welders
Employer
Cold Aire
Cold Aire
Employer
EMPLOYERS
Employer
75
ORGANISATION
ABBREVIATION
TYPE
Color Communications Inc
Color Communications Inc
Employer
Commercial Signs Print and Promotions
Commercial Signs
Employer
Community Connections
Community Connections
Employer
Contact Energy/Mighty River Power
Contact Energy/Mighty River
Employer
Coombridge Industries Ltd
Coombridge Industries Ltd
Employer
Couplands Bakeries
Couplands Bakeries
Employer
Craig Rogers Building Ltd
Craig Rogers Building Ltd
Employer
Culham Engineering Company Ltd
Culham Engineering
Employer
DC Repairs Ltd
DC Repairs Ltd
Employer
DF Transales Ltd
DF Transales Ltd
Employer
Dow Agro Sciences
Dow Agro Sciences
Employer
Downer New Zealand
Downer NZ
Employer
Eastbridge Ltd
Eastbridge Ltd
Employer
Eastside Refrigeration Ltd
Eastside Refrigeration Ltd
Employer
Endevour Precision Automation Engineering
Ltd
Energy Products International
Endevour Engineering Ltd
Employer
Energy Products International
Employer
Ensign Engineering Services Ltd
Ensign Engineering Services
Ltd
Excel Builders Ltd
Employer
Employer
Farra Engineering Ltd
Falcon Manufacturing Group
Limited
Farra Engineering Ltd
Findlater Sawmilling Ltd
Findlater Sawmilling Ltd
Employer
Fire Protection Compliance Ltd
Fire Protection Compliance Ltd
Employer
Fire Security Services Ltd
Fire Security Services Ltd
Employer
Fleet Engineering
Fleet Engineering
Employer
Fletcher Building
Fletcher Building
Employer
The Fletcher Construction Company Ltd
Fletcher Construction
Employer
Fonterra
Fonterra
Employer
Foodstuffs (NZ) Limited
Foodstuffs
Employer
Framework
Framework
Employer
Fulton Hogan
Fulton Hogan
Employer
Garrison Security
Garrison Security
Employer
Garry Gray Engineering Ltd
Garry Gray Engineering Ltd
Employer
Gavin Lowe Energy Solutions
Gavin Lowe
Employer
Genesis Energy
Genesis Energy
Employer
Gillies Metaltech Ltd
Gillies Metaltech
Employer
Gisborne Olympic Pool
Gisborne Pool
Employer
Goodmans
Goodmans
Employer
Gravure Packaging
Limited
Gravure Packaging
Limited
Employer
GW Davies Heating Engineers Ltd
GW Davies Heating Engineers
Ltd
Haack Construction
Employer
Haua Engineering (Rotorua)
Ltd
Heslops Engineering Ltd
Employer
Excel Builders Ltd
Falcon Manufacturing Group Limited
Haack Construction Ltd
Haua Engineering (Rotorua) Ltd
Heslops Engineering Ltd
Employer
Employer
Employer
Employer
76
ORGANISATION
ABBREVIATION
TYPE
Heat Treatments Ltd
Heat Treatments Ltd
Employer
Higgins Group Holdings Ltd
Higgins Group
Employer
High Pressure Equipment NZ Ltd
Employer
Howard
High Pressure Equipment NZ
Ltd
Howard
HPAC Energy Centre
HPAC Energy Centre
Employer
Industrial Tube Manufacturing Co Limited
Industrial Tube Manufacturing
Co Limited
Inghams Enterprises Ltd
Employer
Employer
Integrated Hydraulics Limited
Installation and Piping Services
Ltd
Integrated Hydraulics
IVE Group Limited
IVE Group Limited
Employer
Jack Links New Zealand Limited
Employer
Jackson Engineering
Jack Links New Zealand
Limited
Jackson Engineering
Jackson Enterprises
Jackson Enterprises
Employer
J.M.P. Engineering Ltd
JMP Engineering Ltd
Employer
John Jones Steel Ltd
John Jones Steel Limited
Employer
Kawerau Engineering Ltd
Kawerau Engineering Limited
Employer
Ken Anderson Building Ltd
Ken Anderson Building
Employer
Kernohan Engineering Ltd
Kernohan Engineering Ltd
Employer
Kevin Hyde Engineering
Kevin Hyde Engineering
Employer
KiwiRail
KiwiRail
Employer
KiwiRail Interislander
KiwiRail Interislander
Employer
KiwiRail Interislander
KiwiRail Interislander
Employer
Knight Precision Engineering
Knight Precision Engineering
Employer
Longveld Ltd
Longveld Ltd
Employer
Lyttleton Engineering
Lyttleton Engineering
Employer
Mach3 Industries Ltd
Mach 3 Industries Ltd
Employer
Marinetec Engineering Ltd
Marinetec Engineering Ltd
Employer
Mercer Stainless Ltd
Mercer Stainless Ltd
Employer
Metalcraft Engineering Company Ltd
Metalcraft Engineering Ltd
Employer
Metalspray Engineering Ltd
Metalspray Engineering Ltd
Employer
Milfos International
Milfos International Ltd
Employer
Milmeq Ltd
Milmeq Ltd
Employer
MJ Custom Engineering Ltd
MJ Custom Engineering
Employer
MS Coombes Ltd
MS Coombes Ltd
Employer
Nelson Forests Ltd
Nelson Forests Ltd
Employer
New World Waikanae
New World Waikanae
Employer
New Zealand Aluminium Smelters Ltd
Employer
No company name
New Zealand Aluminium
Smelters
No company name
No company name
No company name
Employer
NRG Home Electrical
NRG Home Electrical
Employer
NZ Electrical Contracting Ltd
NZ Electrical Contracting Ltd
Employer
NZ Wood Mouldings
NZ Wood Mouldings
Employer
NZPC
NZPC
Employer
Inghams NZ Pty Enterprises Ltd
Installation and Piping Services Ltd
Employer
Employer
Employer
Employer
Employer
77
ORGANISATION
ABBREVIATION
TYPE
Otago Sheet Metal and Engineering Ltd
Employer
P & W Engineering Ltd
Otago Sheet Metal and
Engineering Ltd
P & W Engineering Ltd
Palmers Mechanical Limited
Palmers Mechanical Limited
Employer
Pan Pac Forest Products Limited
Employer
Patience and Nicholson NZ Ltd
Pan Pac Forest Products
Limited
Parade Hydraulics and
Engineering Ltd
Patience and Nicholson NZ Ltd
Phoenix Steel Limited
Phoenix Steel Limited
Employer
Presbyterian Support Central
Presbyterian Support Central
Employer
Presbyterian Support South Canterbury
Employer
Profab Central Engineering Ltd
Presbyterian Support South
Canterbury
Profab Central Engineering Ltd
Proform Plastics Limited
Proform Plastics
Employer
Progressive Engineering Co Ltd
Progressive Engineering Ltd
Employer
PSC Enliven
PSC Enliven
Employer
Reefton Engineering
Reefton Engineering Ltd
Employer
Restaurant Brands New Zealand Ltd
Restaurant Brands
Employer
Name withheld
Name withheld
Employer
Roberts Engineering
Roberts Engineering
Employer
Roger Hogg Builders Ltd
Roger Hogg Builders Ltd
Employer
R.R. Bramley and Co
RR Bramley and Co
Employer
S.A.F.E Critical Engineering Solutions
Employer
Salvation Army HomeCare
Safe Critical Engineering
Solutions
Salvation Army HomeCare
Scotty's Construction 2002 Ltd
Scotty's Construction 2002 Ltd
Employer
SEC Group Limited
SEC Group Limited
Employer
Shape Technology Limited
Shape Technology
Employer
Sharland Engineering
Sharland Engineering Ltd
Employer
Sheet Metal Specialists
Sheet Metal Specialists
Employer
Skyline Enterprises Ltd
Skyline Enterprises Ltd
Employer
Southern Colour Print
Southern Colour Print
Employer
Southland Security Centre Ltd
Southland Security Centre Ltd
Employer
Spectrum Care
Spectrum Care
Employer
Spotless Facility Services
Spotless
Employer
Spotless Facility Services
Spotless
Employer
Stainless and Alloy Fabricators Ltd
Employer
Stark Bros Ltd
Stainless and Alloy Fabricators
Ltd
Stark Bros
Summerset Group
Summerset
Employer
Taege Engineers Ltd
Taege Engineers
Employer
Taunton Engineering Ltd
Taunton Engineering
Employer
Tauranga Engineering Ind. Ltd
Tauranga Engineering
Employer
Taymac
Taymac Engineering
Employer
Taymac Stainless
Taymac Stainless
Employer
Te Pari Products Ltd
Te Pari Products Ltd
Employer
Tegel Foods Ltd
Tegel Foods Ltd
Employer
Tennant Engineers
Tennant Engineers
Employer
Parade Hydraulics and Engineering Ltd
Employer
Employer
Employer
Employer
Employer
Employer
78
ORGANISATION
ABBREVIATION
TYPE
TerraNova Homes and Care Ltd
Terra Nova
Employer
Texco Steel Ltd
Texco Steel
Employer
TH Barnes and Co Ltd
TH Barnes and Co
Employer
The Animal Health Board
The Animal Health Board
Employer
The Ultimate Care Group Ltd
The Ultimate Care Group
Employer
Thermal Solutions Ltd
Thermal Solutions Ltd
Employer
Thompson Construction and Engineering
Employer
Tidd Ross Todd Ltd
Thompson Construction and
Engineering
Tidd Ross Todd Ltd
Todd Augers and Equipment
Todd Augers and Equipment
Employer
TracGrip Hydraulics and Equipment Ltd
Employer
Tru-Test Group
TracGrip Hydraulics and
Equipment Ltd
Tru Test Group
Valley Industries Ltd
Valley Industries Ltd
Employer
Waitapu Engineering Ltd
Waitapu Engineering Ltd
Employer
We Can Precision Engineering Ltd
We Can Precision Engineering
Employer
Westland Milk Products
Westland Milk
Employer
WM Ross Engineering Ltd
WM Ross Engineering Ltd
Employer
Wood and Thomson Engineering Ltd
Employer
Wood Robson Ltd
Wood and Thomson
Engineering
Wood Robson Ltd
Woolston Engineering Ltd
Woolston Engineering
Employer
WYMA Engineering NZ Ltd
WYMA Engineering NZ Ltd
Employer
YMCA of Auckland Inc
YMCA of Auckland
Employer
Employer
Employer
Employer
Total 189
INDUSTRY ASSOCIATIONS
The Association of Wall and Ceiling
Industries
Baking Industry Association of New Zealand
AWCI
Beef and Lamb NZ
Beef and Lamb NZ
Business New Zealand
Business NZ
Cement and Concrete Association of New
Zealand
Civil Engineering Testing Association of New
Zealand
Construction Industry Council
CCANZ
Dairy NZ
Dairy NZ
New Zealand Disability Support Network
NZDSN
The Electrical Contractors Association of
New Zealand
Electricity Engineers' Association of New
Zealand
Employers and Manufacturers Association
ECANZ
Federated Farmers
Federated Farmers
Forest Industry Contractors Association
FICA
Fire Protection Association
FPANZ
BIANZ
CETANZ
CIC
EEA
EMA
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
79
ORGANISATION
ABBREVIATION
Fitness New Zealand
FitnessNZ
Florists New Zealand Incorporated
FLONZI
Food and Grocery Council
FGC
Forest Owners Association
FOA
Horticulture New Zealand
HorticultureNZ
Hospitality New Zealand
Hospitality New Zealand
The Institute of Quarrying
IoQ
The Institute of Professional Engineers New
Zealand
The Institute of Refrigeration, Heating and Air
Conditioning Engineers
Maritime New Zealand
IPENZ
Marlborough Registered Master Builders'
Assn Inc
Master Plumbers, Gasfitters and Drainlayers
and Masterlink Limited
Maintenance Engineering Society of New
Zealand
Motor Trade Association
Marlborough Registered
Master Builders' Assn Inc
Master Plumbers
New Zealand Institute of Quantity Surveyors
NZIQS
New Zealand Pine Manufacturers
Association
NZ Association of Registered Hairdressers
Inc
NZ Heavy Engineering Research Association
The Pine Manufacturers
NZ Recreational Association
NZRA
NZ Retailers Association
NZ Retailers Association
NZ Shipping Federation
NZSF
The New Zealand Council for Christian Social
Services
New Zealand Home Health Association
NZCCSS
The New Zealand Manufacturers and
Exporters Association
The New Zealand Milking and Pumping
Trade Association
New Zealand Outdoor Instructors Association
NZMEA
New Zealand Security Association
NZSA
The Petroleum Exploration and Production
Association of New Zealand
Pipfruit New Zealand
PEPANZ
Plastics New Zealand
Plastics New Zealand
Print NZ
Print NZ
Registered Master Builders Federation
RMBF
Road Transport Forum NZ
RTFNZ
IRHACE
Maritime NZ
MESNZ
MTA
NZARH
HERA
NZHAA
NZMPTA
NZOIA
Pipfruit NZ
TYPE
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
80
ORGANISATION
ABBREVIATION
Roofing Association of New Zealand
RANZ
Scaffolding Access and Rigging NZ Inc
SARNZ
The Northland Wood Council
NWC
Waikato Engineering Careers Association
WECA
Furniture and Cabinetmaking Association
FCANZ
NZ Marine Transport Association
NZ Marine Transport
Association
TYPE
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Industry
Assoc
Total 54
INDUSTRY TRAINING ORGANISATIONS
Aviation, Tourism and Travel Training
Organisation
Building and Construction Industry Training
Organisation
Careerforce
ATTTO
ITO
BCITO
ITO
Careerforce
ITO
Communications and Media Industry
Training Organisation
Competenz
CMITO
ITO
Competenz
ITO
Emergency Management Qualifications
EMQUAL
ITO
Electricity Supply Industry Training
Organisation
Extractive Industry Training Organisation
ESITO
ITO
EXITO
ITO
Forest Industry Training and Education
Council
New Zealand Hairdressing Industry Training
Organisation
Hospitality Standards Institute
FITEC
ITO
HITO
ITO
HSI
ITO
Industry Training Federation
ITF
InfraTrain
InfraTrain
Peak Body:
ITO
ITO
Joinery Industry Training Organisation
JITO
ITO
NZ Motor Industry Training Organisation
MITO
ITO
NZ Marine
NZ Marine
ITO
New Zealand Industry Training Organisation
NZITO
ITO
Plastics and Materials Processing Industry
Training Organisation
Plumbing, Gasfitting, Drainlaying and Roofing
Industry Training Organisation
Primary Industries Industry Training
Organisation
Retail Institute
PaMPITO
ITO
PGDR ITO
ITO
PrITO
ITO
Retail Institute
ITO
Service Industries Training Alliance
SITA
ITO
The Skills Organisation
TSO
ITO
Total 23
TERTIARY PROVIDERS
ACT Safety Ltd
Act Safety Ltd
PTE
Name withheld
Name withheld
PTE
AMS Group Ltd
AMS Group Limited
PTE
ATC Professional
ATC Professional
PTE
Blueprint for Learning
Blueprint for Learning
PTE
81
ORGANISATION
ABBREVIATION
TYPE
Christchurch Polytechnic Institute of
Technology
Crown Institute of Studies
CPIT
ITP
Crown Institute of Studies
PTE
Ignite Learning and Development
Ignite Learning and
Development
Independent Tertiary
Institutions
NZITP, Metro ITP
PTE
Jupiter Training Resources Ltd
PTE
Manukau Institute of Technology
MIT
ITP
New Zealand Institutes of Technology and
Polytechnics, Metro Group of Institutes of
Technology and Polytechnics, Industry
Training Federation
New Zealand Association of Private
Education Providers
New Zealand Travel Information Limited
NZITP, Metro ITP, ITF
Peak Body:
ITP
NZAPEP
NZTI
Peak Body:
ITP
PTE
Rapid Results
Rapid Results
PTE
Sadler and Associates
Sadlers
PTE
School of Applied Technology, Bay of Plenty
Polytechnic
Tectra
BoPP
ITP
Tectra
PTE
Training Systems and Solutions Ltd
TSSL
PTE
Unitec
Unitec
ITP
Waiariki Institute of Technology
Waiariki Institute of Technology
ITP
Waikato School of Hairdressing
Waikato School of Hairdressing
PTE
Waikato Institute for Leisure and Sport
Studies
WILSS
PTE
Independent Tertiary Institutions
New Zealand Institutes of Technology and
Polytechnics CEOs, Metro Group of Institutes
of Technology and Polytechnics CEOs
Jupiter Training Resources Ltd
Peak Body:
PTE
ITP sector
CEOs
Total 25
INDEPENDENT MODERN APPRENTICESHIP COORDINATORS
Apprenticeship and Trade Services
MAC
Engineering Taranaki Consortium
Apprenticeship and Trade
Services
ETC
Gisborne Development
Gisborne Development
MAC
Job Finders
Job Finders
MAC
NorthTec
Northtec
MAC, ITP
Regent Training Centre Ltd
RTC
MAC, PTE
Southern Group Training Trust
SGTT
MAC
Smart Careers and Southern Group Training
Trust
Whangarei Education and Business
Services
Smart Careers
MAC
Whangarei Education and
Business Services
MAC
MAC
Total 9
OTHER
Accident Compensation Commission
ACC
Government
Age Concern
Age Concern
Other
Ako Aotearoa National Centre for Tertiary
Teaching Excellence
Auckland City Council Civil Defence and
Emergency Management
Competency International Limited
Ako Aotearoa
Other
Auckland City Council CDEM
Council
CIL
Consultant
Private individual 1
Private individual 1
Individual
82
ORGANISATION
ABBREVIATION
TYPE
Department of Conservation
DOC
Government
Private individual 2
Private individual 2
Individual
Dyslexia Foundation of New Zealand and the
Certified builders from Auckland with
Learning Disabilities
Engineering Printing and Manufacturing
Union
Cobalt Communications
DFNZ and the Certified
builders from Auckland with
Learning Disabilities
EPMU
Other
Cobalt Communications
Consultant
Private individual 3
Private individual 3
Individual
Private individual 4
Private individual 4
Individual
Local Government New Zealand
LGNZ
Government
Ministry of Pacific Island Affairs
MPIA
Government
Private individual 5
Private individual 5
Individual
New Zealand Council of Trade Unions
NZCTU
Union
Northern South Island Regional Rural Fire
Committee
NQF Solutions
Northern South Island Regional
Rural Fire Committee
NQF Solutions
Other
NZ Mountain Safety Council
NZ Mountain Safety Council
Other
Palmerston North City Council
PNCC
Council
Plant and Food Research
Plant and Food Research
Crown Entity
Post Primary Teachers Association
PPTA
Union
Private individual 6
Private individual 6
Individual
Rural Women New Zealand
RWNZ
Other
Private individual 7
Private individual 7
Individual
Site 2
Site 2
Other
Private individual 8
Private individual 8
Individual
Private individual 9
Private individual 9
Individual
Stronger Christchurch Infrastructure Rebuild
Team
Tertiary Education Union
SCIRT
Government
TEU
Union
Timaru District Council
TDC
Council
United Fire Brigades Association
UFBA
Other
Union
Consultant
Total 32
GRAND
TOTAL 332
83