DISCUSSION PAPER - COMPETENCY BASED COMPLETIONS PURPOSE The purpose of this paper is to invite discussion and comment from industry, training organisations and other stakeholders in Victoria’s Vocational Education and Training (VET) System on options for the introduction of fully competency based apprenticeship completions. RATIONALE This paper has been prepared by the Office of Training and Tertiary Education (OTTE) following agreement by the Council of Australian Governments (COAG) on a number of measures aimed at addressing perceived barriers and inefficiencies with regard to apprenticeship training. The measures that COAG has agreed to are: By December 2006, once apprentices or trainees have demonstrated competency to the satisfaction of their employer and Registered Training Organisation (RTO), they will be able to be certified as competent by the State Training Authority (STA), without the need to make special application for this or the need to serve a minimum time. Jurisdictions are required to amend awards, training and other legislation and administrative procedures wherever these prevent early sign off based on competency. To ensure standards are maintained STAs will monitor the duration of apprenticeships and traineeships and will intervene, where necessary, where completion patterns appear irregular. National administrative guidelines will be developed about the average times for attainment of full competency but training plans will no longer refer to nominal durations. The COAG resolutions are reinforced by recommendations from Victoria’s recent review of its VET system. Many of the review’s recommendations have been incorporated into the Government’s Skills Statement – Maintaining the Advantage Skilled Victorians In relation to apprenticeships, the Skills Statement states that: The Government will work with industry to ensure that early completion is a common feature The key to maintaining a highly skilled workforce while accelerating apprenticeships will be to ensure that the quality assurance system for training organisations is rigorous. CURRENT COMPLETION PROCESSES. The completions processes that have attracted the attention of COAG are described below. The difference between apprenticeship and traineeship completions and institution-based program completions arises from the contractual relationship between the parties, the requirements under that contract and, in particular, the existence of parallel workplace based learning experiences alongside delivery of the qualification by an RTO. Traineeships completion process. The current process is as follows: under a training contract the employer provides the trainee with employment and on-thejob learning opportunities; the RTO delivers the required training for the qualification, either off the job or workplace based; on attainment of the competencies contained in the training package qualification or accredited course, the RTO obtains employer advice of the trainee’s competency in the workplace; and completion is recorded when the RTO transfers completion data to OTTE. Ostensibly, this process is competency based. However in practice, there have been instances of trainees completing in considerably less than the nominal duration of their training contracts (the Security industry being a notable example) and instances where the employer has been unaware that the traineeship was over, leading to claims for underpayment of wages. Stakeholders are likely to insist on a greater level of rigour and improved communication in relation to apprenticeship completions. Apprenticeship completion process The current process is as follows: under a training contract the employer provides the apprentice with employment and onthe-job learning opportunities; the RTO delivers the required training for the qualification which may be off the job or workplace based. the RTO determines eligibility for issue of qualification and OTTE is notified of course completion; at this point the employer and apprentice may apply for early completion. Where a reduction of more than six months is sought, an Apprenticeship Field Officer provides a report and recommendation; in the absence of an early completion application, OTTE writes to employers prior to the nominal completion date to confirm completion; and this letter is endorsed and returned by the employer to their Australian Apprenticeships Centre (AAC – formerly New Apprenticeships Centre), which transfers completion data to OTTE and triggers payment of State and Commonwealth completion incentives to the employer. The early completion rate for apprentices has been 24% over the past two years. However the current process and its reliance on applications does not meet the COAG requirements for competency based completions. The nominal duration of training contracts may also be extended by application if competency has not been attained. It should be noted that the distinction between qualification completion and contract completion is contrary to the fundamental principle of competency based assessment. GENERAL ISSUES AROUND COMPETENCY BASED COMPLETIONS Acceptance. The COAG decision is supported by peak industry groups, but a move away from time based apprenticeship completion may be opposed by some employers. Ground for opposition may be that employers could lose some of the financial return gained in the final year of an apprenticeship which compensates for the training investment made in earlier years. Group Training Organisations may be particularly affected in this regard. There is a risk that implementation of fully competency-based completions will make some employers reluctant to employ apprentices or result in some artificial extension of time required to demonstrate competency. Dispute mediation and arbitration mechanisms may be needed to support whichever option (or variation) is ultimately adopted. A strong communications strategy will be required to overcome any initial resistance to change. This strategy will need to include: promotional material directed to employers/ apprentices and via industry associations and unions; education to AACs and them advising employers at sign up training for Apprenticeship Field Officers (including assessor training for all new AFOs) Engagement. Most of the delivery in traditional trades apprenticeships is provided off the job with limited use of workplace based delivery. While practices vary widely, it appears that the level of communication between Institutions and employers is more limited in the case of apprenticeships than traineeships. Professional development may be required for apprenticeship trainers to equip them to engage actively in a dialogue with employers. On the other side of the coin, the engagement of employers with apprenticeship training and delivery needs to be enhanced. In the traditional trades there appears to be a view that training is “what TAFE does”. Some employers make little attempt to link this training with what occurs in the workplace. Engagement between providers and employers, conducted at the worksite and at a time convenient to the employer, would assist in ensuring that training is individualised, avoids duplication and takes account of the capacity of the workplace. Training delivery and assessment In a fully competency based system, delivery should be tailored to the individual through recognition of prior learning and delivery which enables the student to progress at their own. pace. At present, many RTOs only offer lock step delivery or hold back higher performing individuals to the pace of a group or to meet time based requirements of occupational licensing. Some review of training packages and their qualifications may be desirable in order to determine whether assessment criteria and variables are sufficiently robust to allow RTOs to assess aspects of workplace competency such as speed of task performance and repeatability. OPTIONS FOR A COMPETENCY BASED COMPLETIONS PROCESS. Options that consist of competency sign-off either solely by the RTO or by the employer are not presented as options. Apprentice and trainee training is inherently a partnership involving both the employer and the RTO who provide complementary learning experiences. The current traineeship completion process already provides for a dual sign-off and initial consultations with selected stakeholders have produced no support for a unilateral process. Accordingly, the following two models are proposed for a dual sign off of competency by both employer and RTO are presented. Option 1 Dual Sign Off - Employer/ Apprentice driven process This model places the onus on the employer and apprentice to instigate an early completion. The employer and apprentice notify the RTO that the requirements of the training plan have been completed, the RTO satisfies itself that the qualification has been attained, the RTO has the parties sign a “completion agreement” which results in the RTO issuing the qualification and notifying the STA of completion of the contract. The strength of this model is that it is driven by the parties to the contract of training with the RTO acting more as a facilitator. However this same factor is also a weakness in that there is no “driver” to necessarily encourage early completion and either party to the contract could seek to delay completion for reasons unrelated to competency. It may also be interpreted as an application driven process inconsistent with the COAG agreement. Option 2 Dual Sign Off - Registered Training Organisation driven process A more rigorous version of the current traineeship completion process could be applied to both apprenticeships and traineeships. Under this model, when the RTO had completed its final competency assessment it would contact the employer to determine workplace competence. I the apprentice and employer agree, the qualification is issued and completion of contract advised to the AAC/ OTTE. If the parties do not agree then the competency deficiencies are identified and a rectification plan developed. This is followed by regular contact between the RTO and employer until agreement on competence is reached. Alternatively, on completion of the rectification plan, the employer is advised that the contract will be automatically completed after a certain period unless the employer can show cause as to why this should not occur. The strength of this model is that it is driven by an outside agency and is therefore likely to encourage earlier completions. This is reinforced by regular checks or a time limited process for completion. Contract completions could be further encouraged if RTO funding incentives are linked to these rather than to qualification completions. Any potential for abuse could be checked through monitoring of completion anomalies and follow by AFOs and/ or audit. DISPUTES AND APPEALS. During the VET Inquiry consultations, some respondents proposed that there should be an independent appeals process possibly involving Industry Training Advisory Bodies. This assumes an application based process which was subsequently ruled out by COAG. Some respondents proposed that disputes could be resolved by additional testing. This would also be inconsistent with the intent of another COAG agreement concerning the removal of any external process which duplicates the outcomes of VET system delivery and qualification attainment. Additionally, past practice has shown that unreasonable delays may be caused when outside bodies determine applications for trade recognition (as once occurred for non-apprenticeship system participants). It is therefore proposed that a two stage dispute resolution process would be applied. AFOs would initially investigate and mediate disputes over competency based completions. All current AFOs are qualified with the Certificate IV in Training and Assessment and new appointees will also be required to gain this qualification. Any disputes which cannot be resolved may be appealed to the Victorian Learning and Employment Skills Commission or its delegate. WHERE TO FROM HERE? OTTE wishes to receive comments on the options presented in this paper (or any suggested variations on them) from stakeholder organisations. These can be submitted in electronic or hard copy form to Mr Geoff Foster, Manager, Apprenticeship Policy & Services, Office of Training and Tertiary Education, GPO Box 266D, Melbourne VIC 3001 or to foster.geoff.nm@edumail.vic.gov.au. The closing date for submissions is 27 October 2006.