COMPETENCY BASED COMPLETIONS

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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.
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