Berryman, Peter - Australian Traditional-Medicine Society

Related consultation
Submissions - Skills Reform: Improving industry engagement and reforming qualifications in Vocational Education and Training discussion paper
Submission received

Does the role of industry need to be strengthened or expanded across the VET system? Why/why not?

  • What does industry engagement mean to you?
  • How can industry be encouraged to connect with and use the VET system? What does this look like?
  • Are there any roles for industry in the VET system that are not covered or outlined in the case for change?

Response:

Yes, the role of my industry (Complementary Health) does need to be strengthened and expanded. [CONTENT REDACTED].

Industry engagement means the active participation of all representatives in IRC meetings, and their contributions to TACs, with de/briefing to the organisations we represent.

IRC representation from Professional Associations (such as ATMS) encourages industry connection with the VET system, as writing new and revised Training Packages is a critical industry task for ongoing relevancy to practitioners and the Australian public who are our clients.

Regular consultation is required with the relevant Ministers addressing the bizarre industry behaviour around funding (rorting), [CONTENT REDACTED].

Are you aware of the current industry-leadership arrangements led by the Australian Industry and Skills Commission?

Response:

Yes

How effective are the current industry engagement arrangements in VET in meeting your needs?

  • What works well and what could be improved? How could it be improved?
  • How well are you (or your organisation) represented by these arrangements?
  • How well do current arrangements allow collaboration across industry sectors on common workforce and skills needs?

Response:

[CONTENT REDACTED]

What can be done to drive greater collaboration across industries to broaden career pathways for VET graduates and maximise the workforce available to employers?

  • How can workers be equipped with skills that can be applied across different jobs?
  • How can industry support this through the VET system?
  • How can we break down silos and improve collaboration across industry groups?

Response:

Resolution of major industry issues, such as the place of Statutory Registration, and Minimum Education Standards, would drive greater collaboration in our industry of Complementary Health. Such resolutions would also then impact on the registered modalities in the Allied Health professions. Even within the Allied Health professions, the modality of Chinese medicine, which achieved Registration in 2012, has not been given access to all of the schemes (CDM, DVA, NDIS), that all of the other Allied Health professions have. Resolving this anomaly for Chinese medicine practitioners would broaden the career pathways for these graduates and maximise the workforce available to their employers and clients.

Making the best use of the existing VET training pathways allows a worker to start a career in Complementary Health with potentially a minimal investment in both time and money, in a State capital city, or regionally, or internationally. If all goes well, then further investment in training can result in a variety of different, though relevant jobs within Complementary Health. Industry can support this by not having a requirement of Minimum Education Standards to enter this industry, and Recognition of Prior Learning (RPL) across both VET and Higher Education qualifications.

Having VET and Higher Education as separate silos divides the industry. Resolving the Australian Qualifications Framework (AQF) levels and bands that demarcate VET from Higher Education may improve collaboration across industry groups.

Are qualifications fit-for-purpose in meeting the needs of industry and learners now and into the future? Why/why not?

  • Are the different needs of industry and learners effectively considered in designing qualifications in the current system? What works well and why?
  • Are there issues or challenges with the way qualifications are currently designed? What are they and what could be done to address these?

Response:

The current VET qualifications that are available in Complementary Health are fit-for-purpose, though the loss of four Advanced Diplomas by the end of teach out in 2018, in Naturopathy, Nutrition, Homeopathy and Western Herbal Medicine, was a serious mistake gravely affecting the future of this industry. Attempts to reinstate these lost Advanced Diplomas has recently been tried and failed, due to the lack of consensus within the industry (at IRC level) as to the Minimum Education Standards (VET or Higher Education) required to enter the industry, and the lack of government funding made available to support writing new training packages for these lost Advanced Diplomas.

Yes, the different needs of industry and learners are considered in designing qualifications, especially with the recent focus on telehealth, and the right place for online learning for theory and clinical training, and for equity in access to training for regional, rural and international students. Appropriate social distancing for students in a pandemic has also been focal. 

What is missing is research to inform the ongoing development of qualifications, and the continuing professional development (CPD) of trainers in relevant academic matters. Professional Associations (like ATMS) can provide relevant CPD for trainers, and support research with the awarding of financial seed grants. Developing threshold standards for entry into the industry with rotated national exams and marking rubrics would provide the necessary industry standards to resolve fake qualifications and accountability within the industry. The burden of quality assurance (QA) has been unreasonable (by ASQA) which can be resolved by having appropriate industry determined and actioned threshold standards.

Are there any further issues in relation to improving industry engagement in the VET sector that you would like to provide feedback on?

Response:

Taking a Training Package and turning it into a curriculum, with appropriate assessments and clinical training, has been an exceedingly difficult task for RTOs in Complementary Health. Even in the Higher Education sector, self-accrediting universities are not held accountable to the industry for their programs. 

Even though Private Health Insurance companies are not part of Complementary Health, their requirements for standards of education for providers to their members to be able to receive rebates has inappropriately become the default training/education standard. This needs to be reversed and let industry determine training/education requirements, that are then accepted by Private Health Insurance companies.

Competition in the health marketplace is constrained by MBS subsidised services versus Complementary Health services without MBS support. The Australian public are voting with their feet, and the industry would welcome an even playing field.