Walsh, Paul - Australian Industry Standards

Response:

- Throughout 2020, AIS supported the Digital Transformation Expert Panel which was established by the AISC to ‘provide advice on how Australia’s VET system can most effectively respond to digital change underway across industry and its impact on the nation’s workforce’.   

On the Panel’s behalf, AIS undertook extensive consultation across all industries and included discussion with key industry stakeholders, peak bodies and unions.  During the consultation, employer and employee representatives voiced two threshold concerns. Firstly, that the VET system has become overly focussed on credentialing and training at the expense of workforce development and skills formation.  Secondly, that whilst VET “works well” for entry-level training, its relevance to the existing workforce is limited and is an issue of growing concern given the increasing speed of technology change and the need for economy-wide upskilling and reskilling.   

- Expanding and strengthening industry’s role in Australia’s VET system is critical to the success of enterprises, to drive productivity, and to ensure we have a globally competitive economy. To deliver the skills that industry need, at scale, co-investment from industry and governments is essential. 

For industry to significantly invest in upskilling and reskilling of the workforce, and to ‘share the investment’ as the basis for a sustainable, lifelong approach to workforce development in Australia, industry needs to have far greater influence and determinative power in both system design and policy settings.1  

Industry having a greater determinative role will ensure the VET system has a far more balanced focus with efforts and funding directed to upskilling and reskilling the workforce.  Specific programs have been highly successful in driving workforce development and building a culture of co-investment whereby public funds were used to leverage enterprise investment eg. Enterprise Based Productivity Places Program and National Workforce Development Fund. Currently system wide settings are ultimately shaped and decided by senior officials and skills ministers. 

- As a system, we need to engage with industry on a systematic basis to build enterprise capability.  The system’s focus on training, rather than workforce development, means that enrolments have become a proxy for skills of the workforce, industry’s engagement with the system and their support or otherwise of a training package.   

- Australia’s workforce is typically skilled within the enterprise and arguably quicker than can be achieved through formal training.  Helping enterprises to build their own workforce development capacity and using training packages as part of an integrated workforce development system that uses the units for skills analyses, skills audits, job descriptions and career pathways, is core to a more contemporary and dynamic VET system. 

- Ensuring the system supports the existing workforce can, in part, be addressed through the development of discrete training products by Industry Reference Committees (microcredentials and skill sets) so that upskilling and reskilling pathways are available within and between industries (see Q4).  However, development is only part of the solution.  Training products require funding for delivery and industry should have a more determinative role in prioritising funding for upskilling and reskilling of skills sets/microcredentials for their respective industries.  We believe this determinative role is an opportunity to more effectively engage and involve industry, and drive quality training outcomes.  Insights from industry about the future are more direct, timely and relevant than retrospective data scraping of job adverts. 

Response:

Yes

Response:

- AIS is currently engaged as a Skills Service Organisation.  Prior to this, the Commonwealth engaged AIS as an Industry Skills Council and previously, a national Industry Training Advisory Body.  Under each of these roles, AIS has been responsible for the development of nationally endorsed Training Packages on behalf of industry, and a range of associated roles including the facilitation of workforce development, promotion of VET to industry, and design of VET in School pathways.  AIS’ response is therefore written in the context of AIS having been formally contracted to build industry engagement in VET for over 20 years, and its experience in building effective industry engagement mechanisms during that period. 

- Industry engagement is typically interpreted as industry’s involvement in developing and validating training products.  As set out in Q1, we believe that there is a strong need for industry leaders to have a far greater determinative role in policy design and prioritisation within the VET system.   

- We also believe that for the VET system to engage with Australian industry, there needs to be a recognition that no single methodology will successfully work across all industry sectors.  Thereby, the most effective approach depends upon how ‘organised’ each sector is.  Some sectors are dominated by large scale businesses and have a clear voice and direction on VET.  These are the exception, with most industries comprising a mix of micro, small, medium and large organisations that look to pro-active industry/employer associations to represent the mix and nuanced nature of industry views.  Within most industries, unions also play a vital role in representing the views of employees.  

- Ensuring both the views of employers and employees are adequately captured and taken into account in the development of policy settings and training products is paramount to a stable VET system.   

Australia’s national system has been in place since 1992 and for the most part, has enjoyed stability in its high-level objectives and policy direction irrespective of which party formed government.  To a large degree, this has been because philosophical differences have been resolved through the bipartite model of VET (employer and employee representatives).   

Bipartisanship provides stability, which brings certainty for RTOs, and more importantly, certainty for individual employers seeking to use the VET system. Heading into an era where industry co-investment will be paramount to delivering the volume of skills development needed by existing workers, enterprise investment will require stability, along with ongoing policy and program certainty. 

- In relation to the basic principles of engagement, it is important that policy makers and training product developers engage industry representatives from all segments of the innovation adoption curve; the ‘innovators’, ‘early adopters’, ‘early’ and ‘late majority’, and the ‘laggards’. Engaging the ‘late majority’ and the ‘laggards’, given this is a significant proportion of industry, is essential to understanding and responding to what is inhibiting technology adoption and corresponding skills development.   

- Enterprises also need to be representative of all business scales, most especially small business who face the largest barriers to formal training and employ 44% of the Australian workforce.2  As part of this approach, it is necessary to renew and refresh enterprise networks to ensure fresh ideas are brought forward and to test existing assumptions.   

In addition to enterprises, it is vital that the role and corporate memory of industry organisations – both employer and employee – is recognised. Individual enterprises bring a perspective based on their frame of reference.  Pro-active industry organisations bring much broader, tested input with many involved in the design of the national VET system.  Both are needed and neither should be excluded. 

Response:

- When first conceived in 1992, units of competency were short, simple occupational standards that codified the relevant skills and knowledge required to perform competently in the workplace.  Their simplicity ensured maximum relevance across enterprises of different scales, locations and across industries.  Their silence on how to train was intentional.  It acknowledged that as individuals, we all learn differently.  This gave RTOs maximum flexibility on where learners acquired the skills, in the workplace, a simulated environment or an institution.  The approach went to the central tenet of competency based training; it does not matter how and where you learn, only that you achieve competency in the skills and knowledge codified in the unit. 

- In response to poor quality training and assessment by RTOs, the unit template has been repeatedly evolved to include more detail and specificity to assist training providers.  It means that units are now lengthy and less flexible in application than intended. Ongoing concerns with RTO quality and practitioners’ vocational currency mean that some industries now use prescriptive and industry-specific terms in expressing the required skills and knowledge and the associated assessment requirements.  This is particularly the case where the units relate to high risk tasks that pose a risk to the worker, the enterprise or the environment. The use of industry-specific terms can, however, limit the potential for other industries to adopt units of competency where the skills are essentially portable. 

- The concept of cross-industry units has been a feature of the training package policy for 20+ years, albeit under iterative concepts of ‘guideline standards’, ‘generic’, ‘common’ and more recently, ‘cross sector units’.  Whilst the nomenclature has changed, the goal has remained the same – the formal recognition of common skills to drive this portability.  Regardless of approach the concept has had limited success due to two primary reasons.  The first, as outlined above, is the lack of quality in training and assessment which has resulted in prescriptive, often industry-specific units.  The second reason is the need for policy on ownership and maintenance.  That is, if a unit is shared by multiple industries, how the host training package is determined and how all the industries that use that unit are then ensured equal influence when the unit needs to evolve. A requirement to demonstrate at endorsement, that new units do not replicate existing training Package units would be part of the policy. Having managed the cross-sector supply chain project where we were confronted with this issue of industry ownership of units, AIS firmly believes that an industry agreed policy on the ownership and maintenance of ‘cross sector’ units is fundamental to building collaboration between industries and opening up pathways. 

- AIS believes that there are potentially two further opportunities to increase the use of units across industries and increase collaboration. The first is to transfer the industry-specific information into the Companion Volume as AIS did for the Cross Sector Supply Chain project.  For each Cross Sector unit, the Companion Volume now includes extensive links to topical articles, reports, videos, websites and social media for each discrete industry to which the unit relates and to illustrate how those skills are applied in context.  As part of the concept, AIS has committed to treating the Companion Volume as a ‘living document’ continuing to update the content to ensure the latest technologies and practices for each industry are captured.   

- Another option may be to transfer the industry-specific information on training and assessment into a Training Standard.  This would streamline the unit content and ensure greater relevance across industries.  Endorsed to ensure its content is auditable, each industry could have its own Training Standard.  

Response:

- AIS believes that current Training Package policy enables significant flexibility in qualification and skill set design.   

Most qualifications are designed to have a set of core units and sometimes specialist streams which industry deem essential to the occupation/s that the qualification supports.  These are often supported by a bank of elective units to ensure relevance to a range of businesses/industry contexts.   

Whilst qualifications may be designed by industry to enable optimum flexibility, what ultimately gets delivered by RTOs is often only a portion of the units available in the qualification.  Many RTOs simply offer the electives for which they have the staff expertise, the learning resources, or where it is possible to get a large number of students. Employers and students are often given only a small proportion of the electives available in the qualification from which to choose.  As a consequence, many units receive few or no enrolments because they are not offered and despite being sought-after by industry during their development. 

When there is criticism of qualifications not being ‘fit for purpose’, employers often conflate the limited offering by the RTO with what is actually available in the full qualification.  This fundamental issue is rarely understood or acknowledged by reviews into training product design.  As a consequence, the system keeps evolving training package policy only for enterprises and learners to continue to be dissatisfied with what they are offered.  We suggest that this be the subject of a strategic review by ASQA to establish quantitative data on the extent to which this is impacting the system’s ability to meet industry’s needs. 

- One of the areas where training package policy could be improved is in their ability to support upskilling/reskilling.  This involves development of skill sets/microcredentials to formally recognise the portability and progression of skills where job roles are rapidly evolving and workers are at risk of being left behind.  As the global economy digitally transforms, utilising Training Packages as a strategic mechanism to support the existing workforce is urgent. By 2034, automation will displace 2.7 million Australian workers, whilst technology will augment 4.5 million Australian workers.3 

Work underway through the JEDI initiative, which maps the connection between tasks/knowledge within and between training packages, could be useful in identifying possible pathways between industries (with associated Industry Reference Committees validating the connections).  However, as has been experienced with existing skill sets and as flagged in our response to Q1, industry must then be involved in prioritising funding for upskilling/reskilling to better balance the system’s preoccupation with full qualifications. 

- The current approach to funding development and maintenance of training package qualifications/skill sets is yet to meet the needs of industry.  Submitting Cases for Change to the AISC for training product development/maintenance means that they are subject to the decisions of third parties on whether their priority is deemed worthy and when the when the work can commence.   

Under the previous Industry Skills Council (ISC) model, ISCs were funded on a strategic basis, which involved Departmental approval of a three-year business plan that had been agreed by the industry steering committees and covered their respective training packages. This allowed industries to interlink work, establish common units across sectors, run consultative processes in tandem and achieve cost efficiencies.  

Grouping industry sectors together will improve collaboration in developing common units. Funding these industry groupings on a strategic basis will reduce blockages in the Training Package development process, significantly improving speed to market. 

Response:

In this submission, our key points have focussed on: the need for industry to have a strong determinative role in policy design and product development; engaging with individual employers through systematic workforce development services; the key features of effective engagement; and improving cross industry collaboration on training products. Our final key point relates to the perennial issue of quality and reliability of assessment outcomes which continues to undermine industry’s confidence, engagement with, and investment in formal training.   

The original goal of making public funds contestable to both public and private RTOs was to drive competition that would lead to a significant improvement in the quality of training and assessment.  However, a competitive market only functions effectively when there are informed purchasers.  As a VET system, there is still an inadequate amount of independent, relevant information available to potential learners and employers to distinguish poor quality providers.  As a consequence, market forces have done little to influence RTOs’ quality with poor training and assessment practices continuing to exist as evidenced by ASQA’s strategic reviews and audit reports on the system.   

Employers and industry more broadly remain concerned with the integrity and consistency of assessment outcomes, and reflect on the fact that whilst they may set the occupational standard, they still have no control over the actual outcome.  

Within Australia there is no structural separation between the bodies that provide training and those that undertake assessment (and ultimately issue the qualification).  RTOs do both, often using the same practitioner.  We believe that industry should be far closer to the assessment process, particularly where the assessment is of high risk tasks or those that can pose a risk to the worker, the enterprise or the environment.  

We believe that the concept of Independent Assessment Organisations (IAO) could be piloted for high risk occupations, high risk qualifications or where industry or VET regulators find a proven pattern of poor performance.  This focus on risk would be consistent with the system’s existing risk based model for audit and compliance, and could go a long way to strengthening industry’s confidence in the VET system.  We understand from ASQA that ‘assessment only RTOs’ are still enabled through existing regulatory standards to underpin a pilot. 

Importantly, such a mechanism could start to drive Recognition of Prior Learning (RPL) in earnest, and with a strong focus on existing workers. RPL remains woefully under utilised and its use is falling.  In 2018, “less than 5% of all successful subject results were granted through RPL and less than 3% of all students successfully completed any subjects through RPL”4. 

The pilot could be subject to an Expression of Interest from suitable service organisations.  Applicants might include professional industry bodies, industry regulators, expert VET bodies or leading RTOs in partnership with industry.  Such organisations would be subject to regulation and audit by the VET regulators. Results from assessments by IAOs could be analysed by VET regulators to identify any RTO where high numbers of learners are failing to achieve competence and there is no demographic or pedagogical rationale.  VET regulators could follow up with individual RTOs as appropriate to determine compliance with the Standards for RTOs 2015.