At RTO Doctor, we have previously discussed our disappointment in the quality of training packages, in particular during our newsletter from July 2013. It is with even greater disappointment that this month’s feature article provides an open discovery of a cover up of a system failure that has the potential to have dramatic consequences for RTO’s who have qualifications from this training package on their scope of registration.
If an RTO conducted itself in this way, they would be severely reprimanded, if not heavily sanctioned and it is completely unacceptable that government bodies upon whom all of your registrations are reliant, think that they can get away with such incompetence and that it goes unnoticed. This case demonstrates the complete failure of a range of government departments or bodies who are supposed to know better; whose reputation and expectation of quality assurance is expected by every single provider out there, including the public, employers and students. What is very clear is that nobody can currently rely on information provided in the public domain for them to consult and be compliant with when the information is manipulated in such a way.
The best way to tell this story is to start from the beginning. On 31 January 2014, during some auditing work for a client at the time, we identified that in a Diploma qualification on the client’s scope of registration from the CPC08 Training Package, 1 core unit of competency (imported from the parent training package BSB07 Training Package) had been superseded almost 22 months prior on 18 December 2012 and , another core unit in the same qualification that had been imported from the same training package had been completely deleted from the parent training package (BSB07 Training Package) on 18 March 2013. The qualification should have received a new qualification code as a result (as did every other qualification in the same situation across many other training packages) 22 months earlier had the relevant ISC (CPSISC) been ensuring the quality of the qualifications in their training package. Instead, it went completely unnoticed. Another qualification code change should have then occurred after the core unit that had been imported from another training package was deleted. However, none of this was even identified by CPSISC until a phone call and email from the provider to the Building and Construction Industry Training Fund notified them of the issue. Instead, what we currently have is exactly the same qualification code that was issued in version 8 of the training package endorsed on 5 December 2012 when the current training package is in version 9 and was endorsed on 5 December 2013.
The BSB07 Training Package on training.gov.au (TGA) on 31 January 2014 clearly stated that the status of the following 2 units of competency were as follows:
BSBOHS504A – Apply principles of OHS risk management – Superseded – 18 December 2012 (This is still what is showing on TGA)
BSBHRM403A – Recruit, select and induct staff – Deleted – 18 March 2013
It was based on the information provided on TGA that the provider made contact with the ISC. The client in question was in a bit of a quandary because they had to submit their application for audit and while they had received advice to say that they should provide their email to the regulator as evidence of taking action, it was also explained to them that once the ISC became aware of this issue, you would see an urgent update made to the training package outside the NSSC process and that the qualification would receive a new code at the next opportunity to submit a case for endorsement to the NSSC. What this would mean to the RTO is that by the time the regulator got around to conducting their desktop and site visit, the provider’s qualification would have already transitioned and they would have been deemed non-compliant against the standards during the site visit as the qualification was superseded. Through no fault of their own, this provider was going to have to submit something that they knew was non-compliant but at the time of the audit with the regulator, they knew that they would be deemed non-compliant.
On 24 February 2014, while providing some professional development to the staff of another RTO, RTO Doctor was demonstrating how it is unsafe to rely on the information on TGA as being accurate and that you should always do your own checks. The example of the above information was provided. However, when demonstrating the units of competency from the BSB07 Training Package, what had been identified by us at RTO Doctor was that TGA has been updated to reflect entirely new information in relation to BSBHRM403A – Recruit, select and induct staff. The screen shot below (Image 1) clearly shows what was displayed on TGA on 24 February 2014 in relation to this unit of competency. The TGA ruling indicates ‘superseded’ however the version date and version number of the training package have notchanged.
Image 2 on the other hand is taken from page 19 of the BSB07 Business Services Training Package version 9. While someone was busy trying to go into damage control, what they did forget to also update was the summary mapping section of the training package that identifies very clearly (page 19) that the unit of competency BSBHRM403A – Recruit, select and induct staff was Deleted 18 March 2013 and a new unit of competency BSBHRM503A – Support the recruitment, selection and induction of staff will take its place. What you can also see however is that this document also did not receive any version update, date changes or anything at all.
So who is to blame for this system failure really?
Is it the RTO’s fault if they continue to run superseded and deleted units of competency in their qualifications?
The RTO must deliver the qualification as per the packaging rules. However, an argument remains that if the RTO was meeting its requirements of 15.5d (Assessment (including RPL) is systematically validated, it wouldn’t have taken 22 months for the RTO to have been alerted to the fact that one core unit was superseded and it wouldn’t have taken until the internal audit to identify that a core unit of competency had been completely deleted from its parent training package.
Is it the ISC’s fault for not providing sufficient and adequate quality assurance in the launch of its products that anyone in the construction industry relies upon?
In our opinion, absolutely the ISC is partly to blame for this system failure. The ISC’s get paid money on behalf of tax payers to perform a critical role ion the maintenance and development of products that will enhance Australia’s training sector and industry as well as be responsible for the currency and skills of our workforce through the development of current, accurate and industry relevant qualifications for the remainder of our sector to work with in the development of Australia’s workforce. From the ISC’s own website, the following statement is made:
“Inconsistent quality of outcomes within the Australian VET sector remains one of the system’s most enduring issues. With nearly 5,000 RTOs, annual VET revenue of $8.68billion and 1.4 million enrolments in Training Package qualifications in 2011, the delivery of consistent, high-quality training and assessment is now a national imperative. Both policymakers and RTOs must move quickly to restore confidence if enterprises, governments and individuals are to continue their investment in nationally recognised training.”
Surely examples such as these indicate that the integrity of the training packages that they develop, as well as the value and integrity of Australian VET qualifications are a part of the systemic failure of our skills development program? Surely this demonstrates that it is not enough to continue to shift the blame only to dodgy RTO’s? Under no circumstances are we saying that there are not ‘dodgy RTO’s’ and under no circumstances are we saying that all faults lie with the ISCs. What we are saying however is that it is time that everyone lifted their game in order to make the system function effectively. In a period of VET Reform where standards are being reviewed, ASQA’s performance is being reviewed, ASQA’s full cost recovery program is about to be implemented, RTO’s are being cancelled or ‘coerced’ into voluntary relinquishment of their RTO registration, other RTO’s are being suspended and the value of Australian qualifications is being seriously questioned, it is no longer good enough for ISC’s to continue to publish training packages with reference to AQTF 2007, it’s no longer acceptable (and in our opinion, never was) for training packages to continue to provide ‘industry current practices’ that no industry body in the country would ever permit. An example of this situation is where the training package (RII09) requires the student to be assessed moving an underground service when it is actually illegal for them to do so. Again, providers notified the ISC and the issue continues to be an assessable item in the current version.
Who else is to blame for such poor quality assurance of our national training system’s foundations?
We believe that the NSSC also has to shoulder some of the blame here for on most occasions, they are responsible for endorsing these qualifications and training packages (they certainly endorsed the CPC08 training packages outlined in this article as it appears on TGA with the exception of version 6.1 which states that the version change was due to an ISC upgrade). The NSSC is responsible, through its committee for a raft of standards in the VET sector and it seems that in recent times, it’s efficiency has also every right to be questioned. With the recent resignation of the Chair John Dawkins due to his conflict of interest with a private RTO listed on the stock exchange to its questionable approach to investigating the inefficiencies and inadequacies of the VET sector. Selective panels, questions designed so that responses are somewhat favoured and don’t provide an opportunity for comment, lack of interest in really understanding some of the core matters as they are experienced by a range of other stakeholders involved in the VET sector, not least of whom includes students themselves.
The NSSC is responsible for endorsing training packages once they have been approved by a member of the Quality Assurance Panel. While the Quality Assurance Panel is broad and has a range of people, it is effectively up to the training package developer to ‘select’ their own reviewer. A person can be a member of the NSSC Quality Assurance Panel for the duration of their contract and never actually undertake a review of a training package (yet are still required to pay the costs involved in attending induction, moderation etc.). There is no guarantee of work, nor is there any guarantee of remaining on the panel. The ISC is responsible for selecting and paying the panel member of their choice to provide a Quality Report to accompany the training package proposed for endorsement. In that context, it may be that the competing need of an ISC to spend the least amount of money possible as it is tax payer funded will take the path of least resistance to having the case for endorsement approved.
On a final note, it is perhaps timely to note that the Head of the VET Reform Taskforce is also an ex-officio member of the NSSC meaning that she has ‘…been appointed to the NSSC based on the position that she holds. As with all ex-officio members, they are to provide advice and guidance to the Council to help inform deliberations. Ex-officio members are not required to represent the views of their stakeholders, rather they are appointed based on the expertise and knowledge associated with their role or position…’ It is worth taking a look at the backgrounds of those who make up the NSSC, it may help you better understand some of the directions of the future in VET in Australia. Ex-officio members have the same rights and responsibilities as experts members, except for the ability to vote on Council matters.
So, as a final summary, RTO Doctor’s advice continues to be…Never trust that the information on TGA is accurate, always do your due diligence. Your RTO registration could be at risk if you don’t.