The concerns regarding TAE40110 – Certificate IV in Training and Assessment and the concerns regarding the unit of competency TAELLN411 – Address adult language, literacy and numeracy skills date back several years and across multiple areas. The main players include IBSA, ASQA, TAC (we’ve not heard any feedback about the VRQA being part of the confusion), the many providers who deliver TAE40110 – Certificate IV in Training and Assessment and who deliver/ed TAELLN401A – Address adult language, literacy and numeracy skills and the many VET practitioners who have been told to do this, told to do that and no clear message being provided by anyone.
The confusion began in 2012 when IBSA launched a report titled ‘Changes Ahead for VET Trainers and Assessors’. A little presumptuous, IBSA announced that the unit of competency TAELLN401A – Address adult language, literacy and numeracy skills would become a core unit of competency in TAE40110 – Certificate IV in Training and Assessment. Their exact announcement was:
“In July 2014 the current elective unit TAELLN401A Address adult language, literacy and numeracy skills will become a core unit in the TAE40110 Certificate IV in Training and Assessment….When the TAE10 Training Package is revised in July 2014 all new and existing trainers will need to hold, or demonstrate equivalent competency for, the unit TAELLN401A.”
Of course, the first hurdle that IBSA had to climb was that its announcement was in breach of the Standards for Training Packages which required that:
“The proportion of elective choice in all qualifications must be one third or more of total units required to gain a qualification, rounded up or down to the nearest whole unit (see notes under next point). The proportion of electives in all qualifications that can be sourced from other qualifications within the host Training Package, another Training Package, or from accredited courses, must be one sixth or more of the total units required to gain a qualification, rounded up or down to the nearest whole unit.
Note 1: Developers can not increase the size of qualifications in order to comply with the elective requirements.
Reference: [accessed 6 May 2014, 23h13pm].
When IBSA decided to make the unit of competency TAELLN401A – Address adult language, literacy and numeracy skills compulsory a core unit, the qualification no longer met the requirements for flexibility (minimum elective choices to gain a qualification etc.) described previously for endorsement by the NSSC. IBSA then decided that it would make the unit a core in a revised TAE40114 – Certificate IV in Training and Assessment that was due for endorsement in June 2014. However, the nation’s political system got in the way and the NSSC was disbanded leaving no ‘endorsement body’ available for what would appear to be a category 2 change that ISC’s are not permitted to make. IBSA now state on their website that upon endorsement of this qualification (TAE40114) ‘…the LLN unit then becomes a requirement for all trainers and assessors and we expect that practitioners will be granted twelve months to comply i.e. until sometime after June 2015…’
So what is a Category 1 and a Category 2 change and does it really matter?
The importance of understanding the difference between a category 1 and category 2 change is significant because the impact of a category 2 change is substantial (although we’re not suggesting that a category 1 change is not substantial, just that a category 2 change is far more involved). Firstly, it’s important to understand that an ISC (Industry Skills Council) can only make a category 1 change; anything that fits into category 2 must be endorsed by the NSSC or its successor. There are 2 types of upgrades to a training package; the first is an ISC Upgrade, the second is NSSC endorsement
ISC Updates - Any changes to a qualification and/or unit of competency that do not change the outcomes are considered ISC Upgrades.
NSSC Endorsements – Any changes to a qualification and/or unit of competency that changes the outcome must be submitted to the NSSC for endorsement.
Category 1 changes
Category 1 changes do not affect the Training Package version number. They include minor changes such as:
Category 2 changes
Category 2 changes result in a changed Training Package version number and include any changes that may have a significant impact on delivery and/or resourcing such as:
It is important to note however that when the TAE training package was endorsed in August 2013, only 2 qualifications and a skill set were endorsed; and neither of those qualifications contain in the core or elective bank TAELLN411 - Address adult language, literacy and numeracy skills. The two qualifications that were endorsed were Graduate Diplomas however the Skill Set did contain the unit TAELLN411 - Address adult language, literacy and numeracy skills. Unfortunately however, the skill set that was endorsed does not meet the NSSC requirements for trainers and assessors (SNR15.4(a) or AQTF 1.4(a)).
A note on IBSA’s website states ‘Please note that we are unable to say yet what the endorsement date for the new TAE Training Package will be. However it will be sometime after June 30, 2014. We shall advise a date as soon as it becomes clear.’ TAE40114 – Certificate IV in Training and Assessment (proposed) is to be submitted nonetheless in breach of the NSSC rules regarding the number of electives a qualification must have versus the number of core units a qualification must have (flexibility) rules. The newly proposed qualification will be deemed not equivalent as a qualification because the packaging now has 8 core units and 2 electives instead of 7 core units and 3 electives; yes, IBSA have inserted the TAELLN411 unit into the core!
Based on these facts:
Engaging in a debate around these questions and facts would be a fantastic professional development session for providers to have with their training and assessment staff as evidence of maintaining their TAE currency. If your organisation does do this, please let us know how your session went, we’d love to hear your feedback.
So where do I stand with stand alone delivery of TAELLN401A – Address adult language, literacy and numeracy skills?
If you have TAE40110 – Certificate IV in Training and Assessment on your scope of registration, the unit of competency TAELLN401A – Address adult language, literacy and numeracy skills is now a named elective in the packaging rules which means that contrary to advice from a peak body earlier this week, you DO NOT have to have the unit of competency TAELLN401A – Address adult language, literacy and numeracy skills explicitly listed on your scope of registration and therefore you DO NOT have to submit an amendment to scope. If you would like to have the unit explicitly listed you may go through this process however it is not a requirement.
If you have TAE50211 – Diploma of Training Design and Development on scope but not TAE40110 – Certificate IV in Training and Assessment (unlikely but possible), you cannot deliver TAELLN411 - Address adult language, literacy and numeracy skills as it is not a specified elective of that qualification, only TAELLN401A - Address adult language, literacy and numeracy skills is a specified elective.
If you have TAE50111 – Diploma of Vocational Education and Training on scope but not TAE40110 – Certificate IV in Training and Assessment (unlikely but possible), you cannot deliver TAELLN411 - Address adult language, literacy and numeracy skills as the unit of competency TAELLN401A - Address adult language, literacy and numeracy skills is a core unit within this qualification.
If you want to deliver the unit of competency TAELLN411 – Address adult language, literacy and numeracy skills as a stand alone unit of competency without any TAE qualifications, you must apply for an amendment to scope.
Is this a mandatory unit of competency that must be achieved by July 2014 or July 2015?
At this stage, there is no requirement for any trainer and assessor to have either TAELLN401A - Address adult language, literacy and numeracy skills or TAELLN411 - Address adult language, literacy and numeracy skills. IBSA incorrectly advised industry that all trainers and assessors must have this unit as part of their training and assessment qualifications. IBSA have drafted the newly proposed TAE40114 – Certificate IV in Training and Assessment (as discussed earlier) whose sole purpose is to mandate the unit of competency TAELLN411 - Address adult language, literacy and numeracy skills as a core unit of competency, breaching the flexibility rules for training package development. As this qualification has not yet been endorsed and has not yet been through the quality assurance and endorsement process, there is NO requirement for any trainer and assessor to have this unit of competency as part of their TAE40110 - Certificate IV in Training and Assessment.
I submitted an amendment to scope for the unit TAELLN411 - Address adult language, literacy and numeracy skills following ASQA’s previous advice regarding stand alone delivery of this unit. I submitted the application and paid the application fee, my application has been approved/is pending. What can I do?
Good question! You are not alone though. Many providers, in good faith, did what they were advised to do by ASQA and suddenly, this decision means that they have potentially been unfairly treated. You could seek a refund but it is unlikely that you will receive one. You can ask to have the application withdrawn and it most likely will or, you will be encouraged to have it listed explicitly on your scope of registration. We suggest contacting ASQA to determine your rights.
I was delivering TAELLN401A - Address adult language, literacy and numeracy skills within my rights and my scope of registration anyway, how does all of this affect me?
IBSA have indicated that the 2 units are equivalent, they had no choice if they were to undertake the change they did as an ISC upgrade to the training package. What is clear however is that the 2 units are actually not equivalent and if you thought that you didn’t need to make any changes, you would be very wrong. There are performance criteria that have been deleted, merged, an entire element of competency has been deleted, significant changes to required skills/performance evidence, significant changes to required knowledge/performance knowledge and changes to the assessment conditions are all evidence of why this unit should not have been deemed equivalent.
Under the training package endorsement process, an ISC cannot self endorse a unit or qualification that is not equivalent, these are known as ‘Category 2 changes’. For IBSA (and ASQA) to achieve the result that they have, all that could be done was an ISC upgrade. While this change was obviously a knee-jerk reaction to satisfy the outcry from the VET sector, it was handled very poorly. Within the space of 24 hours, there were 2 releases of the TAE40110 – Certificate IV in Training and Assessment on TGA which meant that on 1 day, you could have quite legitimately selected both LLN units as electives but the following day, a slight amendment (the addition of the word ‘or’) in between the 2 LLN electives was made. While in some ways, it has calmed the storm and the outcry, it hasn’t necessarily done people any favours either. As can be demonstrated when comparing the two LLN units, they quite legitimately are not equivalent and in fact, if you delivered them to achieve the same outcomes, you could potentially be deemed non-compliant due to over-delivery. The TAELLN401A- Address adult language, literacy and numeracy skills unit has less onerous requirements than TAELLN411 - Address adult language, literacy and numeracy skills.
To further complicate the issue, if for any reason, the proposed current version of TAE40114 – Certificate IV in Training and Assessment is endorsed, IBSA have declared (and rightly so as it is a category 1 change) that the proposed qualification will not be equivalent to TAE40110 – Certificate IV in Training and Assessment. As such, even though for the past 12 months at least that trainers and assessors have been legitimately racing to obtain this unit will be superseded to ensure that they remain current, they will have to undertake a whole new assessment process for a whole new qualification even though they hold the LLN unit which was deemed equivalent to begin with! So a large population of VET trainers and assessors have undertaken (and paid for) an assessment process that is eventually, most likely going to be worthless if the proposed new TAE40114 – Certificate IV in Training and Assessment is endorsed.
To add further insult to injury, if the issue is not resolved by 26 August 2014 (12 months from the release of the unit of competency TAELLN411- Address adult language, literacy and numeracy skills on TGA), and the new TAE qualifications prior to this date, we may likely have a scenario where no TAE qualification will be able to have the LLN unit included.
Is the issue resolved?
Not by a long shot. Unfortunately, IBSA and ASQA have got themselves into this mess it will be interesting to watch events unfold over the coming months. No matter what, RTO Doctor will have an ongoing update on the RTO Doctor website in relation to the TAELLN411 issue and you are welcome to follow the updates as they occur.