This submission is based purely on the knowledge, skills and experiences of RTO Doctor.  This submission in no way provides feedback from our clients or affiliates.  While it has been suggested that RTO Doctor, like other Consultants speak on behalf of the clients, we as a company have chosen not to do so.  Many of our clients have expressed an interest to not make their views public for fear of any potential negative consequences that may impact them in the future.  As such, all comments, opinions and suggestions are our own.

Attachments from LinkedIn Discussion Groups have been included to represent collective views from a public forum on issues relevant to our submission.  As has been widely discussed in these forums, many people are submitting these discussions as additional evidence and RTO Doctor is following this method of evidence provision to support our findings, while also providing further context to our own contributions to these forums.

For all feedback, questions or comments in relation to this submission, please contact us viaRaelene@rtodoctor.com.au or lauren@rtodoctor.com.au

Introduction

In 2008, Tovey and Lawlor (p.3) wrote about training being “…frequently accused of being spasmodic, of little relevance to organizational, management and individual goals and very hard to measure…Many training programs were faddish in nature, swinging from one flavor of the month to another…Often training programs had been badly designed by unqualified individuals with insufficient experience.”

At RTO Doctor, we find ourselves asking the question, what has changed?  Through this feedback to the VET Reform Taskforce, we hope to contribute valuable knowledge, experience, research and recommendations to ensure that once and for all, Australia’s VET sector achieves its rightful purpose and is sustainable for our nation’s future.

This Feedback Report, submitted as part of the request for submissions, is based on identifying what we see as some of the core issues that are currently plaguing (and destroying) our world-renowned system and proposes some suggestions for changing the status quo.  This report intentionally provides an overview of the historical context of VET in Australia, what the purpose of VET appears to be in today’s economic market, discuss who might be the stakeholders of the VET sector currently and discuss the current perception of VET in Australia because typically, as is shown in the initial stages of our submission, history does have a habit of repeating itself in this sector.  Until these key concepts are clearly understood, there is little point in trying to improve the quality of VET.

 The report also provides discussion and recommendations about regulatory authorities and discusses the current significant This section has been removed for privacy and confidentiality reasons. without the necessary due diligence being performed by the regulators and the unexpected impacts that this is having.  There is discussion about the quality and inconsistency of auditing staff around the country and the impact that this has had on the VET sector and the impact it will continue to have if left unaddressed.  An area of significant concern to RTO Doctor is the discussion that needs to be held surrounding Industry Skills Councils, the Quality Assurance Panel of the now defunct National Skills Standards Council (NSSC) and the quality of the training packages that they are required to produce, continuously improve and endorse.  Other sections that are covered in this report include a discussion about how much importance is being placed on This section has been removed for privacy and confidentiality reasons. and the significant cost recovery of ASQA’s operations and how both of these activities critically impact the VET sector in Australia.

 There is a discussion regarding the accountability and transparency of the complaints and appeals process being implemented by ASQA This section has been removed for privacy and confidentiality reasons.  There is a final discussion about the concept of de-regulation proposed by the current government and being touted by This section has been removed for privacy and confidentiality reasons. earlier mentioned as being the most appropriate way forward.  The report will conclude with a summary of the RTO Doctor position on the reform taking place as well as summarise our recommendations for an improved system that we can all be proud of.

History of VET in Australia

In the mid 1980’s when Australia was facing significant economic challenges including new markets, technology, high unemployment, significant retrenchments due to emerging technology and a global marketplace, governments forged strong partnerships with large industry bodies, professional associations and unions in an effort to enhance employability, increase skill development and be better prepared for a globally and highly competitive marketplace.  These strong partnerships led to a vision of better career paths, work readiness requirements (work preparation) and vocational skills that the decision makers at the time, as well as policy makers felt were lacking.  The Government effectively grabbed VET and used it as a band aid upon which to build policies and frameworks in order to equip the current unemployed and new generations of workers.  It was also a measure that could be used to demonstrate the government’s willingness and attempts at getting people ‘off the dole’ and into the workforce.  The concept of continuous improvement that plagues the VET sector comes from the belief of governments that the workforce is dynamic, fluid and changes rapidly and therefore, the VET sector (the only sector) must remain current with those changes.  The knowledge, skills, attitudes and capabilities that would fill this void would later become known as ‘competencies’.

 As happened in the 1980’s and 1990’s, the Australian workplace has changed significantly, which has meant that the requirements of the VET sector have also changed.  Since then we’ve seen an increase in the workforce by women, a decrease in the workforce by men, more females in leadership roles, people using more cards and cash than cheques, machines are used more and more frequently rather than hand tools, the Australian workplace context has changed significantly from cultural to employment status (fulltime, part-time, casual, subcontracting) even the typical working day and expected work hours have changed significantly.  The use of technology has completely transformed the Australian workplace no matter what industry you are in.  In effect, the Australian workforce was changing significantly and rapidly. The Government needed to find a solution and it appeared that the VET sector could provide it.

 Additionally in the mid 1980’s, despite government intervention to attempt to make training accountable and produce the outcomes it needed, training reform did take place to focus on the needs of commerce and industry and ensure that certain individual abilities required in the workplace were personally attained by those involved in the training.  Various pieces of legislation were developed and enacted to force companies to spend a certain amount of money annually of training which also brought with it some flexibility in what type of training was permitted.  All relevant and related legislation was finally repealed in the late 1990’s as it became clear that the government was not achieving its objectives.

 VET’s presence in Australia has been mostly reflective of Government responses to economic issues and public outcry.  As reported by the NSSC (2013, p14):

 The AQTF 2007 review was in reaction to criticism of AQTF 2002 that the standards were too prescriptive.  The standards were therefore re-focused to support continuous improvement and reducing the regulatory burden, as well as reflect outcomes based objectives.  The AQTF 2010 review was in reaction to provider collapses and concerns about low-quality providers in the vocational education and training market.  Subsequent changes focused on financial management, governance and consumer protection.’

 Currently, the VET sector is waiting to see if the proposed Australian Vocational Qualification System (AVQS) will be implemented or whether something else entirely will be determined.  What is demonstrated through the AVQS is that again, it has been developed based on Government’s reactive response to the economic and political climate, public outcry that the system is too prescriptive and de-regulation should become a key feature and that new and higher level skills, as well as certification for those skills is the supposed driver behind these reforms.  It suggests that the implementation of the AVQS will provide the integrity of the qualifications deriving from the VET sector that is currently missing and this will ‘…support individuals on the career pathways, and ensures employers have the relevant and current skilled workforce to make them productive.’  This all of course sounds very familiar and a step back to the review of the AQTF 2002 standards that were too prescriptive, moving toward the AQTF 2007 which supported continuous improvement and reduced the regulatory burden.

Purpose of VET in Australia

Historically, according to the ‘Kangan Report’ (1974; p23) the purpose of VET in Australia was (and should (author’s addition)):

“To include all programs of education with a vocational purpose…whether the individual is using the program with employment as a primary aim or with the aim of gaining additional specialised knowledge or skills for personal enrichment or job improvement. It includes what is usually known as ‘adult education’. It does not include activities which have no direct educational purpose, and which are not planned as a systematic sequence, for example, social and corporate activities such as meetings of clubs, associations, or work camps having no explicit educational aim.

It should include all programs of education with a vocational purpose…whether the individual is using the program with employment as a primary aim or with the aim of gaining additional specialised knowledge or skills for personal enrichment or job improvement. It includes what is usually known as ‘adult education’. It does not include activities which have no direct educational purpose, and which are not planned as a systematic sequence, for example, social and corporate activities such as meetings of clubs, associations, or work camps having no explicit educational aim”.

As it is today, technical and further education has too often been thought of as something different from mainstream of education – primary, secondary and university. Opportunities for recurrent education should help individuals who wish to repair inadequacies in their initial formal education or add to their knowledge and skills in order to change the direction of their vocational interests.

The Kangan Report (1974) also states that relevance is the key factor in courses and that content must be relevant, that meaningless or underused knowledge and skills should be removed. Despite all of this historical knowledge, nothing has really changed since 1974.  As Tovey and Lawlor (2008, p.31) rightly state ‘Governments, commerce and industry pay scant attention to the qualifications and expertise needed to facilitate the type and nature of learning required to deliver the results of which they constantly talk”.  If they did, there wouldn’t be such significant unrest in Australia’s second largest export industry.  Effectively, what it boils down to is that the purpose of VET will be different for different people.  For the government it means one thing, for the community another.  For TAFE it means one thing, for the private RTO it means another.  For the employer and the student, it can often mean something very different again.  How can we develop a basis for a new system when we don’t actually understand its true purpose?  Maybe there is more than one purpose and it depends on whose needs we are trying to meet.

Stakeholders of VET in Australia

In analyzing the historical context and purpose of VET in Australia, it becomes apparent that for many decades, the key stakeholders of the VET sector in Australia have been:

  • Government
  • Unions
  • Industry
  • Associations
  • Unions
  • Unemployed
  • Unskilled workers

 While some would argue that the ongoing reference in the Kangan Report to technical and further education is not synonymous with what we now know as TAFE, others would potentially argue that this is why today the acronym VET in the majority of circles does equate to TAFE.  A vast range of other stakeholders who are not adequately consulted about VET or even the efforts of reform undertaken by this current government include (but are not limited to):

  • Registered Training Organisations (Public & Private)
  • Students themselves
  • Small businesses who send their staff to training in the VET sector
  • Parents / Guardians
  • Secondary Schools
  • Universities
  • External accreditation bodies including for example the Australian Nursing and Midwifery Accreditation Council (ANMAC) & Australian Children’s Education and Care Quality Authority (ACECQA), Road Traffic Authorities, Civil Aviation Safety Authority, Police agencies across the country, etc.
  • Resource providers such as publishing companies (one of Australia’s largest publishing companies ceased providing resources in 2013 due to the constant change to training packages requiring updates to their resources on a more frequent basis than was financially viable).
  • Trainers and Assessors, administration staff, student support staff
  • Education & Training Support Services including Consultants, Resource Developers, Accountants, Lawyers etc.

 Yet the question must be asked, how many of these stakeholders are accurately and adequately represented in the senior levels of decision-making affecting them?  What is clear is that a large number of those stakeholders rely on the current system to function at its greatest to allow them to perform their role, a number of these stakeholders have never been consulted about the reform process (although regulators never lose an opportunity to consult them about the quality of training that the RTO they are auditing provides).  Industry Skills Councils who are supposed to represent industry have their select few giants that they consult with generally speaking and the average small business owner, the average secondary school, the average University, the average parent/guardian are very rarely consulted and they certainly have not been adequately consulted throughout this current reform process.  Each one of these stakeholders has very different needs, not unlike the training that RTO’s are required to customize and contextualize for each of their stakeholders, the VET Reform Taskforce has a mandate to consult with ALL stakeholders that are affected by any future reform efforts.

Perception of VET sector in Australia

Perhaps unsurprisingly, when the general community hear or see the acronym VET, they perceive it as meaning:

  • TAFE
  • Veterinarians
  • Vietnam Veterans
  • Courses you do because you can’t get into University

 Even amongst those areas of the community who should know better, it seems this is not the case.  Secondary School Information Days/Evenings for preparation into Year 11 & 12 talk about vocational education and training as being TAFE, the local bank managers, the local McDonalds Store, the local Pharmacy, the local dental surgery, the local pathology clinic, the local childcare centre, the local mine site – they all think of vocational education and training as meaning TAFE.  Yet, of approximately 5000 RTO’s TAFE make up a small portion of those providers (

 During this time of reform, there is a range of highly skilled and professional individuals who come from a variety of backgrounds (RTO Doctor included) who would be very eager and capable of providing input into and further developing the new Framework, summarizing and ensuring consistency with the vast amount of feedback provided to the VET Reform Taskforce.

 

Quality of VET sector in Australia

Despite the many knee jerk reactions of government over the years to attempt to reignite the quality standard of VET in Australia, it has been undertaken without really looking at the quality that current systems are providing.  The reactions and previous reforms have all been based upon what the government thinks is best and under the belief that the government solution is the best solution – that government advisers, Ministers and appointed experts to their specialist committees are appropriately qualified and experienced to make the decisions to change the faults of the previous system with very little real accountability or transparency about the process undertaken to achieve the end result.

There has been a real reliance on feedback and ‘consultation’ conducted by Industry Skills Councils for example in relation to what ‘industry’ needs are.  There has been significant feedback from regulators as to what ‘industry needs are’.  There has also been significant input and feedback provided from peak bodies who on the surface appear to be servicing their members but in the process are developing products and services to sell to their members that match the very needs that they are promoting to policy makers as part of the consultation process.  So while the need may be there, bodies seeking to keep themselves profitable are providing the voice being heard by governments to advocate for those needs.

While there is some question about the integrity and reliability of the statistics provided by ASQA’s recent national strategic reviews into aged care training and the white card, and while there is also some question about the integrity and reliability of statistics provided at national conferences and forums by ASQA’s Chief Commissioner Chris Robinson, none the less, the quality of VET provision in Australia is and continues to be a major concern.  While the statistics provided by ASQA are questionable, there is absolutely no doubt in our opinion that the statistics are most likely to be worse than what ASQA have publicly provided.  In our experience, the inconsistency of auditing outcomes has meant that one provider who is deemed compliant on one standard with ‘x’ evidence by one auditor, with absolutely no changes to the evidence or the standards can be deemed non-compliant by another.

It is also our experience that the findings by regulators are but a small sample of what any provider is actually doing and while they may be compliant or have minor non-compliance with some standards, the reality is that regulators are not auditing against an entire scope of registration or across all standards.  In some cases, they do not even audit High Risk Work License (HRWL) units of competency and yet the expectation from the various WorkSafe jurisdictions is that if the RTO has passed audit, they are compliant to deliver HRWL’s.  It also must be remembered that an audit only gives a sample picture of that particular sample at that particular audit at that particular time.  It is common knowledge amongst industry that if one flies under the radar knowing that they are non-compliant and they extend their scope for example within the same training package and get a Consultant in to ensure that it is compliant, they can in most circumstances have their application approved without a site visit, continue to fly under the radar knowing that they are far from compliant in every other area of their RTO and continue to get away with it until re-registration comes along or, someone makes a complaint that is investigated properly by the regulator.

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RTO Doctor lodged a formal complaint with ASQA This section has been removed for privacy and confidentiality reasons. and in that complaint, using ASQA’s processes, we provided a significant amount of evidence to support these allegations This section has been removed for privacy and confidentiality reasons. also lodged a formal complaint substantiating these same issues and as far as we are aware, provided additional information that we were not privy to.  Despite the significant amount of evidence that ASQA were provided with, no further action was taken against the provider and the case was closed both in relation to our complaint (Appendix E), This section has been removed for privacy and confidentiality reasons.

What we can say is that under the NVR Act, at the time of our internal audit This section has been removed for privacy and confidentiality reasons, we identified the following breaches of the NVR Act, Part 6, Division 1, Subdivision A (although the exact number of breaches is unknown because we did not audit every student’s file):

  • Sections 93 & 94 – providing all or part of VET course outside scope of registration

  • Sections 95 & 96 – issuing VET qualification outside scope of registration

  • Sections 97 & 98 – Issuing VET statement of attainment outside scope of registration

  • Sections 99 & 100 – advertising all or part of VET course outside scope of registration

  • Sections 103 & 104 – issuing VET qualification without providing adequate assessment

  • Sections 105 & 106 – issuing statement of attainment without providing adequate assessment

  • Sections 107 & 108 – issuing a VET qualification without ensuring adequate assessment

  • Sections 109 & 110 – issuing a statement of attainment without ensuring adequate assessment

  • Section 11 – Breach of condition of registration

 Further, This section has been removed for privacy and confidentiality reasons. had they conducted a monitoring audit This section has been removed for privacy and confidentiality reasons., at a minimum they would have found that they should have cancelled VET qualifications and statements of attainment under Part 4, Division 2 section 56 of the NVR Act.

 Another example that we provide is just as concerning.  Through one of our Training and Accreditation Council clients, we were alerted to the fact that a provider under ASQA’s jurisdiction was refusing to accept the identical units of competency that had been completed by students at the TAC RTO.  The students had completed a nationally accredited short course with the TAC RTO, placed into employment with a national employment company and as part of accessing government funded traineeships for existing workers, were being enrolled into a qualification on WA’s Traineeship list with the ASQA RTO.

Should the student have claimed the national recognition / credit transfer that they were entitled to receive and requested to receive, they were advised that they would lose their employment (for some students, this would have meant relocating yet again (one example was a student who while completing the short course resided in the southern suburbs of Perth, was offered employment and the traineeship This section has been removed for privacy and confidentiality reasons. (approximately 470kms away) and was told that if she claimed the 6 units of competency she had already completed, she would lose her job.  She notified the TAC RTO who asked us to confidentially notify This section has been removed for privacy and confidentiality reasons. with all of the evidence because the student didn’t want to be known for fear of losing her job however didn’t believe it was right that she was being forced to redo these units so that her employer could receive funding and that the ASQA RTO could also receive funding.

A folio was presented to This section has been removed for privacy and confidentiality reasons. in person This section has been removed for privacy and confidentiality reasons. who refused to discuss the matter, refused to take the folder, refused to do anything about it because of two reasons and we quote:

  • “I don’t have to listen to you, you’re just a Consultant’

  • “Go through the normal channels and lodge a formal complaint like everyone else but they won’t do anything about it because you’re a Consultant and not party to the complaint.  If the student and RTO want to remain anonymous, then the complaint will never be investigated”.

What is very clear to us at RTO Doctor is that despite having significant (and sometimes excessive) powers under the NVR Act, even when presented with copious amounts of evidence of breaches of the Standards and the NVR Act, that unless regulators are prepared to act on and use their powers as the Act allows them to, unless they conduct audits properly, unless they change their attitude, the quality of our sector will not change.

An example of another funding related issue that is causing some significant concern in the provision of quality VET currently is that described next.  It is our experience that an assessor can deem a trainee competent based on the requirements of the training packages etc. as well as their professional judgment and yet because the employer won’t receive their incentives if the trainee is signed off early with provisions in legislation that require competency to be negotiated with an employer and student the outcome report is being delayed to ensure all parties can maximize their funding claim.

The question does need to be asked however, how is it that such a negotiation can take place if an employer is not ‘competent’ to sign off as an assessor on an assessment, including a Third Party Report unless they hold at a minimum the NSSC requirements for trainers and assessors? How are they capable of making a determination of ‘competence’ that is superior to that of the qualified assessor?  How is the trainee capable of making such a determination?  How can either of them make such a decision impartially knowing that they will not receive their incentives?  What does the ethical trainer and assessor do when the assessor and RTO down the road will have no qualms about delaying the sign off to facilitate this fraudulent activity?  As is clearly demonstrated here again, linking funding or quality to employment outcomes is potentially flawed and completely unreliable when funding is involved.  In these cases of fraudulent activity and claiming of government funding that they were not entitled to, how does the government recover these funds?

It is interesting to note that some of the biggest and loudest supporters of deregulation are actually the ones that have the most to hide or have been rightfully deemed critically non-compliant and suspended, cancelled or received similar sanctions.

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 In relation to the suggestions that VET quality should be determined by employment outcomes, we at RTO Doctor are concerned about the implications of this on those providers whose core business is providing training and assessment services to disadvantaged groups where access and equity, socio-economic status and other similar issues are at the forefront of the student needs.  If the focus is moved to training and assessment outcomes it is possible that providers who work with these particular socio-economic groups would appear to be poor performers relative to providers who work amongst demographics that are more likely to be able to achieve in a training and assessment environment. Supporting the unemployed, people with low LLN levels, young people at risk, homeless or people in prison or with criminal histories for example is an area filled with challenges faced by learners such as homelessness, drug and alcohol dependency and poor school experiences. These challenges increase the likelihood of the learner struggling to achieve assessment outcomes and the provider therefore ever being able to be judged as being a high quality provider.

 In a nutshell, the quality of the VET sector comes back to the simple fact that you only get out what you put in.  The system was never designed to provide the outcomes that the community wants or needs, it was built upon a system of government needs, wants and desires, it was based in some cases on creating positions for people who should have been removed from the system years before, it has been built on and grown from a reaction to poor community satisfaction, it continues to build not on what is actually required by the community but rather peoples political agendas, people’s attitudes, abuses of power and people’s egos.

Regulatory framework

The NSSC Standards Policy Framework – Improving Vocational Education and Training: The Australian Vocational Qualification System (2013) had some very significant benefits and drawbacks.  Having said that, it’s not that we necessarily need a new system, just a more focused system, more focused regulation with auditors who do the job properly, consistently and transparently. However, page 6 of this Policy Framework refers to the Standards only being a part of a broader regulation and quality assurance framework of the VET sector, which also encompasses:

  • Training packages and accredited courses

  • The Australian Qualifications Framework

  • State and Territory governments and their approaches to publicly funded training

  • Workforce development activities

  • Internal quality assurance controls of the RTO’s which could also be recognized by other general quality assurance bodies including ISO 9001

  • Provision of consumer information

  • Voluntary memberships or partnerships (although it mistakenly refers to national peak bodies in this category which is not the case as any rights to membership are determined by payment).

 It is imperative that when the Taskforce does review policy making in relation to the VET sector that it does take this into account.  It should also consider, as is addressed on page 8 of the same document that there are many other layers of legislation and policy guidelines (both State and Federal) that must be concurrently adhered to and these must not conflict with each other.  It is also imperative that the Taskforce take into consideration some data from ASQA that may actually not be a true reflection of applications submitted that were deemed non-compliant.  In many cases, the time frames for ASQA to process an application meant that in conjunction with the rapid transition rate of training packages, the materials being audited were always going to be non-compliant against the standards – ASQA have been taking anywhere between 9 and 12 months to conduct an initial registration audit, an extension to scope of registration can take up to 9 months in some cases and there have been numerous losses of applications and when clients have followed up the progress of those applications, they have been advised that they have been lost.  It should also be noted that many of the issues highlighted in the policy document are an accurate reflection of how things are on the ground.  This section has been removed for privacy and confidentiality reasons.

 Some of the negative aspects of the proposed new Policy Framework include the requirement to register as an LTO (there is sufficient feedback from others about why this is not a solution for all providers so we won’t repeat it here).  One area is the decision making of the Accountable Education Officer and the NSSC’s presumption that many providers will already have individuals such as the CEO who could fulfill this role.  This opinion is very misguided in reality.

Many CEO’s are business people, not necessarily Accountable Education Officers and in accordance with the standards around governance, their decision-making is informed by the experiences of trainers and assessors, course coordinators and senior management.   There are very few who would qualify to be the Accountable Education Officer and certainly insufficient information available for such a critical role in a provider’s business operation.

 An offshoot of this particular issue is that we are seeing more and more ‘compliance brokers’ or Accountable Education Officer conglomerates establishing themselves.  Since the release of the Policy Framework, there has been a proliferation of ex-compliance managers establishing themselves as Consultants and ‘experts’ preparing for the day when they can fulfill this role at a huge expense to providers.  It is with this in mind that in May 2013, a group of high quality members of this sector got together to establish a true Not For Profit company whose proceeds will go to the vocational training arm of Headspace National Mental Health Initiative nationally to enhance and promote quality education and training, self-regulate and monitor the activities of its member Consultants and VET Practitioners.  This group will be launching on 1 July 2014 and its sole purpose is to act as a membership, self-regulating peak body for Consultants and VET Practitioners that will also provide continuing professional development, a complaints and appeals mechanism and a national register.  An interim Board of Management has been implemented with representation in each of the States/Territories and members will have to be assessed as being eligible, they will not be able to just pay their membership and get accepted as is the case with all other peak bodies in the sector currently.  The Australian VET Quality Practitioners and Consultants’ Association (AVQPCA) has been designed to identify and enhance the highest quality VET Practitioners and Consultants of the industry, make the industry accountable and transparent and provide a ‘tick of approval’ in some sorts to members who have been through the standards set by the association.  The association will also provide advocacy and opinions and advice where it is relevant to do so and for the benefit for the sector and its members.  

 One final important note in relation to the proposed AVQS Standards is that Appendix A provides cross-referencing of the proposed standards to the proposed LTO standards.  This information cannot be relied upon like many other areas of the document’s foundations because they are inaccurately mapped.  If new standards and mapping are to be released, it is worth ensuring that these basic items are correct if the system is to be implemented while minimizing risk of error and chaos.

 Another area of the regulatory framework that is currently missing is a focus on the provision of training.  Auditors do not currently regulate training, they only regulate assessment as this is all that is permitted under the Standards (i.e. ‘Assessment, including RPL…’.  This also contributes to the proliferation of ‘weetie box qualifications’, the attempts (and often successful attempts) at defrauding government departments of funding. It has also become an area of increased exploitation since VET FEE-Help was introduced.  Suddenly courses that could be delivered (and are being legitimately (and compliantly) delivered in 6 months for example) have been drawn out with no real explanation just so that the provider can make the qualification eligible for VET FEE-Help.

 Other suggestions for consideration include modifying the current or proposed regulatory approach so that it is not just punitive.  Thee needs to be a clear cut benefit or reward for high quality providers that might be an incentive to embrace the standards and engage in best practice rather than simply ‘comply”.  Such a proposition would not be considered satisfactory however if the benefit was reduced or absence of regulation.  It may be that their fees are reduced for example and those who are repeated offenders or carry high-risk pay higher registration fees for example.  There needs to be a much bigger focus on supporting providers to become better providers, assisting them to be the providers we want them to be.   The Regulator needs to provide sufficient information to training providers through training / professional development workshops, guidelines, and helplines to assist RTO’s in interpreting the national standards. The vote for better and defined information has been consistent through the reform consultations so far.

 This section has been removed for privacy and confidentiality reasons.  As was rightly pointed out in Webinar 3 by one stakeholder, it is a little hard to discuss ‘regulation’ in the abstract without knowing the reasons for the regulations. It is not yet clear that even bureaucrats are clear about what they are regulating and why.  Until this question is answered, coming up with another set of standards or regulations/legislation will be futile.

 It is our experience that providers who fly under the radar or are not regulated as often as others struggle to demonstrate compliance at audit and yet in some cases, their applications are processed and approved without ever coming under the microscope (while others have to buy, borrow, beg and steal to have their applications approved – again, the consistency issue).  If you are not going to regulate certain RTOs then how else will the Taskforce propose to achieve the purpose of the regulations? We are yet to see any clear evidence in our experience that self-regulation works for RTOs as RTO Doctor and again, Raelene’s experience as a regulator during the CRICOS re-registration project.  This section has been removed for privacy and confidentiality reasons.

 More than anything however, an important message that the sector needs to hear is will the AVQS be implemented in the next 3, 6 months etc. What is expected to happen in the short term? Many people cannot make informed business decisions with no formal statement; they cannot meet their commitments under the Corporations Act 2001 to ensure financial viability at all times, they are basing business decisions that affect all stakeholders, including Australia’s economy, based on rumour and innuendo.

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