Reviewing the Standards for RTOs 2015
The new Standards for RTOs 2015 are here and with them comes another attempt to regulate some core processes in the RTO world.
When we talk about core processes, at the top of the list is the strategy to deliver and assess a particular training program.
When the Standards for NVR RTOs 2011 were introduced in 2011, we formally defined the strategy as the Training and Assessment Strategy (TAS). Before this, we called it the Learning and Assessment Strategy, Learning and Assessment Plan, Training and Assessment Plan, etc.
According to the new Standards, TAS is: "... the approach of, and the method adopted by, an RTO with respect to training and assessment designated to enable learners to meet the requirements of the training packages or accredited courses."
What has changed?
From a conceptual viewpoint, there are significant changes, as the new definition focuses on implementing the strategy, and not on the strategy itself "...method adopted..." The new definition focuses also on results "... enable to meet the requirements of the training packages..."
The old standards were paperwork-focused. TAS according to the old Standards: "... is the document that outlines the macro-level requirements of the learning and assessment process."
Beyond conceptual changes, what will change?
RTOs will be required to make operational changes in four main areas:
- Industry relevance
- Amount of training
- Assessment practices, and
- Trainers.
1. Industry relevance
Clauses 1.5 and 1.6 require the RTO to demonstrate industry relevance of training practices. This means RTOs are now required to demonstrate evidence of the process used to select the units of competency that will meet the industry needs. Where the RTO is delivering a qualification, this process will be reduced to only the elective units. Considering that units of competency represent workplace "tasks", the RTO must demonstrate how the units selected reflect industry current practices.
The new Standards dig a bit deeper into the "contextualisation" process, and require RTOs to demonstrate (Clause 1.6) how training and assessment practices and resources are responsive to current industry needs. In other words, how the learning and assessment resources (equipment, simulations, procedures, infrastructure, etc.) meet current industry practices. This level of alignment of training and industry practices will require RTOs to maintain a continuous and sufficient engagement with the industry to evaluate the effectiveness/relevance of training.
A key factor in the success of any training program is the trainer and the trainer's industry skills. Ultimately, the aim of the training program is to allow the trainer to transfer those industry skills to learners. Another interesting requirement included in the new Standards (Clause 1.6) is the need to monitor current industry skill requirements for trainers and assessors, with the industry.
These changes about industry relevance will require RTOs to engage with industry in a more dynamic way. RTOs will need to open and maintain a two-way communication strategy to evaluate training results. The sign off approach, where some industry players "endorse" the RTO's TAS is no longer valid. Today, RTOs are required to demonstrate that learners are trained and assessed using equipment, procedures and standards currently in use in the workplace.
2. Amount of training
The only non-negotiable benchmark in competency-based training is the competency standard. The "amount of training" requirement doesn't include a prescriptive timeframe, but an explanation about how learners will gain the skills and knowledge required to achieve the outcomes described in the unit(s) of competency being trained.
What constitutes the amount of training? All learning and assessment activities including but not limited to face-to-face activities (group-base classes, one-on-one mentoring, coaching), online training (synchronous, asynchronous online learning activities), distance learning activities, self-directed learning activities, on-the-job training (structured learning activities, practical activities, supervised/unsupervised activities), assessment activities (formative, summative assessments), etc.
RTOs are now required to calculate/estimate the time required to complete each learning and assessment activity and the summary of all those activities will constitute the amount of training provided, or volume of learning (as defined by the Australian Qualification Framework AQF).
How can the RTO demonstrate the suitability of the amount of training? Learning is a journey. A journey that connects current with desired skill levels. The starting point of the training journey is determined by the existing skills, knowledge and experience of learners.
The learning mode is another factor that can affect the time required to complete the learning journey. On-the-job training seems to be the most time-effective way for vocational training; other delivery modes will require different timeframes to achieve the same results. An assessment only pathway (RPL) should be completed in a shorter time, as learners will not be required to take learning activities.
What tools are available to estimate the amount of training? The AQF developed the Volume of Learning indicators that include standard timeframe ranges for each AQF qualification level. Keep in mind that these indicators are based on the supposition that learners don't have any existing skills, knowledge or experience relevant to the training program.
The RTO's proposed amount of training for a particular program may be outside the range of the AQF Volume of Learning indicators. For example, an RTO may be proposing to deliver a Certificate IV in Training and Assessment in 300 hours (the AQF Volume of Learning for this Cert IV is 600 hours – 2,400 hours), but to demonstrate compliance with Clause 1.2, the RTO is require to explain why the training program will achieve the required outcome in a shorter time.
A valid explanation could be learners that have some relevant skills, knowledge and experience. Obviously, the RTO must demonstrate how those current skills, knowledge and experience are assessed prior to enrolment or commencement of training, and entry requirements for that particular program must be consistent with the amount of training.
RTOs must adopt different training and assessment strategies and practices for different learners' cohorts, and delivery modes, each of them are required to show the amount of training provided.
Clause 1.2 is clearly a reactive approach by the government to provide the regulators with tools to fight against untrustworthy short courses.
3. Assessment practices
The new Standards aim to regulate the assessment systems implemented by RTOs, and not only the assessment tools.
Assessment systems include policies, procedures and their implementation. They also contain the documents, tools, resources (including assessors) used in the process to assess and confirm that competent learners can perform to the standard required in the workplace, as specified in the unit of competency.
Since AQTF 2001, there have been two areas of regulatory focus for our framework:
- The assessment process: designing assessments, performing assessments, collecting assessment evidence, quality review and control of the assessment system
- The assessment evidence: evidence produced by the candidate during the performance of the assessment activities.
What standards must be met in the assessment process? – The Principles of Assessment. What are the requirements for the assessment evidence? – The Rules of Evidence.
The new Standards have simplified, providing a more "ready-to-use" definition of the Principles of Assessments (Standards for RTOs 2015 Table 1.8-1), and Rules of Evidence (Standards for RTOs 2015 Table 1.8-2).
For example, how do we know if our assessment system meets the Principle of Assessment of Validity? I will use the Table 1.8-1 as a guide. The Standards define Validity (for the Principles of Assessment) as:
"Validity requires:
- Assessment against the unit/s of competency and the associated assessment requirements covers the broad range of skills and knowledge that are essential to competent performance;
- Assessment of knowledge and skills is integrated with their practical application;
- Assessment to be based on evidence that demonstrates that a learner could demonstrate these skills and knowledge in other similar situations; and
- Judgment of competence is based on evidence of learner performance that is aligned to the unit/s of competency and associated assessment requirements."
In point 1 above, the RTO is required to demonstrate how its assessment system ensures that when designing assessment activities, performing assessments, and collecting assessment evidence, the RTO covers all skills and knowledge that are essential to competent performance, as stated in the unit of competency. With the audit hat on, the questions here are: Does the RTO have policies, procedures, forms, instructions, samples, internal training, flowcharts, and any other tool that may be needed to ensure the RTO consistently meets this requirement? Based on the evidence produced, is the system working? Has the system been consistently implemented?
The same approach illustrated above must be used for points 1 through to 4 of Validity requirements to demonstrate compliance, and a similar approach must be implemented against the other three Principles of Assessment.
Regarding maintaining quality review and quality control processes for the assessment system, Clauses 1.9 – 1.11 include a more sharp picture about the why, when, how, and who of assessment validations.
Now RTOs are required to have a validation plan for assessment practices and judgments for each training product that determines when the validation will occur, who will lead and participate in the validation and how the outcomes of the validations will be documented and used.
Clause 1.10 includes some specific timeframe requirements, stating that all training products must be validated at least once every five years, and 50% of them most be validated within the first three years of each five year cycle.
Clause 1.11 defines the requirements for the validation team that collectively must demonstrate vocational competencies and current industry skills relevant to the unit being validated, current knowledge and skills in VET, and at least the assessor's skills set. Another new requirement is the need to have at least one person in the validation team who is not directly involved in the delivery and assessment of the unit being validated.
RTOs, especially small RTOs, might find Clause 1.11 challenging from a logistic viewpoint. In many cases, small RTOs may require an external agent to support them during validation activities.
4. Trainers and Assessors
The Certificate IV in Training and Assessment is no longer the only acceptable qualification for trainers and assessors but is the entry level. Trainers and assessors are now allowed to teach and assess in VET if they hold the mentioned Certificate IV, or a Diploma or higher-level qualification in adult education.
Requirements around vocational competencies, industry and VET currency remain the same.
To demonstrate compliance with Clause 1.16, RTOs have to implement a professional development management plan for all trainers and assessors.
Training trainers
Those RTOs delivering any qualification or skills set included in the TAE training package now have to meet some extra requirements:
• Have an external independent validation for all products on its scope
• Trainers delivering the Certificate IV in Training and Assessment must have at least one of the Diplomas included in the TAE Training Package or a higher-level qualification in adult education.
In summary, changes look positive and should support the evolution of our vocational system and help to improve quality. Moving from process-based to outcome-based regulation, moving from transactional-regulation to risk-based-regulation, moving from industry endorsement to industry responsiveness, linking regulations with core functions of training design, delivery, and assessment practices can only help to improve our vocational education and training sector.
What has happened in the past?
New regulation hasn't always effectively improved an RTO's performance but has impacted negatively in high performing RTOs by increasing compliance costs. Why? Because in real life, regulators have not been able to provide an even playing field, and under-performing RTOs still are out there doing business, selling low quality/not compliant courses, and competing on price because they are able to offer a Nationally Recognised Training program, and issue AQF certification documents.
