Ross Woods, 2021
These comments were made in response to a questionnaire on the Standards for Registered Training Organisations (RTOs) 2015 in early 2021. It asked for comments on each clause, and about gaps in the standards.
For each clause in the standards for which respondents agreed to be surveyed, it asked whether the clause:
• is easy to understand
• is too prescriptive and does not provide sufficient flexibility
• is too broad to provide clarity to RTOs
• supports RTOs to be high quality
• places an unnecessary burden on RTOs
• is sufficient to ensure a minimum level of quality
• does not impact on the quality of student outcomes or experiences
• is duplicative with other clauses in the Standards
• is effective in meeting the intent of the Standard
Specific standards
Glossary: Validation
• The rigor of the validation process is not defined, but the definition in the glossary is not very demanding.
• The statement on validation is not correct. It says “Validation involves checking that the assessment tool/s produce/s valid, reliable, sufficient, current and authentic evidence ... ” However, it should be changed to say “Validation involves checking that the assessment tool/s and processes meet the requirements Table 1.8-1: Principles of Assessment and Table 1.8-2: Rules of Evidence …
Glossary: Definition of assessment tools
A definition of assessment tools is urgently needed.
• A general direction (“Retention requirements for completed student assessment items”) gives the following definition:
“Assessment tools include the following components—context and conditions of assessment, tasks to be administered to the student, an outline of the evidence to be gathered from the candidate and evidence criteria used to judge the quality of performance (i.e. the assessment decision-making rules). This term also takes in the administration, recording and reporting requirements, and may address a cluster of competencies as applicable for holistic assessment.”
• Assessment tools should also include instructions to students, and if not already clear in those instructions, a set of instructions for assessors.
• Without a definition of assessment tools, validation is nearly meaningless and auditors can demand whatever they like.
Clause 1.1
• The training and assessment strategy is not actually defined. The SRTO does not say whether it must be documented, expressed in one or more documents, or what kinds of things must be in it. (The term “strategy" is used in the Glossary with the meaning “general approach” and does not refer to a document.
• The mention of “amount of training they provide,” is redundant with 1.2.
• The phrase "consistent with the requirements of training packages and VET accredited courses" is mentioned in several other places.
Clause 1.2
Repeats “amount of training” from 1.1.
Clause 1.2 “determines the amount of training they provide to each learner"
Does it mean that the RTO must provide a separate, different program to each member of a cohort?
Clause 1.8.a
• Mapping documents for assessment tools are de facto compulsory.
• “Validity” has two definitions, one in Table 1.8-1: Principles of Assessment and another in Table 1.8-2: Rules of Evidence.
• For an assessment tool to be “valid,” it once had to reflect closely the requirements of the unit. The same tool is now non-compliant as “unreliable” because it is not contextualised. In fact, the text of some units is already very specific, while the text of other units is so vague that the unit can only be used if it is expressed separately in assessment tools.
Clause 1.10
• Most qualifications expire or are replaced within the 3-5 year time bracket.
• It's easy to forget something if it was planned three or four years ago.
• Any serious problems needs to be fixed well within the 3-5 year timeframe, so by the time of validation, anything wrong should have already been fixed, and validation is just a non-rigorous routine.
• The retention of evidence for six months is not very consistent with the requirements for validation of assessment.
Clause 1.11
(iii) should also allow people with item 3 of Schedule 1.
Clause 1.12 It is burdensome to always have to offer RPL. RTOs should be free to choose whether to offer for each qualification:
• Instruction
• RPL, or
• Both Instruction and RPL.
Clause 1.13
Basically well written.
Clause 1.14
Qualifications are good but they don't guarantee good training and assessment.
Clause 3.1
“The RTO issues AQF certification documentation only to a learner whom it has assessed as meeting the requirements of the training product as specified in the relevant training package or VET accredited course.” This is a time bomb with two meanings: the first is about graduating students. The second is about compliance with course requirments. If an auditor alleges any error in mapping, the RTO is guilty of noncompliance with standard 3 as well as standard 1.
Sections 4 and 5
Sections 4 and 5 both refer to information to students and the general public. They should be put together in one section.
Gaps in the Standards that should be covered
A good system
A good system requires at least three components
• Good, stable standards
• RTOs that understand them
• Auditors who understand them.
“Stable standards”
The standards are unstable, even though they have always been based on the same general philosophy of training. ASQA generally has not revised the standards. With the exception of the two versions of the AQTF, it finds problems with the standard, dumps it completely, and writes a new standard from scratch. This has two particular problems:
• It is like a worn-out car. Every time they fix something, something else breaks down.
• Nobody builds up a body of expertise on how the standards work.
A defective concept of quality
Overall, the Standards have not supported quality outcomes in the VET sector.
The current standards are very compliance-driven and promote rules. A compliance-driven system encourages mediocrity; the purpose is to follow rules to achieve the minimum requirement, not to aspire to excellence. In particular, the current standards over-emphasize “administrivia” and paperwork.
If anything, the Standards have promoted a concept of quality: Keep the maximum possible documentation to demonstrate compliance.
The Standards do not even promote a view of excellence and hardly mention the actual quality of the program, if at all. In particular, the current standards are unconcerned about the actual effectiveness of teaching and learning. Moreover, the idea of continual improvement is peripheral, whereas it should be central to the Standards. (The old AQTF did much better at this, although harder to understand.)
Students have a different viewpoint, and usually describe an excellent program as “I came out as a different person.” They almost never say “I learnt lots of good skills.”
Contextualisation
Auditors tend to require that programs be adapted to their context. This includes policies and training, and especially assessment tools. However, it is a mistake to demand contextualisation when generic systems and tools pose no disadvantage.
Auditors
A clear set of standards is only part of the picture. The system needs to have auditors on board.
• Auditors can almost always ask for more “evidence” of compliance but they don't have a standard for “enough.” They can always say “Not enough evidence” no matter how much they have and how good it is.
• Auditors can't always differentiate between non-compliance, error, risk, and opportunity for improvement.
• The current standards mean whatever the ASQA auditor at the time wants them to mean.
Documentation
The standards should indicate about how much documentation RTOs should keep. The Standards generally only require that the RTO do something to meet requirements, but some auditors still want a separate written record for everything and anything.
RTOs should only have to keep documentation that is useful to the function of their organization. RTOs should not have to keep documentation when its only purpose is to be shown to an ASQA auditor.
The ASQA explanatory handbook
The current ASQA handbook puts items in a jumbled order. It would be easier to use if it were in the same order as the actual standards. It was a mistake to introduce a different order, and should have been delayed. It doesn't matter which order is used, but they should be the same.
Cert IV TAA
The Cert IV TAA is problematical because:
• The Standards require trainers to replace it often, although the actual skills are the same.
• Nobody who applies for it really wants to learn how to train and assess. They think of it a a job ticket to work in the VET sector.
• It is better to get a higher qualification.
What about the ASCF?
• Do RTOs have to map all assessment tools to the ASCF? (I think they shouldn’t.)
• Do RTOs have to assess incoming students according to the ASCF? (I think they shouldn’t.)