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Registration standards

Gaining national agreement on a set of registration standards, codifying them in the ARF and introducing them from 1 January 1998 has been a major achievement of the national VET system. While there have been major transitional problems associated with their implementation since then, there is virtually unanimous support in Victoria (and elsewhere in Australia) for the existence of such standards and unanimous support for rigorous provider registration against them.

endorsement following registration. While some of this activity may be motivated by the wish to develop a commercial product or extend their power and influence, much is the result of industry frustration with current provider registration and a genuine desire to lift the quality of providers operating within their industry. The growing industry view is that the generic national standards do not take sufficient account of differences between industries, that is, one size does not fit all.

This trend is also driven by a related factor — globalisation of skills standards. While skill standards are separate from provider registration standards, and go to the

question of specification of competence in Training Packages more than the ARF, the two are closely linked.

Those companies which compete in the global marketplace know they are competing against global product and service standards and, consequently, think about Australian skills standards as a key enabler. Their concern is that national standards are, in some instances, too low and that there is no national aspiration to raise the standards, only to encompass more people within existing standards. Similarly, some occupations are aware that unless national skill standards are consistently lifted, the Australian skills pool will become uncompetitive and their roles will be reduced to on-shore operatives in a global skills pool where the high-skill jobs are held offshore.

Of the 14 industry bodies whose submissions responded directly to the question of whether the registration standards under the ARF are adequate in their scope, 13 believed they are not.

Confidence of other stakeholders that the registration standards themselves are adequate is also shaky. Of the 17 other submissions which responded directly to this question, only 4 believed the standards are adequate in their scope. These same views were consistently articulated during consultations.

This Review is not the place for a comprehensive analysis of the strengths and weaknesses in the ARF standards. The following comments relate only to the main considerations leading the Review to find that they do not support quality training within Victoria’s apprenticeship and traineeship system.

Ÿ In some respects, the ARF has been constructed within a competent/not competent frame, implying that once a training organisation has demonstrated competence and been registered, that is the end of the matter. It contains no aspiration for continuous improvement against low minimum standards required for initial registration. There is no inbuilt mechanism for continuous improvement of providers against the standards.

Ÿ Both the National Core Standards for Registration and the Training Delivery Standards (listed in Exhibit 2.1 below) fail to distinguish between evidence that a provider has the systems in place to perform against the standard and is therefore ready to provide training and evidence that the provider does actually perform against the standard. Standards TD1, TD2 and TD3 are more concerned with systems and potential than demonstrated capability in practice. TD5 is more about the management of training than training delivery. TD3, on assessment, appears to be the only standard against which a provider’s actual practice may be tested.

Such systems-oriented standards may, at a pinch, be appropriate for provisional registration of start-up providers with no track record of training but they provide

a poor basis for subsequently testing compliance in actual practice against those standards.

Exhibit 2.1: National Product/Service Standards for Training Delivery TD1

Resources for delivery and assessment

Resources for the delivery, assessment and issuance of qualifications, in the area(s) of recognition sought, meet the requirements of the relevant endorsed Training Package(s) and/or accredited course.


Identifying learning needs and designing training products

The organisation can demonstrate its ability to identify the learning needs of diverse clients and to plan/implement appropriate learning strategies. This includes the capacity to design and adapt training products in the area(s) of recognition sought, enabling the endorsed components of the Training Package(s) and/or the accredited course(s) to be achieved.

TD3 Assessment

The organisation can demonstrate its capacity to conduct or facilitate assessment which meets the endorsed components of relevant Training Package(s) and/or the accredited course(s) in the area(s) of recognition sought.


Client services

The organisation provides timely and appropriate information, advice and support services which assist learners/clients in achieving their desired outcomes.

TD5 Issuance of

Qualifications and Statements of Attainment

Qualifications and Statements of Attainment are issued in accordance with the requirements of the AQF Implementation Handbook, the Guidelines for Training Package Developers and specific qualification requirements of the relevant endorsed Training Package(s) and/or the accredited course(s).

Ÿ In most cases, the National Product/Service Standards for Training Delivery are not stand-alone standards about quality teaching and learning. They are only meaningful when referenced back to the requirements of a Training Package.

That is, the ARF assumes that teaching and learning standards are subsumed within and determined by each Training Package. This in turn assumes that each Training Package makes explicit the standards of teaching and learning and that collectively they do so consistently. This is patently not the case. The submission from the Victorian Wholesale, Retail and Personal Services ITB clearly identified the issue from an industry perspective.

Despite pleas from both employers and unions, ANTA and the States have refused to allow Training Packages to incorporate prescriptive provisions for delivery of training. The absence of prescriptive delivery provisions leads some to question the efficacy of delivery in some circumstance.

Even where industry parties have desired to incorporate basic minimum standards for trainers delivering the competencies contained within Training Packages, some of the States have refused to endorse such Training Packages unless all such prescriptions are removed . . .

Consequently, each Training Package now has a provision ‘recommending’ that deliverers meet the industry required standards but, in effect, no minimum requirements of deliverers apply.6

This circularity in the way training delivery standards are dealt with in the VET system means that there are, in effect, no national training delivery standards.

Ÿ The standards muddle the quality of the management of training with the quality of training delivery. While the ARF Training Delivery standards are consistently referenced to requirements of the Training Packages, there is inadequate

reference within the standards themselves to generic training and learning

elements of quality training delivery, distinct from the quality of the management of training. The standards are silent on such characteristics as the capacity of the provider to understand and meet learner aspirations; to accurately diagnose learner needs; to recognise and build on prior learning; to provide constructive feedback to learners on progress; to develop skills for lifelong learning; to

challenge learners; to help learners acquire new knowledge and skills and expand their understanding of working life.

Ÿ The Training Delivery standards make no allowance for differing requirements of institution-based training and assessment, and workplace training and assessment.

This lack of differentiation is highly problematic in the apprenticeship and traineeship system since delivery in the workplace of quality on-the-job training and, increasingly, off-the-job training is central to its relevance and effectiveness.

The complexity of workplace training and assessment should be recognised within the delivery standards. These could include evidence of the integration of the on-the-job and off-the-job experiences to provide a coherent program of learning; of informing employers of learners’ progress; of productive

relationships between the training provider and workplace supervisors, trainers and assessors; of designing training strategies which take account of workplace needs and the like.

Ÿ The ARF relies to a large degree on State and Territory interpretations of Training Delivery standards, despite the intent that these be national standards, not

nationally consistent standards. The only true national minimum standard for providers which is not necessarily subject to multiple local interpretations is the requirement that they be capable of applying Training Package assessment guidelines in practice. At the same time there seems to be an emerging view that these guidelines are highly variable between Packages and not of consistently good quality.

Having considered all the available evidence, the Review has come to the following conclusions.

Ÿ The ARF standards are the result of a series of compromises about which national registration standards all Australian governments were willing at the time to support. They are low minimum standards, and in the light of more than two years of experience in their application, they are no longer adequate. The quality bar needs to be raised.

Ÿ The National Core Standards for Registration under the ARF are probably adequate to ensure the quality of the management of training but their evidence


requirements are not sufficiently stringent to ensure that training organisations have high quality systems for managing training, particularly for managing the flexibility and diversity of workplace training.

Ÿ Neither the National Product/Service Standards for Training Delivery under the ARF, nor their associated evidence requirements, are adequate to ensure quality training delivery and quality learning outcomes.