As the deadline for the change in Standards draws ever nearer, so the emotions surrounding the TAE Upgrade situation continue to rise. Amid those emotions is the question of what will happen to people who have not upgraded?
Before launching into what we think, it is safe to say that the sky will likely not fall in and, to our minds, this means it is better to take a bit more time to get the Upgrade done properly, than try to shortcut it just to meet the deadline.
This article will take a quick look at how we got to here, where we are now, and what could happen if we put meeting the April 1 deadline ahead of ensuring Trainers/Assessors have the skills and knowledge they need to do their jobs.
The change to the Standards is clearly intended to ensure that Trainers/Assessors have sufficient knowledge to do their jobs. Arising from the inconsistent delivery of the older TAE40110 Cert IV, there is the very real problem of supposedly qualified Trainers/Assessors who do not really possess the required knowledge and skills that they are meant to. It is not necessarily because the old TAE did not have the “right stuff” in it. It was more the case that it was not delivered or assessed in a way that people learned that stuff, and were robustly assessed on their knowledge of it.
So, the powers that be decided that a line needed to be drawn in the sand to assure quality training and assessment moving forwards. They did this in a number of interconnected ways:
- Created a new TAE Cert IV that was not equivalent to the predecessor;
- Changed the rules so that non-equivalent new TAE qualifications would not automatically be added to the Scope of Registration of RTOs;
- Changed the rules requiring that Trainers/Assessors had either the new TAE Cert IV, or at least the old one plus TAEASS502 and TAELLN411 (or their predecessors).
It was quite a clever strategy in many ways.
The application process for the new TAE was sufficiently onerous that most RTOs who had the old one did not bother to re-apply. Of those who did, the process was sufficiently harrowing that they were instilled with plenty of fear that inspires (many of) them to try to do the right thing moving forwards.
But, the time taken to get these approvals led to a dearth of RTOs available to meet the demand of all the people needing to upgrade. Similarly, since the standard of delivery has appeared to rise, the challenge of finding TAE Trainers/Assessors who are up to the task has become very real for some RTOs who, in the face of these difficulties, are deciding to curtail enrolments rather than lower standards.
RTOs who are delivering the Upgrades with integrity are finding themselves dealing with the hostility of a great many people who not only resent the need for it, but they resist any suggestion that they might actually not have the skills/knowledge that their past TAE Cert IV was intended to equip them with. The time taken dealing with these students is not inconsiderable because the gaps that they have are likewise not inconsiderable. The notion of an “Upgrade” being something simple is a falsehood: many of the people who are upgrading require considerable support and backfilling simply to get them to the point where they are able, for example, to engage with the requirements of TAEASS502. A case in point here is the sheer number of people who do not know what an assessment tool is.
The future of the VET sector requires that the time and energy be invested into supporting these people, and ensuring that they do learn this time around what they did not learn last time. To do otherwise is to undermine the whole exercise of the past 3 years, and undermine the value that the TAEASS502 unit offers (we wrote more about that here).
Where we are now:
And so we find ourselves approaching the April 1 deadline with arguably an insufficient number of places available to accommodate the needs of the Upgrading students.
Some RTOs with Upgrade programs are advertising aggressively, partly as a public service to remind people of the deadline, and partly to encourage people to not risk not meeting the April 1 deadline. This is often accompanied by an offer to get the Upgrade done in a way that is affordable both in time and money. Perhaps ironically given the supply side limitations, fees appear to be going down as we get closer to the deadline and not up. At the demand side, as we get closer, we have more and more Trainers/Assessors who do just want to “get it done in the cheapest and quickest way”; the prospect of the Upgrade being an educational experience is eroding rapidly.
Of course, this may lead to people meeting the Standard by having the required credential. But, it does not necessarily lead to people having the knowledge or skill that is intended to be possessed.
What is the alternative?
Perhaps the alternative is to look at the way the regulator deals with non-compliances and then work from there to identify what might be the possible implications of not meeting the April 1 deadline.
ASQA has a risk-based approach. Generally speaking, an RTO who is non-compliant and is not aware of it will pose a greater risk than an RTO that is aware of it. That basically means that it is probably better to show that we know where we are falling short and what to do about it, than keep our heads in the sand.
Generally speaking, if ASQA finds a non-compliance of some sort, then they look for a couple of things:
- Was the RTO aware of it and, if so, do they have a plan in place to address it?
- If not, can they put in place a plan to address it?
That being the case, RTOs are best positioned to show that they know what is going on, including their own areas of non-compliance. After all, this is what the Annual Declaration of Compliance is all about. (An interesting aside: what happens if we put in our Declaration on March 30 saying we are entirely compliant, knowing that chances are we will not be compliant come April 1, and then we get an audit that shows we clearly we knew we were about to become non-compliant but did not own up?)
In any case, our thinking is that this provides an opportunity for RTOs to have a plan to ensure that their staff meet the requirements, even if this is after April 1. For example, an RTO could have in place a plan to ensure that some/all of the following is in place, so that Trainers/Assessors:
- are enrolled in a suitable Upgrade program that the RTO has confidence will lead to any gaps in knowledge/skill being addressed
- are being actively supervised in and supported during the period of that enrolment
- possess the required credential to continue delivering and/or assessing post April 1
- have a supervision arrangement in place if required
Some might say that this is all too hard and will choose to “just get it done” to meet the April 1 deadline.
However, just as the Regulator adopts a risk-based approach, RTOs can do the same with regards to the way that their staff meet the new Standard. If the RTO is committed to ensuring quality within its operations, then they may just agree that the real risk is not by having people not upgraded in time, it is from having people who do not possess the knowledge and skills that the Upgrade is meant to address.
Key to an effective Plan is to know what the Standards say you will need, and we will have a look at that in the coming days.
Next time: More information about the Plan for going past April 1.