Rising to the challenges of delivering in a changed world
There is no doubt that VET and ELICOS providers are under enormous pressure. Despite these pressures, providers have been meeting their obligations to students and to the regulator as they continue to operate.
It is clear that many providers have reviewed their business operations to respond to the needs of students, to keep their students and staff safe, and to deliver the training that will give their students the best chance of gaining employment and contributing to the recovery of the Australian economy.
Based on the data available to it and the feedback from students and external stakeholders, ASQA has identified three key emerging areas of growth.
The COAG Skills Council at its 3 April 2020 meeting agreed that critical short-term gaps will emerge in key frontline workforces, in sectors such as aged care, disability support and health care and that new training will be needed to keep these and other sectors operating.
Infection control training has been identified as a priority across industry during the pandemic. In response to this, four new infection control skill sets have been endorsed to enable infection control training across the retail, food and beverage and transport and logistics sectors. The AISC has also developed resources to deliver to these specific cohorts.
ASQA automatically approved 592 RTOs to deliver the required unit so these providers can offer the skill sets.
In addition to the emerging demands for skilled workers in health and caring occupations, there are sectors of the economy that continue to operate and grow, for example, the construction sector.
Where providers are expanding their delivery to meet these gaps, it is crucial that they implement this expansion informed by industry’s expectations and with a commitment to delivering quality VET outcomes for students. In light of some of the practical constraints imposed by COVID-19, it is an especially challenging time to get this right.
Providers should ensure that they are continually reviewing their practices to maintain clear oversight of the following key issues that might arise. Not meeting these requirements can have a significant impact on students by calling into question the quality of their training outcomes and eroding industry confidence in the VET sector. As a result, ASQA will seek to assess these matters during audits.
ASQA concerns
ASQA has identified some of the issues that might arise when providers add new products, particularly in industry areas not previously delivered include:
Potential issue:Not registering delivery of new courses with ASQA can occur when providers move quickly to deliver new courses and do not have systems in place to detect administrative oversights. |
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Potential impact | This oversight can have a dramatic impact on students and the value of their qualifications. It can also have a significant impact on the reputation of the provider. |
Guidance | Confirm you have the training product on scope (either explicitly or implicitly) or that you have received ASQA’s approval to add any new qualifications, accredited courses and explicit units of competency to your scope of registration when planning a new program. These scope items must be approved before you start advertising or delivering the training product. |
Potential issue:Not engaging with industry representatives when planning the delivery program to ensure your training and assessment strategies, practices and resources are relevant to the sector. Once approved for delivery, industry engagement needs to be maintained to stay up to date with current practices. |
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Potential impact | Your training and assessment strategies will lack industry currency and graduating students may feel underprepared for work and find it difficult to secure employment in their field of study. You may receive poor student and industry feedback, which will impact on your reputation. |
Guidance | Make sure you consult with relevant industry stakeholders and incorporate this feedback into the development and ongoing review of strategies. You should document and retain evidence of these engagement activities. Further information is available to you in the ASQA Users’ Guide. |
Potential issue:Not being fully resourced to deliver the training product prior to applying, including having sufficient and up-to-date learning resources, facilities, equipment and trainers and assessors. |
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Potential impact |
Quality training and assessment depends on the skills and knowledge of trainers and assessors with access to the learning resources, facilities and equipment required by the relevant training package. Trainers and assessors who are not skilled VET practitioners with current industry skills and knowledge or who lack access to current and comprehensive resources will not be able to deliver a training product that students need and graduates may not be properly assessed before being issued with a testamur. |
Guidance |
Implement a process to ensure that you have all the necessary resources, facilities, equipment and staff to deliver every training product on your RTO’s scope of registration—whether you are currently delivering it or not. These resources should meet any specific requirements in the training package or accredited course. The quantity of these resources will depend on how many students you are delivering to (or intend to deliver to). Your training and assessment strategies should include guidance on the level of resources needed per student or per group. Further information is available to you in the ASQA Users' Guide. |
Potential issue:Not exercising effective oversight over third parties engaged to deliver services on your behalf. |
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Potential impact | Third parties that fail to deliver quality training and assessment services can have a significant impact on student outcomes and the confidence of employers in the effectiveness of your organisation. |
Guidance |
Your RTO is ultimately responsible for any services delivered by a third party and you must be assured through regular monitoring arrangements that you are exercising effective oversight of their operations. ASQA has issued a General Direction and a supporting Fact Sheet on third-party arrangements to ensure these arrangements are clear and assist providers to exercise effective oversight and meet their obligations. |
As providers look for alternative ways to continue to offer training without a face-to-face requirement, online and other distance delivery has become more common. Many providers have moved to a form of distance delivery to protect the health of their students and staff and to respond to changing consumer demand.
ASQA has published a dedicated webpage on distance delivery to provide advice to the sector on how to continue to deliver quality outcomes when using distance learning techniques and tools. The webpage also provides access to specific industry area resources and insights from providers and other stakeholders to assist those thinking of moving into a distance learning mode.
ASQA concerns
ASQA has identified some of the issues that might arise when providers use online or distance delivery.
Potential issue:Not assessing the suitability of the training package or VET accredited course requirements for distance delivery. |
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Potential impact | Students do not receive the full training and assessment experience and miss out on the practical elements of the course. These students may find it difficult to compete in the labour market and may struggle to adapt to the workplace. Employers may lose confidence in the quality of your organisation, adversely impacting on your reputation. |
Guidance |
When assessing the suitability of a move to distance delivery of a course, it is essential that your organisation analyses the requirements of the training package or VET accredited course. You should ensure that you have the right quality-control mechanisms in place to administer online learning resources and assessments and that the integrity of the training package outcomes is not compromised. |
Potential issue:Not being able to deliver all components of a qualification through online or distance delivery, for example, work placements and workplace assessments. |
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Potential impact | It may take longer for students to complete all components of their courses. The impact on students will be lessened through clear and accurate advice being provided upfront prior to enrolment. |
Guidance |
Depending on your circumstances, you may wish to consider restructuring strategies to deliver theoretical-based units before practical-based units or focusing on training and delivery of content, including in simulated environments, and delaying assessment. You should ensure that clear and accurate advice is provided upfront to students prior to their enrolment and the course structure and the length of the course. You should document and retain evidence as to how this advice was provided to students. |
Potential issue:Not considering learner needs, including the ability, desire and capacity of students to undertake distance learning. If you are moving to online delivery part way through a course that was previously enrolled as, and delivered by, a face-to-face method, you will need to inform students of this change and may need to give them a choice to study in the revised mode, delay studies, or obtain a (full or part) refund. Each student progresses at different rates and this may be more difficult to detect and cater to in an online or distance delivery mode. |
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Potential impact |
If you do not understand and plan for the support and progression requirements of all students, it can result in some students not progressing at the rate required to develop the required skills and knowledge. Students who do not progress as quickly as others or who do not receive the support they require may disengage from learning. Students who are not fully informed of the move to online delivery may have concerns with the revised arrangements, resulting in additional complaints to their providers. |
Guidance |
Your organisation must ensure that it has the systems in place to monitor students for course progress to track knowledge and skills development and assist to maintain motivation. You should implement practices to regularly monitor student engagement through their online activity in a similar way to monitoring student participation in classes. You should consider conducting real-time classroom style activities or offer varied learning opportunities to help with engagement. Where students are at risk of disengaging you should have appropriate strategies to support their re‑engagement. You should document and retain evidence of these interventions. Providers should be transparent about the need to move to online delivery, including whether it is temporary or permanent. They should actively seek student consent for the arrangement, seek to resolve any concerns and, if this cannot be achieved, they should offer student refunds. |
Potential issue:Not verifying that the person you are enrolling, training and assessing is the same person who will be issued with a qualification or statement of attainment upon successful completion. This can be particularly challenging if you deliver distance training, including through online methods, where there are more opportunities for students to submit the work of others than there are in a ‘traditional’ classroom setting. |
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Potential impact | Students that do not hold the competencies for which they are certified can pose significant risks to themselves, their future workmates and employers and the community. |
Guidance |
Regardless of the delivery method, you must be able to demonstrate how you have verified the identity of the student. There are a variety of ways to ensure authenticity in online settings, for example, a student can be required to hold their driver’s licence up to a webcam at the beginning of each virtual class. After the virtual class, the webcam can be used to take photos of the student at random intervals while they are completing the online assessment questions. Maintaining regular contact with students to check comprehension can also assist. You should document and retain evidence of the strategies you use to verify students’ identities in online settings. For VET students you must also verify the learner’s unique student identifier (USI) prior to award issuance, but ideally earlier. |
ASQA has received considerable feedback from providers and other stakeholders about the challenges they have faced in securing work placements and conducting practical assessments.
Providers have found it difficult to place learners in workplaces to fulfil assessment requirements because businesses may be unable to operate or can operate only with limited people on the premises.
During this time, providers have made adaptations when delivering their courses to ensure learners continue to have access to training and assessment. These adaptations include:
- re-sequencing training and assessment strategies to deliver theoretical training and assessment, and offering practical delivery at a later time
- adjusting training and assessment strategies to continue to deliver units of competency that do not contain requirements for assessment in the workplace
- adjusting training methods so that all training is provided in a simulated environment to enable a learner to develop the required competencies before placement in a workplace for assessment.
- making use of simulated workplace environments for assessment, where training package requirements support this mode.
Delaying completion of some units of competencies or an entire qualification until such time that assessment in a workplace can be undertaken, while important in ensuring the integrity of the training product is maintained and to ensure a learner is skilled and job-ready, has consequences both for the learner and the provider.
For some learners this may mean that their courses can’t be completed fully in the expected duration. Learners who were using vocational education as a pathway to other types of higher education may be unable to transition to that training. For others, while completion of a particular training product is not a mandatory requirement for employment, it can be a boost to a new career path or a higher salary.
There may also be visa implications for overseas students and other implications for those overseas students who had hoped to return home at a particular time or who are progressing to further study.
Some unscrupulous education agents may seek to pressure providers to inappropriately certify overseas students by threatening to divert students to other providers.
Providers may also experience additional financial concern particularly where funding contracts pay on completion of a unit of competency.
The AISC has created an emergency response sub-committee to discuss and respond to challenges during COVID-19. ASQA is working with the sub-committee to collect information that will inform decision-making in relation to solutions to support the VET sector.
- For more information in the AISC Emergency Response Sub-Committee including meeting outcomes and advice on mandatory workplace requirements, visit the AISC and COVID-19 webpage.
- To provide feedback on the impacts of COVID-19 on industry and the VET sector, visit ASQA’s website.
ASQA concerns
ASQA has identified some of the issues that might arise when work placement cannot be provided for assessment.
Potential issue:Providers certifying learners as competent in a unit of competency when they have not completed the necessary workplace assessment requirements. Work placement could be needed where the assessment requirements of a training product:
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Potential impact |
Where a training package or VET accredited course requires mandatory work placement (with a minimum number of hours), for skills to be assessed in a workplace or for assessment to be conducted using specific resources, these assessment requirements have been determined to ensure the learner has the skills and knowledge needed by industry to seek employment. Learners may enter the workforce not being able to do the job they were employed to do, potentially creating a health and safety risk in the environment. This oversight can have a dramatic impact on learners and the value of their qualifications. It can also have a significant impact on the reputation of the provider. |
Guidance | Review the assessment requirements of each unit of competency, including the assessment conditions, to understand how performance and knowledge evidence must be demonstrated. Where simulated assessment is allowed, ensure the specific resource requirements can be used. |
Potential issue:Using Recognition of Prior Learning (RPL) as the form of assessment in lieu of work placement or assessment in the workplace, where the learner is not able to demonstrate valid, sufficient, current or authentic evidence in the workplace in accordance with the assessment requirements. RPL is an assessment process that assesses the competency/s of an individual that may have been acquired through formal, non-formal and informal learning. Informal learning can include experiences in the workplace. Where assessment requirements impose a specific number of hours for work placement or specific situations and applications for demonstration of skills in a workplace, an RPL assessment must demonstrate these requirements in the context described in the unit of competency. |
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Potential impact |
Many learners undertake further study to upskill their competencies for the workplace. These learners, although they may have worked in a particular workplace environment, may not be able to demonstrate the full range of situations to the level required in the unit of competency. Other learners may not have current skills and knowledge or have worked in the specific contexts. Determining competency based on informal learning experiences can result in the learner not actually holding the skills, knowledge and attributes required. |
Guidance | RPL must be conducted with the same rigour as any other form of assessment. The assessor must be assured, and must have evidence, that the learner has demonstrated they have worked in the specific situation and context for the required minimum duration or minimum number of experiences. |
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