The VET Reforms are happening. And we are being asked to contribute to the changes. Generally, I think it is a waste of time for many of us to get involved in the consultation process because changes are being implemented anyway. However, I got an email this morning from the Skills Reform Engagement Team at the Department of Education, Skills and Employment reminding me that time was running out if I wanted to respond to the Qualification Design Survey.

Qualification design elements

I decided to do the survey. It first wanted to know my thoughts about the following key qualification design elements:

• Qualifications based on appropriately grouped occupation and skills clusters to deliver broader vocational outcomes for students (including supporting stronger recognition of cross-sectoral and transferable skills).
• Simplifying products and removing complexity through the separation of occupational and training standards to reduce the level of prescriptive conditions in current qualifications and make better use of industry and educationalist expertise.
• Stand-alone and/or stackable short form training products, with improved pathways advice to support students to rapidly upskill or reskill to pursue new career opportunities (including facilitating stronger articulation pathways between school, VET and Higher Education to support lifelong learning).

Here is my reply to the survey.

The first point, about ‘Qualifications based on appropriately grouped occupation and skills clusters to deliver broader vocational outcomes for students (including supporting stronger recognition of cross-sectoral and transferable skills)’, is a reasonable idea. It is not a new idea, but it has been difficult idea to implement for the past few decades. If competency standards become too vague then they will weaken the VET system in Australia.

Some people do not focus on the details of a skill and how it may differ in different situations or circumstances. For these people they may think it is okay to have a ‘operate a vehicle’ unit of competency. But one unit of competency cannot cover operating a car, taxi, van, truck (different types of truck), forklift, tractor, etc. This is an exaggerated example design to illustrate the concept. We can only go so far in creating generic or cross-sectoral skills.

There has been many examples how generic or cross-sectoral skills have been widely used for many years. For example, first aid and make presentations.

The second point, about ‘Simplifying products and removing complexity through the separation of occupational and training standards to reduce the level of prescriptive conditions in current qualifications and make better use of industry and educationalist expertise’, is a really bad idea.

The separation of occupational and training standards will destroy the founding and fundamental principle of an Australian VET system that is industry-led. This proposal will not simplify or remove the perceived complexity.

Keep educational experts away from prescribing qualifications. In 1993, Australia implemented the new training system that we now know as VET. Industry and employers replaced educational experts as the people who should determine the skills needed by their workforce. Let’s not go back to a system that created unemployable VET graduates.

The third point seems to cover several points:

• Stand-alone and/or stackable short form training products
• Improved pathways advice
• Facilitating stronger articulation pathways between school, VET and Higher Education.

Nothing new about these three sub-points. Skill Sets have been with us for more than a decade. Governments have squandered away millions of taxpayer dollars on creating and re-creating pathway advice. Investment in ‘new’ career advice needs to be done once and then maintained. We should not have to start from scratch everything we have a change of government or change of minister from the same government.

In regard to articulation, this has been an aspirational feature of Australia’s VET system for decades. VET people think it is a good idea. University people seem to have trouble with the idea with some exceptions. For example, dual-sector universities use it as a feed-in strategy to capture students who did not get the ATAR score need to do the higher education qualification. They may offer the student an opportunity to do a diploma for a year, and if successfully completed, the student is offered a second-year placement in a bachelor degree qualification. Articulation is selective and only offered when the university sees a marketing opportunity.

We should stop thinking that articulation is VET Reform. It should be shifted to being a Higher Education Reform.

Overall, the current key design elements of the Australia VET system include:

• Qualifications based on occupations, and in some cases grouped occupations
• Cross-sectoral and transferable units of competency are widely available and used
• Stand-alone and stackable skill sets are widely available and used
• Career pathways advice have been, and continues to be, available
• The possibility of articulation has been available for a long time.

I don’t think these elements need to be tested.

Qualification design objectives

The survey gave the following preamble.

Trials will be underpinned by the following design objectives to ensure they align with the direction of the future training system design:

1. Broader vocational outcomes to recognise skill commonality and promote labour mobility, where feasible.
2. A reduction in unnecessary training product duplication.
3. A reduction in training product complexity, through reducing over-specification and improving training delivery and assessment advice.
4. An enhanced relationship between training products, training needs and pathways to employment and further education.
5. Greater training product flexibility and enhanced responsiveness to changing industry need through short courses (micro-credentials and skill sets).
6. Improved articulation and pathways between education sectors, building on the AQF review recommendations.

And here is my reply to the survey.

1. If the recently released BSB Business Services Training Package is an example for the future of broader vocational outcomes, then we are heading in the wrong direction.

2. The reduction in unnecessary training product duplication has already commenced. Why are we being consulted when it is already happening?

3. During 2020, there was evidence that an attempt to ‘reduce training product complexity’ has commenced. For example, the Release 7.0 of the BSB Business Services Training Package has made changes. But in the name of simplification, we are actually increasing the complexity. We know have training package documents (from training.gov.au), implementation guides and other companion volumes (from vetnet.gov.au), and interpretation guides. Multiple places to look for information, with the quantity of documentation increasing. And every new document seems to have different layout and format.

4. Anyone who knows the Australian VET system can understand the relationship between training products, training needs and pathways to employment and further education. Some people may be ignorant of these relationships. The VET system does not need the enhancements. These people need to learn more about the VET system – it is not that hard to learn.

5. For decades, the Australian VET system has had all the design elements to be flexible and responsive to client needs. It is inflexible and unresponsive RTOs have should be addressed. Many people have incorrectly blamed qualification design for issues. Most qualifications offer great flexibility and units of competency can be contextualised, with the exception being qualifications needing to be more rigid due to a regulator’s requirements.

6. We should stop thinking that articulation is VET Reform. It should be shifted to being a Higher Education Reform. (Articulation was covered by my comments to the previous question.)

In conclusion

The time it took to respond to the survey was probably a waste of time. However, after the VET Reforms have been implemented and the Australian VET system has be damaged, if not destroyed, then I shall have the great pleasure saying that someone should have listened to me.

I think the public consultation process is primarily a sham. The VET Reforms are going to happen anyway, and some reforms have already commenced. There seems to be a big rush to implement something before the next federal election, even if that something has no merit.

What do you think about the tsunami of VET Reforms? Did you know that the changes had already commenced?