|Hello and welcome VET News,
I mentioned in our last VET News that we were following a matter making its way through ASQA that related to a very wrong audit finding in relation to a trainer’s equivalent vocational competency. I was literally inundated with emails following that last VET News with RTOs sharing their own experience in relation to this area of compliance with one common theme. This is the absolute inconsistency in auditor interpretation of evidence in support of equivalent vocational competency. Many RTOs described the same crazy situation that one of our client’s experienced with one auditor confirming a trainer’s equivalent competency whilst another auditor looking at the same trainer, the same evidence at a different time and finds the opposite. I can report that following the provision of some additional evidence, the non-compliance was resolved.
But,,, clearly there is a systemic problem out there with the reliability of auditor decision making. We need to drag the concept of equivalent vocational competency out from being an unpublished rule and bring it into the light by putting some published rules and guidance around the minimum evidence requirements and by establishing some accepted rules for common qualification areas. I took note some time ago how ASQA have published a guide to recognise the various qualifications that would be accepted as examples of suitable “adult education qualifications” for the purpose of delivering TAE training products. Why did they publish this? Because this rule in the standards (Schedule 1, Item 3) is so vague that it needed to be better defined to assist RTOs to comply with the regulator’s expectation. Go figure!
So, lets build on this idea and see if we can agree on some basic rules around the minimum evidence requirements in support of equivalent competency. As an example, can we agree that a trainer that holds a Bachelor of Nursing and a current AHPRA nursing registration with a minimum of three years demonstrated experience working in the age care sector, has sufficient vocational competency to deliver the qualification CHC33015 – Certificate III in Individual Support? Surely it is self-apparent to accept that this person has the skills and knowledge to deliver aged care training without the need to require this person to waste significant time preparing some lengthy competency mapping. There must be many dozens of vocational areas like this where we can say, if you hold this higher related qualification and have this experience, then this is sufficient evidence that you are competent to deliver this qualification. I think of this like an equivalent vocational competency guide, or some other sexy name. Come on ASQA! Let’s try and develop this type of more helpful level of guidance to reduce the compliance burden rather than simply continuing on the same old path.
Another very basic idea is, why doesn’t the regulator maintain a register of approved trainers? If a trainer’s equivalent vocational competency is sampled at an audit and the auditor confirms their competency for the delivery of a specific qualification, why not put this in a database so that in future audits this does not need to be re-evaluated? This would be more efficient for the regulator; it would reduce the RTOs compliance uncertainty and would support productivity. These are just two suggestions which the regulator could act on which would provide some much needed clarity to an area of compliance which is so dreadfully inconsistent.
I made a point on LinkedIn this week that we are entering a skills shortage the likes of which we have not seen for many decades. Finding and retaining skilled and experienced trainers is going to become increasingly more difficult and expensive. We need to remove these silly barriers to entry where possible. A great place to start is to simplify the rules when it comes to equivalent vocational competency. The regulator needs to sort out its inconsistent regulation and put in place some systems and guidance which provide RTOs more certainty to employ these trainers and reduce the time wasting in preparing micro level evidence to convince some auditor that this trainer is competent. We need to keep on banging this drum until they get it.
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