Hello and welcome to VET News,
I am getting lots of questions over the last few weeks about language literacy and numeracy assessment and how this is going to work with the introduction of the revised standards. It is a fairly deep topic to be honest, but I will do my best to cut through the noise and address the common questions I am getting. Firstly, lets just confirm what the new requirement is:
Outcome Standards for NVR Registered Training Organisations2025, Standard 2.2 (2)(a) require the RTO to demonstrate: taking into account the requirements of the training product, it has procedures in place to review, prior to enrolment, the skills and competencies of prospective VET students, including their language, literacy and numeracy proficiency and digital literacy.
Ok, here are some common questions I am getting.
Question. Is this a new requirement or a change to the current standards?
Yes and no. The national regulator currently uses clause 5.1 in the current standards which honestly doesn’t make any reference at all to language literacy and numeracy assessment. I would say for the last five-six years the national regulator has conveniently interpreted that language literacy and numeracy assessment is a compulsory requirement under this clause and has regulated as such. So, we can say that it is not a new requirement, but it is more specifically stated within the revised standard which I think is great. Nothing better than clarity.
Question. Does this mean that LLND assessment must occur prior to the student’s enrolment?
Yes, it most definitely does. I think what’s important when you consider the complexity of how you are going to do this is, at what point do you consider the student to be “technically enrolled”. This (the enrolment) might be something that you push back in the process to allow time for the student to engage in the LLND assessment prior to you formally confirming their enrolment. You can designate the point when the enrolment is confirmed by issuing the student with a confirmation of enrolment letter after LLND assessment. When you take the students details online and any online payment, I would be referring to this as a course registration not an enrolment. You will need to review your enrolment process and procedure to organise the LLND assessment to happen before the student’s enrolment is confirmed. Note, unlike standard 2.1(2)(d), the LLND clause (2.2 (2)(a)) makes no mention of fee payment, so it is up to you when you want to confirm the enrolment. As a guide, I would say the enrolment should, at a minimum, be confirmed before the student is commenced.
Question. It’s not possible for us to engage with the student face to face prior to the commencement of the course so the only way we can administer the LLND assessment is online, and we are concerned about the cost and authenticity of this assessment and this acting as an unnecessary barrier to entry to engage in our services. What do we do about this?
That’s a great question and it’s clearly not something that the national regulator has considered. If you are going to conduct the LLND assessment online then you will need to implement mechanisms that verify the authenticity of the person completing the assessment just like any online assessment. Some of the commercial online services that provide these services have these authenticity mechanisms built in but obviously this comes at significant cost. I also agree that putting up complex steps (such as an LLND assessment) that students need to step through even before they engage in the course is highly likely to result in less enrolments and these students will naturally migrate to training providers that are less concerned about compliance. Obviously, every provider will need to consider their own response to this situation but for those that are really concerned about the cost and the impact on enrolment numbers, I would recommend changing your terms and conditions to identify that the student’s enrolment is not confirmed until LLND assessment has been completed. Administer the LLND assessment with the student face-to-face as part of their orientation and induction and confirm the enrolment only after the LLND assessment is complete and student support has been considered.
Question. We deliver short courses such as a half day course and in most cases one or two day courses. Are we really expected to put students through a full language literacy and numeracy assessment prior to undertaking a short course?
Yes. Now, you might not like my answer but that is no different to the current situation even before the new standards are introduced. Again, I recommend that you offer an online registration for the course which may include payment and then you conduct a simplified LLN assessment right at the beginning of the day probably about the same time they complete the AVETMISS information collection sheet and verify identity. I would also point out that for many years we have implemented arrangements with clients to have a fairly simplified LLN assessment built into the enrolment form. The national regulator has always been very happy with this and this is reinforced by the commentary that was in the draft standards where it recognised that LLN assessment for short duration low-cost courses can be “fit for purpose”. Which is a nice way of saying that they can be simplified.
Question. We deliver an online learning module before the student turns up to undertake the face to face training. Does the student need to complete LLND assessment before they commence this online learning module?
Easy answer, yes. If your students are engaging in online learning then they are commencing the course at the point they commence the online learning so, you really would have no choice in this instance other than facilitating an online LLND assessment as part of the enrolment prior to commencement.
Question. Do we need to incorporate digital literacy assessment for all of the courses we offer regardless of the mode of delivery.
No. My advice to clients at the moment is that, unless your course involves a component of using technology or undertaking online learning, there should be no particular requirement to assess the students digital literacy skills. So, if you are delivering a first aid course or working at heights course as an example, if there is no online learning component then digital literacy assessment should not be required in this example.
Question. Is it compulsory that every student regardless of the education background and/or vocational achievement need to complete a LLND assessment.
It’s a great question. This is one where I can only give my common sense answer, but time will tell once the national regulator starts to undertake their audits post June 2025. Apparently, this question was asked of an ASQA representative in a forum for community colleges in New South Wales and the answer was quite blunt. Apparently, they said “yes”, all students will need to complete LLND assessment without any exceptions which obviously makes absolutely no sense. We have been using sensible exceptions within our policy product for many, many years without ever been questioned. If the student can demonstrate they hold qualification at or above the level they are entering, if the student holds a high school certificate, if the student is a returning student and has previously completed LLND assessment and successfully achieved the previous course requirements, in all of these situations, I would say that it is common sense that these students should not need to complete additional LLND assessment. To do so is relatively insulting to them, it’s a waste of their time, your time, your money, and as discussed before, it also creates an unnecessary barrier to entry. This is not to say that you should not still engaged with the student to identify any student needs but in these obvious situations conducting another LLND assessment would seem ridiculous. So, I have reviewed and refined our policy position but essentially, we have retained the same policy and time will tell if that prevails.
General points. Just to finish off this topic, I might just make a couple of final points:
- LLND Assessment is not meant to be a barrier to entry or a mechanism to determine if a student is suitable for a course. The primary purpose of LLND assessment is to identify student support requirements so that these can be responded to and the student can have support arrangements put in place. Now, very rarely it might identify a student that is so under skilled that it would be unfair to them to enrol them into a course that is beyond their capacity and in these situations the student should be referred to relevant professional support services where they can improve their basic core skills. Just remember, the primary purpose is to identify support requirements so that you can respond to these.
- LLND Assessment tasks must align with the target ACSF and ADCF level or include tasks which identify the student’s level. If your LLND assessment are not aligned with and mapped to these frameworks,,, fix it. There are some reasonably good, free to download resources at the following website: https://www.skillseducation.com.au/pages/acsf-resources
- LLND assessment must be reviewed by a person who is competent or trained to do so and if the student is not at the required level, you need to respond to this. Your support arrangements might be passive and straightforward and may not require significant intervention with the student, but you certainly cannot just ignore the assessment outcome and hope for the best. This is the whole purpose of doing the LLND assessment so you need to put arrangements in place to respond to these students and put appropriate support arrangements in place where necessary.
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Good training,
Joe Newbery
