Equivalent Vocational Competency

One of, if not the most subjective compliance issues that we encounter is how RTOs and auditors consider the concept of equivalent vocational competency.

What is equivalent vocational competency and what clause does it relate to? Let’s start with the second question first to put things in context. Clause 1.13 a) of the Standards for Registered Training Organisations (RTOs) 2015 requires the following:

1.13. In addition to the requirements specified in Clause 1.14 and Clause 1.15, the RTO’s training and assessment is delivered only by persons who have: a) vocational competencies at least to the level being delivered and assessed;

This requires that if a trainer and assessor is delivering training and assessment as nationally recognised training, they must hold the actual “competencies” they are delivering. Notice the use of the word “competencies” as opposed to the general concept of “competency”. This is very deliberate and is intended to ensure that the trainer holds the actual units of competency which are being delivered. In many cases, this is exactly what is happening. The trainer will often hold the actual competencies they are delivering or may hold a superseded unit of competency which can be verified on the national training register as equivalent to the current unit being delivered. This situation is very straight forward and is objectively compliant. This is not equivalent vocational competency, it is simply, vocational competency.

So, what is equivalent vocational competency? The concept of equivalent vocational competency is not defined within the actual standards for RTO which is why this area of compliance can be so subjective. To its credit, the regulator has inserted a relatively helpful section within its recent Spotlight On series on Vocational competence and currency (click). It says the following:

Your RTO should apply a consistent approach to assess whether a prospective trainer and assessor has an equivalent unit of competency. Your approach should:

• establish the requirements for the applicable unit of competency
• determine a clear relationship between the evidence provided by the trainer and assessor and each of the requirements
• confirm that the trainer and assessor has broad industry knowledge and experience for each of the requirements
• verify the evidence provided by the candidate.

 

When the trainer does not hold the actual units of competency being delivered, they need to prove through providing evidence that, they are competent to deliver these units of competency. This can be very confronting for these trainers because it is probably the first time, someone has ever questioned their competency. This can often be after they were initially recruited and can present a challenging situation for those responsible for managing compliance. No matter how confronting or challenging, if the trainer does not hold the actual units of competency (or superseded units of competency) the question must be asked and it is the responsibility of both the trainer and the RTO to work together to establish the required evidence to verify equivalent vocational competency. If I were to propose a definition for equivalent vocational competency, it would be this:

Equivalent Vocational Competency: A person’s current vocational knowledge and skills equal to that specified in a unit of competency, often demonstrated through evidence of prior learning and relevant vocational experience.

As an example, I was looking at a client’s evidence last week where they are delivering the qualification ICT40518 – Certificate IV in Programming. The nominated trainer had completed a Bachelor of Computer Applications in another country and since arriving in Australia had also completed a Diploma of Information Technology (Software Development), a Diploma of Software Development and finally a Master of Information Technology. The trainer also still works in the IT sector as a freelance web designer and software developer. The evidence presented to me included all of those verified qualifications, CV, references confirming current and ongoing work and a myriad of recent professional development evidence. It took me all of about 10 minutes to accept that this trainer was completely vocationally competent. The trainer does not hold the actual units of competency, but the body of valid and authentic evidence that directly confirms the trainers high level of competency and ongoing work performing the tasks directly relevant to the units of competency being delivered, is very clear. This is an excellent example of the RTO demonstrating that the trainer holds “equivalent vocational competency”. I have complete confidence that when this evidence is presented to the auditor in ASQA (this week) it will be found compliant with clause 1.13a.

Highly Subjective

During my time as an auditor with various VET regulators, the concept of equivalent competency would regularly be discussed during auditor moderation. The trouble I have always had with the regulator’s approach is that, ultimately it comes down to how the auditor personally interprets the evidence before them and relies on their own perception and experience. If their own personal audit paradigm comes from a place of trust, confidence, and reason, then of course they would accept the above scenario as equivalent vocational competency. Conversely, if their personal audit paradigm is fueled by their power to make a finding over the RTO, a lack of personal confidence and reason, then the opportunity arises for the auditor to find some reason to identify the evidence as “not sufficient” or not directly relevant to the units of competency been delivered, et cetera. It is absolutely the auditor’s own judgement that decides this because of a lack of quality review within the ASQA audit process and an absence of any formal decision framework to govern these decisions. It is subjective. The RTO walks away scratching their head thinking, “I really don’t know what other evidence we could have provided”. Have you ever found yourself in that situation? I bet many of you have.

Don’t get me wrong, there are frequent situations where the client will present a trainer records to me and I simply don’t agree that the trainer holds equivalent vocational competency. There was a recent example of this only last month where the client was seeking to deliver the qualification CHC33015 – Certificate III in Individual Support in the context of the residential aged care sector. The nominated trainer held the qualification CHC40312 – Certificate IV in Disability which obviously relates to a different care context and sector and is superseded. Notwithstanding this, there are some units of competency that would cross over and, in some respects, the mechanics of providing care are similar. I mapped the units of competency for the two qualifications and found about three units of competency which I could be satisfied were equivalent. This left about 10 units of competency which do not appear to be vocationally equivalent. So, I looked at the other evidence the client had provided which included a CV, trainer matrix and professional development evidence. The nominated trainer had worked in the aged care sector between 2003 – 2005 before they had undertaken any formal training. From 2005, they had held positions in various disability care organisations particularly specialising in delivering home disability care services and in 2013 acquired the above Certificate IV in Disability. In 2015 the trainer obtained their TAE40110 qualification and commenced delivering training and assessment services for an RTO in aged care and had held a number of different positions within different RTOs since that time as an aged care trainer.

My client was basing their decision to nominate this trainer on the fact that the trainer has worked in numerous RTOs over the last few years delivering aged care training and has a wealth of industry experience. The reality is this trainer had no obvious experience working in the aged care sector. They certainly held qualifications in disability care and had significant industry experience in that sector which is not the same as providing individual support in the residential aged care sector. The evidence presented of the trainers competency was not sufficient or valid to demonstrate vocational equivalent competency and just because other RTOs had made the mistake of utilising this trainer in the delivery of aged care training, this does not provide any justification or basis of approval to nominate the trainer to deliver aged care training now. The client made the point that the trainer currently works in aged care but there was no evidence available of this and none has subsequently been provided. I assume that the trainer told the client that they are working in aged care but has never provided evidence of this. This situation is an excellent case study of an RTO nominating a trainer for a qualification that does not hold sufficient vocational competency or industry experience.

But, there are a myriad of situations which fall in between the examples provided in this article so far, such as:

• A trainer might hold a related higher qualification but hold none of the units of competency being delivered and not be able to demonstrate any significant industry experience. For some reason qualifications like project management and leadership and management seem to feature in this space. Obviously without any industry experience it is simply not possible to demonstrate equivalent vocational competency. Now, if you change this scenario to include significant evidence of industry experience, it changes the way the evidence is interpreted completely. Lets take an Accountant who is a practicing CPA who holds a TAE and is delivering the Diploma of Accounting. If I could verify the qualification and the directly relevant industry experience performing the tasks relevant to the units of competency, I would be fine with this. If you take away the relevant industry experience, it does not matter that they are a qualified accountant, without evidence of experience in performing the actual tasks, the trainer is not able to demonstrate their vocational competency.
• Another classic situation is where the trainer may have significant industry experience detailed within their CV, hold impressive qualifications which are not directly relevant, not hold any of the units of competency being delivered and has provided minimal evidence to verify the industry experience outlined within the CV. These situations are extremely frustrating for the RTO because they know the trainer is highly experienced and is valued by learners and they have relied on the details within the trainer’s CV and verified references as evidence of vocational experience. In this case, information in the CV and verified references is not valid or sufficient evidence of vocational competency. The RTO would need to prepare detailed mapping information that the trainer would compile to detail specific evidence from their experience relevant to each unit of competency to prove their vocational competency relevant to the units of competency being delivered. Just because a trainer holds a swag of qualifications, unless these are directly relevant to the units of competency been delivered, these are irrelevant. Experience on the other hand is king but, is hard to demonstrate and requires deliberate planning and effort.

A classic example I give to clients in the above situation is an audit I completed on behalf of a regulator back in 2008. The RTO was based in Brisbane and was delivering the BSB40307 – Certificate IV in Customer Contact. I remember that the nominated trainer did not hold the actual competencies or the qualification they were delivering. Instead, the trainer held a Diploma of Business (Frontline Management). When I queried the vocational competency of the trainer, the RTO was able to provide further evidence which included a CV and verified references which confirmed that the trainer was previously a shift supervisor at the Qantas Customer Call Centre in Sydney managing customer contact for about six years up till 2007. I contacted the referee at Qantas and confirm this. I had no doubt in my mind that this trainer was competent and experienced in the units of competency they were delivered, and I accepted this. When I think of that situation in today’s context, I would recommend to that RTO today to prepare some additional evidence in the form of a competency mapping and specific evidence relevant to each unit of competency as suggested in the regulators fact sheet.

Treat it like an RPL situation

I frequently say to clients that making a claim for equivalent vocational competency where the nominated trainer does not hold the actual units of competency being delivered, is like applying for RPL to the auditor. Have another read of the guidance provided by the national regulator above and ask yourself, does that description of evidence sound like RPL? Absolutely it does. When an auditor reviews evidence of your trainer’s competency and currency and the trainer does not actually hold the units of competency being delivered, the auditor needs to be provided sufficient and valid evidence to agree that even though the nominated trainer does not hold the actual units of competency being delivered, it is very clear from the available evidence that the trainer is certainly competent and experienced. I will often flip the situation for the client when they have not provided sufficient evidence to agree to this and ask them, if this trainer submitted this evidence to you and applied for RPL would you grant the units of competency using recognition of prior learning? Of course, the client’s answer is always no, and this underlines the point that the evidence being presented by the RTO in support of the trainer’s equivalent vocational competency is not sufficient.

If you have a trainer who does not hold the actual units of competency they are delivering, I recommend that you apply the following steps:

1. Firstly, gather all of the trainers qualifications and undertake a careful analysis of the units of competency they hold and compare these to the units of competency to be delivered to identify any units of competency which are similar or are identified as equivalent on the national training register. Although the unit of competency may technically not be equivalent, if it has a similar occupational outcome, this can often be accepted as supporting evidence of equivalent vocational competency.
2. After confirming any possible unit alignment, focus in on the units of competency which do not align and require supporting evidence. Now, approach this from an RPL prospective and ask the trainer to consider each unit of competency and what evidence they could provide that verifies their current competency. It is important that you apply the same rules of evidence to this as normal assessment. The trainer needs to nominate evidence that is valid, authentic, current and sufficient. Currency is of particular importance. The trainer needs to demonstrate that they are competent now, not 10 years ago. Evidence might include examples of actual work completed, duty statements, references, performance appraisal, formal and informal learning, ongoing work participation, et cetera.
3. Document this information into a competency mapping where the unit of competency title and maybe the elements of competency in a table on the left and the response by the trainer including a reference to available evidence and referees if available on the right. Referees are quite valuable to nominate as they can verify currency of the nominated trainer’s competency. One thing to avoid when preparing these competency mapping tables is the practice of simply copying the response information and evidence from one unit of competency to the other. This often results in evidence which is very generic and not valid for each unit of competency. I often recommend that the trainer respond to each unit of competency like a selection criteria response in a job application. Each response should be unique and highlight their current capability and competency performing the task. If you get back a competency mapping document where the trainer has simply pasted the same generic and higher-level response against every unit of competency, send it back.
4. Keep a copy of the nominated evidence which is mentioned in the mapping document. It is quite important that if the auditor wants to verify some of the evidence which is specified in the mapping document that this is available. Clearly, you should also verify the evidence submitted by the trainer which should include verifying references and referees, confirming the authenticity of evidence, requesting additional evidence where required.

This evidence should obviously complement the other normal evidence that you will be retaining on the trainer’s file such as the CV, employment / contract agreement, copies of qualifications, completed trainer matrix, evidence of professional development, et cetera. I recommend that you implement an arrangement to review this competency mapping information approximately every six months to ensure that it maintains its currency.

Why not just go and RPL?

When you consider all the effort required to demonstrate vocational equivalent competency, would it not be simpler just to go get RPL and have the relevant units issued? The regulator would not advocate this, and I do not particularly advocate this approach either. A trainer who truly holds vocational equivalent competency should not be expected to go and RPL often to a lower level qualification just to satisfy a requirement in the standards. The problem is this requirement in the standards is so subjective that it really is a lottery sometimes in how equivalent competency evidence will be interpreted. The only way to really remove the subjectivity is to hold the units of competency hence the option of RPL. On a number of occasions where a client has been responding to a non-compliance for equivalent vocational competency, we have utilised RPL as a strategy to verify the trainer’s competency and to provide evidence of the achieved qualification and units of competency as rectification evidence. Providing that the trainer has the industry experience, this is a solid strategy at converting a subjective compliance situation to completely objective and removing the power from the auditor. Notwithstanding this, during the normal operation of the RTO, always preference the approach of strengthening the evidence of equivalent vocational competency over requiring trainers to undertake an RPL process. Whilst an expedient strategy, it is often costly and insulting to the trainer who will often hold higher related qualifications.

Conclusion

If you intend to use trainers who do not actually hold the competencies they are delivering, this article is relevant to you. Other than non-compliance with assessment, the RTO using trainers who could not provide evidence of vocational competency is one of the most common non-compliances that we see. This is one of those poorly defined compliance requirements in the standards which is why it is highly subjective between different auditors. Your objective should be to prepare your trainer records in such a way that they rise above the subjectivity and would be considered compliant by the vast majority of auditors. I know that good trainers can be hard to come by but, don’t fall into the trap of accepting flimsy evidence of vocational competency. Verify everything and make sure that you can provide evidence that directly demonstrates the trainer’s competency in the units of competency they are delivering.

Good training,

Joe Newbery

Published: 13th October 2020

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