The Amount of Training – Part One • Newbery Consulting

The Amount of Training – Part One

Introduction

Put your hand up if you are confused about what ASQA expect with regard to the “amount of training”. Ok, I thought so. You can all put your hands back down.

I find this concept of the “amount of training” to be one of the most confused requirements in the VET sector. Where did it come from? ASQA invented it in 2014. In fact, I reckon it can be credited to a certain individual in the Brisbane outpost. It was published in the 2015 RTO standards and of course features in clauses 1.1 and 1.2.

Since its introduction in 2015, it has been one of the worst handled policy implementations I have ever seen. Even ASQA initiated its own strategic review in 2017 (click), where the Chief Commissioner, Mark Patterson himself admitted that the regulation of duration in VET is complex and confusing. At the time this strategic review was released, I was stunned by the ineffectual recommendations that it made. Two years have now passed and not one of these recommendations has taken effect, including recommendation No 1 which simply required the inclusion of a clear definition of the “amount of training” to be included in the actual standards. I mean seriously, how many rocket scientists and bureaucrats does it take to come up with a sensible definition and publish it within the standards? Two years on and we can still only guess what the regulator actually means when it says “amount of training”.

Confusion reigns

Just to give you a snippet of the confusion within ASQA about this, in its own fact sheet (click) it identifies that the amount of training includes formal learning activities such as classes, lectures, tutorials, online or self-paced study and workplace learning. It excludes assessment and this correlates with what we are experiencing at client audits where auditors from the national regulator are removing time allocated for assessment when considering the amount of training. Now, compare this to its own strategic review report where it recommends that the amount of training include assessment activities. I mean, the contradiction is stunning. If they really think that assessment should be included when calculating the amount of training, why don’t they just update the fact sheet? Add to this, the huge variation in the way that different regions within ASQA are interpreting the requirement. The Brisbane office is typically soft and flexible, the Sydney office is typically hard and inflexible, and the Melbourne office is just simply inconsistent. Seriously, the Melbourne office is all over the place. VET regulation in Victoria is an absolute lottery. We actually will vary our advice to clients depending on what jurisdiction the client operates in. That is crazy and is a symptom of poor auditor moderation and inadequate national oversight over the regions and individual auditors. Anyway, you get the picture. It’s basically a mess. We have a poorly defined published regulatory requirement, a regulator who can’t even agree with itself and RTO’s who are jumping at the shadows trying to understand exactly what the regulator expects. It actually does my head in and I am a little disappointed for our sector.

So,,, in an effort to support the sector (as we do) and to provide some clarity and understanding, I have provided some considerations on how to comply with clauses 1.1 with regard to the amount of training. In the next part of this series, I will focus on clause 1.2.

I hope this helps.

The fundamentals (as at today anyway)

The first thing to note is that the standards require the RTO’s training and assessment strategies and practices to include an amount of training that is consistent with the requirements of the training package. The training packages provide no advice on the amount of training as such but does position qualifications at a particular AQF level.

These AQF levels have an allocated volume of learning indicator (click). To identify the AQF volume of learning indicator, you are best going direct to the source and identifying the allocated volume of learning for each AQF level within the AQF Levels Criteria and Qualification Type Descriptors table, AQF 2nd edition, (click). As an example, the volume of learning indicator for a diploma qualification is 1 to 2 Years (1200 to 2400 hours). I seriously have no idea why they allocate 1200 hours to 1 year. I don’t think this came out of the original AQF doctrine. Oh well, we should blame that on ASQA as well! 🙂 But seriously, why is it 1200 hours for each year? I mean, why isn’t it 750 hours per year or 500 hours per year? If anyone knows the answer to this, please email me.

Anyway, it is really important to understand that the volume of learning is not the only consideration in determining the amount of training. The volume of learning is a dimension of the complexity of the qualification. The factors which influence the required amount of training include:

– the number of units of competency that make up the qualification

– the breadth and depth of the required knowledge and skills of each unit

– how the training is being delivered (mode of delivery)

– the entry level and current experience of the target learner

The volume of learning indicator is expressed as a “typical” range such as our diploma which has a typical range of 1200 to 2400 hours. Why is it expressed as a range? Because all of the factors identified above will influence how much time and training is required. Obviously, the more complex the course, the more time required.

In its fact sheet, ASQA say that “If your RTO intends to deliver to learners who are new to the industry area and/or who do not have any workplace experience, the amount of training required that is described in the training and assessment strategy would closely match the timeframe listed with the AQF volume of learning.”

So, I generally try and get the client to identify the amount of training which is allocated across all various modes of training delivery to maximise the final amount of training. I am not advocating artificially inflating the figures just to reach the minimum volume of learning. This is important and the subject of discussion further on. My point is here, you need to think outside the box of simply focusing only on face-to-face training. How else is the learner engaging with the content? Are there opportunities to introduce new learning engagement strategies to increase the amount of training in the current course duration?

Activities that make up the AQF volume of learning include all learning and assessment activities. The important part about that statement is that the AQF volume of learning can include assessment. The way that ASQA define the amount of training (at the moment) is that it includes training only and excludes anything to do with assessment. This is important because we generally advise clients to avoid including amounts of time allocated for assessment in an overall time allocated for the amount of training. This can have a serious impact on the time because, assessment is ultimately the only way you are achieving competency and it often forms a big component of most courses.

We recommend that the following activities be included in calculating the amount of training:

Supervised training:

face-to-face training
onsite training in the workplace
tutorials, workshops or field trips
supervised e-learning such interactive video sessions or chat forums

Non-supervised training:

structured and compulsory self-paced learning activities
structure and monitored online learning activities
structured and compulsory distance learning activities
structured and compulsory workplace learning activities

We recommend that the following activities not be included in calculating the amount of training:

optional learning support
recommended or even prescribed reading
watching videos
recommended personal study or preparation
self initiated learning activities
work experience or attendance

What is Training?

The definition of “training” (in the context of the amount of training) is something that also needs to be considered very carefully. The fact sheet I have quoted above simply says that “training” comprises the formal learning activities you provide to a learner. These can include classes, lectures, tutorials, structured online or self-paced study, as well as structured workplace learning. So, anything where “training” is occurring.

But, ASQA has some unpublished rules about how it interprets non-supervised training and how these activities need to be conducted to justify them as training. We identify the following six factors which need to be present in order to justify time allocated for non-supervised training, these include:

the learner completes actual work and submits these for review
the trainer reviews the work and provides the learner feedback to monitor their progress
the training activities are aligned to the requirements of the units of competency
the activities are a compulsory component of the course
the time allocated is proportionate to the activity being undertaken
the organisation can provide evidence to verify that these activities were completed

Let’s look at these in more detail:

1. The learner completes actual work and submits these for review. One of the very unfortunate practices that has emerged in the last few years is the practice of including an allocated amount of time to training activities for which the RTO has no developed basis for. It is a very common occurrence in the audit’s that we undertake where the RTO will claim an amount of self-paced training that the learner is undertaking. This might be five hours a week over a 40-week course (200 hours). I ask to see the developed self-paced training activities that the learner is completing in this time and the RTO says “Oh, these are allocated by each individual trainer as homework” or “this is the time that the learner spends reading the learner guide”. The problem with these situations is, the regulator will simply not accept “reading” as training and unless there is a developed activity that the learner is actually completing and unless you can produce evidence of the actual structured activities, it simply is a thought bubble and is not “training”. The training conducted online, self-paced, in the workplace, et cetera needs to be identifiable as an actual activity that the learners’ complete and submit something or record something that will be reviewed by the trainer. Don’t simply make claims about an activity when there is no actual designed and developed activity which the learner is completing. Otherwise, it’s not training.

So, we advise clients to develop a self-paced learner guides which include these activities if they are claiming self-paced learning. If they are allocating time to workplace learning then we recommend that they develop a comprehensive workplace learner guide which includes a range of activities that learners’ need to complete on the job and record evidence of this. It’s important to note, that this is not assessment, this is simply training to enable the learner to develop their skills across the full range of situations that may present in the workplace.

2. The trainer reviews the work and provides the learner feedback to monitor their progress. Over the last six months, I have observed ASQA introduce new requirements for how it regulates training. It’s hard to know if this is just auditors operating off reservation or an unpublished policy that has emerged out of formal auditor moderation. In any respect, I have seen enough of the pattern across jurisdictions to now provide this as a standard recommendation to clients.

Unless the RTO can provide evidence that the completed training is subject to review by the trainer and includes feedback provided to the learner then it simply won’t be accepted as training. I mean, this probably sounds like an obvious statement, but there aren’t too many RTO’s who actually collect completed self-paced learning activities from learners, have the trainer (at $50 an hour) review these and provide feedback to the learner. Just to be clear, I am talking about training here and not assessment. The trainer/assessor will also need to review, assess the completed assessment work (at $50 an hour) on top of this.

I have had a number of instances particularly across Victoria and New South Wales where the auditor has rejected time allocated to an activity as training because there was no evidence that the trainer had reviewed the work and provided feedback to the learner. I now refer to this as a “feedback loop” and recommend clients to build this into their delivery model. This has seen some clients move these self-paced learning activities online where the learner’s work can be reviewed more efficiently and in some cases responses provided by the learner can be provided programmatically. By this, I mean marked automatically within a learning management system, particularly where the outcomes of these learning activities are objective. Other clients have incorporated the review of completed self-paced learning activities into classroom activities. So, at the beginning of the session, the trainer will ask students to produce their completed self-paced learning activities which are then subject to a classroom discussion and the trainer signing off each completed workplace learning record (so last century!).

The take-home point is, there needs to be a feedback loop where the trainer reviews the work completed by the learner as training, so the learner can benefit from the input from the trainer and the trainer can monitor the progress of the learner.

3. The training activities are aligned to the requirements of the units of competency. The training activities that you develop need to align with the requirements within the unit of competency. Again, you would think within our competency-based training and assessment model that this is a completely obvious statement, but I often see activities such as work placement or self-paced learning where the RTO cannot easily identify how the units of competency actually relate to the activity.

I recommend that clients develop their training and particularly non-supervised training to align with the units of competency that comprise the course or the unit clusters. This means, that we see clients developing workplace learner guides with tasks aligned with particular units of competency or self-paced learner guides aligned with specific units of competency. You need to be able to show the relationship to the units of competency the learner is undertaking.

The training needs to form part of the designed learning pathway for the learner to acquire the required knowledge and skills in order to achieve competency. Makes sense!

4. The activities are a compulsory component of the course. The training activities that you allocate time in your training and assessment strategy need to be compulsory. If they are not compulsory, then they do not form part of the designed learning pathway. I have observed auditors from the national regulator reject time allocated to training activities which are not compulsory. The common example of this is where an RTO may allocate an amount of time for optional learner support. Refer to and explain these activities within your training and assessment strategy by all means, but do not allocate these non-compulsory activities time in your amount of training.

5. The time allocated is proportionate to the activity being undertaken. You need to make sure that the time you allocate for certain activities is realistic. If you allocate 10 hours a week to self-paced learning, there needs to be a sufficient volume of activity that it would take the average person about 10 hours to complete. When a client allocates an amount of time for self-paced learning, structured online learning or structured workplace learning, I look to see the amount of activity which is allocated in that week or against that unit of competency.

The national regulator does the same and if there is insufficient developed activity which corresponds with the allocated time then it simply will be rejected. The strategy is made non-compliant because it does not reflect the current delivery model and the amount of training does not enable the learner to acquire the required skills and knowledge. Sound familiar?

A good way of identifying how much time is required to complete an activity is by getting feedback from current or past learners who have already completed those activities. If you are including allocated workplace activities within a workplace learner guide, then get some feedback from the supervisor or employer about the required time to complete those tasks. It’s really important that the time you allocate to activities is proportionate to the work required to be completed.

6. The organisation can provide evidence to verify that these activities were completed. Finally, you need to be able to provide evidence of these completed training activities. This might present in the form of a retained completed learner guide or a retained completed workplace logbook. If you are delivering your training online, then presenting evidence of completed training activities can be a little easier.

The concept of being able to provide evidence of completed training activities is problematic. For instance, I have seen auditors from the national regulator (Sydney) not accept time allocated for self-paced learning because the RTO could not produce evidence of completed self-paced learning work. Of course, the RTO explained that they review the work but allow the learner to keep this work for their own reference and so it is not retained by the RTO in its record system. The auditor didn’t take any notice of the client’s explanation and made the client non-compliant because of an insufficient amount of training directly related to the fact that this evidence could not be produced. I find this grossly unfair and challenge the national regulator to identify any general direction it has issued or any legislative instrument which specifies the obligation of the RTO to retain evidence of completed training. If you are going to regulate something then publish the regulatory requirement in black and white so everyone is on the same page!

So, whilst I find this last requirement very problematic, there are some ways that you can retain evidence of completed training activities. I would absolutely recommend that any learner who attends face-to-face training with the RTO is recorded on an attendance record of some description. Any work completed by the learner in the form of structured workplace learning activities should be retained in the form of a workplace logbook or perhaps using one of the cloud-based services such as my profiling. When it comes to completed self-paced learning work activities, it can be a little more difficult. Perhaps getting the teacher to maintain a consolidated record of the work they have reviewed prior to handing it back to learners or recording comments or observations in regard to the learner’s completed work within the notes section of your student management system. Obviously, the objective is to try and find an efficient way of retaining this evidence without becoming a costly administrative burden.

Keeping it real

The other important consideration when preparing information that describes the amount of training is to, keep it real! You should avoid including arbitrary numbers and calculations simply to arrive at the minimum benchmark volume of learning. I see clients doing this all the time. A good example that I reviewed recently at an audit was a certificate III course (12 units) being delivered over 12 months (40 weeks) as a traineeship. The learner was attending the RTO for face-to-face training seven hours per day, one day per week (280 hours). The learner was also completing self-paced learning activities which were developed within a self-paced learner guide and required a commitment of five hours per week which is pretty realistic (another 200 hours). Miraculously, the client had allocated 720 hours for workplace learning. Of course, the total arrived at 1200 hours! When I quizzed the client about the 720 hours, they admitted that it was simply included to align with the volume of learning because that’s what they thought ASQA wanted. No!

The RTO is much better off just describing the real time even if this number is not at the level needed to align with the volume of learning. So, if that means that the combination of face-to-face training and self-paced training, online learning amounts to only 480 hours, that’s okay. It means that we need to have a look at the course and be confident that the structured activities is giving the learner every opportunity to acquire the required skills and knowledge and importantly allowing them the opportunity to develop their skills and practice performing tasks before they are subjected to assessment. It might mean that we do look at opportunities for the learner to complete structured workplace activities as a component of their traineeship. We might undertake an analysis of the units of competency and identify the specific workplace tasks and compile these into a workplace learning record that is completed over the course duration as a record of the application of skills and tasks in the workplace directly relevant to the units of competency. After engaging with the workplace, you determine that this only adds another 300 hours bringing the total to 780 hours. That is okay! The amount of training is less than the minimum volume of learning indicator of 1200 hours, but you are confident in the course structure and now need to identify a valid rationale for why the course is below the required volume of learning. If the course is well designed and provides a valid learning and assessment pathway to achieve the units of competency then 780 hours is totally fine. Include a well-structured rationale for the reduce timeframe and bingo! The take-home point is, keep it real and do not include amounts of time which are not valid.

Keeping it realistic

The final point I want to make is about keeping it realistic. A few weeks ago, I did an audit with a client that was delivering a course over a semester (20 weeks) to existing workers, working full-time in a related field to the course. When we unpacked all of the various modes of training they had included as non-supervised training activities, it looked something like this:

structured online learning – 7 hours per week
self-paced learning – 10 hours per week
project research – 5 hours per week

I went through each of these modes of delivery and the client indeed had designed non-supervised training activities behind each of these quoted amounts of time. That’s great. It occurred to me that this developed learning pathway would require the learner to complete approximately 22 hours per week of non-supervised training activity. That means they are spending about 4.4 hours, five nights per week completing non-supervised training activities. Now, the learner might be a member of that rare and freakish section of our community that can do this, but when it comes to the average Australian, no way! The allocated hours are completely unrealistic. Just think about it for a moment. You spend all day at work and get home about 5:30 PM. You go straight into domestic bliss and navigate your way through dinner. If you are lucky, you hit the books at about 7:30 PM and finish about midnight… five nights a week. Totally unrealistic! If you add kids into that mix, then all assumptions are out the window.

So, the length of the course needs to be taken into account with the allocated non-supervised training activities. I see client’s strategies with ridiculous time allocations just to justify the volume of learning. In reality, the course should be delivered over a longer duration. As a general rule, and for a learner who is an existing worker, I think 5 hours per week is totally realistic. 10 hours per week is verging on the maximum and 15 hours per week is getting unrealistic. Anything over 15 hours per week and you are living in fairyland!

Conclusion

I totally realise that there are many factors which are inhibiting RTO’s from delivering an amount of training which is consistent with the requirements of the training package. Not the least of these is the limitation of the amount of funding that can be accessed for funded programs and the increasing cost of delivery. There are also significant competitive forces at play and loud demands from industry for shorter duration programs to support their productivity. These are all part of the mix of reasons why a course is being delivered in a shorter duration. I get it. The hard reality is that the regulator does not recognise any of these issues as a valid excuse for a low amount of training. It’s like, white noise to them. As you try and explain this, the auditor will just look down their nose at you while thinking to themselves what a dirty and cheap private RTO you are!

Ok, I probably went a bit too far there, but you get my point. 🙂

The absolute trick to compliance is to offer a good course with a structured learning and assessment pathway which provides suitable opportunities for the learner to acquire all of the required knowledge and skills and be able to practice applying these prior to their assessment. That is basically the panacea of complying with the amount of training requirement. Make sure you apply the factors that help to justify your allocated training particularly where this training is non-supervised and keep it real and realistic. Finally, don’t forget to include a robust rationale for why the amount of training is lower than the volume of learning indicator.

In our next edition, we will focus on providing a justification or rationale for a reduced amount of training applicable to clause 1.2 of the RTO standards. Keep an eye out for Part Two of the Amount of Training.

Good training,

Joe Newbery

Published: 27th September 2018

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