The Draft Revised Standards for Registered Training Organisations (RTOs) strive to elevate the quality of vocational education and training (VET). However, their success hinges on the balance between clear mandates and potentially ambiguous language that could lead to inconsistent application. This article delves into the aspects of clarity and ambiguity within these standards.
Part 1: TRAINING AND ASSESSMENT
Clearly Written Provisions:
The recent draft standards for training and assessment have made strides in outlining the requirements for delivering quality education. Clause 1.1 (subclauses a, b, and d), for example, leaves little room for doubt regarding the need for engaging and well-structured training sessions. This clarity is vital as it sets the tone for the quality of education that learners can expect.
Similarly, clause 1.3 is trying to stipulate on assessment systems are commendable. By insisting that these systems be consistent with the training product, the standards ensure that the evaluation mechanisms are directly relevant to the course material, enhancing the overall learning experience.
Clause 1.4 discusses the necessity of a fair and appropriate assessment system that enables accurate judgements of learner competency. However, it fails to define the specific requirements for an appropriate system. Nonetheless, the standard emphasizes the importance of conducting assessments in a fair and unbiased manner. The definitions for the principles of assessment and rules of evidence were modified in sections 1.4 a and 1.4 b. We are uncertain about the reason behind these changes.
The directive in 1.6 is also straightforward, mandating that all facilities, resources, and equipment be fit for the intended purpose and sufficient in quantity. This practical requirement is the backbone of any effective training program, providing a solid foundation for both learners and educators.
Areas of Ambiguity:
There are, however, elements within the standards that could benefit from further clarification.
1.1 (c) raises the question of "sufficient time" according to whom? It's important to recognise that each learner is unique and may require varying amounts of time to grasp and master the subject matter at hand. With the diverse learning styles and abilities, it becomes crucial to consider and accommodate these differences in order to create an inclusive and effective learning environment.
Clause 1.1 (e) stipulates that if the training product necessitates work-integrated learning, work placements, or similar community-based learning, the vital skills and knowledge must be attainable within that specific environment. This raises the question: who will be capable of attaining these skills and knowledge? Will they truly have the abilities, skills and competencies to do so? How these will be measured?
The clause 1.2 (c) refers to "current industry practice" - according to whom? In what way is the criteria defined?
The term "engages effectively" in clause 1.2 is one such example. While engagement is a crucial part of education, the lack of a clear definition for what constitutes effective engagement leaves room for subjective interpretations.
One issue with 1.3 is (c) informing any necessary changes to assessment tools from the results of testing. When it comes to vocational education and training, what exactly does testing mean? It is not just a matter of pre-validating assessment resources, right? Could we elaborate on what should be included in the pre-validation process? 1.3 defines the concept of being "fit for purpose" in relation to the assessment system. However, it is important to acknowledge that the term "fit for purpose" may be subject to varying interpretations.
Clause 1.5 (g) (ii) stipulates that the individuals conducting validation must be impartial, without any employment or subcontracted relationship with the RTO for training and assessment purposes, and should exhibit no additional involvement or interest in the RTO's operations. However, it should be noted that a contractor or consultant, despite having no other association or vested interest in the RTO, becomes involved in the RTO's operations as soon as they conduct and submit their invoice for validation activities.
Recognition of prior learning and credit transfers should not be grouped together in clause 1.7. In one, assessments are conducted without training, in the other, only administrative processes are carried out.
Clause 1.7 (d) stipulates that decisions regarding credit transfer and recognition of prior learning must be fair, consistent, transparent, and maintain the quality of the training product. What is the point of making this statement regarding RPL? In any event, it is a form of assessment and must adhere to the rules and principles!
Part 2: LEARNER SUPPORT
Clearly Written Provisions:
In the realm of learner support, the draft standards make clear provisions in clauses 2.1 and 2.6. Learners are guaranteed access to clear and accurate information, which is crucial for informed decision-making. The emphasis on a training environment that fosters wellbeing and diversity is also a clear and positive directive.
Areas of Ambiguity:
Nevertheless, the terms "suitability" in clause 2.2 is open to interpretation. Without specific benchmarks, it's challenging to measure and ensure the appropriateness of the support to the learner's needs.
Stated in clause 2.4, it is important to ensure that learners have "reasonable access" to trainers, assessors, and other staff in order to effectively progress through the training product. However,
it is worth noting that the interpretation of what constitutes "reasonable access" can vary depending on different perspectives and contexts.
In the clause 2.9 (b) (ii), it explicitly states the importance of identifying reasonable timeframes for actioning appeals. However, the question arises: what determines these so-called "reasonable timeframes"? It is often left for the Registered Training Organization (RTO) to self-identify what it considers as reasonable timeframes, taking into account various factors and considerations.
Part 3: VET WORKFORCE
Clearly Written Provisions:
Clauses 3.2 and 3.3 set clear expectations for the credentials and current skills required of individuals involved in training and assessment. These are critical for maintaining high standards in education delivery.
Areas of Ambiguity:
Clause 3.1. (e) of the draft, there seems to be a numbering error. It should be 3.1. (b) instead. This section discusses the importance of fostering continuing professional development and providing support for staff to understand and meet the Standards. But what does "fostering" exactly mean in this context?
Clause 3.1. (c) (incorrectly referred as 3.1 (f)) states that roles with 'integrity' are expected to uphold certain values and principles when it comes to the delivery of services. However, the question arises - what exactly are the measurements of integrity? And furthermore, who will define these measurements? It is crucial to establish a clear and comprehensive understanding of integrity and its benchmarks to ensure transparency and accountability in service delivery.
Clause 3.2 (b) should include clear and comprehensive guidelines that outline the expectations and requirements for individuals working under direction. It is important to differentiate between working under direction and working under supervision arrangements. While working under direction implies following specific instructions and guidance, working under supervision arrangements typically involves a broader oversight and monitoring of tasks and progress. By providing explicit guidelines, it ensures clarity and helps to establish a consistent understanding within the context of the clause.
Part 4: GOVERNANCE
Clearly Written Provisions:
The governance clauses, specifically 4.1 to 4.3 and 4.5, provide unambiguous directives concerning accountability, leadership, role definitions, and financial viability. These are essential for the transparent and responsible operation of any RTO.
Areas of Ambiguity:
Yet, clause 4.4's use of "fit and proper persons" could be interpreted differently across various legal and operational contexts, necessitating further explanation. Due to the changes made to the fit and proper person requirements, it is necessary to clarify who fits that definition. Similarly, 4.6's mention of systematic monitoring and evaluation lacks specificity regarding methods and frequency, which is vital for effective risk management and continuous improvement.
There are numerous terms mentioned in the draft that are open to different interpretations, which can potentially create substantial issues between RTO personnel and the regulatory bodies that govern the standards. of clarity can lead to misunderstandings, conflicts, and delays in the implementation of the regulations, ultimately hindering progress and effective communication within the industry. It is crucial, therefore, to address these ambiguities and foster a shared understanding to facilitate seamless collaboration and adherence to the established standards.
General Observations:
The recurrent use of terms such as "quality assured," "fit-for-purpose," "effective," "reasonable," and "current" throughout the document exemplifies the need for more precise definitions to minimise subjective interpretations and promote consistency.
Incorporating examples or more explicit descriptions of the expectations and methodologies to meet these standards could greatly enhance their utility and applicability.
Conclusion
While the draft standards provide a solid framework for quality training, assessment, learner support, VET workforce qualifications, and governance, refining ambiguous terms and providing detailed guidance is essential. Such enhancements would help ensure that these standards are applied consistently and effectively, thereby elevating the quality of vocational education and training across all Registered Training Organisations.
