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My Submission to PwC

My Feedback to PwC on TAE40116 Package

This document is in response to PwC’s request for feedback on the TAE Training Package.

I am an instructional designer with several RTOs who use my resources for TAE40116 and TAE50116. I am also a trainer/assessor for International Teacher Training Academy (ITTA), supporting over 50 students undertaking TAE qualifications. This gives me valuable information on the practicalities of delivery and assessment of TAE40116.

Firstly, we should look at the intent of the qualification, as stated in its description, namely:
This qualification reflects the roles of individuals delivering training and assessment services in the vocational education and training (VET) sector.
This qualification (or the skill sets derived from units of competency within it) is also suitable preparation for those engaged in the delivery of training and assessment of competence in a workplace context, as a component of a structured VET program.

Therefore, this is an entry level qualification, designed for those who have vocational qualifications and expertise and wish to become trainer/assessors either in an RTO or an enterprise.

We must therefore bear in mind, when considering the evidence requirements in the units of competency, that the candidate for assessment will not currently be working in an RTO. This means that the evidence requirements must be designed to be practical and achievable – which currently is not the case.

Trainer/assessors in the VET sector (an RTO)

Tasks they perform
An entry level trainer/assessor in an RTO performs the following tasks:
• Planning to deliver training and developing session plans.
• Delivering training:
This may be group training, individual coaching or (more frequently) training of remote learners through an on-line portal with electronic interaction and support.
• Reviewing learning resources provided to them and, in some cases, supplementing these. Learning resources are normally provided by the RTO. They are either developed in-house by experienced personnel or purchased                             (as with my resources).
• Conducting formative assessment to confirm that the learner is ready to move to the next phase in their learning pathway. Formative assessment resources are normally provided by the RTO and align with the learning resources.
• Conducting assessment through a learning and assessment pathway, providing feedback and support to candidates and complying with the Principles of Assessment in the process of conducting the assessment.
• Making the assessment judgement and ensuring that evidence is recorded and reported which meets the Rules of Evidence.
• Participating in validation of assessment tools and assessment judgements.
• Collaborating in moderation of assessment judgements, knowing when to seek the opinion of a lead assessor where they may have a borderline case.
• Participating, with the support of an experienced lead assessor, in conducting RPL evidence gathering and assessment.

Tasks they do not perform
An entry-level trainer/assessor does not perform the following tasks:
• Designing learning programs, delivery plans and assessment plans.
These are provided by the RTO. They must understand what these are and follow them – not create them.
• Designing assessment instruments and assessment tools.
These are provided by the RTO. They must understand what constitutes a valid assessment tool and they must be able to evaluate whether a tool which is provided to them meets the requirements of the unit of
competency or cluster.
If a trainer/assessor has the knowledge and skills to validate an assessment tool (TAEASS403) this is sufficient.

Enterprise trainers and assessors
TAE40116 is inappropriate for this cohort. There should be a separate qualification (not a skill set of units from TAE40116) which is designed specifically for this type of trainer/assessor, using industry consultation to identify exactly what skills and knowledge they require.

Background to issues with TAE40116
This qualification was intended to overcome issues related to “tick and flick” qualifications being issued by some RTOs for TAE40110. It does not follow that there was anything seriously wrong with the qualification TAE40110. The issue was, in fact, the failure to “police” the system through audit processes.

The introduction of TAE40116 was used as an opportunity to require all RTOs who needed scope to complete a new scope application, rather than the usual automatic approval if they held scope for the superseded qualification. Although the application process was extremely detailed, it is now clear that the problem has not been resolved. There are RTOs who have been granted scope for TAE40116 who are not providing quality training and assessment. Complaints to ASQA have been made. However, these RTOs continue to have scope.

Several of my client RTOs have received complaints from trainees about training received elsewhere. I have personally received calls from trainees who located me via my own website about one RTO which is registered in Australia but actually operates out of the Philippines. These people are always encouraged to make a formal complaint to ASQA.

TAE40116 as a “licence to practice”
The RTO Standards require all trainer/assessors in an RTO to hold this qualification (or, currently, TAE40110). It is possible to employ an unqualified trainer/assessor, provided they work under supervision. However, most RTOs are not prepared to do so for fear of non-compliance at audit. There is no clear definition of the term “under supervision” and is therefore open to interpretation at audit. This is too much of a risk.

For this reason, the TAE Certificate IV is, in effect, a licence to practice as a trainer/assessor in an RTO. For other licenced outcome qualifications, there are usually nationally adopted assessment tools that must be used. This does not apply to TAE40116.

Therefore, it would be valuable to develop a set of national assessment tools that must be used for the qualification. I have offered to assist with this development and so have a number of my colleagues who are highly experienced in this area.

Reviewing the current units of competency

TAEDES402 Use training packages and accredited courses to meet client needs
This unit is equivalent to TAEDES402A and the evidence requirements are practical. The unit should be the first in the learning pathway, as it introduces the learner to the VET system, training packages, qualifications, units of competency and the AQF.

This unit is not relevant for an enterprise trainer/assessor, as they are not delivering nationally recognised qualifications.

Recommendation: Retain this unit but clarify the wording of the PE so that it is clear exactly what “analysing” means in this context. Change the code to TAEDES401.

TAEDES401 – Design and develop learning programs
Trainer/assessors do not design and develop learning programs. In fact, RTOs do not use learning programs at all. They develop a Training and Assessment Strategy and this needs to be done at a higher level within the RTO.

There is no need for this unit. Some of the knowledge and performance requirements could be incorporated into TAEDES402.

Recommendation: Delete this unit

TAEASS401 Plan assessment activities and processes
Trainer/assessors do not design assessment plans. In fact, RTOs do not use assessment plans. They are incorporated into the Training and Assessment Strategy. However, it is useful to know how to plan assessment to ensure there is a range of activities which will meet all of the unit requirements.

Trainer/assessors at the entry level do not design assessment instruments. Nevertheless, they should know how to do so, as they will need this knowledge as they become more experienced.

Therefore, this unit should be retained.

Performance evidence:
   • planning and organising the assessment process on a minimum of five separate occasions

Five separate occasions is overkill. Note also that this PE is not clearly stated. The candidate can document assessment plans. The candidate can develop and document assessment instruments. The candidate cannot organise an assessment process because they do not work in an RTO.

Recommendation: re-word this PE.

• planning and organising two Recognition of Prior Learning (RPL) assessments (which may be two of the five assessment processes above.)
We don’t create assessment plans for RPL. It takes as long as it takes and happens in different ways. This is the reason that RPL is so much more difficult than a learning and assessment pathway because there is less structure.
The candidate therefore cannot plan and organise an RPL assessment. They do not work in an RTO.
The candidate can develop and document an assessment instrument for RPL – but not a plan.

Recommendation: re-word this PE.

TAEASS402 Assess competence
This is the unit which is most unrealistic in its assessment requirements:

Performance evidence
The candidate must show evidence of the ability to complete tasks outlined in the elements and performance criteria of this unit, including:
   • assessment of at least five candidates within the vocational education and training (VET) context against at least one endorsed or accredited unit of competency according to the organisation’s assessment processes and practices.

This has been interpreted by ASQA as “real VET candidates”. The only “real VET candidates” that can be assessed are those who are undertaking a qualification with an RTO. To repeat the point yet again the candidate is not working in an RTO.

They cannot therefore conduct assessment on 5 “real VET candidates”.

   • using recognition of prior learning (RPL) processes in the assessment of at least one candidate (which may be one of the five candidates above)
    • making reasonable adjustments in the assessment of at least one candidate.
The assessments must be undertaken under the supervision of a qualified assessor and cover an entire unit of competency for each candidate, including:
   • the application of different assessment methods and instruments involving a range of activities and events
   • using two-way communication and feedback with the candidate
   • exercising judgement in making the assessment decision
   • recording and reporting assessment outcomes in accordance with the assessment system and organisational, legal and ethical requirements
   • reviewing the assessment process.

To make the point yet again – how can a candidate conduct the assessment under the supervision of a qualified assessor if they are not working in an RTO? This can be achieved in a workshop group training environment where the trainer/assessor acts in the role of the qualified assessor but not otherwise. Most TAE candidates are undertaking the course remotely. Very few are in a position to attend workshops.

In relation to using two-way communication and feedback with the candidate, this has been interpreted by ASQA as oral communication. This simply doesn’t reflect the reality. Assessments are submitted. The candidate is not present when the assessor conducts the assessment. The assessor then responds in writing. The problem here is with the interpretation. As assessors we do have two-way communication with our candidates but it is usually by email or handing back the marked assessment, with the odd telephone conversation if necessary.

ASQA is demanding direct observation of the 5 assessments demonstrating “interact with others” and “oral communication”. Unless the assessment is face to face (which is the exception) this can only be achieved with a video. We are already encountering situations where a video is not permitted by the employer or a video would contravene the Privacy Principles.

• Delete the requirement for “real VET learners” and allow for simulated assessments, which allow us to truly test the candidate’s ability to conduct assessment because we can design the tasks to trap common errors made during
assessment. It also allows us to properly benchmark the assessment tasks.
• Change the requirement to writing detailed, supportive and accurate feedback to the candidate (instead of two-way communication) or make it clear in another way that two-way communication is not necessarily face to face oral
• Delete “under the supervision of a qualified assessor” as this can only occur in an RTO. The assessment which the candidate submits is already assessed by a qualified assessor.

TAEASS403 Participate in assessment validation
This unit was a definite improvement, in that the candidate is now required to map the tools – which is essential to validation.

I think it’s unfortunate that the unit only relates to validation of assessment tools. Trainer/assessors must also validate assessment judgements. This is a requirement of the Standards.

TAEASS502 Design and develop assessment tools
This unit should never have been made a core in the Certificate IV. It is at Diploma level and needs to be. In the previous iterations of the Cert IV, this unit was an elective – which is appropriate.

Note also – Many people are slipping through the net. They already hold TAEASS502B and are therefore entitled to Credit Transfer. However, their original qualification was a tick and flick and they have no more idea of how to develop an assessment tool than my pet cat.

• Return to making this unit an elective.
• Change the unit requirements so that it is NOT equivalent to TAEASS502 – in the same way TAEASS401 and 403 required further learning and assessment for upgrade. That way we will be able to identify those who already hold
the unit but don’t have the skills and knowledge and we can build them into the upgrade.

TAEDEL401 Plan, organise and deliver group-based learning
There is an argument for making this unit an elective. Group-based learning is declining in favour of remote learning. My personal preference is to retain this unit as a core, as it provides opportunities to develop overall training delivery skills, whether the person will end up training groups or not.

Performance evidence
facilitating group-based learning by preparing and delivering at least three training sessions, including:
   • at least two consecutive sessions of at least 40 minutes duration, that follow one of the learning program designs, to a learner group of at least eight individuals
   • at least one session delivered to a learner group of at least eight individuals, with evidence of how the characteristics and needs of this group were addressed
   • identifying and responding to individual needs
   • accessing and using documented resources, and any support personnel required to guide inclusive practices.

This is completely impractical. It is not always (or even usually) possible to get a group of 8 individuals together for training.

Assuming TAE40116 is being delivered face to face in a workshop and the deliveries are observed during the workshop, then a minimum of 9 is required. This has effectively precluded RTOs from offering workshops for less than 9 participants.

If, as is usually the case, the candidate is self-paced working remotely – but not in an RTO – it is unconscionable to require them to gather together a group of 8 individuals for 2 group training sessions, one following from the other.

Note the last two PE. These are vague. Is the third session supposed to include some sort of reasonable adjustment for a disability or LLN need? What “documented resources” are supposed to be used and for what purpose? It says “any support personnel required”. What if no support personnel are required in the circumstances? Does that mean we can ignore this?

It would be unusual to have a real situation where the candidate can deliver training to a group of 8 where there is one or more participant with a special need. Therefore this is an unrealistic requirement. It would be far better to enhance the knowledge evidence in this area, so that the candidate demonstrates that they know what they should do if the situation occurs.

In reality, this third session with “special needs” is usually a role play if done in a workshop. For instance, one person may pretend to be blind and put on dark glasses. Everyone has a laugh but it doesn’t demonstrate any kind of competency in performance.

If the candidate is delivering this group training remotely to a person with special needs (assuming this might be possible) we run foul of privacy legislation

What do we really need to see, remembering that many trainer/assessors won’t deliver group training face to face and that group training on-line will become more and more frequent?

• Remove the requirement for 8 learners.
• Make it clear in the PE that group delivery may be face to face or via electronic means such as a webinar.
• Enhance the KE to cover addressing special needs and inclusivity in detail, as it relates to group delivery
• Reduce to 2 deliveries following on from one another, 30 minutes in duration.

TAEDEL402 Plan, organise and facilitate learning in the workplace
There is even more of an argument to make this unit an elective. This is an excellent unit for an enterprise trainer but hardly relevant for an RTO trainer/assessor.

This unit focuses on apprenticeships and traineeships from the point of view of supporting learning in the workplace. While a number of RTO trainer/assessors support learning for apprentices and trainees and need to understand how this works, this is only a proportion of the total.

Not every RTO trainer/assessor will be in a position to use the skills and knowledge comprised in this unit.

• Make this an elective in TAE40116
• Make it a core in the new qualification Cert IV in Enterprise Training

TAELLN411 Address adult language, literacy and numeracy skills
The VET sector is coming to terms with the fact that they must also address LLN at the same time as providing vocational training. Why this is necessary is another issue, and begs further investigation of the education system as a whole.

My main concern with this unit is the requirement in several places to seek the advice of a “qualified LLN practitioner”. Unfortunately there is no such thing. This presents TAE trainees with a real problem. I know of one RTO who advises their trainees to “Google it”. I have received several calls from such trainees because their own RTO was singularly unhelpful. (Incidentally, this is the same RTO which is based in the Philippines.)

We could overcome this problem quite easily. We now have a skill set comprising TAELLN411, 412 and 413. I have already recommended to PwC that this skill set could state in its description that attainment of the full skill set constitutes qualification as an LLN practitioner.

Sandy Welton
tel: 0407 131 075

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