In a recent case pending for June 2016 approval the PM and the Minister for Education assistance was sought about the deficiencies in the case for endorsement presented by CPSISC for CPCCWHS1001 Prepare to work safely in the construction industry.
The stats are simple.
- 95% of white cards are delivered in an E-Learning / Online format with the average course time being between 2.5 to 4 hours to complete.
- 90 % of the age grouping is between 15 and 25 years that actually complete the program
Why would we force students who learn everything via a high tech environment suddenly back to a book / in class format that doesn’t recognise learning styles and the ability of the learner to work faster?
The costs to industry will be more than 1 Billion Dollars if they make this change crippling all levels of industry form small to large with much higher costs.
The project was supposed to be guided by a Project Reference Group to oversee the project and facilitate industry input. These key Group Members listed below and the CPSISC Consultant drove the words “ Real Time” to be inserted into to the final document “Not Approved by the Consultation Group” from which also the CPSISC Consultant excluded a range of key people who questioned and opposed them in several areas. Particularly around consistency of minutes and objections to what was being proposed.
A number of serious allegations where raised by the participant from the group around probity and conflicts of interest that CPSISC ignored and dismissed who then excluded those members from any further inputs into the group by removing them from all mail outs and information about the process moving forward.
The big losers in this case are:
- the students looking for good quality and consistency in Delivery and Assessment and convenience of getting the program access anytime and anywhere
- the entire E-Learning, Training and Development Industry who have worked so hard to get Australia to be seen as a center of excellence with good systems, processes and technology particularly around Fraud Prevention and consistency of content and delivery and assessments where the regulators don’t enforce the same rules upon face to face providers.
- the employers who now have to lose staff to inadequate training and delivery by face to face all be cause it was driven by people who are frightened of what they don’t understand.
The big winners are the groups who actually sat on the approving committee that benefit substantially from the exclusion of Online by inserting the words “Real Time” into the case for endorsement without proper consultation and feedback from construction and training industry.
If we look under the heading – Section 3 “Impact of Changes”, there is no mention of the cost and time consequences of the proposal. Specifically, the change from a model supplier under the current Unit of Competency “CPCCOHS1001A Work safely in the construction industry” to the current proposal is not mentioned or costed. Such an assessment would have validated the cost benefit of changing the compliance burden for RTOs and the cost (time and money) to students and industry against the benefits to the community given the intimate connection between the unit of Competency and the issue of a whitecard under the National WHS Laws.
Much has been made by ASQA of its review which has fed into the CPSISC proposal. At no stage has the ASQA and CPSISC proposal considered:
- What should be the true baseline, had ASQA set (and enforced) an appropriate standard? Rather the report works from the sub-standard permitted by ASQA and presents that as the base line for the industry. The baseline was and remains, what should have been delivered under the existing unit of Competency. From this base line there is limited if any justification for the changes recommended by CPSISC who clearly disregarded and altered much of the feedback given to them by key stakeholders and industry.
- What changes ASQA has instituted since it discovered its shortcoming, to ensure changes to law and enforcement strategies, to improve RTO performance? Now that ASQA has improved its oversight of RTOs, the substandard RTOs have started to leave the industry. It is unclear why the current RTOs are being forced to adopt regressive solutions, rather than enhance the existing online facial recognition solutions. We are forcing the training and construction industry backwards thirty years and making Australia and laughing stock of the 1st world countries.
- What is current best practice consistent with the current law, standards and enforcement strategies? Given the shift in technology, face to face has become less reliable than the current effective online solutions. This is acknowledged by the extensive work that CPSISC themselves undertook to take the best online solutions and them adopt them as their own solutions to create their own saleable products to both RTO’s, Trainers and the Industry. Wasn’t there just a slight conflict of interest in this alone?
- What are the consequences for the administration of whitecard by the State agencies to prevent duplication and overlap? Current State agencies have their own conditions and standards for student identity. These standards plus the USI have increased the oversight and integrity of student identity within the government framework and have complemented the changes RTOs have made in their own sphere of control to ensure only the student undertaking the course is assessed and can receive a whitecard.
- The need to communicate in English, which means that as an RTO that undertakes verbal assessments we continue to mark students as not meeting requirements. This approach is inconsistent with face to face training where students with poor command of the English language are often assessed as competent. A clear example of the failures of face to face training was recently reported in the Security Industry (“Sydney firm selling Queensland test and answers for security guard licences” http://www.abc.net.au/news/2016-03-09/test-and-answers-for-security-guard-licences-sold/7232240). The proposed Unit of Competency does not address this issue, whether in the Unit of Competency, the case for endorsement or in the ASQA review.
The report references work conducted over 4 years ago and reported by ASQA in December 2013 and makes no assessment of changes in industry, standards and technology since that date.
The original report by ASQA did not discuss deficiencies in face to face training and now seeks to set Australian industry back thirty years in terms of delivery, assessments and technology as a country that is already struggling to compete with outside economic forces and competitors adding a whole new level of costs and inefficiencies that just can’t be justified.
The case for endorsement makes no mention of the extra costs to be borne by the students, the community or the RTOs to meet ASQA’s poor enforcement or for the cost of what appears to be a marginal change between current complying practices. Using the true 2016 baseline of current RTOs offering this course, the main problem now rests with face to face training. Accordingly the review and the case for endorsement remains fatally flawed.
The true baseline of RTOs providing E-Learning via online training and assessment consists of:
- student ID verified through facial recognition
- validation of training and assessment through course invigilation through use of webcams
- validation of training and assessment through course through verbal assessment by qualified trainers, including through skype
The extra costs to students and the community by the proposed changes to the course have not been costed or validated. For example most courses content and assessments can be delivered online in around half the time.
Accordingly all E-Learning / Online learners will be left to waste half their time or under the proposal will have to complete substantially more assessments than face to face students to fill in the spare time created by online delivery making them over-assess thus breaching Australian Quality Training requirements.
Working on the base line and the six hours means that every student will now spend twice as much time learning the same material and undertake the same assessment. The new unit of Competency contains no substantive change in content and assessment. The cost to the community and students is not included in the case for endorsement.
The recommendation of 6 hours split between training and assessment is nonsensical unless the purpose is only to exclude online training and learners that can learn faster. It disadvantages all students. Self-paced learners will complete training faster given the range of students from tertiary qualified to school leavers. Accordingly online learners and tertiary qualified students will not be eligible for the qualification, because they will finish under 6 hours.
The alternative is the time gap for these students will be taken up by more assessment. For face to face, we will now be back to the NSW WorkCover requirement of six hours, supported by statutory declaration that it took six hours. We can provide a copy of this document if required.
Given this enforcement model, it would not be surprising that ASQA will now have to live with accepting a (false) statutory declaration attesting to six hours of training and assessment but will also have to reject a (true and verified) statutory declaration as to identity and observation. How can this be sustainable and suitable for the Construction and Training Industry as well as the regulators in each state who control the issuance of the White Cards as part of a legal requirement and right to work on site.
These statements are based on our experience with the old NSW WorkCover where it was proven that RTOs encouraged students to falsely complete the NSW WorkCover Statutory Declaration stating they had spent six hour of attendance when clearly they hadn’t. Despite the absurdity of this, the NSW WorkCover Statutory Declaration actually set the times and ensured that this six hours was spent without a break.
Accordingly neither of the following make sense:
- Six hours duration for training and assessment. Especially as this is without a cost benefit assessment from the true baseline for the Unit of Competency, as it affects the operation of the WHS Laws in Australia.
- Reverting to face to face training and assessment given the true baseline for the Unit of competency and the change in the VET Sector and the technology since the review. This included better standards, more professional enforcement of those standards and technology change. This technology enables real time facial recognition technology, matching official documentation to the person undertaking the training and continues to run real time, so as to assure the RTO that the person undertaking the assessment is the person matching official documentation. Face to Face does none of this and fails to maintain consistency of delivery, assessments and identification verification.
This one single change will have a massive financial impact on many large to small companies involved in construction and training nationally and creates a very unfair advantage for a number of key parties who also were the key winners and decision makers in these recommended changes.
AELA is urging the government to suspended immediately this decision pending a proper review and presentation of case that covers both modes and the pros and cons of each along with a validated cost/benefit model.