SUBMISSION

Response to Discussion Paper: Industry Engagement in Training Package Development - Towards a Contestable Model

24 December 2O14

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About Us

The Health Services Union (HSU) is a growing member based union fighting for dignity and respect for health and community services workers. HSU members are at the forefront of some great nation building changes in the National Disability Insurance Scheme, Public Health and Aged Care reform.

We are a driving force to make Australia a better place.

HSU members work in aged care, disability services, community health, mental health, private practices and hospitals. Members are health professionals, paramedics, scientists, aged care workers, nurses, technicians, personal care and support workers, clerical and administrative staff, disability support workers, managers, doctors, medical librarians and support staff.

We are committed to advancing and protecting the wages, conditions, rights and entitlements of members through campaigning and workplace activism. HSU also provides a range of services and support to assist members with many aspects of working and family life.

HSU National is the trading name for the Health Services Union, a trade union registered under the Fair Work (Registered Organisations) Act 2OO9.

Contact: Chris Brown Acting National Secretary, HSU National M. O418 564 199 E. chrisb@hsu.net.au Mark Farthing National Project Officer, HSU National M. O447 744 5O9 E. markf@hsu.net.au

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Introduction HSU National welcomes the opportunity to provide a response the discussion paper Industry Engagement in Training Package Development – Towards a Contestable Model. At the outset we wish to reaffirm our commitment to the current bipartite, independent and industry-led system of training package development through the twelve Industry Skills Councils (ISCs). We also wish to flag our concerns that in seeking to dismantle the ISC system, the Government is addressing a problem that does not exist. Indeed, while the Discussion Paper references concerns about the “quality of VET training” as one of the key reasons for reform, this catch-all criticism conflates industry concerns with the quality of training delivery with the quality of training development. While it is true that there are legion problems with the former,1 the same cannot be said of the latter. According to the National Centre for Vocational Education Research (NCVER), of the minority of employers who were dissatisfied with the VET system (16.9 per cent in 2013) nearly 60 per cent reported poor quality or low standard of training delivery as the reason for their dissatisfaction.2 Conversely, prior to the introduction of training packages and their development through the network of ISCs, most employers were concerned about course content.3 The same turnaround has been seen for students. In 1997, as training packages were about to launch, nearly a third of TAFE graduates were dissatisfied with the quality of their training, by 2011 it was only 1 in 10 students.4 To be clear, we are not saying that the current training package development process is perfect, however we wish to make the point that policy change of the scale suggested in the Discussion Paper must be carefully assessed and have a sound rationale—neither of which the Government has demonstrated.

Rather than addressing each of the Discussion Paper’s focus questions this Submission states our position on the ISC model and outlines what features need to be kept if changes to this model are inevitable; raises our concerns with the policy direction proposed in the Discussion Paper; and provides our view on the three proposals. Please note that this Submission should be read in conjunction with the Australian Council of Trade Unions’ Submission, which the HSU endorses.

The ISC Model & Essential Features of Training Package Developers The HSU is a strong supporter of the principles underpinning the ISC model. ISCs provide a consistent point of contact for industry and this stability is essential for the effective continuous improvement of training products, as it ensures continuity in consultation mechanisms and points of contact across multiple development cycles. Additionally, as single institutions responsible for industry research, consultation and technical writing, ISCs provide efficiencies through a holistic, integrated approach to training package development. It is a model that is well regarded internationally, with the OECD remarking that: “Australia has a very well developed VET system which enjoys a high degree of confidence. In particular, the engagement of employers is strong; the national qualification system is well established and understood;

1 See, for example: www.abc.net.au/news/2014-10-19/training-college-watchdog-urged-to-stamp-out-spruikers/5823072; furthermore, the problem is so widespread to have necessitated the establishment of a Senate Inquiry into the operation, regulation and funding of private vocational education and training providers in Australia. 2 NCVER (2013) Employers’ use and views of the VET system 2013, p. 14. 3 NCVER (1997) Employer Satisfaction with Vocational Education and Training – at a glance, p. 6. 4 NCVER (2011) Student Outcomes Survey 2011, p. 9.

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the VET system is flexible and allows for a fair amount of local autonomy and innovation to adapt learning to local circumstances.”5 This is due in large part to the leadership of the twelve ISCs.

We also contend that ISCs are a logical policy response to the challenge of collaboration in sectors with multiple industry peak bodies, often with contested or overlapping coverage. By virtue of their independence and bipartite governance arrangements, ISCs are able to mediate and balance competing stakeholder interests in the process of developing training packages. While it could be seen that our strong support for bipartite governance arrangements is driven by self-interest, it is well recognised internationally that “the engagement of employers and unions is necessary to ensure that the organisation and the content of vocational programmes meets the needs of employers, students and indeed the wider economy.”6

It is these features: bipartite governance structures, independence and a consistent and integrated approach to training package development—that have made ISCs so successful. If the Government is determined to replace the functioning ISC system, these features must be carried over to the new organisation(s) responsible for training package development.

Concerns with Government Policy Direction We are troubled by the fact that the Government appears to have already decided to dispense with ISCs once their current round of funding expires on 1 July 2015. Given that this decision has been made prior to any meaningful consultation, it represents an incredibly rushed change to a policy framework that has served students, industry and Government’s (of both persuasions) very well over nearly two decades. Again, we emphasise the point that we made in the introduction to this Submission: that while the current system should be interrogated to ensure it is delivering effective outcomes, the case for abandoning the ISC model has not been made. Rather, like so many of the Government’s policy “reforms” this decision appears to have been made on the basis of ideology rather than evidence.

We also have serious concerns with the suggestion that qualification development under any new model would be prioritised for those sectors or organisations that have the capacity to make financial contributions. The need and value of skills to employees, employers or, indeed, the Australian economy should not be determined by the financial capacity of a particular sector or organisation. While we agree with the sentiment expressed in the Discussion Paper that financial contribution sends “a strong signal of industry commitment” this ignores the realities faced by large sectors the Australian economy. Indeed, were this principle to be enacted it would favour the participation of well-resourced, high-margin sectors and large corporations, whereas sectors dominated by not-for-profit providers and with high numbers of volunteers, such as community services, would be disadvantaged despite the huge social and economic benefits they confer on the Australian economy. In-kind contributions are a much more reasonable and equitable way to ensure industry “buy-in” and commitment to skills development, which already occurs in the current training package development process through the ISCs—a fact glossed over in the Discussion Paper.

5 OECD (2010) Learning for Jobs: Summary and Policy Messages, p. 167. 6 OECD (2010) Learning for Jobs: Summary and Policy Messages, p. 19.

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Finally, given the degree of power and responsibility it will hold in VET system moving forward, we have serious concerns around the makeup of the Australian Industry Skills Committee (AISC) and the shroud of secrecy around this new body. Indeed, the scant information we do have (that it will comprise eleven members) does not bode well given that comparable international bodies such as the UK Commission for Employment and Skills has twenty-six Commissioners and includes union representatives. To our knowledge, not a single union official has been approached to sit on the AISC and this lack of representation, coupled with its limited size, will mean any claim that the AISC is the authoritative voice of industry is farcical.

Views on Proposed Options Approach 1

This approach should be outright rejected. As a largely government-run, rather than industry-led, process this approach will likely alienate industry from participation. Furthermore, the requirement to make a business case to argue for the development of units of competency and qualifications will entrench a system of training product development that is reactive, rather than proactive. In short, skill needs will only be addressed once they are identified and causing issues in the economy. Given the long lead times for development and implementation this approach will render Australia’s training system unresponsive. This approach also fragments the process of qualification development across multiple organisations and individuals, which will likely result in inefficiencies. Finally, this approach vests far too much influence and power in the AISC. It is absurd to believe that eleven individuals, no matter how qualified, will be able to weigh-up and determine the skills priorities for an economy as large and dynamic as Australia’s.

Approach 2

This approach should be outright rejected. It is likely to experience significant difficulties in managing the competing interests of involved parties and will entrench a disproportionate level of influence of those provided a position on the Industry Sector Committees, particularly, those given the responsibility of chairing a committee. Moreover, without independent oversight of the gathering of industry intelligence, which involves collating and assessing diverging views and competing interests, the outcome will be more reflective of the views of those with greater influence in the process. This will lead to the decreased relevance of, and loss of confidence in, national qualifications, particularly in highly fragmented sectors. Similar to Approach One, this approach is likely to increase development costs and inefficiencies through the compartmentalisation of qualification development.

Approach 3

Out of the three approaches described, this is the only one that can achieve the eight attributes for training package development outlined in the Discussion Paper. However, it is our strong view that this approach, particularly when taken in conjunction with the decline of state-based ITABs, will further alienate industry from the VET system. It is worth remembering that when the eleven ISCs were introduced under the Howard Government they replaced twenty-nine bodies, with the new ISCs deliberately grouped into industry categories that more closely aligned with Australia’s modern economy. However, in its March 2011 report, the Senate Inquiry into ISCs noted that some industry groups (both employer and employee) had found this reduction was too severe, denying industry bodies and employers the ability to effectively

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influence training package development.7 Ultimately, it is the HSU’s strong view that if the Government’s is sincere in its claim to want “the best quality training standards” then it should abandon its decision to expedite the introduction of a new, contestable training package development model until:

• A proper round of consultation takes place, including the reissue of a new Discussion Paper that actually elucidates a sound rationale for moving away from the ISC model and provides the pros and cons of maintaining the current system.

• The composition of the AISC is made public, membership broadened and its role and powers are clearly explained to all stakeholders in the VET system, including unions.

• All ISCs have been given the opportunity to meet the original deadline of 31 December 2015 to transition training packages to the 2012 Standards for Training Packages

• The outcome of the Review of Training Packages and Accredited Courses Discussion Paper is actually known. After all, if the architecture and product design of training products is to change it will have an enormous bearing on the capabilities required of training product developers.

7 The Senate Education, Employment and Workplace Relations References Committee (2011), Industry Skills Councils: Final Report, pp. 52-54.