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Addressing issues relating to unduly short courses – discussion paper (December 2017)

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Thank you for the opportunity to review and submit feedback regarding the discussion paper referenced above related to the Australian Skills Quality Authority’s (ASQA’s) Strategic Review.

As a Skills Service Organisation (SSO), our role involves supporting our 17 Industry Reference Committees (IRCs) that represent approximately 90 diverse service-related industry sectors, to undertake Vocational Education and Training (VET) training product review and development. This paper was shared with members of the IRCs we support. On behalf of the IRCs, SkillsIQ has collated the feedback and so this paper provides a collection of views from various IRC members across the different issues and questions raised in the paper.

Members from the following IRCs have provided feedback:

Ambulance and Paramedics Children's Education and Care Client Services Community Sector and Development Complementary Health Direct Client Care and Support First Aid Personal Services - Floristry Tourism, Travel and Hospitality

Please note the feedback provided reflects the views of IRC members only, and not SkillsIQ. SkillsIQ has made a separate submission as an independent organisation within the VET sector.

Addressing issues relating to unduly short courses – discussion paper Feedback from Members of IRCs supported by SkillsIQ

General Comments on Discussion Paper Themes:Dieticians Association of Australia, National (Direct Client Care and Support IRC member)

We support the proposal to define the minimum amount of training required to address the risks arising from unduly short courses, and concur that these risks are particularly relevant in qualifications that fall under the remit of the Direct Client Care and Support Industry IRC.

The Dietitians Association of Australia want to see VET sector training support quality care in aged care in community and residential care, mental health, disability, child care, education and health care.

Australian Association of Floral Designers, National (Personal Services IRC member)

Firstly, I would like to address competency-based training as it has great relevance to the issue of unduly short courses. Unduly short courses are in the majority lock step training by set intakes. By contrast, competency-based training has been utilised by leading industry training R.T.O.’s since 1997 and it is highly successful relating to apprenticeship training as employers do not wait for an intake. There are no intakes under this mode of delivery as all students commence when industry drives the need for commencement. Students can pro-gress at their rate of skill level and this is quantified by industry. The industry supports an in-dustry trainer (R.T.O.) who is meeting their training needs or alternatively turns away from an R.T.O. if the R.T.O. is not meeting industry needs. The employer can withdraw and transfer their apprentice at any time. Therefore, an industry training R.T.O. must be respected by in-dustry for their competence to train the industry. This creates a clear division between R.T.O.’s. Damage is incurred within an industry if an employer finds the training is insufficient and not meeting their needs. Apprenticeship support will fall if this occurs.

Victoria’s apprenticeship numbers in floristry outstrip the other states as confidence in formal training is constant, however make no mistake the industry knows who to support for training and clearly who not to support.

Unduly short courses cause damage to these quality providers as well as damage to learners who undertake such short duration courses. Industry believes these unduly short courses train “backyarders” or non-genuine students for industry entry and they will not support em-ployment of these students. The standard of training, not meeting industry needs, damages the respect industry has for training. The unfortunate fact in this situation is a how a genuine learner is disadvantaged if they genuinely pursue a floristry career. A quality R.T.O. can be faced with a list of credit transfers and realise the skill level required for industry is not being met. The R.T.O. must recognise the credit transfer yet it damages their reputation if this stu-dent is in industry as the lack of skill does not meet industry standards. The R.T.O. is forced to backtrack this student, who is disillusioned having entered a course with credit transfers of a course with National recognition that industry says is not meeting their needs. I reiterate this damages respect for training and places a quality R.T.O. in a difficult position with both the learner and the industry. If the R.T.O. backtracks it is at their cost, protects their training repu-tation and it also puts them out of compliance!

Funding is available to students who undertake unduly short courses where often they have not approached industry to seek their recommendations. If they were paying for the course it may encourage them to consult with industry as after all it is industry who will or will not em-ploy them. We would question why funding is available for unduly short courses.

Secondly, by contrast, there are some R.T.O.’s who take set intakes of students and train without any, or only minimal contact with the floral industry. The floral industry will not support or employ students who progress through a trade certificate studying multiple days and achieving a qualification that is not worth the paper it is written on. The question of competence also comes into focus. A student may be deemed competent on the day of learn-ing and assessment, however with concentrated learning and no actual practice then the skills will diminish. An employer paying full wages for a ‘qualified’ florist will not tolerate lapses in how to make an item or taking far too long to make a floristry product. These students enter these unduly short courses mainly underfunded positions, using tax payers hard earned

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money, with almost no chance of an outcome of employment. There is also the question of competency-based learning. This does not exist in unduly short courses in floristry. All training is lock-step as mentioned earlier. This does not allow for the over achiever or the under achiever as all students progress through the items together as a group.

Thirdly, duty of care is an issue with management of all involved in the Educational sys-tem. A responsible R.T.O. must respect industry needs and direct teacher/trainers to always consider the industry the student is training for and make sure they are work ready through the course. There can be no false illusions about the industry. Training packages are purely setting an industry path of training to meet industry needs. Unduly short courses are pushing students through a course at too rapid a rate and industry needs are not being met. These courses are damaging respect for training and devalue a good training package

Fourthly, the issue of providers who offer quality training are losing students to unduly short courses. This is due to the speed to obtain a qualification. Compliance for a small pro-vider is costly and some small, high quality providers have been forced to leave the market in the Personal services space.

Finally, before addressing the questions in the papers I would like to raise the issue of a sub-stantial number of florist business in Victoria that have changed hands to specifically to for-eign owners. Most have no knowledge of floristry and the ownership is to achieve residency. These businesses are run into the ground and change hands again even though they are run-ning at a loss. They will not employ apprentices and often staff are paid in cash and the own-ers are frightened of apprenticeship as it involves governance. This is damaging to the in-dustry and to training. Many of these businesses employed apprentices in the past and this has completely stopped. This is a part of apprenticeship decline as many of the previous own-ers fully supported this mode of training. If these new owners were more aware of the support they can provide in offering apprentices and that government will reward them perhaps this may partly change however all mentoring falls to the R.T.O.

Some students of unduly short courses do not have the English skills to enter the course and their motivation is questionable to the outcome of working in a commercial florist. We are aware of students studying in floristry accredited courses who cannot read and only speak limited English. How is this possible one would ask?

As I have had an association with the hairdressing industry as well as floristry for many years we believe our comments regarding unduly short courses are totally pertinent to the Hairdressing Industry as well.

Restaurant & Catering Australia, National (Tourism, Travel and Hospitality IRC member)

It is not for Training Packages to outline a duration of learning as they only describe the out-come’. The system should focus on real consideration of assessment outcome and whether the graduates of learning pathways are truly competent. If they are (ascertained through audit and compliance activity) then it doesn’t matter how long the learning is. It is impossible to de-cide on the length of a program without considering the cohort, the mode and method of deliv-ery.

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Recommendation One

ASQA proposes that a definition of the ‘amount of training’ that focuses on supervised learning and assessment activities be included in the Standards for Registered Training Organisations (RTOs) 2015, the Standards for VET Accredited Courses 2012, the Standards for Training Packages 2012 and the Training Package Development and Endorsement Process Policy.

General Comment Summary:

There is mixed opinion regarding defining the ‘amount of training’ for learning and assessment. Those in support of outlining minimum and/or set hours have stressed that it is only one element of the quality strategy. It should not be determined in isolation, and other parameters which are fundamental to consider simultaneously are:

Competency and outcomes Student cohorts Teacher and student ratios RTO teaching practices, including work placement conditions Mode of delivery Industry standards and requirements.

Overall, any attempt to define an ‘amount of training’ needs to be informed by industry.

IRC members opposing this action feel the focus should instead be purely on ‘assessment outcomes’ and setting minimum standards on competency. The attention should not be around length of time, but instead be driven by assessment requirements and ensuring learners are graduating with the right skills and competencies. Some courses are also already deemed to be overly prescriptive (in regard to inundated hours) and a number of issues regarding awarding Recognition of Prior Learning and non-essential and non-paid work experiences are occurring due to mandated hours applied in assessment conditions.

General Comments:

Lady Gowrie Tasmania, Tasmania (Children’s Education and Care IRC member)

Important elements to consider include differences between learner cohorts; work experience, life experience, previous qualifications, aptitude, learning style.

A minimum amount of training should be specified as informed by industry, with the flexibility to submit a variation providing evidence against specific criteria.

The VET system is based on demonstrating competency. It could be said that it should not be about how long the course is because a person in effect could walk in the door and do the as-sessment and be found to be competent. And further, a course could be of a length that seems adequate, yet that does not mean that it was quality teaching and assessment. The ar-gument here is about qualitative vs quantitative.

When advertising or offering a course that is shorter than the industry recommendation evid-ence to support why must be available on request from industry, peak bodies, ASQA or the potential learner. An appeal should be able to be lodged by any of those people to ASQA or repeal of the short course.

Maybe a better definition of competency. Whilst the wording that is currently used as the definition is not incorrect, maybe it needs further parameters to ensure consistency across so many industries. It does also rely on humans (which could be said to be a fault of the system as humans will always see things as we know them).

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Association of Massage Therapists, National (Complementary Health IRC member)

The issue of "unduly short courses" is not terribly prevalent any more in the massage sector due to the rather prescriptive nature of the most recent iteration of our quals, including the 200-hour supervised work requirement, and market forces brought to bear by private health insurance companies enforcing qualification "duration" requirements for provider eligibility. If anything, AMT would be better placed to comment from experience on the pitfalls of overly-circumscribed course length requirements, in terms of providing barriers to awarding legitim-ate RPL and exposing students to potentially exploitative practices (as unpaid labour).

Discussion Question Responses:Discussion Questions IRC member feedback Member’s details

1.1 What are the important elements in a definition of amount of training in a competency-based training system? What is your suggestion for a definition of ‘amount of training’?

The important elements in defining ‘amount of training’ surrounds the minimal level of ‘quality learning’ required to demonstrate knowledge to skill transfer at a level that reflects best practice in the workplace. It is practical by nature and needs to show repetition of tasks that moves the learner from ‘unconscious incompetence’ to competent. It will be dependent on student/teacher ratios, assessment and workplace access/supervision rather than just ‘time’.

Note: I think ‘amount of training’ from a purely time perspective needs to focus on ‘amount of assessment’ rather than just ‘amount of training’.

Ambulance and Paramedics IRC member and First Aid IRC member

‘Amount of training’ could indicate the length of time and effort required of the trainer to assist/support a novice to:

Engage meaningfully with the knowledge requirements of the unit;

Enable linkages to be made between the knowledge require-ments and the practical demonstration of skills in a workplace/simulated workplace;

Trial student’s skills performance and rationale for actions, (linking knowledge requirements to behaviours) in a variety of circumstances, allowing for contingencies

Provide feedback to allow reflection on skills performance and improvement in practice.

There has been an increasingly common expectation that workplaces will provide the required mentoring and skill development opportunities to enable a student to achieve competence in units. In some cases this has overtaken the RTOs responsibility to fully prepare the student.

TAFE QueenslandQueensland

Client Services IRC member

It is not for Training Packages to outline a duration of learning as they only describe the outcome’. The system should focus on real considera-tion of assessment outcome and whether the graduates of learning pathways are truly competent. If they are (ascertained through audit and compliance activity) then it doesn’t matter how long the learning is. It is impossible to decide on the length of a program without considering the cohort, the mode and method of delivery.

Restaurant & Catering AustraliaNational

Tourism, Travel and Hospitality IRC member

A definition of ‘amount of training’ should include minimum number of supervised face to face hours, maximum number of distance/online training hours and minimum number of fieldwork practicum hours (where required). This should also require minimum attendance requirement as a number of RTOs are finding loopholes in the competency-based assessment system. This also includes intervals between classes.

Australian Community Workers AssociationNational

Community Sector and Development IRC member

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Discussion Questions IRC member feedback Member’s details

The amount of training should refer to face-to-face theoretical training, supervised practical training, work experience training and theory and practical exams supervised by an appropriate professional, online training where appropriate, and off-campus activities such as written assignments, research activities, self-paced learning and any relevant course activities monitored by log-book and endorsed by accredited subject trainers/experts.

Ideally, the volume of learning (VOL) for each type of training for each unit of competency should be nominated in hours. However, VOL should not be too restrictive. Any qualification above diploma level, i.e. advanced diploma or graduate certificate, should allow for the fact that the learner will most likely have extensive work experience and be working at a professional level. Working professionals cannot afford to take time off work to, say, take up a course with a stated VOL of 1,200 hours. In situations like this, it may be more practical for an advanced diploma or graduate certificate to be completed in no more than 400 hours, depending on the required skills or vocational outcomes.

Laser Therapy & Natural MedicineNational

Complementary Health IRC member

It is important to have courses of sufficient length to cover key learning concepts and practical experience in care/support worker training to ensure students are able to ‘put theory into practice’ with adequate placement opportunity. For example that allied health assistant training includes underpinning knowledge and the opportunity to apply this knowledge in a work context. An Allied Health Assistant (Dietetics) may learn underpinning nutrition theory, but will need the opportunity to practice this theory in the context of negotiating menu selections with a patient on a modified diet.

Length of time is not a suitable indicator of achievement alone. But courses need to be of sufficient length to teach theory and provide practice exposure to practice skills then to enable demonstration of competency.

Students must demonstrate acquisition of key concepts (knowledge) and have competency observed in supervised practice. That requires that key concepts and competencies are clearly identified in the course material

Dieticians Association of AustraliaNational

Direct Client Care and Support IRC member

The amount of training is summed up by the nominal hours in ap-prenticeships sought by industry to provide an assurance about the competence of graduates. These hours of training are mainly ac-curate as they are fused with industry workplace practice. This is not the case in unduly short courses.

Australian Association of Floral Designers National

Personal Services IRC member

The “amount of learning” needs to include supervised and non‐su-pervised learning activities, so that potential students have a clear idea of what is expected of them.

Amount of training needs to cover: a range of learning opportunities include supervised and non-supervised learning activities in the time percentages that are applicable to the particular

qualification in question, and be clearly summarised in each qualification.

for students to understand how much time would be expected for them to complete to gain a qualification and for a particular RTO to be clear as to their responsibilities.

Amount of training could cover a range of these ten learning opportunities:

Coalition of Celebrants AssociationsNational


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Face-to‐Face education; Individual interaction, Group Interaction; Su-pervision/ Mentoring; Placements; Written Assessments; Research; Use of Equipment; Written Assignments; Auditory Assignments; Audio-Visual Assignments.

The time percentages or proportions need to be those applicable to the particular type of qualification in question.

Note: Assignments work would include estimates of reading time required.Reasons for differences may be related:

specifically to the type of employment available for that occu-pation (employed or self-employed), and

to the skills required for that occupation (people oriented or technology oriented)

For example, for the training for an occupation such as an independent celebrant, the opportunities for placements and mentoring are minimal because:

celebrants are self employed in competition with each other, and ceremonies are one-off, once in a life-time events that cannot

be redone/ fixed if mistakes are made (i.e. one may remarry but usually not to the same person, a person may have birth-days but not for the same number of years).

Therefore a course primarily about technology and using certain equip-ment may have percentages as follows:

Face-‐to-‐Face Individual/ Couple inter-actions

Group In-teraction

Written As-signments

Audio/ Audio-‐ Visual As-signments

5% 0% 5% 35% 5%

Use of Equipment

Research Supervision Mentoring Placements

35% 10% 0% 0% 0%

Whereas people oriented qualification, such as counselling, may have a different mix of learning opportunities.

Here a qualification needs to have a greater proportion of face‐to-face learning, and using assignments and technologies to provide the level of opportunities for students to apply theoretical concepts in practical situations.


Group Inter-action



25% 5% 5% 15% 10%

Use of Equipment


5% 5% 5% 5% 20%

Currently some Certificate IV courses have 100 to 400 hundred hours placement, plus 10+ units of competency.

Celebrancy could not offer that type and simplicity of placement of say a Veterinary Assistance Course, without analysis of the skills and where opportunities of where these could be found for celebrancy students.

As ceremonies and celebrations are primarily inter‐personal events that are group based (family and community), a celebrancy qualifica-tion needs to have a very significant proportion of learning based upon face-to‐face, individual/ couple interactions and group interactions

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where communication, public speaking and presentation skills can be practiced and assessed.

For people oriented occupations, online learning presents a particular set of challenges for the RTOs as these types of activities cost more to deliver.

For these types of qualifications, there needs to be a mandated minimum number of hours of face‐to‐face learning plus a mechan-ism for students to rank the quality of their training in an independ-ent setting.RTOs should also be encouraged to look at alternative ways of deliv-ering learning experiences. For example in Celebrancy community groups such as Rostrum and Toastmasters, Senior Citizens, busi-ness groups etc. could be approached for “placement-type” experi-ences.

Technology is increasing a part of professions and businesses, which as self‐employed workers, is critical to their ability to access and/or in-teract with clients; and/or provide services to clients.

All RTOs need to develop strategies that use 21st century technologies, such as:

audio‐recordings, online forums, closed face‐book groups, Skype inter-views, creating and using websites (with functions to sell services and products), video recordings, and open source learning platforms; etc.

in their delivery (including assignments) and assessments of a qualifica-tion.

The fact that many RTOs are businesses can undermine the incentive to spend time in reviewing and changing the delivery of the qualifica-tion to adapt to innovation and emerging roles, services or products. For the qualification as being offered by an RTO, the “amount of train-ing” is the total nominal hours of study (both supervised and unsuper-vised) for the core and particular elective units, in the time proportions for that range of learning opportunities that is being offered by that RTO.

1.2. Where in the regulatory framework would this definition best sit to improve student outcomes?

Upfront and somewhere obvious. It needs to be transparent to both the student/ teacher and ‘management’. PDS for starters.


RTOs should be able to recognise students with prior experience and those currently working in the sector. Recognition of Prior Learning (RPL) is still an option for RTOs to support these students. However, allowing loose flexibility will not help increase and maintain overall quality of the training program. RTOs should be able to continue to conduct ‘fast-tracked’ workplace delivery of courses.



An explicit definition should be provided in the RTO Standards and in Student Handbooks and/or product disclosure statements. In addition, the Australian Qualifications Framework should be adjusted to eliminate the current vague references of, for example, 6 to 12 months training.



The amount of training should be in the description of a Qualification or Accredited

Course on the training.gov.au website as the range of nominal hours – minimal to maximum for that particular qualification and

in course information on the RTOs website as the actual hours, this RTO expects and detailed in the various propor-tions required.



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The AQF could also benefit from a minimum to maximum nominal hours translation. To a novice/ new learner, ½ a year to 2 years means nothing in terms of how many hours of work are actually in-volved.Given industry is the employer I remain with the definition in number one.



1.3. If an amount of training is defined, how can industry ensure that innovation and flexibility in delivery of training is retained?

What criteria could be used to ensure the RTO has the scope in which to justify its rationale for shorter course duration?

1. Easily. 2. Low student/teacher ratios i.e. 1:1/1:4 especially for assessment (note the teacher could be electronic with adequate invigilation). It’s the quality vs quantity argument. Low student numbers with high supervision and good workplace support. Learning indicators (i.e. assessments) that demonstrate the student is progressing (can’t move on until they have completed one aspect). Time: get them to ‘step away’ from their course and then have to come back (i.e. a few weeks later) to sit the final assessment to ensure they have consolidated learning (and not just data dumped it all). If students can demonstrate they have learnt /applied the skills outside of the classroom i.e. communication in their ‘day job’. Other pathways to recognising skill development (which actually all contributes to time spent learning).


This depends on the industry. In the community services industry it should be possible to identify a core set of transferable skills to be structured into a course. There should be an option to bring in additional electives where necessary. Having a prescribed duration will help the RPL process and credit transfer. Currently different RTOs are delivering the same course at different skill levels with different delivery periods. Having a standard structure and prescribed time will support an effective delivery of vocational courses. Ultimately this will ensure employment outcomes for all graduates and a protection of the VET qualification.



Risk factors should be key criteria for judging whether an RTO can justify its rationale for a shorter course duration. Another aspect that should be considered is whether completion of nominal hours is necessary in all cases. For advanced diploma or graduate certificate courses, a maximum of 400 hours might be more appropriate because learner education levels are higher and/or work experience greater than those held by learners taking on a diploma course. In my view, it is not feasible to limit the volume of training to the number of hours for some post-graduate courses because it removes flexibility and innovation in the way training is conducted.

Volume of hours should only be defined for qualifications below advanced diploma level. This would ensure that graduates have completed sufficient training to equip them with the professional knowledge and skill to become independent workers. Extensive practise is the only way to ensure that students are competent to take on a new job role/profession. Once graduates attain professional qualifications at diploma level, any add-on skills provided in higher-level courses should be competency-based, and should not be restricted by volume of hours, where flexibility and innovation can be restricted. The reason for holding this view is the fact that students holding a diploma are very likely working full time as a professional worker, making it difficult for them to devote another 500 to 1,200 hours full time to gain a higher qualification.



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Furthermore, it is also reasonable to assume that skilled and knowledgeable workers who have established a solid foundation in their chosen profession would find it easy to add on specialised knowledge and advanced skills. The criteria to justify any rationale for shorter course duration should cover the following points:

a) Meeting the learning/vocational outcome objectives of a course

b) Evidence of performance/work experience mapping the knowledge and skills against the job role

c) Ability to meet criteria set for both theoretical and practical assessments and the competency standards of the job

d) Evidence-based documentation and verification from an industry body and/or accredited assessors from relevant fields.

The industry through the IRCs should be able to make recommenda-tions on amount of training on a regular basis as well as be able to recommend certain changes to the qualification, without necessarily having to compete for funding in the overall VET sector.

The industry should not be the only part of the VET system to ensure innovation and flexibility in delivery of training. The RTOs also need to be required to demonstrate they are:

keeping up with changes in educational tech-niques and changes in technology, and

adapting their training delivery and assessments as a con-sequence

which it is understood, they are currently required to demonstrate as a part of the audit process.

“Shorter course duration” has an underlying assumption that all training only needs to be to a minimal standard. Whilst it is vital to ensure all graduates have a minimal standard, the training could also be assumed to enable some of the group to go beyond minimal knowledge, skills and experience.

There should be little justification for a shorter course duration, unless all students in the course group have been assessed as competent in those areas that are being excluded from the course, as the volume of learning is based upon the assumption that the students are new learners (i.e. have no previous knowledge or skills in the field related to the qualification

For example, it cannot be assumed that because all the students in a particular group are over the age of 50 or that all have worked in a specific job role, that they will all have certain skills or knowledge in relation to a specific topic. Perhaps 80% do, or even 95% do, but not providing the required learning experiences to a student who is not competent, does no favours to the student, the recipient/s of their ser-vices, their colleagues, their employers or the VET system.

This is not to say that some students are not able to satisfy some units (or partial units) through RPL. For example, if they have been a mar-riage celebrant and their registration has lapsed, they could potentially complete a shorter version of the course, only completing the units of competency that cannot be satisfied through the RPL process.

For a quality‐training product, the RTO needs to ensure that all students have the required knowledge and/or skills to be exempted from certain competency units in the course.

The student would be spending time being assessed for: recognised prior learning / current competencies if they

have worked in the occupation, or completed a previous qualification that has been superseded, or



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the ability to apply their knowledge and skills in the new industry/ context, if they have passed the unit of competency delivered in another qualification

with unit’s assessment tools by the RTO to ensure that the student has the knowledge and skills competency required for the occupation.

So in reality the same volume of learning would apply whether the quali-fication is delivered as

if all students are “new learners”, or a mixture of an apparent shorter course and extra time spent

by the RTO and students to ensure all students are competent in the required knowledge and skills

A shorter course duration should be under competency-based training where a student is deemed to be skilled at a faster rate than another in their skills and competence and this is quantified by the employer. If training is outside of apprenticeship an in-dustry skills committee could be sought to justify the competence of the student meeting industry needs and there must be industry engagement during the training.



1.4 For qualifications that would have a prescribed duration, what are the implications for recognition of prior learning, credit transfer and transition of students when qualifications are updated?

Not a lot as RCC/RPL contribute towards time spent learning the requirements of that qualification. It’s the mapping document from old qual to new update that should dictate any gaps and then that is used to determine RCC/RPL and credit transfers.


While unrelated specifically to short courses, I do identify a risk with RPL processes that are insufficiently robust to honestly assess the competence of the applicant against the knowledge and skill requirements of each unit. The expansion of poor quality RPL delivery and assessment undermines the value of the qualification and hence compounds some of the issues already discussed with short courses.

TAFE QueenslandQueensland


Updated qualifications can be addressed through RPL, credit transfer and student transition through challenge tests to assess claimed competencies and by addressing training gaps in any new or revised units of competency. New qualifications should not supersede all knowledge and skills gained in previous qualifications. Unnecessary training wastes learners’ time, money and energy and might only lead to training outcomes bordering on regression. It is ludicrous to destroy all of one’s life achievements simply because some groups want to re-develop and/or upgrade qualifications.



As noted in 1.3 the volume of learning recognition of prior learning, credit transfer and transition of students when qualifications are updated should be able to be accommodated.



There is the question of imported units that are superseded yet current within another package. Updated qualifications and credit transfers are often misunderstood by employers. There needs to be a clear direction of this process from ASQA to employers. Not from R.T.O’s as industry can blame the R.T.O. and hold them ac-countable for decisions out of their realm.



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1.5. What is your suggestion for a definition of ‘new learner’? What processes would an RTO need to establish to verify a student’s new learner status? What documentation would support audit processes?

Unless you have been granted RCC /RPL everyone is a new learner aren’t they? They are new to learning that particular skill/subject and this is stated at their enrolment which would be the audit trail. No RCC/RPL = new learner.


I believe a ‘new learner’ would be someone who is studying a particular subject for the first time and has no experience in or knowledge of, say, a particular subject or job role. The absence of verifiable evidence of previous training and/or USI records may also help confirm that a prospective student is indeed a ‘new learner’.



A student who has no previous knowledge or skills or experience in the field related to the qualification and who has school leaver’s levels of literacy and numeracy and ability to participate in a learn-ing environment.

All students need to be initially assessed for entrance into the qualification on their

English literacy, language and numeracy their learning skills ability their identity

as part of their application for entrance into the qualification.

The identity issue has been highlighted in the celebrancy field, when some non-English speaking graduates of the Certificate IV in Celeb-rancy are authorised by the government for marriage work, then attend professional development. At this point their inability to participate raises questions as to whether or not, the person who was qualified was in fact the person who did the assignments and completed the work.

Any student not performing well at the application stage may be re-quired to do LLN competency units before entrance into the qualification or the RTO organise support so that the learner can complete the course.

If a student has not completed a school leaving level qualification in Australia, and does not perform well in any area of the assessment for entrance, then the RTO needs to arrange an assessment in their first language and the need for prior LLN units or support services to assist their participation in the course.

The RTOs application process for entrance into the qualification, and how this is used for assessing literacy, numeracy and their learning skills ability.

The RTOs processes for managing those applicants who have not per-formed well in any area of the assessment for entrance, entrance into the qualification, both those with English as a first language and those not.



A new learner should have the opportunity to be assured they are training to meet industry needs with a job already in place or the greatest opportunity to be work ready.



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1.6. In establishing a definition of amount of training, what are the implications for current definitions of volume of learning in the AQF? How could the definition of an amount of training (which includes only supervised learning activities) best be aligned in order to inform the review of the AQF and volume of learning (which currently includes supervised and unsupervised learning activities)?

You need to make sure that the definitions are complementary and don’t contradict each other, otherwise there shouldn’t be any great implications.


‘Volume of learning’ includes nominal hours which can be either face-to-face, online or distance education. A number of disreputable providers have exploited this definition to take fees from students and deliver unduly short courses. Minimum number of supervised face to face delivery and mandatory minimum attendance requirements will ensure relevant AQF skill level.



See answers to 1.1 and 1.2 provided above. However, it may be worthwhile defining what is meant by the terms, “amount of training” and “volume of learning”. For example, should the amount of training cover only supervised learning? If so, the amount of training should re-defined to include theory and practical training, work experience, assignments, research activities and different modes of delivery, e.g. online, correspondence, video, etc. Another point to consider is the fact that the AQF describes volume of learning as activities that include supervised and unsupervised activities. This suggests a need for greater uniformity across the VET/education qualifications landscape. Clearly the two terms are not interchangeable and require explicit definitions e.g. volume of learning should be referring to hours or duration of learning, whereas the amount of training covers much broader activities and study dimensions.



As noted in 1.2 above the Australian Qualifications Framework needs to set overall number of hours required for that level of Qualification as Volume of learning.

Volume of learning in the Australian Qualifications Framework needs to set overall number of hours required for that level of Qualification to in-clude both supervised and unsupervised hours.

As noted in 1.1 above, our suggested definition of “amount of training” would equal the Volume of learning in the AQF in hours, but specify the proportions or percentages of the different learning opportunities to meet the Volume of learning for a specific qualification.



The amount of training can follow the defined or suggested hours but without industry engagement the skills often erode. The key is interac-tion and practice with industry. To enter floristry training a student must want to deal with the public, want to sell, handle transactions, work safely and prepare and construct a broad range of items within a required timeframe. I do not believe a student trained out of industry should train more than two days per week and they must have some industry interaction. Apprenticeship indenture is for three years there-fore, a course of nine months (or sometimes less) is an insult to the in-dustry.



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Recommendation TwoASQA proposes the development of a risk-based approach to the inclusion of an appropriate amount of training when training packages are revised or developed by industry reference committees (IRCs).

General Comment Summary:

A strong sentiment was voiced regarding the competency, expertise and representation of IRCs to suitably review and guide training package developments, and thereby question the need to develop a risk-based approach. IRCs represent a range of stakeholders, including RTOs and industry, and are well supported by technical experts to ensure reviews and outputs are fitting and meet industry and quality standards.


2.1. How well are IRCs equipped to provide technical expertise on course delivery arrangements to be able to determine an appropriate amount of training? Who is best placed to provide the technical expertise to IRCs to assist in determining an appropriate amount of training? How do RTOs provide input given they are largely excluded from IRC participation?

1. If the IRC is appropriately represented, they have either good insight into the course delivery arrangements for their area or the ability to find the information. The issue will be for providers not represented at IRC level- this will require more industry/public consultation. 2. Technical experts in the respective fields within industry are best placed to provide the advice required. 3. Don’t agree with this statement. Firstly they are represented on most IRC’s and secondly their role as far as input goes is to inform the IRC and industry of the resourcing requirements (personnel/equipment/money et.el) and consequently the feasibility of any changes made to delivery modes. Industry and the IRC will decide if the workplace requires it and support accordingly.


IRC members have been selected by AISC on the merits of their qualifications and experience. IRC’s are diverse and include all highly relevant stakeholders. Where technical expertise is needed appropriate personnel are sought we reject the notion that the VET sector is not represented. Several representatives are on CS&D IRC alone. It is noteworthy, however, that VET sector representatives have a vested interest in shorter courses and limited fieldwork placements. RTOs should not be included in determining the amount of training required, this information should come via consultation/representation of the industry and employers. It is the role of RTO’s to deliver industry driven courses.

Where specific technical expertise is required IRC’s have capacity to facilitate a technical advisory group with recognised experts.



Ideally, IRCs should be made up of industry representatives and RTO employees skilled in course development, delivery and knowledgeable about the subject matter. The knowledge that an IRC would be able to provide may assist the current practice of employing course developers to interview industry professionals and RTOs about the steps a trainee needs to go through and the time it takes to achieve competency in a particular subject. The problem with engaging professional course developers is that they are not always able to grasp and/or obtain accurate information for framing elements and performance criteria from industry specialists. Because of this some training packages end up containing inaccurate and often ridiculous material that is not representative of the industry the training package and/or qualification is



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purported to represent. Ideally, training packages should be subjected to the same degree of scrutiny and consultation as that applying to the accreditation of privately-developed courses. This process should involve professional course developers, RTOs and industry experts.

The IRCs are made up of a unique range of representat-ives of relevant bodies for a set of occupations that have some common skills and target groups. Therefore they can advise as to the amount of training in consultation with the industry workers, associations, and employers.

There should be at least one representative of an RTO / training provider in each IRC. It is imperative that the IRCs have a solid representation from RTOs, as they are the ones who understand how a unit of competency needs to be implemented.

A competent trainer with an understanding of the VET system would be best placed as they have had practical teaching experience and understand the nuances of training.

An ASQA representative may be helpful for IRCs to understand how ASQA auditors will implement their recommendations.

There needs to be a step in the system for comments and feedback from RTOs to the IRC,

and for ASQA auditors to comment upon RTOs’ con-

cerns to the IRCbefore any major changes are recommended by an IRC to a specific qualification.

Any comments/feedback from the RTO that is not taken on board need to be addressed and reasons for the non-in-clusion should be noted and made available to the RTOs.



IRC’s present their experience in industry or repres-ent industry associations with knowledge of their in-dustry. Some are very familiar with training packages and delivery and some are not. A suggestion would be to send or interact with the major apprenticeship training R.T.O.’s for their feedback on specific ques-tions to assist the IRC’s. I believe the amount of train-ing under competency-based training and the justific-ation by industry is working very well. Unfortunately, unduly short courses are totally lock-step, (they should not be) and not answerable to industry. They should be accountable.



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2.2. ASQA has identified a range of factors that increase the risk for unduly short courses (page 11). Do you agree with these factors? Are there any other factors that should/could be considered in the context of unduly short courses?

The ASQA factors are a good place to start. It is all to do with how you judge quality.


The ECEC sector has minimum qualification requirements and therefore this could be an influence to unduly short courses. This was particularly relevant at the introduction and implementation stage of the NQF. Working towards a qualification: Actively progressing is not defined in the National Regulations.

Lady Gowrie Tasmania Tasmania

Children’s Education and Care IRC member

This statement particularly interested me - from a perspective of a teacher/trainer. While cost pressures have definitely played a role in increasing the attractiveness of short courses for RTOs, I think this is matched by the desire of individuals to achieve a ‘piece of paper’ without any laborious expenditure of energies. Dedication to engaging in a significant way with essential knowledge required for holistic demonstration of skills across a range of contingent situations is quite limited. Rather a focus on ‘one off’ perfunctory demonstration of basic skill is more common. Retention, integration and transference of knowledge and skills does not appear to be the aim of these courses.

TAFE QueenslandQueenslandClient Services IRC member

Yes agree. Mandatory minimum attendance should be a requirement.



Yes. We agree with the factors identified by ASQA. Additionally, recent history and fraudulent actions by some RTOs have shown that the VET Fee Help scheme is a major contributing factor to the incidence of unduly short courses. The student fee help scheme is a huge temptation to RTOs operated by get-rich-quick entrepreneurs who believe that such help schemes are ripe for exploitation. The solution is to remove the temptation and scale back student fee help schemes. VET Fee Help should be aimed at addressing industry skill shortages. Fee help should not be provided for post-graduate courses, i.e. advanced diploma and graduate certificate courses. Diploma holders should have sufficient skills to pursue a profession and be able to stand on their own two feet. It is a waste of taxpayers’ money to subsidise professionals who can support themselves to gain higher qualifications.



We agree with ASQA’s finding that there are many providers offering good-quality training, but that there is unfair market pressure from providers who offer unduly short courses and inadequate training. The VET sector must be structured to reward good providers and not to create unintended perverse incentives. This is particularly important given that there is an inherent time lag before ‘poor’ performers are identified, with consequent potential harm both for individuals and the community.

We also submit that for some qualifications there is risk where there is a lack of ‘hands-on’ learning. Not all skills can be acquired ‘on-line’. For example: an Allied Health



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Assistant (Dietetics) may learn underpinning nutrition theory, but can only learn the challenges of negotiating menu selections within challenging situations in a real-world context e.g. busy wards with staff with other priorities, patients who are not engaged in their nutrition care plan, what it is like dealing with cognitively impaired patients, etc.

Yes, agree.Are there any other factors?

The perceived status of an occupation An occupation’s perceived earning ability The opportunity for part-time or casual work The fact that RTOs and other learning institutions

rely on fees from students and are in competition with each other, rather than having direct funding from government, means some RTOs are pressured to drop fees and standards, cut corners and not ensure that all students are fully competent when they graduate.



It could be argued that the amount of training may be sufficient in hours but not in achieving on-going com-petence in the case of unduly short courses. I again refer to the hours stated in apprenticeship, with prac-tice in industry, as the leveller.



2.3. What other sectors, other than those identified by ASQA, would benefit from this risk based approach to training package development? How did you identify these sectors (for example, what factors regarding this sector were relevant in making this opinion/decision?)

I find this a bit sad. The risk based approach for the sectors identified from ASQA invariably came from problem that needed to be fixed. Once upon a time training and service delivery for anything came from the pursuit of ‘best practice’, not because something went wrong. Something will always go wrong- we are human.

Adopting a model based on the likelihood of ‘consequences’ to an incident, rather than just likelihood or incidences / amount of incidences now raises the question of ‘what is an acceptable consequence’? Does our risk averse society make this approach just as problematic?

There is a point not too far off that our inability to accept risk will make doing the job impossible (some would argue it is here now). If you leave any sector ‘unchecked’ for long enough you’ll need to actively risk manage it. Therefore, you could apply it to all sectors.


A risk-based approach should prevail across all industries. RTOs, as with any field of endeavour, always have the potential to attract cowboy elements intent on making a fast buck. Look at what happened to VET Fee Help, the roof batts scheme and the NBN roll-out. Public servants need to assess the risks associated with providing money from the public purse. That is the only way to stop wasting taxpayers’ money.



We concur with the findings of the ASQA’s strategic review that Aged and Community Care sectors are a matter of priority for specifying a mandatory amount of training, but would recommend that healthcare qualifications are also included as a priority sector (e.g. Allied Health Assistants, Mental Health, Alcohol & Other Drugs and Health Service Assistants).



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Workers delivering these services frequently work with vulnerable clients and undertake tasks that could place individuals and communities at risk is underlying technical skills and knowledge is insufficient. This fits within the risk framework identified by ASQA.

All qualifications that do not deliver competent graduates waste time and money and impact on the economy. People based occupations impact on mental health and wellbeing, social and family health, and in some cases physical health.

Competent people based services, early intervention and support can improve individual and family’s health, well-being and functioning, which in turn can reduce the cost to government of a range of legal, welfare, health and other services.

Celebrancy would benefit from a mandated number of hours of face-to-face learning because of the increasing tendencies of training to be done online and as self‐direc-ted learning.

Prevention and harm minimization strategies are more cost effective in addressing a range of mental and physical health related illnesses. For example, doctors and mental health workers supported the recent change to the Mar-riage Act as an important strategy to minimise the risk of mental health, alcohol and other drug problems and sui-cide in LGBTI communities.

Each contact with services, particularly in the area the legal, health, welfare, and associated fields are opportun-ities for change for an individual, couple and family, which may be used or lost. For example, celebrants deliver once in a lifetime event for families and other groups that cannot be replicated. A poor performance is not simply disappointing - it ruins an opportunity to build stronger and more respectful and positive relationships. For funer-als, a poor performance by the celebrant can be harmful rather than helpful for the grieving of those most affected by the loss of a loved one. For marriages, a poor perform-ance can fail to highlight the significance of marriage for the marrying couple and their family, and leave a bitter experience for family and friends who have usually inves-ted time and considerable expense in the wedding.

Family and community networks are hugely im-portant as a safety net in troubled or difficult times, or for families with inter-generation prob-lems.



Industry associations should be more involved provided they justify their involvement in the discussion put for-ward on behalf of their industry.



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2.4. Do recent and proposed changes and reforms in the VET sector contribute to dealing with these issues, and are there alternative ways to achieve the same goal?

I think the changes and reform are a good start. The alternate way would have been to not do it in the first place…there were enough people who voiced their concerns when ‘we’ headed down this path (it hasn’t always been so)- but they were ignored.


Given that the apprenticeship system is working well it should be the base model. Supporting apprenticeship is vital and the change to employers paying yearly fees has been damaging as employers weigh up incentive versus fees and cost to send apprentices one day per week. Tax payer’s money would be better spent supporting more incentives for the employers to employ apprentices. Funding for unduly short courses, if withdrawn, would change this situation overnight



Regulatory burden is costly. Although sound compliance is required, the focus should be on quality, but this is hard to measure. Maybe an evaluation framework specifically measuring quality outcomes (not completion rates as this does not particularly define quality).



Employers and industry bodies should be given the opportunity to evaluate courses delivered in each state and region. This will be additional layer of quality assurance and risk management.



Some of the changes and reforms may control these issues. However, it is obvious that the Federal Government and the bureaucracy needs to be more vigilant and to plug all possible likelihood of fraud during the planning and risk assessment stage and well before implementation.



As these changes proposed by ASQA that are aimed to increase the quality of training provided, and thus the competency of graduates, appear to be evidence based, they should assist. As part of an RTO’s compliance, there needs to be regular validation (working with another RTO to cross check a sample of assessments to ensure consistency).

One alternative strategy may be as noted above, a more transparent and easily assessable system of finding the RTOs who deliver a particular qualification with a ranking by graduates as to their training experience and its ap-plication in the industry.



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Recommendation ThreeASQA proposes that RTOs would be required to publish a product disclosure statement (PDS) that includes the range of learning activities expected for each training product on their scope of registration. The PDS, to be developed by the Australian Government Department of Education and Training (the department), would be available on RTO websites and the RTO’s entry on the My Skills website.

General Comments Summary:

Should PDSs be implemented, IRC members raised a number of related issues for consideration, including the need to ensure PDS’s reflect different student cohorts. A template would support RTOs to provide the required details (and support quality providers that perhaps are not as strong in marketing to provide suitable details), and students to access comparable course information.

Lady Gowrie Tasmania, Tasmania (Children’s Education and Care IRC member)

This [PDS] could give more choice to learners. Maybe a template that is used so that they could compare apples with apples. Suggest the template is prepared by industry or there is a document that sits alongside it that indicates what industry see as ‘quality’ training and assessment.RTO’s would have to be able to submit multiple options though. How else could you demonstrate that you meet the needs of different learner cohorts? An example of this is the multiple different ways that the Cert 3 in ECEC can be delivered e.g. jobseekers, existing workers etc.

Need to consider LLN and the VET industry Jargon and marketing of the product. Some RTOs may be better at talking the talk, but not necessarily walking the talk. This is of concern. PDS to be more general i.e. list the learning delivery as a mix of face to face, online in-service mentoring. Driven by industry and learner to be fully informed at interview stage (not an online enrolment) to ensure they have the information they require to make an informed decision.

Measuring completions (just data) can be dangerous as completions do not necessarily equate to quality as we are seeing today.


3.1. What impact and costs would a provider face in implementing ASQA’s proposal?

Costs should be minimal if they are already delivering a quality product. Impact wise will be in terms of time and HR- making sure their current processes match any emerging requirements.


Implementing PDS for training course offerings is unlikely to have any impact and/or costs for RTOs just as the new enrolment form details have been revised to meet NCVER data collection requirements.



If, as recommended here, the IRC would, in consultation with the in-dustry, RTO’s and ASQA, recommend the “Amount of Training” pro-portionate to the learning activities in hours and arrange this to be available on training.gov.au.The costs would be in providing advice and feedback to the IRC be-fore the Amount of Training is determined. This cost to the RTO could be offset by reducing contacts by potential students trying to ascertain what time they would need to set aside to commit to the training.

If the RTO is to determine the mix of learning activities for the “Amount of Training”, rather than the IRC, then the same applies. The cost to the RTO in providing information of the amount of time for each time of learning activity, would be offset by reducing con-tacts by potential students trying to ascertain what time they would need to set aside to commit to the training.



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ASQA’s proposal can potentially penalise a quality provider. A student should be made accountable for accepting public funding and why they want to enter the floral industry. There should be mandatory experience within the industry. All efforts should be made to encourage apprenticeship. A quality R.T.O. already has a huge workload and in some cases office staff outweigh teaching staff. All units of study are available on the websites and time duration should be stated. It is the speed of the unduly short courses that is the attraction to prospective learners. Many assume the quality must be there as the course is recognised and funded. A student would be better placed to seek an industry referral for training. A good R.T.O interviews and advises students of what the course involves. Comments such as “I was in nursing but I have a bad back so I thought of floristry” should involve R.T.O. advice as to what floristry is all about including daily lifting. It may be more pertinent for industry IRC’s to write about what is involved with the industry and what employers will require. Many have no idea of the pressures of floristry meeting time deadlines constantly.

A quality R.T.O. turns more students away than it accepts due to industry unsuitability. Unduly short courses will accept anyone. There are many members of the public who still feel that a florist plays with flowers all day and what a lovely profession it is. The fact that an apprentice can study for up to three years amazes some members of the public. Examine the impact on apprentice-ship training when the employers were made responsible for the yearly fees. Some have stated that the cost of a day out of the store as well as fees negates any incentives. Put more effort into industry supporting quality apprenticeship training as this is the very best way to learn.



3.2. What impact would this have on the flexibility of RTOs to deliver training?

None…flexibility as a mode of delivery should not have anything to do with quality or really time. It is meant to improve quality by giving the learner more choices and control over their learning which in turn keeps them motivated. Most online platforms track usage and all good delivery uses a variety of methods- not just one and low student/instructor ratios for face to face training will also support learning.


May reduce the flexibility for industry and RTOs to collaborate in customising and designing a delivery framework to meet the particular cohort needs.



RTOs should be able to recognise students with prior experience and those currently working in the sector. Recognition of Prior Learning (RPL) is still an option for RTOs to support these students. However, allowing loose flexibility will not help increase and maintain overall quality of the training program. RTOs should be able to continue to conduct ‘fast-tracked’ workplace delivery of courses.



Nil. Laser Therapy & Natural MedicineNational


If the RTO were to determine the mix of learning activities for the “Amount of Training”, rather than the IRC, then there would be more flexibility. However as noted earlier, incentives for updating in the cur-rent system are few. Either change needs to be mandated or funded to ensure that the delivery of qualifications is updated, as the industry requires.



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Direct this proposal to those delivering unduly short courses and leave the quality providers of apprenticeship training to work and please industry.



3.3. How could a PDS take into consideration the various flexible and innovative ways in which a single training product may be undertaken?

By describing different methods of delivery. Using an example. NOTE: the RTO could also put forward for consideration an accelerated pathway for the qualification/competency if there was a particular need to do so.


A draft guidance document prepared by ASQA or some other authority could be adapted by RTOs so that they can detail any flexible and innovative ways in which their training product(s) are undertaken.



Each qualification could outline the Volume of Learning and Amount of training in a table such as follows:

Name of Qualification Certificate IV in CelebrancyName of RTO Nomi-nal hours

Training on the River P/Ltd 600hours


Group Inter-action



50 hours 25 hours 20 hours 250 hours 150 hours

Use of Equipment


50 hours 50 hours 0 hours 0 hours 5 hours



It is relevant to note that the level of trainers of unduly short courses is sometimes questionable. If they were dealing with in-dustry and responsible daily for the training they put back into the workplace the level of training may well differ. Competency based training should be monitored as this mode allows for flex-ibility and lock step is far more limiting.



3.4. What would trigger an RTO to update each PDS?

For those that are diligent- you wouldn’t need a trigger. They would do it automatically. For the others- you’ll need to mandate a time- i.e. every 2 years (or a set of circumstances) I suspect.


An update of each PDS might be triggered by a legitimate change in course delivery circumstance or to make the PDS more explicit and more transparent.



As noted in 3.2, either change needs to be mandated or funded to en-sure that the delivery of qualifications is updated as the industry re-quires, or as noted, if there were a feedback system as noted in 2.3, then poor reviews may assist in an RTO updating its PDS.



It should be considered that quality R.T.O’s often write their own Learner Guides and Assessments. Answers are fully written for auditors, yet these guides are not monitored for correct industry content by ASQA through its IRC’S. There are industry referrals, but a change of training package creates a mammoth workload for a provider to have compliant Learner Guides and compliant assess-ment tools. We believe ASQA, through its IRC’S, should view and comment on each R.T.O.’s Learner Guides and Assessment tools. This would be more beneficial than P.D.’s.



3.5. Are there Does the government put out a ‘good TAFE/RTO guide’ like the Ambulance and

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alternative ways in which training product information could be provided to students to enhance consumer protections, and at which point in their enrolment/training should this be provided?

myschools website so that people can compare providers? Those that didn’t meet set standards wouldn’t be on it. Some sort of quality seal of training? (like the master builders association). Give the RTO’s a nice carrot rather than a big stick to strive towards. PDS should be provided at the first enquiry by a student and on the RTO’s website.

Paramedics IRC member and First Aid IRC member

Cooling off period – Interview required prior to enrolment vs sign up online.



Amount of supervised face to face training should be published on RTO website and marketing materials.

Data on graduate destinations and employment outcomes should be made available to students.



In the interests in informed consent and transparency, training product information should be provided on RTO websites and through written promotional material (e.g. Student Handbook and RTO prospectus) available to prospective students in the public domain. In addition, such information should be reinforced at pre-enrolment interviews.



A clear and appropriate scope for qualifications is essential in the Direct Client Care and Support Industry Sector. Discussion of scope of practice for qualifications within this sector is important for future care/support workers and to ensure expectation of students and employers are appropriate. For example: the Dietitians Association of Australia would like to see inclusion of food and nutrition units within courses designed to educate care/support workers in various sectors. This does not mean these workers would necessarily have the full range of skills and knowledge to undertake the full scope of responsibility of Allied Health Assistants (Dietetics). A PDS is an opportunity to make it clear to both students, graduates, employers and the broader community what training to expect from a particular qualification, and the tasks that this might (or does not) qualify an individual to undertake.



As noted in 3.2 above. PDS needs to be available pre-enrolment and be confirmed in their application process.



Encourage employers to state what they require from their work-ers. Real industry insights for a prospective student to consider may assist to give them more insight into what the industry is all about.



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Documents

Submission details - Department of Education€¦ · Web viewIn the community services industry it should be possible to identify a core set of transferable skills to be structured