CATOHR RESPONSE TO PwC TAE16 REVIEW

Feedback on TAE40116

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

I am an instructional designer who has been providing holistic and clustered Certificate IV Training and Assessment materials to RTOs around Australia since 2008 as well as RPL Assessment Tools for many qualifications across a broad range of industry sectors.  I have also been Certificate IV Trainer and Assessor for over 14 for a number of RTOs supporting 100s of students undertaking BSZ, TAA and TAE qualifications.  Through my business CATOHR I have worked as a Quality Consultant across Australia for over 10 years. During this time I have provided compliance advice and support to 100’s of public and private RTOs, this gives me valuable information on the practicalities of delivery and assessment of TAE40116, TAE50116 AND TAE50216.

Firstly, we should look at the intent of the qualification, as stated in its description, namely:

This qualification reflects the roles of individuals delivering training and assessment services in the vocational education and training (VET) sector.

This qualification (or the skill sets derived from units of competency within it) is also suitable preparation for those engaged in the delivery of training and assessment of competence in a workplace context, as a component of a structured VET program.

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

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

Trainer/assessors in the VET sector (an RTO)

Tasks they perform

An entry level trainer/assessor in an RTO performs the following tasks:

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

Tasks they do not perform

An entry-level trainer/assessor does not perform the following tasks:

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

NOTE: It has to also be borne in mind that under the Principles of Assessment, particularly the Principle of Reliability that the ability to change things such as session plans and contextualise materials and assessments is usually undertaken by a “senior trainer” to ensure that there is consistency of assessment and delivery across the board in order to meet this heavily audited principle. Many RTOs forbid trainers and assessors to change anything including Lesson Plans with the approval of a Compliance person, so much of what is being asked at this try level in many cases is becoming increasing irrelevant due to audit requirements.

Enterprise trainers and assessors

TAE40116 is inappropriate for this cohort as it makes people who will never develop an assessment tool or conduct a validation or undertake a spikey profile to undertake this training that is virtually of no use to them and makes it extremely difficult for them to maintain their currency. There should be a separate qualification (not a skill set of units from TAE40116) which is designed specifically for this type of trainer/assessor, using industry consultation to identify exactly what skills and knowledge they require.  The course in Field Based Training and Assessment 10235 NAT is closer to what is needed for this cohort and already has the Resources Training Council’s Approval but should have a full review for suitability for other sectors.

Background to issues with TAE40116

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

The introduction of TAE40116 was used as an opportunity to require all RTOs who needed scope to complete a new scope application, rather than the usual automatic approval if they held scope for the superseded qualification.  Although the application process was extremely detailed, it is now clear that the problem has not been resolvedThere are RTOs who have been granted scope for TAE40116 who are not providing quality training and assessment.  Complaints to ASQA have been made.  However, these RTOs continue to have scope despite the fact that they have had previous breaches of Standards 1 and 2 and yet many who had no previous issues with the regulator were denied TAE40116.

TAE40116 as a “licence to practice”

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

Nor do I believe that the TAE Certificate IV is, in effect, a licence to practice as a trainer/assessor in an RTO as there should be many pathways to being a trainer and assessor.  By assuming the qualification is a licence to train and assess then we have to ask the question why TAE40116 is not a prerequisite to the TAE50116 Diploma of VET or TAE50216 Diploma of Training Design and Development?  We currently have this ludicrous situation with TAE40116 being called some sort of licence but people simple by pass it and gain a Diploma or the double Diplomas with no rigour attached to them. The current relationship of TAE40116 to the TAE Diplomas makes a mockery of TAE40116 being called a benchmark or licence!

Reviewing the current units of competency

TAEDES402 Use training packages and accredited courses to meet client needs

This unit is equivalent to TAEDES402A and the evidence requirements are practical.  The unit should be delivered prior to any assessment units, as it introduces the learner to the VET system, training packages, qualifications, units of competency and the AQF.

This unit is not relevant for an enterprise trainer/assessor, as they are required to follow whatever is given to them and simple just need to know how to conduct assessments as they won’t be writing or mapping assessments.

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

TAEDES401 – Design and develop learning programs

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

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

Recommendation:  Delete this unit

TAEASS401 Plan assessment activities and processes

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

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

Therefore, this unit should be retained.

Performance evidence:

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

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

Recommendation: re-word this PE.

  • planning and organising two Recognition of Prior Learning (RPL) assessments (which may be two of the five assessment processes above.)

It is not my belief that people who undertake Certificates IV should be planning RPLs at all as this is a higher level skill and that is reflected that it is given an entire unit in the Diploma. This part should be removed from the unit. It is my belief that only experienced assessors should be conducted RPLs as they require a higher degree of mapping and assessment knowledge (which requires practice and is not for someone at “entry level”)

TAEASS402 Assess competence

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

Performance evidence

The candidate must show evidence of the ability to complete tasks outlined in the elements and performance criteria of this unit, including:

  • assessment of at least five candidates within the vocational education and training (VET) context against at least one endorsed or accredited unit of competency according to the organisation’s assessment processes and practices.

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

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

  • using recognition of prior learning (RPL) processes in the assessment of at least one candidate (which may be one of the five candidates above)
  • making reasonable adjustments in the assessment of at least one candidate.

The assessments must be undertaken under the supervision of a qualified assessor and cover an entire unit of competency for each candidate, including:

  • the application of different assessment methods and instruments involving a range of activities and events
  • using two-way communication and feedback with the candidate
  • exercising judgement in making the assessment decision
  • recording and reporting assessment outcomes in accordance with the assessment system and organisational, legal and ethical requirements
  • reviewing the assessment process.

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

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

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

Recommendations:

  • Delete the requirement for “real VET learners” and allow for simulated assessments, which allow us to truly test the candidate’s ability to conduct assessment because we can design the tasks to trap common errors made during assessment. It also allows us to properly benchmark the assessment tasks.
  • Change the requirement to writing detailed, supportive and accurate feedback to the candidate (instead of two-way communication) or make it clear in another way that two-way communication is not necessarily face to face oral communication.
  • Delete “under the supervision of a qualified assessor” as this can only occur in an RTO. The assessment which the candidate submits is already assessed by a qualified assessor.
  • It is not my belief that people who undertake Certificates IV should conducting RPLs at all as this is a higher level skill and that is reflected that it is given an entire unit in the Diploma. This part should be removed from the unit. It is my belief that only experienced assessors should be conducted RPLs as they require a higher degree of mapping and assessment knowledge (which requires practice and is not for a beginner)

 

TAEASS403 Participate in assessment validation

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

 

TAEASS502 Design and develop assessment tools

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

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

Recommendations:

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

TAEDEL401 Plan, organise and deliver group-based learning

No consideration seems to have been given when designing this unit that Group-based learning is declining in favour of remote learning or that regional and remote RTOs also have trouble making up the magical “8”.  My personal preference is to retain this unit as a core, as it provides opportunities to develop overall training delivery skills, whether the person will end up training groups or not.

Performance evidence

facilitating group-based learning by preparing and delivering at least three training sessions, including:

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

 

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

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

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

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

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

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

If the candidate is delivering this group training remotely to a person with special needs (assuming this might be possible) the question can be raised if this practice breaches privacy legislation.

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

Recommendations:

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

TAEDEL402 Plan, organise and facilitate learning in the workplace

There is even more of an argument to make this unit an elective.  This is an excellent unit for an enterprise trainer but hardly relevant for an RTO trainer/assessor where they deal with Trainees or Apprentices but not all do.

This unit focuses on Apprenticeships and Traineeships from the point of view of supporting learning in the workplace.  While a number of RTO trainer/assessors support learning for Apprentices and Trainees and need to understand how this works, this is only a minority proportion of the total.

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

Recommendations:

  • Make this an elective in TAE40116

TAELLN411 Address adult language, literacy and numeracy skills

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

I am not a huge fan of this unit as the primary resource the ASCF is a very unreadable document and the usefulness of it to the general trainer/ assessor is questionable.  I have held this unit like the majority of colleagues since it become compulsory in 2012 and like most of my colleagues have never once needed to undertake a “spikey profile”.   Predominately this unit is about “reasonable adjustment “which we have all been required to undertake since BSZ days.   The absolute fact is that when a student comes to a RTO the chances of the RTO being able to assist their literacy and / numeracy levels is remote given the lack of time and funding for such pursuits. If a student has a severe problem they are referred to a “specialist “LLN agency that is funded to assist.

This unit should be an elective if not removed totally (and yes I know it’s a government thing but totally impractical).

 Relationship between TAE40116 and the TAE Diplomas (TAE50116 and TAE50216)

There is a disconnection across the TAE16 package overall due to the following:

  • The TAE 16 package does not adequately recognise and understand the role of enterprise trainers and assessors and by forcing them to undertake units for TAE40116 (such as TAEASS401 and TAEASS403) validation they are being made to undertake irrelevant units which they will never use and find it difficult to maintain currency. Enterprise Trainers and Assessors need units modified to be “fit for purpose” not just units taken from a qualification not made for them and told to “fit” in

 

  • The TAE40116 package does not recognise the needs of specialist trainers who often undertake “sessional” work to assist their industries such a Real Estate, Mortgage Brokers, Conveyancers”. These trainers often work (many in their own businesses) and train to assist others to enter the industry.  Training and Assessing is NOT their full time job.  The advent of TAE40116 will see many of these people disappear from the VET (as they see it all as too hard) and create skill shortages.  These people will not design assessment, undertake training or assessment plans, they are walk in delivery and assessment that is it.  Like the Enterprise trainers and Assessors these people also need a more fitting skill set to meet their needs and continue other contribution to the VET sector.

 

  • The TAE40116 resembles an Egyptian mummy being held together only by all the bandages that have been applied over the past 4 or 5 years. When you take these bandages off all you have is nothing but fragments of what was once something functional. If TAE40116 is an “entry” level qualification which is what we are all told – then it needs to reflect Entry level requirements.  There is NO need for specialisations at this level and some of the units identified in this response such as TAELNN411 and TAEASS502 need to be either electives of allocated to the one of the Diplomas.

 

  • The fact that you can now by pass Entry level training into the VET sector and go directly to a Diploma is nothing short of a disgrace and already we are seeing the folly of this decision. We now have people with double Diplomas with less that 6 months experience in the VET sector – how is that possible??? The Diplomas were establish for “experienced” trainers and assessors to expand their skill sets and specialise in areas such as LLN, E-Learning, Assessment, Training Design and Development.  Where do these people who have not undertaken Certificate IV and been not been made to gain “sufficient practice” get a thorough understanding of Training Packages or the Principles of Assessment and Rules of Evidence?  Currently we have “idiots” with TAE Diplomas making them worthless.  TAE40116 MUST be a prerequisite for either of the Diplomas and preferably applicants into Diploma courses must have verifiable evidence of having undertaken a minimum 1- 2 years practical – such as the Community Services Industry introduced a few years ago when they faced the same dilemma of people by passing Entry Level qualifications and going straight to a Diploma.  I would go as far as to suggest Diploma applicants must have undertaken say a minimum of 400 hours delivery and 200 assessments. This situation needs to be fixed urgently as we have people not doing TAE40116 and accessing funding for TAE50116 and TAE50216 and rapidly watching a further erosion of skill within the sector.

 

TAE Diplomas (TAE50116 and TAE50216)

I am still trying to fathom why we have 2 Diplomas as most people are undertaking the double diploma by undertaking the 10 common units across the Diplomas.  It’s like a two for one deal that you see on a shopping show!

So why do we have 2?  Why not just have a Diploma and people can specialise in the areas they want where people can just select the units that will suit them.  We can cut two of the units out of the Diplomas TAEDEL501 Advanced Facilitation Practice and TAEASS501 Advanced Assessment Practice simply by making TAE40116 a prerequisite to the Diplomas (as mentioned above).

The compulsory nature of TAELLN501 is questionable as many have seen NO benefits from TAE411 (as previously discussed on page 8) and likely to get even less from TAELLN501.

The compulsory nature of TAEPDD501 Maintain and enhance professional practice is a joke in fact this unit should be deleted.  ALL VET Trainers and Assessors are REQUIRED by the Standards for RTOs 2015 to undertake and document PD. So why is this even a unit?

I believe there is a case for including / creating additional units within in the Diplomas as electives to replace the 3 units I have suggested be deleted these include:

  • Conducting Internal Audits
  • Standards for RTOs 2015
  • Enhanced PC requirements in the TAEASS503 Lead Assessment Validation Processes to include validation of other areas  other than just the assessment tools itself, such as completed assessments