However, despite their great efforts, they have left a hole that will allow for continued erosion of standards and a further decline in confidence.
Introducing Peter and Peta, three TAE Certificate IV graduates.
Peter completed his TAA40104 in 2006. He attained this entirely through RPL, based on his BSZ98 qualification, which he completed in a single day in 1999. Peter has never actually designed learning programs based on accredited units of competency nor delivered training to a group of learners. He has not performed the duties of a Trainer/Assessor since completing his TAA Cert IV. Peter wishes to upgrade to the new TAE40116. He presents proof of completing the TAA40104 10 years ago and requests a Credit Transfer for the equivalent units.
Peta completed her TAE40110 in 2010. She completed it with an RTO as part of an intensive 3-day program that included all assessments. Her qualification included the unit, TAEASS502A. As part of her TAE course, she did put together an assessment instrument but has no experience in developing assessment tools. Peta wishes to attain both the new TAE40116 Cert IV in Training & Assessment as well as the TAE50116 Diploma in Vocational Education & Training. She presents proof of having completed her TAE40110 and requests Credit Transfer for the equivalent units, including for TAEASS502.
Pieter completed their TAE40110 in 2012. They (they prefer to be gender-neutral) completed their Cert IV in a robust and correct manner. Pieter has not undertaken any training or assessment-related work or activities since then. Pieter wishes to attain the new TAE40116 Cert IV and, just like Peta, presents proof of completing the TAE40110.
Registered Training Organisations are required to adhere to the Standards. They cannot pick and choose which parts of the Standards they can emphasise and so they are bound by Clause 3.5:
The RTO accepts and provides credit to learners for units of competency and/or modules (unless licensing or regulatory requirements prevent this) where these are evidenced by:
- AQF certification documentation issued by any other RTO or AQF authorised issuing organisation, or
- Authenticated VET transcripts issued by the Registrar.
This is commonly known as Credit Transfer, which the AQF defines as
a process that provides students with agreed and consistent credit outcomes for components of a qualification based on identified equivalence in content and learning outcomes between matched qualifications.”
In my own inquiry to ASQA, the respondent made clear that
Where a learner provides suitable evidence they have successfully completed a unit or module at any Registered Training Organisation (RTO), RTOs must provide credit for that unit or module. This is regardless of the date they successfully completed the unit or module.
ASQA advises learners must not be required to repeat any unit or module in which they have already been assessed as competent unless a regulatory requirement or license condition (including industry licensing schemes) requires this. Where a learner provides suitable evidence they have successfully completed a unit or module at any registered training organisation (RTO), an RTO must provide credit for that unit or module. If a student wishes to enrol in gap training, they may do so, however, an RTO cannot compel a student to enrol in further training if they have already been deemed competent in that unit of competency.
I sought to clarify if there are any limitations on how far back in time we go with the notion of equivalence, and it was confirmed that there really is no limit:
ASQA can confirm that credit transfer may be awarded to a student if your organisation can determine that the content of the units of competency they have completed match the content of the units they wish to be credited with. This is regardless of the date they successfully completed the unit or module. If the content of the units are not equivalent, your organisation may wish to undertake a process of Recognition of Prior Learning (RPL).
What about Peter, Peta and Pieter?
In all of these situations, our professional instinct is to request currency of practice as an indicator of their knowledge and skills, and the absence of currency for all three creates some apprehension. We would not wish these people to possess a qualification that bears our RTO name.
For Peter, we are concerned by the knowledge that he has never actually participated in any activity that would equip him with the knowledge and skills that are embodied within the Cert IV TAE.
For Peta, we are concerned by the knowledge that the 3-day course she did was patently inadequate in instilling the required knowledge and skills for the units for which she is seeking Credit Transfer.
For all three, we are concerned by the absence of currency and our professional instinct would be to request evidence of that as an indicator of their knowledge and skills.
And yet, for all three we are bound to award the relevant units by Credit Transfer. It does not matter that we know that neither of these people possesses the skills or knowledge that the units of competency are intended to represent. To request evidence of currency is an RPL process, and that is in contravention of the Standards.
Regardless of their clear lack of competence, all three of these people will be able to receive the new TAE qualification.
What does it mean for the TAE40116 Certificate IV in Training & Assessment?
The new and additional hoops that RTOs need to jump through mean that many people are expecting that only those RTOs with integrity will be approved to deliver them. And with that comes the belief that holding the TAE40116 will be somehow more credible than the TAE40110:
- For the authorities, this is likely to be something that they are hoping for so that confidence can be restored.
- For many RTOs, this is likely to be something that they are hoping for, such that having the new TAE qualifications on scope provides a badge of credibility in a market repeatedly shaken by publicity surrounding questionable practice.
- For many RTOs, this is likely to be something that they would be hoping for, such that they can have greater confidence that people holding the new TAE qualifications will actually have the skills and knowledge that the qualifications represent.
However, this Credit Transfer loophole means that those people who never were competent may continue to operate – or enter into – the VET sector as if they were. It means that RTOs who are committed to only awarding qualifications to people who are truly competent are hamstrung into doing the opposite, which will erode the credibility of the RTO as their graduates inflict their incompetence on the industry. It means that the RTO Managers and other people involved in hiring trainers and assessors will not be able to rely on the new TAE qualifications as a true indicator of a person’s ability to perform the duties for which they are employed.
And it might just mean that the new TAE40116 is not much better than the old.