1. law, govt and politics
2. government

SUBMISSION
Response to Discussion Paper:
Review of Training Packages and Accredited Courses
18 February 2014
About Us
The Health Services Union (HSU) is a growing member based union fighting for dignity and respect for health
and community services workers. Our members are at the forefront of some great nation building changes
in the National Disability Insurance Scheme, Public Health and Aged Care reform.
We are a driving force to make Australia a better place.
HSU members work in aged care, disability services, community health, mental health, private practices and
hospitals. Members are health professionals, paramedics, scientists, aged care workers, nurses, technicians,
personal care and support workers, clerical and administrative staff, disability support workers, managers,
doctors, medical librarians and support staff.
We are committed to advancing and protecting the wages, conditions, rights and entitlements of members
through campaigning and workplace activism. HSU also provides a range of services and support to assist
members with many aspects of working and family life.
HSU National is the trading name for the Health Services Union, a trade union registered under the Fair Work
(Registered Organisations) Act 2009.
Contact:
Chris Brown
National Secretary, HSU National
M. 0418 564 199
E. [email protected]
Mark Farthing
National Project Officer, HSU National
M. 0447 744 509
E. [email protected]
2
Introduction
HSU National welcomes the opportunity to provide a response to the Government’s review of training
packages and accredited courses. Rather than addressing each of the Discussion Paper’s focus questions this
brief submission provides our broader views on VET reform before dealing with particular issues in the
Discussion Paper. Our views are informed by our longstanding involvement in the Community Services and
Health Industry Skills Council (CS&HISC) and our members’ experience of VET.
At the outset, we would like to point out that the sector is suffering from reform fatigue. The 2012 Standards
for Training Packages are still in the process of being implemented and the Discussion Paper clearly states
that “there is general agreement that they will assist in improving training outcomes” however, based on the
signals emerging from the VET Reform Taskforce, ISCs will not be given the opportunity to complete this
important transition. HSU National has serious concerns that these constant, abortive attempts at reform are
further disengaging industry from the VET system. It is our view that all ISCs be given the opportunity to
meet the original deadline of 31 December 2015 to transition training packages to the 2012 Standards for
Training Packages prior to any further major reform of either training packages or ISCs. Finally, the
Government must not simply pay lip service to its claim that this review is “focused on the needs of
individuals and employers” and ensure that any changes to the system architecture do not favour employers
at the expense of students and workers.
Please note that our response should be read in light of our submission to the discussion paper: Industry
Engagement in Training Package Development – Towards a Contestable Model, which was submitted to the
Department of Industry on 24 December 2014. This submission should also be read in conjunction with the
Australian Council of Trade Unions’ submission, which the HSU endorses.
Changing the Skills Mix
Certificate I and II Qualifications and Preparatory Qualifications
At present, government targets and funding policy favour the promotion of Certificate III level qualifications.
We are concerned, however, that simply setting targets for higher-level qualifications risks encouraging
credentialism to the extent that job entry requirements may be raised without any accompanied skills
utilisation. As such, we support a thorough and thoughtful reappraisal of the role of Certificate I and II level
qualifications which includes an examination of their potential suitability as preparatory qualifications.
We are also concerned that in the section covering preparatory qualifications, the Discussion Paper makes no
mention of the National Trade Cadetship (NTC) program, which was specifically designed to address issues
around preparatory qualifications outlined in the paper and more closely link the secondary education
system with VET, yet was defunded by the Government in the 2014-15 Federal Budget. Any conversation
about preparatory qualifications must take into account the work completed through this project.
Skill Sets
In-principle we do not oppose further development of skill sets. We would, however, be concerned if public
funding for skill sets came at the expense of full qualifications. The Discussion Paper clearly states that the
review is “focused on the needs of individuals and employers” and while skill sets can be beneficial to both,
the fact that they focus on narrow job-specific skills can limit worker mobility between occupations and
3
industries—thereby favouring employer needs over those of workers. However, the consequences of
restricted occupational and industrial labour mobility have implications broader than the industrial relations
landscape since it is commonly accepted that restricted occupational and industrial mobility acts as a brake
on economic growth. Given these issues, if skill sets are going to become more prevalent then they must be
designed from the ground-up as building blocks to full qualifications.
Changing the System Architecture
VET Quality Project
We support a stronger role for ISCs in ensuring that RTOs consistently interpret, deliver and assess the
requirements of the standards for all training package units and qualifications as articulated in the VET
Quality Project. In particular, there needs to be major improvements to the standards of assessment. We
note that this change is currently being integrated into training packages as they are migrated to the
Standards for Training Packages and reiterate our comments at the beginning of this submission that this
process needs to be allowed to reach completion and assessed before further wholesale reform is
considered.
On another note, we are very concerned that the Discussion Paper notes that some RTOs have reported that
these quality measures can be “costly and difficult to organise.” While it is our strong view that training
should not be inordinately expensive, if the reality is that quality improvements are going to cost more then
this is simply a cost that industry and governments are willing to pay. Ultimately, good quality training does
cost money and public funding should reflect this fact.
Accredited Courses
With the number of accredited courses on the national register approaching the same number of training
package qualifications, we believe that they are undermining the notion of a national VET system. It is our
view that where training packages are unable to meet an area of demand then it should be formally
registered with the responsible ISC to examine in future training package reviews to determine whether it is
an isolated/enterprise-specific issue or an actual, emerging national skill need. If it is the former then there is
no need for a nationally recognised qualification and the skill need can be met with unaccredited training. If it
is the latter then the requisite skills can be codified and formalised in the training package.
Underutilised Training Packages
We support the approach outlined in the Discussion Paper whereby training packages and qualifications that
are no longer held on scope by RTOs for an agreed period of time are removed. However, we do not support
the implementation of any kind of system resembling this until accurate enrolment and completion data is
available for both publicly and privately funded VET. Furthermore, we would not support an automatic
removal process. Extensive industry consultation would need to take place before removal could occur.
Change the System Focus: the Real Issues in VET
While training packages have been in place for some time and it is appropriate to examine if they are still fitfor-purpose, nevertheless we question the underpinning assumption in the Discussion Paper that they are
the primary cause of declining employer confidence in the VET system. Such scepticism is warranted given
that the vast majority of employers are not involved in the training package development process and their
4
opinions on the worth of national qualifications are based upon the skills and knowledge of VET graduates;
not the content of those qualifications. Given this, it is unreasonable to place the blame for falling industry
confidence in the VET system solely on training packages.
We strongly believe that the real issue facing the VET system is the proliferation of poorly regulated, rentseeking, for-profit RTOs delivering sub-standard training coupled with a failure of the regulatory system. It is
our view that the work being undertaken by the Senate Education and Employment References Committee
through its inquiry into the operation, regulation and funding of private VET providers will do more to
address the real issues eroding industry confidence in the system.
5