What is "the time"?.... It is a unit of measurement!
time is the fire in which we burn

What is "the time"?.... It is a unit of measurement!

It is said that time is the fire in which we burn, and for many RTOs, it seems their time is up.

I can only hope they will rest in peace, but this doesn't seem to be happening.

This is not the case for all RTOs, but the RTOs in danger of falling victim of "Natural selection" is, as Darwin stated, the ones who have not adapted to their current environment.

"Industry Currency" has nothing to do with the length of service.

In fact, in the case of training, it may actually be your length of service that is the bias causing your unconscious incompetence. You may know your "why", you know "how", you just don't know what to do.

I'm not saying what you do doesn't have value; it just doesn't have value for everyone anymore.

To give you an idea what we mean by this, we are planning sessions in a similar style to "the antique roadshow"; going around telling RTOs what still has value to industry, and what doesn't based on current industry needs. It is not just about what Industries will pay for, there are also things they would be prepared to pay extra for!

There is still a place for everyone in the Vocational Education and Training (VET) sector

That said, it just may not be in the business of issuing formal qualifications anymore. If you want to do that, you have to play by the rules, and you have to understand them.

The VET system is not falling apart

It is actually getting put back together. It was bend, not broken. The ones who know what to do are not going tell others what to do. Why would they? If you haven't worked out they system has already changed, and don't realise it is being implemented without you... well.... Darwin is not wrong!!! That's natural selection at work in the VET sector. I could throw in a bunch of cliché to try and illustrate my point, like "an empty can rattles the most", or "you can't fill a cup that is already full", but basically it is like herding cats.

People say that is impossible, but impossible is just something YOU haven't done yet.

FYI for the RTOs that can adapt to the changes in the VET environment, while the others are busy writing their applications to this year's "Darwin Awards" (I'm not worried about offending people, as they would have stopped reading by now, which is just one of the problems victims of natural selection have in the modern world), lets start with one interruption of implementing an industry currency policy..... not saying its the only way, or my way is the best, just have not been told were it is wrong. Einstein would call it a "scientific consensus" rather than an opinion, but here is mine anyway:

RTOs have been says "ASQA says currency is....", however ASQA only accepts or rejects an RTOs policy on what the RTO considers currency. It is actually the RTOs policy, based on risk factors relating to each training product, so the period is set by the RTO.

This is implied in the standards for RTOs, not specifically stated, but the short answer is “it depends”. On what? I hear time and time again RTOs saying "but it doesn't say in the standards how to work out the time frame!".

Yeah....sorry... it does... and that is the answer you will get from ASQA. However, that takes more TIME to explain; and while ASQA may tell you what to do, they will not tell an RTO how to do it. That is them telling you how to do your job, or effectively doing your job for you.

Example of risk factors relating to an industry

(press pause, and make yourself a coffee/tea before continuing!):

In the Glossary (std RTOs, 2015):

Current industry skills are the knowledge, skills and experience required by VET trainers and assessors and those who provide training and assessment under supervision to ensure that their training and assessment is based on current industry practices and meets the needs of industry, so…

Industry means the "bodies that have a stake in the services provided by RTOs" (see examples in the glossary), which leads to….

  • Industry engagement, for the purposes of Clauses 1.5 & 1.6, which states…..
  • "1.6. The RTO implements a range of strategies for industry engagement and systematically uses the outcome of that industry engagement to ensure the industry relevance of... its training and assessment strategies, practices and resources"

which leads you to std 1.10, and this is where the time frames are referenced:

  • 1.10. For the purposes of Clause 1.9, each training product is validated at least once every five years, with at least 50% of products validated within the first three years of each five-year cycle, taking into account the relative risks of all of the training products on the RTO’s scope of registration, including those risks identified by the VET Regulator.

Still there?.... Take a deep breath, now keep reading. To unpack the above:

Most RTO believe the use of the word “Cycle” means that in two cycles of 5 years, and you can do unit A in year one, and don’t have to do it until year 10 in the next cycles. 

This is not the case as the words “validated at least once every five years” means that if you validate unit A in year 1, it has to be done again by the corresponding stage of year 6, so it is actually a rolling 5-year time frame for an individual unit.

For trainers and assessors to be involved in the process to make sure the products are current, a person on the panel need to have:

vocational competencies and current industry skills relevant to the assessments being validated

So, this is where the 5-year time frame is set as a “standard” for compliance….

However… an "industry standard" is a "benchmark", so not the minimum standard, and don't look for it to be specifically stated in the standards for RTOs, again, it is just implied.

The term benchmark comes from the high tide water mark on the bench seats along rivers; the low tide is the standard, as in the expected minimum, however the "benchmark" is the highest expected level in normal conditions. Doesn't mean the water won't come over the benchmark to a higher level in the event of a king tide or storm swell, but the benchmark IS predictable, and so an industry benchmark for industry CAN be set by RTOs through industry engagement (just like you can research tide levels).

OK, but I digress, back to it... The standards (yes, the ones for RTOs, 2015) say:

“50% of products validated within the first three years …., taking into account the relative risks

so it is up to the RTO to risk assess the industry in which they train. Thus, it is the RTO's policy that determines the time frame, and risks associated, with current industry practices being out of date, which brings it back to Std 1.8-2: 

“The assessor is assured that the quality, quantity and relevance of the assessment evidence enables a judgement to be made of a learner’s competency”, as well as 

“The assessor is assured that the assessment evidence demonstrates current competency. This requires the assessment evidence to be from the present or the very recent past.”

 This means that an industry current "assessor" for a unit of competency is the person working for an RTO that is most qualified to determine the currency period. They are also the person most qualified to assess the evidence of currency; So if you can't "self-assess" your own currency evidence, and compliance knocks it back, compliance is saying you don't know how to assess your students!

Just to point out why it is so important for you to put the required effort into filling out your trainer matrix.... if you can't do it, this demonstrate an assessor has NOT maintained currency in TAE practices, and an RTO has every right to place an assessor under supervision if they can't complete their own matrix. Even if "they have been a trainer for 20 years!"..... but moving on (still with me? I did warn you it takes TIME)

The Validation process is intended to validate of assessment practices and judgements, and Validation is the quality review of the assessment process, which must be done by “qualified assessors” …. And assessments under the ASQA “General Direction – Retention requirements for completed student assessment items”, updated 12 May 2016, ASQA only wants RTO to hold assessments for 6 months as a definition of “current training practices” (excluding TAE applications and funding rules)

I know, right!... so... if your RTO has a 3 year currency policy, an assessor who has currency in a unit 3 years and 3 month ago at the time of the validation session may only be qualified to validate outcomes as an industry expert for assessments completed more than 3 months ago, so not Qualified to validate outcomes in the most recent 3 months……you haven't followed the RTOs own rules, so have not done what you said you would. If you set a higher standard, you have to enforce it, or the RTO is non-compliant with most of STD #2 (monitoring training).

When ASQA says in an Audit the currency period is 3 years, that is because that is the time period your RTO told ASQA it is! The RTO can't blame ASQA's Auditor, or even say ASQA set the time frame.

When an RTOs sets a time frame, this is what actually happens in most cases (and how RTOs end up just saying 3 years):

To mitigate risks, compliance managers (who set the policies), who often don’t know the rate of change in the industries their RTO delivers training to, sets the period of currency is set at 3 years as a blanket rule for all trainers. I say again; this is the RTO’s policy, not ASQA. ASQA could say you are non-compliant if your trainer’s currency in more than 5 years old, as that is the period set in the standards for the currency validation of the "training products" delivered by the RTO…. However,…

If an RTO has a policy in the employment contracts of the trainers and assessors that they must maintain industry currency from the last 3 years, and at Audit an assessor has no industry currency in a unit for the last 3 years, the assessor is non-compliant with their work contract (so in breach of their written agreement to provide training services), but the RTO is also non-compliant under std 2.2a:

The RTO systematically monitors the RTO’s training and assessment strategies and practices to ensure ongoing compliance with Standard 1 (all of std 1)

Confused? 

You are not alone. Trainerpd.com has been setting up systems to update industry currency, gives advice on what could be justified as “current” in their industry, plus ways to update industry currency (other than having to go to work in the industry).

As an indicator of the focus of an RTO, you could look at:

  • A compliance based RTO’s view of the timeframe for currency would be 5 years
  • A Quality based RTO would say 3 years for currency as a benchmark to mitigate the risks
  • A small business/start-up focused RTO would have a currency period of less than 1 year

The RTO is within their rights to choose their standard, but can’t say “it is ASQA policy. In Any case, an Auditor may still not accept evidence of currency if an RTO can’t justify how the time frame for industry currency is determined by industry.

For example, an Auditor could have a reasonable argument to say an RTO is not providing quality training in business admin if they did not deliver training using MS Office 2013/16 in their assessment tools, as clearly the time frame for currency is 3 years in this industry. Microsoft updates their software every 3 years, and trainers would be required to show PD specifically in current, or the superseded MS Office program, but MS Office 2010 is now two versions ago, so no longer considered current.

To be a trainer and assessor, you must comply with the standard for RTOs (2015), but if you are already employed and the RTO changes their policy, you should see advice from either the ACCC or Fair Work Australia depending on if you are an employee or contractor.

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