An open letter to ASQA: Put an end to the waste, invest in a strategy that might actually work

Dear ASQA,

RE: Regulatory Strategy Repeat #7

We are now acutely aware of our VET industry’s failings, but when will you start being proactive and come forward with a solution?

One can’t help but sigh with frustration when reading the latest regulatory strategy, published 22 August 2017.

I am confident that most VET professionals do not need to be reminded that ASQA harbours concerns about the capability of trainer/assessors. To be frank, we don’t need to hear your perceived issue being reiterated time and time again: “ASQA will maintain its increased scrutiny….”, which seems to indicate there is a need to persuade or convince someone that this action is required. Rather, we would collectively hold great interest in supporting a solution that moves our Industry forward!

The solution is not to invest copious amounts of labour and funds into investigating a known issue and generating a solution such as a TAE qualification upgrade that is NOT mandatory and therefore produces no improvement. Perhaps this is why the regulator has not evidenced any significant improvement to their identified issues even in the light of their recent scrutiny.

The reality is that the TAE upgrade solution in its present form, with minimal providers seeking to continue their efforts at TAE Cert IV re-registration due to economic feasibility and procedural frustrations, is not making any impact on improving existing capabilities of industry trainer/assessors. Instead it has ground the education and development of future trainer/assessor capability to a halt. Few new entrants mean the same, alleged problematic people are the only people continuing to participate in VET.

Please take some responsibility for the current situation. Pointing the finger at RTOs for the current state of affairs is neither helpful or proactive. Instead, please consider implementing the following solutions:

#1 Regulating to ensure those parties who currently own/manage, or seek to own/manage an RTO, are capable, informed, and educated leaders. After all, this is where the change must be made to drive ethical quality improvements through our Industry. Perhaps you, the regulator, can develop this mandatory AQF qualification for RTO owners? You could take charge of ensuring all RTO owners complete this qualification, and are therefore educated, informed and assessed against your RTO standards, practices and benchmark ethical principles and expectations.

I am aware that some progress has been made to formulate a qualification for our Industry such as 10610NAT Diploma of VET Compliance Management. But I would anticipate it to be quite difficult for any organisation to write training/assessment resources for this qualification without adequate input and support from ASQA to help mitigate operational risk. Attempting to write such resources without regulator confirmation and agreement to all content in this qualification is akin to drinking from a poisoned challis. In an industry that suffers from constant change and inconsistent interpretation of the rules from your auditors, internal compliance officers, RTO owners and other industry stakeholders, what are the chances of getting the content correct? Only through education of RTO leaders and subsequent performance management by ASQA, can you ever hope to directly address underperformance, and remove or de-register those who fail to perform against agreed standards.

#2 The pathway to our industry’s recovery can be forged with the new ethical, educated and qualified RTO leaders. I would like to suggest that these leaders can apply the existing VET capability framework. Take note that this already actually exists! This framework is suitable for the development of trainer/assessor capabilities across practitioner domains and sets out how to develop practitioner capability for teaching, assessment, industry collaboration, systems and compliance. All RTO managers should know and apply this framework. It is hard to understand why this was not at the forefront of the strategy to address your concerns regarding non-compliance from current VET practitioners?!

In conclusion, I firmly believe it is time to regulate the implementation and use of the VET Capability framework.

If you are unsure of how this framework could be implemented and integrated into your performance management system, please get in touch.

What is missing in our industry is leadership, clarity and solutions that have a positive impact. Any industry consultation you undertake has been in pursuit of already held convictions, resulting in all your initiatives falling victim to confirmation bias. Enough is enough.


Yours sincerely

Andrea Stockton


Co-authored with Matthew Garratt