ASQA’s Latest Push is Based on Flawed Research…We Need Real Solutions to VoL Concerns

In June this year, ASQA released a Strategic Review Report on issues relating to short training. ASQA’s key findings include several known issues in the VET industry:

  • Concern about unduly short training is widespread and longstanding.
  • Regulation of duration in VET is complex and confusing.
  • There are many cases where learners are not gaining the competencies specified in VET qualifications.
  • Advertising of short courses is widespread (potentially over a quarter of all courses are less than the AQTF requirements).
  • Good quality providers are facing pressure to decrease quality (deliver faster) in order to compete or are forced to leave the market place.
  • It is currently difficult for students to compare providers of a qualification to determine the best option for their needs.
  • The long-term sustainability of the VET system is at risk unless the issue of unduly short training is definitively addressed.


Mandatory Volume of Learning will not solve any of these issues.

Adding VoL as a “solution” to “unruly short courses” has added additional complexity, confusion and frustration to an already confused, complex and frustrating system. This is also acknowledged in ASQA’s Strategic Review Report.

These problems are all no-brainers. I do not feel that these known problems required extensive research or detail, but justifying these “key findings’ take up the bulk of the report. Many online discussions around this report have been influenced by the so-called key findings (I agree with the findings, so I agree with the recommendation, or have we, the stakeholders of VET, asked for this/deserve this?)

The report should have focused on why volume of learning (VoL) is the answer to the seven known issues above (rather than investigating if these known-issues are real!). There are a number of concerns that simply have not been reviewed or even thought about in ASQA’s report:

1. Does anyone actually believe quantity will equate to quality?

As someone who has done a lot of work in both instructional design and marketing, the goal is almost always on reducing content/training/materials while still meeting key outcomes. Do we risk locking out innovative training methods if we are constantly fearing making training too short (or for that matter, too long)?

The other side of this argument takes me back to my days as a biology student. Those classes were long and tiresome because we spent all our class time copying text off overhead projectors and writing answers to textbook questions in a notebook. I’ll hazard a guess and say these activities would be a cheap way of padding out resources to meet any new volume of learning requirements…but is this actually improving training quality? I personally couldn’t wait to get out of that class.

It is somewhat amusing that I regularly hear a saying from both clients and stakeholders in my line of work that sums up this first point:

“(We want) quality NOT quantity.”

Here is a good article that goes into this point (and the amount of complexity and confusion brought on by VoL) more thoroughly.

2. Can anyone actually say how long it takes someone to learn something?

According to academics who have studied this: no. When VoL first came out I went to an ACPET discussion with a knowledgeable academic who spoke on this topic. There are a lot of factors that influence volume of learning, for example:

Individual Factors:

Aptitudes, development level, LLN, general world knowledge, specific prior knowledge, health, social/peer relationships, motivation, attitude to occupation, attitude to learning, attitude to delivery mode, anxiety, belief, sense of control.

Learning content factors:

Declarative knowledge, intellectual skills, discriminations, knowledge of concepts, principles and procedures.

Learning process factors:

Trainer/teacher skills, learning resources, physical environment, social environment, group size, support systems, mode of delivery, learning activity design, level of direct instruction, opportunity for guided practice, opportunity for workplace application…

This is not an exhaustive list. The academic had more. Many more. How can we even have a boundary around how long a certain cohort should take to learn something when there are so many factors at play? There are also no guidelines or estimate around how much to reduce/increase volume of learning by for each of those items…because everyone is different.

Regulators also need to be realistic about what can be extracted or tested prior to enrolment. Many of the items in the list that relate to students are deeply personal. Many students come to VET because they have disengaged with traditional education and what to learn in a way that is practical, straight forward, no frills. Volume of Learning risks shunting VET towards a pathway that looks even more like school. RTOs shouldn’t be expected to know everything about a student before they sign up, otherwise we will see an even greater exit from our sector as a result of the first impression of VET being days of interviews and testing…the very thing these students were probably trying to escape.

3. Qualifications at the same AQTF level are very, very different.

After a quick search I found some Certificate III courses have just 10 units, while others have over 70. Some Diploma courses have just 8 units, while some have over 30. The significant differences in the units that make up a qualification and the number of units needed to complete a qualification are certain to impact on the amount of learning each person does. Setting a standard time for learning at each AQF level does not make sense, if the qualifications have not been designed with that consideration.

4. Other countries are doing it….so that means we should too?

One key finding ASQA puts forward as justification for VoL is:

Other countries provide greater specification of duration, demonstrating that in competency-based training systems there are still circumstances in which mandating duration is considered a necessary means of regulating quality.

Now I believe that unless those other countries have a good reason for mandated volume of learning, then it should not be a “key finding” and instead should be more an ‘interesting but not really that important’ side note. Having reviewed each of the countries listed, I did not find any factual evidence of mandating duration being necessary for quality as suggested in the report.

Scotland and New Zealand’s systems, for example, are based around the academic year. In Scotland, a certificate typically takes one year to study, and therefore units and outcomes are designed to fit into a 12-month study period (not unlike traditional school or university systems). Similar to this, New Zealand assigns each unit with a credit point value. Credit points are based on 1 year = 120 credits.

The British system involves training providers putting forward their own curriculum and total qualification time to their regulator for approval (i.e. they can set it to what they think is needed).

In other words, the countries listed in ASQA’s report have structured their qualifications around the academic calendar. Australia’s system has been structured around competencies needed for job outcomes. The structure of our qualifications are completely different to the countries in the report. It is not reasonable to even compare these systems! I also saw no evidence or research around whether the overseas systems were performing better than Australia, and if time allocations had anything to do with this. Which leads to my final point:

5. You cannot, in my opinion, assign an arbitrary time it should take to complete an Australian qualification due to its diverse make up and the fact that time was not given any consideration when the qualification was designed.

I’ll let the graphs in the ASQA report explain why (everything between the dotted lines is the current volume of learning targets):

Keep in mind these are actual graphs from the report. Note that there is no way to tell how many units of competency are expected to be completed in these timeframes (see point 3) so it makes complete sense that 68% of Cert III courses are estimated (advertised) as being either longer or shorter than the prescribed volume of learning hours.

Here we can see approximately half (50%) of providers advertising Diploma programs above or below the volume of learning band.

There are more extreme cases. Certificate I courses, for example, have almost 80% of providers outside the volume of learning band!!

Regulating Volume of Learning is Not the Answer.

ASQA wants to make “sensible and proportionate change to the VET regulatory framework [that] will enable effective regulation of the amount of duration, provide industry with a lead role in addressing the risks of poor-quality training (by specifying their requirements), and empower industry and prospective learners with the information to more readily compare training providers and their offerings.”

I say adding VoL as a “solution” to “unruly short courses” has added additional complexity, confusion and frustration to an already confused, complex and frustrating system. Instead, why doesn’t ASQA simply:

#1 Prioritise audits of RTOs that are advertising significantly lower completion times for qualifications.

I’m sure practitioners in our industry could easily identify the “unruly” players to ASQA if they let them. ASQA should prioritise auditing the complained about providers’ training resources and evidence being collected via assessment practices. If poor quality is discovered, hit the provider with a breach under the existing legislation. Last time I checked, quality training and assessment was well defined (well before VoL was added in) and people should be playing by these rules. The graphs above show that it may not actually even be as big of a problem as we originally thought.

#2 Re-purpose funds into awareness campaigns that will help potential students better make a decision about which course to undertake.

According to this report, each student is allocated just $3 towards education on Careers advice, and current approaches to educating students are not useful. That is just not good enough.

The amount of money it would take to consult, maintain and regulate the time needing to be spent on every single unit of competency will be astronomical and, as per my points above, useless. I would like us to see students making more informed choices, not money invested into the creation of more rules created to take care of providers who….aren’t following the rules?!

#3 Ban advertising course duration, so it is removed from students’ decision making process.

Instead, ASQA could seek to mandate a generic statement that all RTOs must use if asked about course duration. Maybe something like “We recognise every student is different, and will take different amount of time to complete study. On average, students take [regulator to provide average time after consulting RTOs delivering qualification] to complete [insert relevant qualification].

#4 Quality will only be improved via better trainers and training and assessment resources.

Please recognise these as two very different jobs and skill sets. If you assume development of quality assessments is a task every Trainer/Assessor has the experience and skill to do, you probably haven’t given consideration to the actual skills, knowledge and capabilities needed to develop training and assessment resources. Let’s start a conversation about why the current training and assessment resources are not meeting the mark.

Bonus Option for RTOs: If you are a quality provider being negatively affected by others advertising unrealistic, short duration for training, there is something you can do right now: join them.

There is no reason why you can’t allow candidates to complete a qualification in a short amount of time IF the candidate has existing skills and knowledge that can be recognised AND you have a streamlined and compliant process to recognise these skills. You can use RPL as a viable pathway way to offer qualifications in a shorter time-frame without reducing quality. We have an exciting new product that leverages technology to dramatically simplify the RPL process…and creates a gap training plan for candidates at the same time! Please check out our current RPL/project here and let us know what you think. If you are a quality provider, we need you to remain in our industry and we (at LEI) will do everything we can to help!

In Conclusion…

Volume of Learning is yet another example of unnecessary complexity and burdensome processes that fall way short of solving the serious issues plaguing the VET industry. Far more appropriate options are available.

It should come as no surprise that a review into ASQA operations has received significant support from industry.


Co-authored with Andrea Stockton