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

The long-term sustainability of the VET system is at risk unless the issue of unduly short training is definitively addressed.

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

  • Concern about unduly short training is widespread and longstanding.
  • Regulation of training duration in VET is complex and confusing.
  • In many cases, 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.
  • Students find it difficult to compare providers of a qualification to determine the best provider for their needs. This often results in students choosing providers who advertise courses that are both cheap and of short duration making it extremely difficult for quality RTOs to compete.

The report justifies the implementation of mandatory volume of learning (VoL) as a way to resolve these issues.

The reality is mandatory Volume of Learning will not solve any of the issues listed in ASQA’s report.

Adding mandatory VoL as a “solution” to “unduly short courses” instead adds further complexity, confusion and frustration to an already confused, complex and frustrating VET system. This is actually acknowledged by ASQA in its Strategic Review Report.

The original version of this article received wide-reaching support and consensus that there are more appropriate solutions to the issues listed above:

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

It is currently a simple process to identify RTOs that are likely to have an issue with quality (just search for RTOs advertising unreasonably short course duration). Should ASQA struggle with identifying such providers, VET practitioners can easily assist. ASQA should prioritise audits of RTOs who are advertising short durations. If poor quality training and assessment practices are discovered, ASQA can penalise the provider under existing legislation/standards. Quality training and assessment requirements are well defined in the Standards for RTOs (even before VoL was added in) and providers should adhere to these rules. Graphs in the ASQA report also indicate that “unruly short courses” are not even as prevalent as is suggested. There should be no excuses for lack of action from the regulator on RTOs who are apparently causing so many problems in the VET industry.

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

According to this analysis, 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 the points in the full version of this article, useless. We should invest in solutions that will allow students to make more informed choices, rather than creating and maintaining more rules created to take care of providers who…aren’t following existing rules!

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

If ASQA believes creating a new rule is an imperative part of a solution, why not seek to mandate a generic statement that all RTOs must use if asked about course duration? For instance: “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 [relevant qualification].

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

ASQA has long said that there are significant issues with the sub-standard quality of assessment instruments. Yet solutions put forward by the regulator (like VoL and changes to the TAE Training Package) are not evidence based. They also contradict highly regarded tools like the VET Practitioner Capability Framework and industry requests for a TAE more aligned with the skills and knowledge needed to perform training and assessing effectively. It is unsurprising that there has been no reported improvement in this issue since ASQA’s inception in 2011.

Any arguments in favour of requiring trainers or assessors to develop the skills to create quality assessments ignore the actual skills, knowledge and capabilities needed to develop training and assessment resources. Solutions that will actually address the issue of training and assessment resources quality must be the focus.

In short, Volume of Learning is yet another example of unnecessary complexity and burdensome processes that falls way short of solving the serious issues identified in the report. Far easier and simpler options are available.


Special thanks to Andrea Stockton and Anna Ridgway for their contributions to this article.