Deschamps, Gabrielle - Enterprise Registered Training Organisation Association (ERTOA)

Response:

ERTOA believes the role of industry does need to be strengthened and expanded across the VET system.
Industry engagement should be the exchange of information between industry, employers and training package developers.  When writing training packages, the writers should be the vehicle for the needs of employers and industry.  However, under the current system, the opposite is the case.  Often the training package developers consult to get the answers they seek, and ignore the feedback provided.  Further information about the feedback mechanism to IRCs will be noted below.
Much of industry doesn’t need encouragement to engage with the VET sector.  EROTA is aware of many employers and industry members who contact their SSOs and IRCs to provide feedback, and often can’t receive an acknowledgment of their contact, let alone a response.
When a response is provided, there is the distinct likelihood that there is minimal consideration for feedback with the IRC being influenced by the Skills Minister office. An example of this is the Certificate III in Rail Signalling being merged with the Certificate III in Railyard Operations and creating a new qualification Certificate III in Rail Operations. This decision is effectively requiring students to complete additional UoC for no tangible benefit linked to job role.
No-one knows what industry needs better than industry.  Consultation should be genuine and not be driven by an agenda.  An example of this is the recent reduction of AQF qualifications due to low or no enrolments.  One of our members provided feedback that despite low numbers in a Certificate III qualification, they had invested significant time and money in developing a training offering aligned to this Certificate III qualification, which relates to a highly specialised yet small cohort of workers within their industry.  The feedback provided was ignored.  The qualification was removed from the National Register and is no longer available for use.  Subsequent requests to reinstate the qualification advised that this was not possible.
The agenda to reduce overall qualifications in the system was the agenda in the example above.  Industry provided feedback and this feedback was ignored.  This has a direct impact on safety within the industry and leaves the cohort of workers unable to complete a VET qualification related to their job-role.
In addition, ERTOA members consult with other ERTOA members and industry partners broadly about business requirements.  Competitors or not, there is often open discussion about work practices and requirements across employers.  Such industry engagement and consultation should be fostered and enabled and supported both by SSOs and IRCS, as well as broader government.

Response:

Yes

Response:

ERTOA has very limited representation on IRCs, despite seeking representation on most IRCs which align with our members’ industry area.  Whilst there is an accepted understanding within ERTOA that each IRC has limited membership, the requirement for each IRC to have a specific “balance” of members (i.e. one industry association, one union, etc.) is seen as a restriction which has the potential to reduce the information the IRC is able to obtain from their members.
In addition, some of those who sit on IRCs are subject to very strict confidentiality, which includes restricting consultation with industry and/or members on the matter under discussion with the IRC.
Another issue is, where consultation is sought, there are very short, and sometimes ridiculously short timeframes allowed for industry to provide their response.  An example of this is the recent changes to the PUA training package.  During this process, the IRC sought feedback from industry bodies on draft units of competency.  In doing so, the industry bodies were allowed 24 hours to provide feedback on the draft units of competency provided, which was often up to 30 at a time.
The combination of the above practices leads to decisions being made on the fly, which are more personal decisions than industry decisions.  
ERTOA believes that a better balance of industry partners on the IRC would assist in broadening industry input into the construct of AQF qualifications and specific units of competency.  However, the greatest change which could be implemented is to allow IRC members to consult with their broader industry groups at the initial stages of consultation, to ensure changes align with industry needs and requirements across the board, not just for a small number of representatives.
ERTOA believes that the current arrangements for industry collaboration through IRCS are hamstrung by the practices noted above, which actively discourages participation by industry and which in turn hamper information being obtained about workforce and skills needs.

Response:

A common complaint of the ERTO environment is that learners are familiar only with the work requirements, processes and procedures of the company who trains them initially, and that the skills learned while completing their qualifications are not transferrable.
ERTOA has long argued that this complaint has no foundation.  Being trained on the job not only provides learners with knowledge, but also the environment in which to apply that knowledge.  They learn how to find and follow processes and procedures, complete their job role to a high level of expertise and often work in a team environment.  Should that learner transfer to another organisation, they will undoubtedly need to learn the employer specific policies and procedures to complete their job role, but all the skills they have learned with their first employer will transfer and assist a smoother transition for such an employee.  
Understanding that all employers benefit from training their employees, whether they remain with that employer or not, may assist with breaking down silos.   Accepting that an employee who has been trained in another organisation will be onboarded into subsequent organisations with existing and transferrable skills should be considered to improve cross-industry collaboration, as many industries can benefit from training provided outside of that industry.  

Response:

ERTOA believes the simple answer to this is no.  Many of our responses above have led to the current situation whereby qualifications are not fit for purpose. 
In light of the lack of effective consultation and collaboration with industry noted above, units of competency are overly prescriptive and, in several instances, cannot be met by all industry members.  An example of this is TLI42615 Certificate IV in Train Driving, which is used in industry to qualify train drivers on a rail network.  This qualification contains a core unit TLIB3075 Inspect and prepare a motive power unit, which states in the Performance Evidence as follows “Checking and replenishing fluids and carrying out lubrication requirements on a motive power unit”.  The rail industry dictates that maintenance of motive power units is done by engineers, not train drivers.  Additionally, lubrication requirements on an electric engine are incredibly limiting.  However, with this unit of competency being a core unit in the qualification, and an industry benchmark for train drivers, such requirements are very difficult to achieve in a live environment, even more so the second requirement when working with a fleet of electric trains.
True and broad industry consultation at the outset of training package development would help alleviate these problems, as members of industry understand there are other applications to which a unit of competency may apply and should accordingly build flexibility into both units of competency and qualifications.

Response:

1.	ERTOA 
The Enterprise RTO Association (ERTOA) was formed in late 2006 and represents enterprises with embedded Registered Training Organisations (RTOs).  ERTOA has two broad aims:
1.	Support and assist the member enterprise RTOs and their staff to operate effectively and efficiently by enabling members to:
 	seek advice, exchange ideas and experiences with colleagues from other organisations on all aspects of setting-up and running an enterprise RTO;
 	participate in regular meetings with colleagues from other enterprises to discuss issues of concern, exchange ideas and give and take advice; and
 	participate in, and contribute to, an association that has a mandate to commission and publish research on specific issues facing enterprise RTOs (ERTOs).
2.	Provide formal representation and promote the interests of member enterprise RTOs by:
 	interacting as an association, and in a coordinated way, with State Training Authorities, Industry Skills Councils, Department of Education Science and Technology and other Vocational and Technical Education (VTE) players, on the issues faced by enterprise RTOs in order to promote greater recognition of enterprise RTO activities and interests;
 	participating as a formal association with a ‘seat at the table’ whenever discussions occur, and decisions; and
 	influencing the Australian VTE sector regarding enterprise RTO issues and interests.
3.	ERTOA is in the perfect position to comment on this discussion paper, as our members are industry, the employer, the trainer and the end user of the trained staff.  
The membership of ERTOA has grown since it was formally incorporated as an association and as at February 2021, stands at 53.  These 53 members employ over 1 million Australians or 1 in 10 working Australians.  
More information and a full list of members is available at:  www.ertoa.org.au
2.	Background
ERTOA members opt to maintain ERTOs as an enabler for them to do their business better.  Most members have a limited scope of registration closely aligned to the main job roles their staff perform.  A small percentage of ERTOA members maintain their ERTOs because of their specific industry compliance needs (e.g. members from the Financial Services Sector) or to assist them in employing trainees.
The majority of ERTOA members receive no government assistance in providing training to their staff and to move staff towards either nationally recognised qualifications, or unit(s) of competency (UOC) from those qualifications which align specifically to job roles within their businesses.
ERTOA members make a very considerable contribution to skilling Australian workers.  The most recent survey of ERTOA in 2019  (reflecting 2018 data) showed over 54,000 qualifications issued in the calendar, comprising over 670,000 UOC.
Many ERTOA members maintain exemptions to reporting AVETMISS data, due to the nature of their businesses.  Given this, a significant amount of training and assessment activity being undertaken by ERTOs is not captured in the annual Total VET Activity Reporting. (TVA).