Skills for All Funded Training List – Views on the Consultation Survey

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Note: this blog post is quite long (and so is the survey), the headings should help you get to the bits you are interested in, the post mirrors the survey and I’ve included my responses representing WPAA and Workforce BluePrint and based upon our practical experience.

Please let me know what you think, do you agree, disagree or have you got an entirely different perspective?

On the back of the South Australian State Government 2012-13 Mid-Year Budget Review outlining major employment, training and skills savings,consultation about the composition of Skills for All Funded Training List in Feb 2013 is underway from 19 December 2012 to 21 January 2013.

The main activity for the consultation is by completing the Funded Training List Consultation Survey but first you must read the proposed changes to Funded Training document and the Proposed changes to Skills for All based on demand? blog post.

Starting the survey

Weird is one way to describe the survey, there isn’t an intro to it at all or an indication as to how many questions there are or what will actually happen with the information you provide.

Skilled Trade WorkersTo start with you are asked to enter your organisation’s details including name and addresses plus type of organisation which I would have though needed a drop down box to choose a category so data could be analysed from different perspectives.  Contact officer details come next but there’s no statement about what will happen with your contact details, is this for follow up or further communication?

Training Package

The third question asks for Training Package details???  Is this meant for Registered Training Organisations? Employers? Learners? Industry? What happens if you want to make comments about multiple qualifications from different Training Packages on the proposed changes list?  It’s a mandatory question and I’d suspect that many respondents would drop out here as it also asks for the course name, code and ANZSCO code.  Why ANZSCO code when the proposed changes to Funded Training List in Feb 2013 doesn’t even have this as a column in the table?  Course code is not included in the table either.  I’ve worked in Vocational Education and Training (VET) for over 18 years, WPAA are VET specialists and had to go searching for this info.

Although I want to give feedback about a number of qualifications (called courses in the table) I have to choose one.  So I’m going to make my comments on the Certificate IV in Occupational Health and Safety as I strongly feel this shouldn’t have enrolments ceased (or have the action ‘cap’ against it).

The Training Package box should be a drop down list (with the correct titles) as I think in the results you could get all sorts of strange packages.

Job Openings

After hitting next there is this statement about job openings,

The number of job openings is derived from the methodology developed by the Training and Skills Commission. Job openings occur from growth in the industry or occupation and from replacement demand, where replacement demand arises from people retiring or from people leaving the occupation to work in a different occupation. 

The predicted number of job openings relating directly to the course is outlined in the document ’Skills for All Courses Proposed for Capping’.

If you do not agree with the number predicted, please complete this section with the data sources of any research or provide independent corroborating evidence.

OK this is where I have a big problem with the underpinning approach to the formula, evidence for job openings and the relationship with proposed course capping.

Skills for All?

Firstly, Skills for All is for “All” this includes job seekers and existing workers so why just focus on job openings.  In South Australia we know the jobs market is in maintenance mode and/or slightly depressed so where does the skills needs for existing workers come into play?  This is where there is a major gap in intelligence for government planning and policy making.

Certificate IV in Occupational Health and Safety – don’t cap

Secondly a qualification like a Certificate IV in Occupational Health and Safety is not just for ‘Safety Inspectors’ as the Consultation on proposed changes to Funded Training List in Feb 2013 document suggests.  In our workforce projects we refer to skills like workplace health and safety as ‘functional skills’ as many job roles need the same skills and competencies.  Having developed thousands of job skills profiles across many industry sectors through our workforce planning and development work I know that competencies in this qualification (and/or the whole qualification) is needed by most business owners, managers, supervisors and leaders on top of their technical skills.

Why?  Well an obvious answer is that it is an expectation by most enterprises that people, especially those in leadership roles, will have skills in OHS and as an external driver the harmonisation of Work Health and Safety Laws.  From 1 January 2013, South Australia’s work health and safety legislation – which includes the Work Health and Safety Act 2012 (SA) and the Work Health and Safety Regulations 2012 (SA), supported by Codes of Practice – will align with New South Wales, Queensland, Tasmania, the Australian Capital Territory, the Northern Territory and the Commonwealth.  I predict that the demand for this qualification will significantly increase through 2013 as more businesses become aware of these changes and their obligations and this isn’t yet reflected in the Skills for All enrolment figures to date because of the 1.1.13 implementation date.

For a job skills profile you identify common/core skills that are needed for all job roles (some would call these Employability or Foundation Skills), plus Functional Skills (like Occupational Health and Safety, Management, Training and Assessment), plus Job Specific Skills (technical skills, often a group of narrower skills and/or qualification).

Common/Core Skills + Functional Skills + Job Specific Skills = 2-4 Qualifications from multiple Training Packages and across multiple Australian Qualification Framework levels.

The formula of a job role = 1 qualification is flawed, out of date and simply not what happens in reality with enterprises and industry sectors.

Annual Average Job Openings

Next you are asked about the annual average job openings.  To make the survey make sense I’m going to enter the number of people that I believe will need to gain this qualification and/or skills in workplace health and safety at a Certificate IV level.

I’m using the following data source identifying the number of business owners in South Australia.  On top of this figure I could estimate the number of employees that would need these skills and/or qualification but to be conservative I’ll use the ‘business owner’ figure.  From Table 5: Estimated number of small businesses by main state of operation and industry Operating at end of financial year, 2008–09 in South Australia is 138 429.

You are then asked to identify the average number of job openings – predicted future.  Does this mean the number of job openings only in the next year or how far out do I need to predict and then average?

I’m going to take a 1 year view to keep things simple and say how many out of the 138 429 business owners are likely to need development in workplace health and safety.  Based upon our training needs analysis work we are finding around 80% of business owners need updated/new skills in occupational health and safety, so I’ve entered 110 743.

Safework SA should be a good source of data on the training needs of SA Business Owners and workplaces however I couldn’t find a report or analysis of training needs, rather resources that address issues for small businesses.  The Australian Work Health and Safety Strategy 2012-2022 outlines a number of action areas and strategic outcome including:

Health and safety capabilities – Improved work health and safety capabilities;

  • Everyone in a workplace has the work health and safety capabilities they require.
  • Those providing work health and safety education, training and advice have the appropriate capabilities.
  • Inspectors and other staff of work health and safety regulators have the work health and safety capabilities to effectively perform their role.
  • Work health and safety skills development is integrated effectively into relevant education and training programs.

And for leaders:

  • Communities and their leaders drive improved work health and safety.
  • Organisational leaders foster a culture of consultation and collaboration which actively improves work health and safety.
  • Health and safety is given priority in all work processes and decisions.

Duration in the Occupation

Duration in the occupation is the next section of the survey with the following statement,

People who complete the course may decide to work in the occupation that is specified in the document ’Skills for All Courses Proposed for Capping’. We are interested in understanding replacement demand for particular occupations so please complete this section to indicate the duration that an individual may on average work in the occupation.

Continuing with business owners that require occupational health and safety skills, perhaps the replacement demand calculation makes a bit more sense however to answer you need to know graduate destination data and turnover figures for three years or more.  Now does this question relate to new and/or existing workers as a ‘graduate’ could be both?  Lifting the lid on completion rates in the VET sector: how they are defined and derived outlines the following average completion rates:

Table 3 Latest completion rate estimates for VET qualifications Cohort Commencing in Projected qualification completion rate (%) Subject load pass rate (%)
Students enrolled in AQF qualifications 2008 28 80
Full-time students aged 25 years and under enrolled in AQF qualifications 2008 37 78

Note: AQF = Australian Qualifications Framework

Source: NCVER (2011b).

The average completion rate varies from 28-37% so I’ll take 28% to be conservative and then we need to predict the number that will work in the specified occupation (business owner) remembering we are talking about existing businesses, this equates to 31 009.  The likelihood of completing a VET qualification 2005-07 is useful too (although a few years old) as it provides figures via states and territories, qualification levels and fields of study.

Retention rates in occupations is difficult to source so I’ll look at business success rate with recent reports suggesting 60% of existing businesses in 2007 were still operating 4 years later, so my figure goes down to 18 605.

Occupational Classification

The survey then says,

The occupational classification assigned to the qualification is derived from official information from If it is deemed that the occupational classification is incorrect, please provide information from the industry or professional association of the most appropriate occupational classification.

You can add an alternative occupational classification and then the name and contact details of industry or occupational body providing information so here I’ve added Business Owners and the SMART Business Association that I chair, Worksafe Australia and IBSA’s Business Services 2012 Environmental Scan.

Questions 14 and 15 state:

If a course is a specific requirement for an occupation that is not listed on the document ’Skills for All Courses Proposed for Capping’, please provide evidence of research that shows the proportion of people working in the occupation that possess the qualification for the occupation.

Proportion of people working in the occupation with the specific qualification and Data source.

I really don’t get the purpose of this question so I’ve left it blank.

Additional Occupations

With question 16 we get to the heart of my evidence based argument (but there was no indication earlier in the survey that this would even be asked),

There may be additional occupations that make use of the qualification. Provide an indication of these additional occupations and the industry in which they are employed.

Occupation and Industry/Industries

Business Owner – All industries is my response.


Then we’re onto ‘Enrolments’:

Under Skills for All there has been growth in the number of enrolments in many courses compared to the same period last year. In some cases this growth indicates that there has been a shift from privately funded activity (no State Government funding) to Skills for All funding. The aim of Skills for All is to increase the number of South Australians with post-school qualifications so Government funding should complement, not replace, privately funded activity. 

Where there is evidence of substitution of private levels of funding, course enrolments under Skills for All will be capped. A large fall in privately funded enrolments together with a rise in the number of enrolments under Skills for All suggests substitution is occurring. The estimated fall in privately funded activity is outlined in the document ’Skills for All Courses Proposed for Capping’.

The total number of privately funded enrolments may not be captured in this analysis. If you disagree with the estimated decrease in privately funded activity, please provide information regarding training providers who are delivering the qualification and the number of their privately funded students.

Who other than the providers themselves would know this information?

On the issue of conversion and funding substitution, this is where I’d like to make significant comments but this survey only has the opportunity to enter examples of provider names and contact details where this is happening.  For a true analysis of the trends a month by month picture of enrolments over the past 24 months or so together with data on whole VET effort for South Australia (which doesn’t exist as only publicly funded programs are reported and aggregated) prior to the introduction of Skills for All is really what is needed.

In my Skills for All observations blog I said,

..Skills for All [was] a number of months in the making and RTOs held off new enrolments over this period as they wanted students to benefit from the new funding arrangements.  This has meant a significant conversion of enrolments in a short time and I do not think this is truly reflective of actual demand, that is demand that built up over 9-12 months all converted in 2-3 months.

The transfer of privately funded VET into publicly funded VET via Skills for All is a fundamental change to the VET market and client expectations (i.e. access to subsidised places) which was totally foreseeable.  I could never understand how (or if) financial forecasts for potential Skills for All implementation scenarios were undertaken with the VET market opportunities so open for individuals.

As an example I have a Master of Education as my highest qualification (I must admit I like the idea of Dr Perry so I am considering a Doctorate) and I can undertake any qualification on the Skills for All funded list, 1 skill set/year and any number of priority courses.

Government Priorities

Now the survey moves to government priorities:

Skills for All funds courses that are in priority sectors for the State Government. Please indicate what specific government priority is being addressed by the course and how.

Government Priority:

South Australian state Strategic Plan – Improving wellbeing with a clear focus on the safety of South Australians in all aspects of their lives; and Goal: We are safe and protected at work and on the roads – Target 21: Greater safety at work

Achieve a 40% reduction in injury by 2012 and a further 50% reduction by 2022 (baseline: 2001-02).

How is it being addressed: Certificate IV in Occupational Health and Safety plus Safework SA programs.

The Skills for Jobs 5 Year Plan 2012 states,

…factors impacting on the demand for labour such as new technology, environmental concerns and workplace health and safety legislation mean that these workers require access to skill sets [qualifications – Wendy’s note] to be able to adapt to this changed environment if these sectors are to survive in South Australia. (p. 11)

Issue and impact of decision to cap

Question 23 in the survey asks you to provide a concise description of the issue and an indication of the impact of the decision to cap enrolments in the course based upon this explanation:

The analysis outlined in the document ’Skills for All Courses Proposed for Capping’ is based on information available to the Department. There may be other matters affecting the operation of the training market for the course that may not have been included in the analysis. Particular matters may include impact on specific cohorts, providers or occupations. Please provide a concise description of the issue and an indication of the impact of the decision to cap enrolments in the course.

My response in relation to the Certificate IV in Occupational Health and Safety is that this is a functional skill area required by business owners and numerous employees within enterprises primarily due to the following:

From 1 January 2013, South Australia’s work health and safety legislation – which includes the Work Health and Safety Act 2012 (SA) and the Work Health and Safety Regulations 2012 (SA), supported by Codes of Practice – will align with New South Wales, Queensland, Tasmania, the Australian Capital Territory, the Northern Territory and the Commonwealth.  The Act:

  • establishes health and safety duties, including the primary duty to protect any person from exposure to hazards and risks that arise from work
  • provides for worker representation, consultation and participation including through Health and Safety Representatives and Health and Safety Committees
  • enables compliance and enforcement through SafeWork SA, the regulator, and
  • provides for the creation of regulations and Codes of Practice.

Through our workforce planning projects, training needs analysis, competency framework and professional development program we consistently see occupational health and safety as a priority development need across all industries and job roles.

Other strategies

Number 24 says,

The decision to limit the number of enrolments in a qualification may be complemented by other strategies that ensure that public funds are directed to areas of need and priority. Please indicate any suggestions of strategies that you consider appropriate for the qualification.

My suggestions include:

  • skills and/or training needs analysis to be undertaken by Safework SA or relevant body on the impact of the implementation of harmonised legislation particularly for business owners
  • undertake future skills profiling in the forecasting process to understand the multiple qualifications required for job roles particularly for critical/priority job roles and therefore identify the numbers of specific qualifications required annually (with the flexibility to change based upon external factors and drivers such as the economy and legislation)
  • differential subsidies for job seekers, new and existing workers including business owners
  •  validation and support for functional skills required by multiple job roles including occupational health and safety, management, training and assessment and reflection in maintain related qualifications on the Skills for All funded list
  • sharing of information from our work with practical examples of skills demand and job skills profiles where 1 job role does not = 1 qualification
  • redesign of this survey to be more user friendly with explanatory notes and the opportunity to make further comments
  • making transparent the definition of ‘demand’, Skills for All financial forecasting with scenarios and the logic behind the proposed changes
  • independent review and analysis of Skills for All, based upon evidence and implementation identifying areas for improvement

I invite the Skills for All team to contact me via Workforce BluePrint to discuss these suggestions.

Recognition of Prior Learning (RPL)

There’s more with question 25 on RPL,

Recognition of Prior Learning (RPL) does not lead directly to an increase in skill levels but does allow for recognising existing skills to encourage continued studies. 

Training providers have been informed that a qualification achieved solely through RPL is not considered a quality outcome under Skills for All as it would be a better outcome for the student to have been enrolled in the higher level course and experience some skill development.

Training providers must ensure students are assessed and guided appropriately on to the right course for the student as there is no subsidy for RPL at Certificate I and II levels and these courses will remain fee free for the student.

The Government is proposing to stop funding RPL at lower levels (Certificates I and II).

It is the Government’s view that if a significant amount of RPL is required at these course levels, the student is not enrolled in the most appropriate course for them.

All interested parties are invited to submit feedback using this survey.

Please provide information and specific examples where funding for RPL at Certificate I and II course levels is warranted.

Having been a long supporting of RPL as a skills stock-take, learning and confidence building process I’d make the following comments,

I disagree with the statement of the purpose of RPL as there are many motivations (not just continued studies) for RPL including:

  • Australian Apprenticeship
  • Career change
  • Compliance
  • Job requirement
  • Job seeking
  • Labour market re-entrant
  • Legislation/regulation
  • Licensing
  • Overseas recognition
  • Personal interest
  • Skill improver
  • Upgrade industry currency

RPL should occur at the qualification level appropriate for the person and the job role or job opening.

It is inequitable and unnecessary to stop funding RPL at lower levels however a lesser rate or percentage of funding or co-contribution may be an answer.  RPL at these AQF levels is mostly important for those individuals how have no formal qualifications, this may include job seekers, those returning to the labour market or those people with multiple barriers to employment or career development.  Another cohort who would be disadvantaged is school leavers as they may have developed skills through part-time work that when formally recognised could improve their chances of employment and entry into higher level qualifications.  The other area to consider is where a Certificate I or II (and/or units from these qualifications) may be prerequisites for higher level units of competency or qualifications.  Having run a number of RPL projects and developed profiles for disadvantaged groups, school leavers and retrenched workers I know that gaining a Certificate I or II via RPL increases people’s confidence and workforce participation rates.


Finally the end of the survey with this declaration:

*26. I declare that the information is, to the best of my knowledge, true and correct. I acknowledge that DFEEST may use the information provided by me to investigate this issue. I understand that this information may be used for investigative, data analysis and further Skills for All analysis purposes. I understand that DFEEST may contact me in relation to this matter.

YES please! BUT how do I now make comments about all the other qualifications I’d like to give feedback on?

PS. I’m not going to do he survey again, it took me a few hours!

Written by: Wendy Perry, Head Workforce Planner, Workforce BluePrint and VET Specialist, WPAA.

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