submission 64

8/4/2019 Submission 64

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Strengthening the AQF

CCI Submissionto theConsultation Paper

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Strengthening the AQF:

A Framework for Australias Qualifications

Submission to July 2010 Consultation Paper

August 2010

Prepared by the Chamber of Commerce and Industry of Western Australia


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Table of Contents

Abbreviations................................... ..................................................... ......................... 3

About CCI .................................................. ........................................................ ............. 4

Context ...................................................... ....................................................... .............. 4

Executive Summary.............................................. ........................................................ . 5

The Proposed Australian Qualifications Framework.................................................. 6

Nomenclature...................................... ........................................................ ................... 7

Senior Secondary Certificate of Education ........................................................ ......... 9

Australian Qualifications Framework Policies.......................................................... 12

Draft AQF Generic Skills Policy............................................................................................... 12

Draft AQF Qualifications Issuance Policy.............................................................................. 13

Draft AQF Qualifications Pathways and Linkages Policy..................................................... 14

Endnotes ................................................... ..................................................... .............. 15


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Abbreviations

ANZSCO Australian and New Zealand Standard Classification of

Occupations

AQF Australian Qualifications Framework

ATAR Australian Tertiary Admission Rank

CCI Chamber of Commerce and Industry of WA

SSCE Senior Secondary Certificate of Education

VET Vocational Education and Training

WACE Western Australian Certificate of Education


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About CCI

The Chamber of Commerce and Industry of Western Australia (CCI) is the leading

business association in Western Australia.

It is the second largest organisation of its kind in Australia, with a membership of

almost 6,000 organisations in all sectors including manufacturing, resources,

agriculture, transport, communications, retailing, hospitality, building and

construction, community services and finance.

Most members are private businesses, but CCI also has representation in the

not-for-profit sector and the government sector. About 80 per cent of members are

small businesses, and members are located in all geographical regions of WesternAustralia.

Context

In an environment of anticipated labour and skills shortages, it is imperative that

Australia has a robust and flexible education and training system that ensures

employers can access suitably qualified workers and is internationally competitive.

Improvements that lift the overall performance of Australian education andtraining will deliver strong outcomes and be responsive to the needs of industry.

Education and training plays an important role in increasing workforce

participation, upskilling existing workers and educating the future workforce

through the provision of flexible achievement options and transparent pathways.

This submission builds upon a number of CCI papers. These include:

Strategies for Growth;

Building Western Australias Workforce for Tomorrow; and

Building a Better Tomorrow: Education Reform in WA.


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Executive Summary

The proposed Australian Qualifications Framework (AQF) provides employers

with explicit direction on the knowledge, skills and application that aredemonstrated by holders of specific levels of qualifications. However, a number of

important issues must be addressed to achieve national consistency and common

understanding among all stakeholders. These include:

inadequacy of consultation with key stakeholders such as industry and

employers;

misrepresentation of the Senior Secondary Certificate of Education in the

proposed framework; and

lack of consistency with current industry practice and employer expectations.

In addressing these issues, the following recommendations are made in this

submission:

1. The AQF Council should consult over a longer timeframe and adopt a

transparent process that actively seeks input from all stakeholders, including

employer groups.

2. The types of work in the level summaries and the purpose statements of each

qualification type should be consistent with the Australian and New ZealandClassification of Occupations (ANZSCO) skill level descriptions.

3. The Senior Secondary Certificate of Education should be spread across

Level 13.

4. The generic skills listed in the Draft AQF Generic Skills Policy should be

limited to employability skills.

5. In developing a policy on reporting qualifications and achievement, employers

should be consulted on the information they need to effectively assess a

potential employees qualifications.

6. The AQF Council should correct inconsistencies in policies on credit transfers

and implement a quality assurance mechanism to ensure its consistent national

application.


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The Proposed Australian Qualifications

Framework

Industry has clear expectations of the level of proficiency that workers who hold

specific qualifications can demonstrate. Employers use this understanding when

assessing potential workers for suitability and matching job roles to qualifications.

Industry welcomes the opportunity to provide input into the proposed AQF.

However, the consultation period for the July 2010 paper is too brief. The final

face-to-face briefing was held in Melbourne on 29 July; the closing date for

submissions is 4 August. This timeframe is too short to enable detailed and

considered responses.

Consultation must involve all stakeholders who will be affected by the proposed

AQF, including employers. Education and training providers have specialised

expertise that should be utilised in the consultation process. However, the

consultation process has been biased towards this group of stakeholders.

The AQF Council should adopt a more transparent consultation strategy that

actively seeks input from all stakeholders. A longer timeframe would provide

opportunity for a detailed and well-considered response. All written submissions

made to the AQF Council should be made public, unless specifically requested not

to by respondents.

Findings: The consultation has been too brief. Additionally, past consultations

have been biased towards education and training service providers and not sought

input from employers.

Recommendation: The AQF Council should consult over a longer timeframe and

adopt a transparent process that actively seeks input from all stakeholders,including industry and employer groups.


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Nomenclature

The AQF defines knowledge, skills, and their application across ten levels. It also

maps qualification types awarded by schools, vocational education and training(VET) providers and tertiary education providers to these levels. The language

used in the proposed Australian Qualifications Framework (AQF) is inconsistent

with industry understanding and expectations.

The level summaries and the qualification type descriptors both use the following

terms to describe the types of work undertaken by graduates at particular levels or

of specific qualifications: skilled work; paraprofessional work; professional or

highly skilled work; and professional practice.1

However, definitions for these

terms are not provided in the Glossary of Terminology. This lack of clarity may

cause confusion among employers applying the proposed AQF to their workers.

The Australian and New Zealand Standard Classification of Occupations

(ANZSCO) is a system that employers are familiar with and is widely used both

by individual States/Territories and nationally. The Australian Bureau of Statistics

(ABS) uses ANZSCO to classify occupations into five skill levels. Its key feature

is that it takes into account knowledge and skills, and the application of knowledge

and skills demonstrated through previous work experience and on-the-job training.

ANZCO is used by State and Federal government departments and

non-government organisations in a variety of contexts. Examples include:

Department of Immigration and Citizenship ANZSCO is used to

differentiate between visa classes under Australias skilled migration program;

National Centre for Vocational Education Research ANZSCO is used by

Registered Training Organisations when reporting on VET activities; and

Department of Training and Workforce Development ANZSCO is used in

the State Priority Occupations List to identify jobs that are in high demand and

considered industry-critical in Western Australia.

In describing the types of work that holders of different level qualifications are

able to undertake, the nomenclature used should be consistent with ANZSCO Skill

Level descriptions in order to provide greater specificity and alignment with

industry expectations.


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Findings: Australian and New Zealand Standard Classification of Occupations

(ANZSCO) is already being used in VET reporting and is widely used both in

States/Territories and nationally. It takes into account AQF qualifications and

learning through work experience and on-the-job training.

Recommendation: The types of work in the level summaries and the purpose

statements of each qualification type should be consistent with the Australian and

New Zealand Classification of Occupations (ANZSCO) skill level descriptions.


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Senior Secondary Certificate of Education

The proposal to align the Senior Secondary Certificate of Education (SSCE) with

Level 3 is inconsistent with employer expectations of school leavers. Placing theSSCE at the same level with holders of Certificate III implies that school leavers

have the same knowledge and skills as someone who has successfully completed

an apprenticeship and holds a Certificate III qualification. Placing the SSCE and

Certificate III on the same level will potentially misrepresent school leaver

qualifications to businesses.

Employers are familiar with the Australian and New Zealand Standard

Classifications for Occupations (ANSZCO). While ANZSCO places compulsory

secondary education on the same level as AQF Certificate I, it also allows for

relevant work experience and on-the-job training to be considered when

determining skill level.2

In Western Australia, senior secondary students study courses at one of three

stages; some courses have an additional fourth stage. Generally, there are three

main patterns of study:

Year 11 students who study Stage 1 units progress to Stage 2 units in Year 12;

More capable students study Stage 2 units in Year 11 and Stage 3 units in Year

12; and

Students study only Stage 1 units during their final two years of senior

secondary schooling.

Students who have studied four or more courses at Stage 2 or Stage 3 in their final

year of secondary schooling receive an Australian Tertiary Admission Rank

(ATAR) following the successful completion of external examinations. The ATAR

enables students to be considered for admission into a university. Students who

study Stage 1 or 2 units in Year 12 complete Vocational Education and Training

(VET) through Certificates I, II or III.3


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Chart 1

Year 12 Attainment

WACE students who also study VET

0

5,000

10,000

15,000

20,000

2005 2006 2007 2008 2009

Source: Curriculum Council

0

5,000

10,000

15,000

20,000WACE VET

There is an increasing trend in the VET qualifications being achieved as part of the

WACE (Chart 1). Nationally, the number of students involved in VET in Schools

between 2007 and 2008 increased by 26 per cent.4

In 2009, 33 per cent of students

obtaining a WACE were enrolled in one or more units of competency in Year 12.5

The majority of VET qualifications obtained by these students were achieved at

either Certificate I or Certificate II level, but there is an increasing trend towards

Certificate III and Certificate IV (Chart 2).

Chart 2

VET Qualifications Achieved

Year 12 Students in 2009

Cert I

39%

Cert III

9%

Cert IV

1%

Cert II51%

Source: Curriculum Council


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Industry has specific expectations of the level of competence demonstrated by

holders of different AQF qualifications. For instance, in the construction industry:

outcomes for Certificate II qualifications indicate a labourer who can operate a

narrow range of skills under supervision;

outcomes for Certificate III qualifications indicate independent knowledgeable

tradespeople such as a plant operator or carpenter; and

outcomes for Certificate IV qualifications are employees who can supervise

others.

Placing school leavers on the same level as people with Certificate III

qualifications implies that school leavers are also independent and knowledgeable.

While this may be the case in some instances, this view is not commonly held

among employers, especially in the case of students with minimal or no work

experience.

The current proposal to map the SSCE to Level 3 misrepresents a school leavers

qualification to employers. The SSCE should be spread across Level 13.

Findings: While there are large numbers of school students studying VET, for

those who have not studied VET and have no work experience, industry

expectations of school leavers differ from expectations of holders of AQF

Certificate III qualifications. Placing both qualifications on the same level

misrepresents school qualifications to businesses.

Recommendation: The Senior Secondary Certificate of Education should be

spread across Level 13.


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Australian Qualifications Framework Policies

The draft policies contained within the proposed Australian Qualifications

Framework (AQF) impact on businesses providing education and training services,

as well as general employers. To avoid unnecessary regulatory burden, any policy

changes should be based on the following principles:

justified policies should focus on achieving national consistency and

ensuring high quality outcomes;

transparent the development of policies should be underpinned by a

transparent process that involves extensive consultation with all relevant

stakeholders; and

costs should be commensurate with benefits

any costs associated with thedevelopment of policies, and their subsequent compliance, should be

commensurate with the benefit derived from the policy.

Draft AQF Generic Skills Policy

In Western Australia, the Workplace Learning Course studied in schools is

underpinned by employability skill groups. Similar courses operate in schools

across Australia. In the Vocational Education and Training (VET) sector,

employability skills are embedded in nationally endorsed Training Package Units

of Competency. Compliance with this policy will require changes to the teaching

and/or assessment of school workplace learning courses, nationally endorsed

training packages, and university courses.

The Draft AQF Glossary of Terminology implies that generic skills and

employability skills may be used interchangeably. This is inaccurate.

Employability skills are commonly used and widely understood across education

and training sectors, and industry, and specifically to the following eight areas:

communication;

teamwork;

problem solving;

initiative and enterprise;

planning and organisation;

self management;


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learning; and

technology.6

While generic skills include the employability skills, generic skills extend to other

areas that may be described as social awareness skills. These include areas such as:

being respectful to others; cultural understanding; and having a global perspective.

Some universities include similar skills as part of their graduate attributes.

The supplementing of employability skills with social awareness skills is not

justified. Further, a consequence of having to comply with the Generic Skills

Policy is the cost of having to revise every training package and high school

workplace learning course. The additional skills are already implicit in a number

of the employability skills. For instance, the employability skills of teamworknecessitates that individuals be respectful to others when working in a team. The

industry specific employability skills that are contained within the Training

Packages have been developed in collaboration with industry. Using the current

Employability Skills Framework provides a more focussed context within which to

develop these social awareness skills.

Findings: Employability skills are widely used and understood among education

and training providers, and industry. They underpin workplace learning courses

that are offered in secondary schools, and are embedded in Training Package

Units of Competency. Generic skills are broader than employability skills,

extending to areas of social awareness.

Recommendation: The generic skills listed in the policy should be limited to

employability skills.

Draft AQF Qualifications Issuance Policy

Industry welcomes national consistency on the information that is reported on

qualifications and student achievement. However, there has been a lack of

consultation seeking employer input. The AQF Council should seek input from

employers on the sorts of information they require to effectively assess a potential

employees qualifications.

Recommendation: In developing a policy on reporting qualifications and

achievement, employers should be consulted on the information they need to

effectively assess a potential employees qualifications.


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Draft AQF Qualifications Pathways and Linkages Policy

An effective national Qualifications Pathways and Linkages Policy makes it easier

for employers to transfer workers between different States/Territories. Further,

nationally consistent policies on credit transfers also enable effective articulation

between education and training sectors, irrespective of States/Territories.

There are currently contains two draft policies dealing with credit arrangements on

the AQF website: AQF National Policy and Guidelines on Credit Arrangements

and AQF National Policy and Guidelines on Credit Arrangements. Both policies

contain different arrangements for credit transfers. This will cause confusion

among education and training providers, and result in qualifications being awarded

before all course requirements have been met.

The AQF Council needs to correct the inconsistencies and implement a quality

assurance mechanism that ensures that the policy is consistently applied

nationally.

Findings: There are inconsistencies present in Draft Policies dealing with credit

arrangements.

Recommendation: The AQF Council should correct inconsistencies in policies on

credit transfers and implement a quality assurance mechanism to ensure its

consistent national application.


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Endnotes

1AQF Council, Strengthening the AQF: A framework for Australias qualifications,

Consultation paper, July 2010, p.14.

2Australian Bureau of Statistics, Information Paper: Australian and New Zealand

Standard Classification of Occupations, 2005, Catalogue 1221.0, p.13.

3Curriculum Council, The Western Australian Certificate of Education for students

starting Year 11 in 2011, retrieved from http://www.curriculum.wa.edu.au/internet.

4

National Centre for Vocational Education Research, VET in Schools 2008, retrieved fromhttp://www.ncver.edu.au/vetsystem/31111.html.

5Curriculum Council, Year 12 Statistics for 2009.

6Retrieved from

http://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Ov

erview.aspx
http://www.curriculum.wa.edu.au/internethttp://www.ncver.edu.au/vetsystem/31111.htmlhttp://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Overview.aspxhttp://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Overview.aspxhttp://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Overview.aspxhttp://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Overview.aspxhttp://www.ncver.edu.au/vetsystem/31111.htmlhttp://www.curriculum.wa.edu.au/internet

submission 64

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