INDUSTRY TRAINING REVIEW:
Summary of submissions received on the Consultation Document - Proposal to improve the performance of the Government’s investment in industry training
Table of contents
Table of contents 2
1. Introduction and background 3
2. ITO functions and roles 8
QUESTION 1 Arranging training and clarifying expectations 9
QUESTION 3 Increasing expectations of completions 16
QUESTION 4 Skills leadership 22
3. Apprenticeships and traineeships: definitions and funding 31
QUESTION 5 Higher subsidies for apprenticeships 32
QUESTION 6 Extending apprenticeship support 38
QUESTION 7 Options for apprenticeship co-ordination fee 41
4. Industry training at higher levels and transferability across sectors 47
QUESTION 8 Increasing training at levels 5 and 6 47
QUESTION 9 Transferring between tertiary sectors 52
5. Quality assurance 57
QUESTION 2 Standard settings 58
QUESTION 10 External moderation and managing consistency of graduate outcomes 63
QUESTION 11 Quality assurance settings 69
Appendix: Submissions received 78
1. Introduction and background
1. On 1 August 2012, as part of the ongoing policy review of industry training, a consultation proposal was circulated for public comment. The proposal:
· clarified the roles of Industry Training Organisations (ITOs)
· increased the performance expected from ITOs
· linked industry training to employment and education work-streams to strengthen the dynamics between education, employment and industry
· enabled learners to transition more easily between employment based and other types of training.
To guide feedback the consultation paper asked submitters 11 specific questions about the proposed changes to industry training.
2. We have grouped the proposed changes in the consultation document into the following areas:
· ITO functions and roles
· apprenticeships and traineeships: definitions and funding
· industry training at higher levels and transferability across sectors
· quality assurance.
The remaining sections of this report briefly outline the proposals in each area and summarise the feedback.
3. Consultation closed on Wednesday, 12 September 2012. A total of 332 submissions were received from:
· 187 employers (189 submissions)
· 54 industry associations
· 23 ITOs (including the Industry Training Federation)
· 25 tertiary providers (including peak bodies)
· 9 independent Modern Apprenticeship Coordinators (MACs)
· 32 other submitters.
Overall summary of responses
4. Responses to the consultation document generally supported the proposals.
5. The proposal outlining options for the apprenticeship coordination fee was the most contentious. Most independent MACs were strongly against both proposals to change the funding rates. The MACs contend the proposed changes would give ITOs a monopoly of modern apprenticeship coordination and eliminate independent MACs.
6. The proposal to open up skills leadership to non-ITO organisations also caused some controversy. Most employers’ submissions were against this proposal, while there was only mixed support from industry associations. However, this may have been because the intent of the question was misinterpreted by some submitters as removing the skills leadership function from ITOs, whereas the purpose of the proposal was to open up skills leadership to other organisations.
7. Some of the issues raised, such as implementing a working group on the governance of ITOs, were outside the scope of the proposals in the consultation document.
8. Although we endeavour to provide some evidence of the number of submitters supporting different proposals or voicing the same argument, some caution needs to be taken in interpreting these numbers. Many responders made submissions on one or two proposals only, so the number of responders on many proposals is smaller than the number of non-responders. In addition, of the 189 submissions from employers, 130 came from Competenz-linked employers. Most of these employers made submissions on a standard form letter provided by Competenz. The views of Competenz-linked employers may not be representative of the employers’ views more generally.
Employers
9. Responses were received from a wide variety of employers ranging from large employers with more than 600 employees, to small-owner operators. Employers who responded operate in a variety of industries including construction, care, dairy, energy, engineering, food, maritime, service, tourism, and hospitality.
10. In general, employers supported the proposals. However, they detailed the following areas of concern:
· the importance of aligning training with industry requirements
· the lack of recognition of the in-kind costs employers bear in training
· the importance of retaining current levels of funding for levels 2 and 3 as employers were concerned focus on higher-level qualifications may marginalise foundation levels
Industry Associations
11. There were 54 industry association submissions.
12. Industry associations support ITOs retaining arranging training. They state strong support for ITOs being responsive to industry and being recognised and incentivised for this.
13. Industry associations support increased completion targets. However, they were concerned higher completions should not be at the expense of lower level qualifications. They stressed it was important levels 1-3 qualifications retain their importance and that there will be no decrease in quantity or funding of these. Moreover, the measures adopted for measuring completions should be linked to industry.
14. Industry associations expressed mixed feedback on the skills leadership function proposal. Some support the proposal to make skills leadership more industry focused, while others think ITOs should retain this role or advocate a combination of industry and ITO responsibility for skills leadership.
15. There is widespread support for introducing a higher apprenticeship subsidy rate. Industry associations also strongly support extending apprenticeship support to all apprentices, but this should be balanced with protecting youth involvement in the scheme.
16. Industry associations were split over whether they favoured an incorporated apprenticeship co-ordination fee or a separate fee. An incorporated fee is seen as easy to administer and more cost effective, but there is a concern how this would affect transparency and independent MACs.
17. Industry associations generally support allowing a greater volume of industry training at levels 5 and 6 and increased transferability for learners.
18. Industry associations hold a range of views on how external moderation should be conducted and how to manage the consistency of graduate outcomes. In general, industry associations agree that the whole training system is dependent on high quality, consistent moderation and the moderation system must therefore be simple, robust and reliable. There is also general support for a common currency of learning and skills.
Industry Training Organisations
19. There are 23 ITO submissions. ITOs are generally supportive of the overall direction of the proposed changes.
20. The main points ITOs raised include:
· ITOs strongly support themselves retaining the functions of arranging training and setting standards.
· ITOs strongly indicate that they do not wish to lose the skills leadership role. They want to remain involved in this role, either in partnership with industry or retaining complete responsibility for this function.
· ITOs want to ensure that any changes in completion targets are industry-led and meet industry needs. They suggest flexibility of targets to take into account the realities of industry work flow including different learning situations and learner groups.
· ITOs support increased funding for industry training. They also strongly support developing a simple, clear definition of what an apprenticeship is.
· ITOs are generally supportive of increasing provision at levels 5 and 6. However, many question why a cap is needed, at all.
· ITOs are generally supportive of recognising completions for learners who transfer between tertiary sectors. However, many ask how this will work in practice.
· ITOs agreed that consistency in qualification outcomes in individual standards is important and that at least some external moderation needs to be retained to ensure industry confidence in the system. However, there were a range of views on how external moderation should be conducted and how to manage the consistency of graduate outcomes. There was also general support for a common currency of learning and skills.
Tertiary Providers
21. There were 25 submissions from tertiary providers.
22. Providers maintain there is the need for a clear distinction between what constitutes ‘arranging’ and ‘delivering’ training. They were concerned that ITOs circumvent the rules restricting them from delivering training.
23. There was mixed feedback on whether ITOs should retain their role as standard setters because of the conflict of interest between ITOs not only setting standards, but also arranging training.
24. Providers generally supported the other proposals. They support a review of unit standards and suggest uptake of unit standards is currently limited by factors such as unit standards being too task specific or detailed. A common currency was also widely supported as this would benefit employers by ensuring more accurate expectations of what an employee can bring to the workplace.
Independent Modern Apprenticeship Coordinators
25. Nine independent modern apprenticeship coordinators (MACs) made submissions on the consultation document.
26. The greatest concerns of the MACs were with the proposal 7, options for the apprenticeship coordination fee. Most MACs rejected both options proposed, as they considered this would give ITOs a monopoly of modern apprenticeship coordination and eliminate independent MACs. They argued this proposal was inadequate given the poor performance of many ITOs and previous accountability concerns over their performance.
27. Responses to other questions also reflected independent MACs concerns over poor performance and accountability of ITOs. In the view of many MACs, ITOs focus on minimising cost and maximising revenue, rather than on supporting quality training. Given the poor past performance of ITOs some MACs questioned whether ITOs should retain their arranging training role. Although there was some support for additional funding of apprenticeships, there was also concern over how of this funding would be spent by ITOs.
Other submitters
28. There were 32 submissions from other organisations or individuals. These came from a wide variety of submitters, including central and local government agencies, consultants, unions, Crown entities, and private individuals. Eight of these submissions primarily address training for emergency management personnel.
29. There are few over-arching themes from submitters in this category. However, many submitters did indicate their overall support for the directions outlined in the proposals. One theme that did emerge across questions was the value placed on training at levels 1-2. There is strong support for ensuring that any changes to the current system do not undermine provision and quality at this level.
Emergency management
30. There are serious concerns about whether the proposals meet the needs of a coordinated emergency management sector. Submitters stated that the proposals do not take into account that in emergency management the majority of trainees are volunteers and their service provides a public good to the community. The aim and types of training are also different compared to workplace training generally is the focus of training is not to increase productivity, but to ensure they are ready for action in the event of an emergency.
31. Several of the submitters support Emergency Management Qualifications’ (EMQUAL) proposal for the creation of standard setting bodies alongside ITOs. These bodies would align training standards, but have no responsibility for arranging and delivering training. Seven submitters support EMQUAL as the best organisation for this role.
2. ITO functions and roles
Proposals
ITOs focus on providing excellent service and support to employers and trainees.
Higher expectations of qualification and programme completions for ITOs.
Industry will be responsible for communicating skill needs to Government, with support from the Ministry of Business, Innovation and Employment (MBIE) and the Tertiary Education Commission (TEC).
Overall
32. Most submitters agree with clarifying expectations of service to employers and trainees of ITOs. It is felt this would help to improve the consistency of performance and accountability.
33. In general, submitters support ITOs retaining their function of arranging training. ITOs are seen as best placed to arrange training due to their industry focus and institutional knowledge.
34. Providers and employers commented that the main risks of this proposal relate to the variability of service between ITOs and the extent of ITO coverage across industries and geographical locations. Some MACs questioned whether ITOs should retain their function of arranging training given their previous poor performance.
35. ITOs claim that defining too narrowly services and support could stifle innovation and flexibility.
36. A higher completion expectation for ITOs is also well supported. Submitters state that this would provide many benefits including improving returns on investments in industry training, increasing skill levels and encouraging improved cooperation between ITOs and tertiary providers.
37. Industry associations, employers, tertiary providers and ITOs all express concern that an emphasis on higher-level qualifications might marginalise levels 1 and 2 qualifications. Moreover, employers and industry associations commented that focusing on completions might lead to too much emphasis on qualifications rather than skills that add value. Another risk identified by independent MACs is that this might result in ITOs ‘dumbing down’ qualifications to achieve completions and too much emphasis on short-term targets.
38. There was a lack of consensus on the proposal to open up skills leadership to non-ITO organisations. On the one hand, some said this would improve links between industry and Government and make training more relevant. Independent MACs thought this would lead to improvements in skills leadership. On the other hand, most submitters are concerned over how small businesses or certain sectors would have a voice in this process and how this would be implemented. Many submitters feel ITOs are better placed to continue to represent industry, rather than industry providing skills leadership. ITOs and industry associations note the skills leadership role is neither well-defined nor funded.
QUESTION 1 arranging training and clarifying expectations
In your view, what are the benefits and risks for employers and trainees in your industry of retaining the arranging training role of ITOs and clarifying expectations of service to employers and trainees?
Employers
39. The majority of submitters, 160 of the 188 employer submissions, support their ITO and note the value ITOs bring to business. Reasons for this support include: connections between ITOs and individual businesses; cost efficient and effective service provision; and active engagement with employers in facilitating training opportunities.
We value the roles ITOs have in arranging industry training and ensuring a high quality of delivery is adhered to for both on- and off-job learning within the industries we operate in. We strongly value the trainee/apprentice coordination service provided by ITOs which provides effective direction and monitoring for our learners at this level. Downer New Zealand
40. ITOs’ collaborative approach is valued by a wide range of employers, including members from the engineering and food industries, particularly when arranging on-the-job training. Employers emphasise the importance of on-site, employer-led training, as it is efficient, convenient and well-aligned to job requirements. Employers also collaborate with ITOs to develop learning materials.