Raspberry Training

Seems some of you liked my last rant, so since I have an audience to blurt out my frustrations to, I thought I’d grab your ear and keep raving!

Now before I start, I’m not saying I’m a VET guru. I get things wrong, often. I may (likely even) have some of the statements in this blog wrong. I’m happy to debate it out, and happier if I learn something from that debate.

So here goes….my list of things I’ve heard from other VET professionals that I just don’t agree with (and my justifications). And I’m going to say, many of these things (almost all) came from Compliance Managers or other high-level managers.

And before some of you who’ve known me for years say anything, yes, it’s true, I used to believe some of these things myself.

That’s not compliant because:

It’s not sufficient because there aren’t written tasks for every PC

Hang on…the KEs are well covered, and the P in PC stands for “Performance”. And performance can’t be assessed unless someone applies skill (see my last post).  Written questions assess knowledge, the practical skills assess performance.

And here’s a tip from ASQA “Avoid overuse of document-driven knowledge assessment” (page 57 of the User Guide)

Every PC must be covered by 3 different assessment instruments

Wait…what? Can you refer me to that clause?

You must have at least 3 different assessment instruments

See above

Learner guide must state unit code clearly

This one goes back to 2015, but very relevant to 2020. The BSB package had just been updated, and I was adjusting our assessment tools to meet the new package requirements (not that there was a lot of change that time). Anyway, the assessment tools were all adjusted and titled correctly, but because the unit had very little change, and we had a whole pile of purchased learner guides from the old package, we just continued using those learner guides. (side note….and other supplementing learning materials!)

Compliance Manager goes into a spin saying this is a serious non-compliance, and that if ASQA finds out we’re using a Learner Guide with the incorrect code we could have our registration suspended.

Really…..over the letter A. And what standard does that relate to again? And, does that mean that we have to have the unit code on every single piece of learning material we give to a student. Handouts, textbooks, legislative documents etc.

A big nope from me.

The RTO code / UOC code / qualification code is not stated in the footer of every page of the student handbook / information booklet / assessment tool / learner guide

Again, what clause would that be? Yes, the codes (and product names) need to be clearly stated on each of these documents, but there is no compliance requirement for this information to be on the footer or header of every single page.

Best practice…maybe. Non-compliance?…just no.

You need to use the word ‘learner’ not ‘student’ because that’s the term used in the standards

Actually, no its not.  The User’s Guide uses the term ‘student’ 663 times and the term ‘learner’ 211 times.

And I’m just not even understanding where this is coming from. You don’t like the term ‘student’, fine, but don’t call it a non-compliance for God’s sake!

You can’t use normal assessment instruments for RPL

Well I’m not suggesting we don’t have specific tools for RPL mode, but um…..why can’t I use instruments from a training and assessment tool kit? If it’s a decent role play or observation task, can you explain why the instrument is unusable?

And there is that thing called ‘flexibility’ in the Principles of Assessment…..

Lets be honest, documentary evidence just can’t cover off on every single item in RPL. Sometimes (usually…) we do need to assess that existing skill through other assessment methodologies. (maybe I’ll do a rant on RPL one day….)

Every student must have an LLN assessment

Actually, no. The RTO does need to determine the support needs of individual learners (Clause 1.7), but there is nothing there saying an LLN assessment is compulsory.

LLN assessments are a great tool for assessing the students LLN competencies, and I’m a fan, but its not the only method for conducting assessment of student need. I’d even argue that if it’s the only method being used, that its probably missing a whole bunch of potential needs.

I’ll agree ONLY if there was no other assessment of need conducted. But if appropriate alternative methods were used – suck it up. Its compliant.

Side note – Yes I know this is a requirement in some funding contracts, but this situation was not in that context (nor is this blog)

Know the difference between (your opinion) of best practice, and the actual requirements of the Standards for Registered Training Organisations

You know, we have a whole lot of crap we have to deal with to ensure compliance, but seriously, don’t add stuff that’s not required!

There is a difference between your opinion of best practice, and non-compliance. An RTO can (if they choose to pile on more compliance requirements) make these RTO policies, but don’t confuse your (or your organisation’s) preferences or policies with the requirements of the Standards for Registered Training Organisations.

Cheers

Coleen

Originally posted 18 November 2020