Strengthening The AQF: A Framework For Australia's Qualifications

Strengthening the AQF CCI Submission to the Consultation Paper
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 ATAR CCI SSCE VET WACE Australian Qualifications Framework Australian Tertiary Admission Rank Chamber of Commerce and Industry of WA Senior Secondary Certificate of Education Vocational Education and Training 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 Western Australia.
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 and training 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 are demonstrated 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 Zealand Classification 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 the SSCE 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 20,000 WACE VET 20,000
15,000
15,000
10,000
10,000
5,000
5,000
0 2005
Source: Curriculum Council
0 2006 2007 2008 2009
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 III 9% Cert IV 1%
Cert I 39%
Cert II 51%
Source: Curriculum Council
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Industry has specific expectations of the level of competence demonstrated by

Strengthening the AQF
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.
CCI Submission to the Consultation Paper
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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 the development 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 teamwork necessitates 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

Strengthening the AQF
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.
CCI Submission to the Consultation Paper
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Endnotes
AQF Council, Strengthening the AQF: A framework for Australias qualifications, Consultation paper, July 2010, p.14. Australian Bureau of Statistics, Information Paper: Australian and New Zealand Standard Classification of Occupations, 2005, Catalogue 1221.0, p.13.
Curriculum Council, The Western Australian Certificate of Education for students starting Year 11 in 2011, retrieved from http://www.curriculum.wa.edu.au/internet.
National Centre for Vocational Education Research, VET in Schools 2008, retrieved from http://www.ncver.edu.au/vetsystem/31111.html.
5
Curriculum Council, Year 12 Statistics for 2009.
Retrieved from http://www.deewr.gov.au/Schooling/CareersandTransitions/EmployabilitySkills/Pages/Ov erview.aspx
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Strengthening the AQF CCI Submission to the Consultation Paper