A shared responsibility – Apprenticeships for the 21st century
Final Report of the Expert Panel
A response from Group Training Australia Ltd
March 2011
1. Introduction
GTA welcomes the opportunity to respond to the report of the Apprenticeships Expert Panel. We agree with the panel’s findings and recommendations which are largely consistent with positions held by this organisation and expressed by us in various forums and publications over many years.
We have attached to this submission a copy of an issues paper canvassing the effectiveness of the current Australian Apprenticeships Support Services arrangements which GTA developed following recent consultations with the department on this subject. We believe that our issues paper already addresses many of the questions and topics on which you have specifically invited stakeholders to comment in relation to the report of the Expert Panel. This issues paper is also available at www.grouptraining.com.au < Policy<GTA Policy<Submissions and Issues Papers>.
In this submission we propose to respond to those of the panel’s recommendations where we feel we can add value, and to elaborate on the information in the attached issues paper as necessary.
2. Response to Recommendations
2.1 Recommendation 1
Establish a National Custodian to oversee reform that will ensure Australia has a high quality
Australian Apprenticeships system that:
· responds to the needs of the economy
· supports nationally consistent standards for employment and training of apprentices and trainees
· focuses on retention and completion of apprentices and trainees
· supports high quality skill development to ensure all apprentices and trainees have well rounded and highly respected skills required by the economy.
As a first step an independent taskforce should be established to work with the eight jurisdictions to
align their systems and develop a framework and process for the establishment of the National
Custodian. The taskforce would be led by an independent chair and have a representative from each
state and territory government, a union and an employer group.
GTA believes that the idea of a National Custodian has merit but will be complicated by federation politics if it is to achieve its objectives as outlined in Recommendation 1 and, more particularly, in Recommendation 2.
Recommendation 2 goes to the issue of the crowded and confused market which in large measure is a function of the States and Territories as well as the Commonwealth all occupying this space, and all with their very own training administration requirements. The provision of Australian Apprenticeships Support Services (AASS) through Australian Apprenticeships Centres (AACs) has also not proved to be the one-stop-shop service initially envisaged. AACs have to compete with a range of other operatives in the field who are making demands on employers’ time. These include Group Training Organisations (GTOs), RTOs and the increasing array of people being employed by State and Territory Authorities who all add to a sense of duplication of effort.
As GTA asserts in the attached issues paper little of this effort appears to make any difference to completion rates for apprentices or trainees because so much of the effort is directed at selling and signing up with too little on supporting apprentices, trainees and employers in any meaningful way.
How could the concept of the National Custodian ameliorate this situation? GTA believes that to have any impact the National Custodian essentially needs sovereign powers, or an arrangement of the kind that has facilitated the establishment of the new national VET regulator or the harmonisation of OH&S laws, without which we run the risk of failure to achieve genuine national consistency and efficiency of effort. Whether this could be done by a referral of powers from the States to the Commonwealth, which would surely have to be the national Custodian, or by way of some other mechanism would be up for negotiation.
2.2 Recommendation 2
Enhance the quality and effectiveness of the Australian Apprenticeships system by clarifying the roles and consolidating the number of stakeholders in the system, ensuring that services are provided by the most appropriate provider, duplication of service delivery is reduced and administrative processes are streamlined. The National Custodian would ultimately be tasked with this role and will require Australian and state and territory governments – in consultation with industry, unions and other key stakeholders – to work together. In the interim the independent taskforce would progress this work.
See 2.1 above.
2.3 Recommendation 3
Establish a formal accreditation process for the pre‐qualification and training of all employers of apprentices and trainees to ensure a nationally consistent minimum standard of high quality employment and training is provided. In addition establish an Excellence in Employment Scheme to recognise and reward those employers who have consistently demonstrated their commitment to excellence in training apprentices and trainees.
Recommendation 3 is about improving the capacity of employers to train. GTA’s issues paper developed a market segmentation analysis of the different types of employers of apprentices and concluded that, while some employers have the capacity to train and ensure the employment experience is a satisfactory one for their apprentices, many employers appear to lack this capacity. The Expert Panel has also recognised this as a problem and proposed a formal accreditation process for the pre-qualification and training of all employers of apprentices and trainees to ensure a nationally consistent minimum standard of high quality employment and training is provided.
How might this be implemented? GTA sees two ways in which this might be approached. The first is to mandate that all employers of apprentices and trainees undertake an approved or accredited short course designed to provide them with the basic skills and behaviours required of someone who is in the position of an on-the-job supervisor. Of course this assumes that on-the-job supervisors themselves have the necessary vocational competencies to be able to train in accordance with the requirements of the training plan, something that cannot always be taken for granted and which needs to be better regulated.
There may be a precedent for short courses directed at on-the-job supervisors in the former Training of Traineeship Supervisors and Training of Training Supervisors (TOTS) courses which were developed and funded by the Commonwealth from the late 80s to support the introduction of traineeships and to improve the quality of industry training more generally. GTA understands that, over time, these courses were made voluntary and provided on a fee-for-service basis by TAFE or other providers with some State Training Authorities subsequently assuming responsibility for promoting their use. We are not aware however of any current requirement for any employer to undertake any kind of formal training in this area.
The problem with a mandatory approach is that many supervisors of apprentices are operators of small businesses such as sole traders or sub contractors in industries like building and construction. These people will be disinclined or simply unable to spend time seeking accreditation to be an approved employer of apprentices and trainees and are at risk of opting out of training if forced to do so.
The alternative to this approach, at least for this category of employer, may be to make payment of the Commonwealth employer incentive conditional on an employer’s willingness to be formally assessed for his or her capacity to train and to be mentored during the course of the training arrangement, all of which would be undertaken by appropriately qualified personnel who could ensure that the on-the-job training experience is consistent with best practice.
GTA believes that this latter service is one which the field staff of group training organisations would be ideally placed to provide to employers who employ apprentices directly since it is one they provide to their own host employers. Such an arrangement would have to be sufficiently resourced and some additional training might be necessary but the generally higher completion rates achieved by group training organisations attests to the efficacy of this approach.
Finally, there is some international evidence of employer accreditation schemes for on-the-job trainers and supervisors, although in what precise form is not clear. The recent Productivity Commission draft research report on the Vocational Education and Training Workforce refers to the Ordinance of Trainer Aptitude which applies to the skills and behaviours required of in-company trainers of apprentices in the German dual system[1].
2.4 Recommendations 4 and 5
4. Establish structured support for employers to provide high quality employment and workforce development experiences for eligible apprentices and trainees. The focus of Australian Government support should be on assisting employers to provide high quality on‐the‐job and off‐the‐job training through support services such as mentoring and pastoral care.
5. Redirect current Australian Government employer incentives to provide structured support services to eligible apprentices and trainees and their employers in occupations that are priorities for the Australian economy. While a wide range of occupations should be trained through apprenticeship and traineeship pathways, Australian Government support should focus on occupations that have tangible and enduring value for the economy – both in the traditional trades and the newer forms of apprenticeships and traineeships, such as community services, health services and information technology.
GTA supports the proposal to limit the payment of Commonwealth employer incentives to employers of apprentices in the traditional trades and trainees undertaking selected traineeships. This is consistent with the position GTA has advocated publicly for some time on the use of these incentives. GTA is also open to the idea that eligibility for employer incentives for selected traineeships could be limited to small or even medium employers, or host employer, on the assumption that large employers particularly in industries like retail are unlikely to need incentives to employ and train staff.
In implementing this recommendation policy makers may need to have regard to other factors including:
· different regional needs;
· the role of traineeships in creating pathways for disadvantaged job seekers or as a pre-requisite to employment such as in the meat industry; and
· State and Territory government decisions about employer training entitlements.
The funds that are saved by creating this concept of eligible apprentices and trainees should be used to improve the quality of the training and employment experience for all apprentices and trainees. The training and employment experience consists of on and off-the-job training.
The on-the-job training is undertaken by the employer or supervisor who ideally has some understanding of how to impart skills to a learner, as well as an appreciation of the kinds of behaviours that are most conducive to motivating the learner to want to learn and complete the training. These are the skills that recommendation 3 hopes to ensure become the standard for approving employers to train.
The off-the-job training also needs to be integrated with the on-the-job training to ensure that theory and practice are as one. This is critical if competency-based training and assessment is to mean anything. Integration means that there is a strong relationship between what is happening in the training room and the application of that learning on the job. It also means that the assessment of competency is undertaken by both the on and off-the-job training providers acting in tandem.
Unfortunately there are too many examples of a serious disconnect or decoupling of the relationship between the on and off-the-job training including instances where the off-the-job training hasn’t even begun until well into the apprenticeship. The training reforms implemented in Victoria to ensure that funding follows the learner rather than being paid to the training provider has apparently been effective in eliminating some of the worst examples of this problem.
However, there are also frequent examples of apprentices whose on-the-job training fails to provide them with the opportunity to develop in any depth the range of skills encompassed by their training plan. GTOs can usually address such shortcomings by rotating apprentices between different host employers.
While such examples would appear to be a failure of the current regulators, presumably the State and Territory Training Authorities, there may be a case for this function to be handed to the new Australian Skills Quality Authority. As this body is expected to beef up the regulation of training providers, it might be possible to make it responsible for ensuring that RTOs which deliver training to apprentices and trainees take more responsibility for the relationship between the on and off-the-job training.
2.5 Recommendation 6
Reinforce the need for a shared responsibility for the Australian Apprenticeships system by establishing an Employer Contribution Scheme in which employer contributions will be matched by the Australian Government. Employers who meet defined benchmarks for training and support of eligible apprentices and trainees would have their contribution rebated, either in part or in full.
As this recommendation will not be implemented it would seem unnecessary to comment further.
2.6 Recommendation 7
Facilitate a cooperative and flexible approach by governments and industry bodies to allow for the continuation of both training and employment of apprentices and trainees during periods of economic downturn. Early intervention should be a key element of this approach. Support for a range of measures to be in place until economic recovery occurs could include:
· reduction of work hours offset by additional training
· increased off‐the‐job training
· placement with other employers within the industry
· increased mentoring and support.
Following each of the economic downturns in the early 80s, the early 90s, the less serious ‘tech wreck’ of 2001 and more recently the global financial crisis there has been both a decline in apprentice commencements and an increase in the number of out-of-trade apprentices – those whose training contract has been suspended or cancelled because their employers can no longer afford to employ them.
The numbers in both categories have varied depending on the seriousness of the crisis and the efficacy of counter-cyclical measures implemented by government. These measures however are often reactive and ad hoc when what is need is some kind of systemic automatic stabiliser to mitigate the worst effects of a downturn.
The group training network, which often serves to provide advance warning of economic or industry downturns, is ideally placed to be part of any such mechanism subject to sufficient resourcing. GTA has in the past suggested the following initiatives to deal with out-of-trade apprentices: