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(EIT) Engineering Institute of Technology 1

A Review of Vocational Education & Training

Vocational Education and Training Review

January 23rd 2019



Vocational Education and Training Review Submissions

Department of the Prime Minister and Cabinet

A response to two questions on the ‘submission’ site: https://www.pmc.gov.au/domestic-policy/vet-review/vet-review-submissions

What is working well in the VET sector?

1. The accredited courses; that they are encouraged and supported by ASQA and industry.

2. The ‘delegation of regulatory responsibility’ to high quality, low risk RTOs.

3. The encouragement of innovation, championed from the top (the Chief Commissioner).

4. The beady eye that the regulators are keeping on fraudulent and/or poor quality providers.

5. The recognition that VET is just as critical as the HE sector (but still without adequate action

from government and other key stakeholders).

What are the key challenges in the VET sector?

1. The reputation of the VET sector remains tarnished due to the rorting of the VET FEE HELP

loan system.

2. VET is perceived to be inferior to a university education and yet the students and the

vocations which depend on it drive the Australian economy.

3. The Training Packages often lack relevance or remain outdated.

4. Many of the processes used to accredit courses are complex - overlooking what is

fundamental: the quality of learning and its relevance to the industries it serves.

5. Some lack of consistency – RTOs present the same qualification, but with varying levels

of quality.

6. VET remains disconnected from HE.

7. The competency-based approach to VET is undermining the value of the higher level

qualifications – AQF levels 5 and 6.

8. The competency-based approach is not respected by international students and their

employers. They prefer the module, grade-based structure.



The Terms of Reference: A Response The Review will have regard to VET funding, policy and regulatory settings and how they can be optimised to support both school leavers and workers to maximise the achievement of relevant skills and employment outcomes from the VET sector. EIT’s suggestions:

Allow the demands of industry and real skill shortages to direct regulators when assessing the value of new and existing courses: a student with a qualification, but without the prospect of a job is a travesty.

Embrace the use of modules in accredited courses.

Consider the strength of accredited courses when compared with training packages.

Ensure there is course fee transparency and clarity to students on loan repayments.

Actively encourage working students to pay for courses; to use tax refunds as recompense.

It will examine skills shortages in VET-related occupations, in particular any tension between VET outcomes and the needs of industries and employers, and what might be done to better align these. EIT’s suggestions:

Encourage relevant and high quality accredited course design and continuous improvement. These are well placed to service the needs of industries which are undergoing rapid change. (Accredited courses are more nimble and less clumsy than the training packages.)

Reward industry for their input into course creation and enable a more agile method of upgrading out-of-date courses/training packages.

It will consider expected changes in future work patterns and the impact of new technologies and how the VET sector can prepare Australians for those changes and the opportunities they will bring. EIT’s suggestion:

Reassess and reconsider those regulatory parameters which may hinder good course design. (For example, the recent and very short-sighted push to remove modules from accredited courses - to the detriment of the courses, the students and the industries which demand high quality training and education.)

The Review may consider the flexibility of qualification structures, particularly for mid-career workers, and for industries seeking rapid deployment of new skills. EIT suggestion:

Consider the inclusion of micro-credentials, based around the module structure. The Review may have regard to community perceptions of the effectiveness of the VET sector and the accessibility and utility of information about VET options and outcomes, both for employers and students, including information linking training options to employment outcomes. EIT suggestions:

Elevate the status of VET: by providing the sector with the same level of funding that the HE sector gets and by connecting the two sectors more simply.



With VET elevated: o Industry, parents and students will appreciate the critical nature of the vocations driven

by the sector. o The public will view the sector as the facilitator of life-long learning, for upskilling or side-

skilling.

Promote the sector more vigorously: o Government and effective independent providers. o Training packages and high quality accredited courses.

The Review may seek out case studies of best practice in VET, and consider whether specific trials should be undertaken to test innovative approaches likely to deliver better outcomes. EIT suggestion:

Innovative approaches to VET already exist. Consider the following summary of an approach to learning in engineering across the sectors:



Online Education is Coming of Age

Hands-on engineering via remote and virtual laboratories and

simulation software

A significant shift in the world of engineering is changing the reality of online learning. There is a

prevalence of computing devices being embedded into everyday objects and it is a growing and

determined trend. This trend, otherwise known as the Internet of Things (IoT), means that many

everyday objects have the ability to send and receive data.

It is this development which changes the

dynamic in the world of engineering and has

strengthened the premise for online

learning. IoT is facilitating the acquisition of

meaningful and practical engineering skills

even when they are studied online and off-

campus.

The Engineering Institute of Technology

(EIT), an international college dedicated to

the education and training of engineers and

technicians, has been captivated by the impact that the

Fourth Industrial Revolution is having on education.

For many years EIT employed the tried and tested classroom-based training model with physical

labs lugged around the world to city venues and onto engineering sites.

This was a remarkably effective venture (if somewhat cumbersome) with over 520,000 participants

over 25 years. But as online technologies began to emerge the Dean of Engineering at EIT, Dr Steve

Mackay, contemplated the changing face of education and realised that it would ultimately serve

engineers well. He witnessed many in the industry being denied access to the education and training

they needed because of the tyranny of distance, the responsibilities of demanding jobs and budget

constraints.

Steve spent four years of extensive research

(resulting in a PhD), during which he analysed

the various online learning platforms and

available ‘tools’. This enabled him to devise an

optimal method for EIT. He settled on an

innovative, live and interactive approach to

teaching, where industry-experienced

instructors and lecturers are streamed in to

students around the world, and where they

have access to high quality remote labs.

In traditional learning environments students

of engineering rely on physical labs for

Internet of Things (IoT) – Happiest Minds Insights https://www.happiestminds.com/Insights/internet-of-things/

Demiblogger https://demiblogger.wordpress.com/



hands-on practical applications. Given the inextricable link between engineering and technology, the

utilization of the internet has become a key part of modern engineering education and offers

equivalence to physical delivery modes. EIT students use simulations and log into remote or virtual

labs with real equipment to ably apply their learning.

Learning through EIT means that students, wherever they are based in the world, can access remote

labs. They can interface with a pneumatic circuit control using a microcontroller, for example. There

are also labs involving field instruments; they include data acquisition, pumps, motors, industrial

modems and routers. Sensors can also be accessed: flowmeters, ultrasonic sensors, oscilloscopes

and temperature sensors.

For demonstrating the processes and operations of real-world sites, simulations are an invaluable

tool. An example of a process plant simulation, giving students access to both the operator and field

technician roles, is the Simtronics DSS100 package. Using this software students can ‘walk’ through

an industrial plant to tune a process loop, for instance, or diagnose a fault: an instrument air failure

or the failure of a valve due to feedback position error.

The simulation kits range from compressors, pumps, distillation columns, heaters and boilers. And

they are realistic. With diagnostic tools rapidly becoming internet-based, these simulations are very

closely aligned with real world plants. In fact, in many cases they are more useful – students are

able to access a greater range of ‘situations’ than is possible on site.

Students are stretched in terms of identifying and remedying encountered problems and support

from experienced teachers is available to assist them.

There are some significant benefits inherent to practical applications tackled online. Apart from the

accessibility and flexibility they offer, the limits of equipment can be tested. In an online medium this

can be done safely – something that cannot be achieved with real equipment.

Studies show equivalence in learning material face-to-face and online. And as the technologies

become increasingly sophisticated they will all but disappear. When learning reaches that juncture -

where students are no longer aware of the technologies involved, but are able to interact with

excellent teachers and access labs which ‘take them onto the worksite’ - then online education will



have come of age.

The future of engineering education must have the capacity to reach all students and then prepare

them for real jobs in industry. And similarly, engineering graduates must have access to opportunities

which allow them to continue to develop professionally, alongside their work, throughout their careers

and beyond.

The following information contains our plea:

Retain modules in accredited courses

The Engineering Institute of Technology (EIT) – in a nutshell

Key arguments for retaining modules in VET – a Summary



Overview of the Engineering Institute of Technology

Background

The Engineering Institute of Technology (EIT) is a Registered Training Organisation (2008)

and a TEQSA approved higher education provider (2014), with a head office in Perth.

EIT provides engineering and technology education and training, at diploma and degree

levels, to students in over 140 countries.

All EIT vocational enrolments are fee-for-service.

EIT has built up 11 accredited advanced diplomas within the VET sector since 2008. They

are accredited by the Western Australian Training Accreditation Council (WA TAC).

The 11 qualifications do not replicate Training Package; they are accredited courses

designed to address industry needs that the training packages are unable to cater for.

EIT vocational courses make use of an online platform of learning: live, web/video

conferencing technologies and for practical applications - simulations and remote or virtual

labs (with real equipment).

EIT instructors are drawn from industry and based around the world.

Our perceived strengths

Our independence and our strong ties to industry around the world have encouraged us to become

agile and driven our innovative approach to education and training.

This in turn has enabled us to:

Adjust efficiently to the changing labour market and the changing face of business and

industry - which is increasingly driven by technology.

More quickly introduce accredited courses to service the demands of industry.

Create and offer unaccredited micro-credentials for those in industry needing to update their

skills throughout their working lives.

Offer quality education and training to those who cannot access a campus due to full time

work and/or because they live remotely.

Employ and continuously refine our online tools and technologies.

React swiftly to feedback from instructors, students and their industry employers.

Continuously improve our course offerings.

Enhance the structure of our courses.

Refine our assessments:

o To optimise student performance and learning.

o To optimise the quality and accuracy of data for the students’ employers

Why Regulation may undo us

Despite the standards allowing their use, Ministers responsible for vocational education and

training, decided that all courses were to rely solely on units of competence and all modules were

to be removed.

The WA TAC’s decision has been strengthened by the national VET regulator ASQA’s decision: to



disallow the use of modules in all new courses assessed for accreditation.

The Engineering Institute of Technology argues that by replacing modules with units of

competency at AQF Level 6, the VET sector will suffer. And this is why:

The Fourth Industrial Revolution is the current and developing environment; it is

characterised by disruptive technologies and a range of trends driven by knowledge and

software. It is having a major impact upon jobs and therefore also impacts vocational training

which is structured around units of competency and modules.

The term module is used to describe a body of knowledge (and concomitant skills); whereas a

competency describes what a person can do and is an attribute of the learner. Put simply,

knowledge refers to the learning of concepts and factual information, whereas skills are

proficiencies developed through practice.

The standards include the use of Modules and they have proved signally successful in accredited

courses, from which thousands have graduated in Australia and worldwide.



Key Arguments for Retaining Modules in VET

A Summary

1. They are needed in the current environment marked by massive growth in knowledge

Knowledge is a key driver where there is strong growth in artificial intelligence, software use, data

communications and the automation of processes. Many skilled tasks (originally acquired within

VET) are now automated; making it necessary for practitioners to constantly adapt. They can up-

skill or side-skill, but in order to future-proof themselves they need to acquire the knowledge ‘around’

the skills they have - to ensure they can manipulate these proficiencies and cope with contingencies.

Employers require staff to remain relevant and proficient in their fields and to this end they need

them to think critically, communicate effectively, to be creative and show initiative.

2. Employers in industries around Australia respect them

Industry and indeed employers from some of Australia’s largest organisations want vocational

courses which can be undertaken whilst working ‘on the job’ and which are linked to employee

progression within the workplace. Many employees are building on already established skills (and

indeed knowledge), but require content which is current and allows for growth within the very

industries that are increasingly effected by disruptive technologies.

Furthermore, employers have indicated that student achievement can be more clearly represented

through marks/percentages rather than a competent or not yet competent.

3. The modern training environment of online or blended learning suits them

Technology Enhanced Learning is gradually becoming more common. In this environment the

content being delivered, the assessments and practicals are mainly knowledge based (with the

requisite physical skills being learnt on the job). This makes the application of modules particularly

apt.

4. They make pedagogical sense

Skills are naturally predominant components of qualifications up to AQF level 4 (or Certificate IV); in

fact this is where they reach their apogee. What characterises diplomas and advanced diplomas

(and above), on the other hand, lies primarily within the domain of knowledge and therefore modules.

5. Micro-credentials rely on them

Modules are particularly suited to the rapid growth in micro-credentials. These are mainly knowledge-

based courses and are currently being considered for inclusion in the AQF.

6. They bridge the VET and Higher Education Sectors

Modules form a meaningful bridge between the two education sectors because the structure and

language in one is not dissimilar to the other. They facilitate the exchange between these two

important, but disparate sectors.

7. The international market acquiring Australian qualifications desire them



There is significant resistance to units of competency in higher level VET qualifications. The more

limited assessment indicators have failed to resonate with our large cohorts of overseas students.

The use of grades and percentages, via module-based delivery and assessment, on the other hand,

is familiar and indeed prized by Australian and international employers and students alike.

8. Knowledge loves them

The definitions of modules and units of competency, and the interpretations of these definitions, have

become the regulator’s burden. Phrases in the standards such as ‘where it can be established’

leaves the definitions and their applications open for discussion.

For the accredited course designer the burden shifts: the overarching driver is selecting the most

appropriate approach to structuring and teaching the content in order to best service the learners

and the industries in which they work.

Conclusion

We believe modules are integral to the modern VET system and are indispensable. We think it would

be precipitous to remove them and the standards seem to agree - there is nothing that precludes

their use. All we ask is for the status quo to be maintained.

We believe that the impact of the current environment, marked by the rapid growth in knowledge,

alongside disruptive technologies, will be better weathered by students if their course content is

knowledge-based and designed around modules. Thus structured students are more likely to

transcend the boundaries of time and place which skills alone will struggle to facilitate.

The following documents add to the discussion

The role of Modules in Vocational Education and Training - A discussion paper prepared by

Russell Docking

A letter designed by Mr Phil Clarke (on Dr Steve Mackay’s behalf) and sent to Minister Sue

Ellery

Bloom’s Taxonomy and the Three Learning Domains – Prepared by Dr Steve Mackay

Two letters of support for EIT from industry leaders

Comments from EIT VET graduates



The Role of Modules in Vocational Education and Training

A discussion paper prepared by Russell Docking

Introduction

We are on the verge of the Fourth Industrial Revolution, one that is driven by knowledge and

software, and this is having a major impact upon vocational training.

Looking back we see that VET training reform has presaged the revolution, and since its inception,

competencies and units of competency have been the hallmark of these national training reforms,

standards and practices. These replaced traditional subject-matter based curricula in the drive for

greater industry relevance, greater precision in assessment and certification, and a more skilled

workforce. Early attempts to specify competencies abandoned knowledge altogether, but it was

soon discovered that a skilled operative without a sound knowledge base was ineffectual, and

knowledge was restored as a significant component of competency.

The preoccupation with skills driven competency overshadowed the continuing need for knowledge-

based training, and so this was excluded from National Training Packages. Knowledge-based

training does, however, remain in accredited courses in the form of VET modules. There it has

survived, in part because accredited courses continue to be the incubator of new approaches to

training and to service new areas of industry, and in part because the knowledge-based approach,

in the form of modules, provides specialised training where student numbers are too small to justify

their inclusion in National Training Packages. Yet there is now some risk of their total abandonment.

This paper reviews the current status of VET modules, how they continue to be relevant, and how

they are being used to make a valuable contribution to VET and the industries and communities they

serve. We start with a look at what modules are and how modules are considered within the VET

standards framework.

The Concept of a Module

The term “module” is used to describe a body of knowledge (and some concomitant skills) associated

with a segment of learning. Whereas a “competency” describes what a person can do and is an

attribute of the learner, a module reflects a sample of an area of learning, not the learner, and

assessment outcomes are described in terms of the sample proportion of the module absorbed by

the learner.

Modules focus upon knowledge and its use… which ranges from relatively simple remembering,

through understanding, application, analysis, evaluation and synthesising (the cognitive domain of

Bloom’s Taxonomy). All these involve mind or cognitive skills … thinking … and where new ways of

thinking are involved it would be appropriate to describe outcomes as competencies. What

characterises modules is that the learner is applying ‘old’ skills to a new body of knowledge, and the

module is defined by that new knowledge. This knowledge will include knowledge of terminology,

principles and rules, and it will also include knowledge of skills and processes. Knowledge

essentially refers to the learning of concepts and factual information. Knowledge is primarily



evidenced by question and answer, whereas skills are primarily assessed by performance and

demonstration.

Knowledge is of great importance to education and to training. In the context of VET and industry,

knowledge can serve to support and reinforce skills, provide insight into how skills and tasks work,

help us cope with contingencies, support industry awareness, and support transfer from one skill to

another, from one workplace to another, and from one time period to another. Skills tend to be time

and place dependent, knowledge can transcend these boundaries.

Where the outcome is describing industry relevant performance attributes of the learner, we are

talking in VET unit of competency terms. Those performance attributes (thinking, doing) would of

necessity be supported by relevant knowledge, but the primary focus is on the performance. This is

reflected in the syntax of units of competency, with unit and element titles expressed as an “ability

to …”

Where the outcome is describing an industry relevant body of knowledge or subject matter, we are

talking in VET module terms. That body of knowledge might invoke existing skills for its acquisition

or application, but the primary focus is on the new body of knowledge. For the remainder of this

paper, when we refer to “module” we mean an industry relevant VET module that inculcates new

VET knowledge. This is reflected in the syntax of modules, with module and learning outcome titles

expressed as a subject or topic.

Module-based knowledge plays a crucial role in an ever-changing industry landscape. While the

skills that are used remain relatively stable, the knowledge base is shifting and expanding rapidly.

For example, while research skills have remained relatively unchanged for decades, the subject

matter of the research has expanded exponentially. Module-based knowledge contributes to transfer

over time and context, reinforces retention and meaningfulness, wider application and ultimately

higher productivity. It adds value to any earlier competency-based training by extending its scope,

longevity, and applicability.

Finally modules form a meaningful bridge between the VET Sector and Higher Education. The

interface between these two sectors is complicated by the fact that each operates on a different

paradigm with different purposes and outcomes. Modules can provide the shared language that

facilitates the exchange between these two important but disparate sectors ... particularly as they

share the same qualifications framework (AQF).

It is critical that modules remain in the VET sector at advanced diploma levels to meet industry

needs, employer needs and employee needs. They contribute to career progression, enterprise

productivity and safety, and are more familiar and accessible to those who first encounter VET after

progressing through higher education.

Modules and the Standards for RTOs

The Glossary in the Standards for Registered Training Organisations (RTOs) 2015, Compilation No.

1 2017 defines modules in the following terms: Module means a group of learning outcomes in a

VET accredited course where it can be established that it is not possible to develop an appropriate

unit of competency.



‘Modules’ are also mentioned in the Glossary references to ‘Code’ and ‘Training Product’. Within

the Standards, modules are referenced at Clauses 1.1, 1.2c, Table 1.8-2, 1.26c, 3, 3.5, and Schedule

5 (Certification).

The term ‘unit of competency’ is referred to within the Standards in the Glossary (‘Code’, ‘Module’,

‘Skill Set’, ‘Training and Assessment Credential’, ‘Statement of Attainment’, ‘Training Package’,

‘Training Product’, ‘Unit of Competency’), Clauses 1.2c, 1.3c, Table 1.8-1, Table 1.8-2, 1.26c, 1.27,

3, 3.5, (1.25), Schedule 4, and Schedule 5.

The two terms are almost always paired, except where only units of competency can apply (Glossary:

‘Training Package’, Clause:1.25). Other cases would appear to assume that for ‘unit of competency’

one can also read ‘module’ (for example, Clause 1.3c and Table 1.8-1)

Thus it would appear that VET modules enjoy a status within the Standards comparable to that of

units of competency. The fact that they are part of a VET accredited course testifies to the fact that

they must be of necessity relevant to industry, enterprise, education or community needs.

Modules and Units of Competency

Returning to the Glossary definition, modules are said to be legitimate “where it can be established

that it is not possible to develop an appropriate unit of competency.” This issue will now be explored.

It would be pedantic to point out that the definition of ‘Unit of Competency’ in the Glossary states that

it is a specification ‘as defined in a training package.’ Given that an accredited course is not a training

package, it follows that an accredited course cannot contain units of competency, and could only

contain modules. Such an argument is fatuous, but it illustrates the danger of assuming that the text

of the Standards has been written with such precision that the comparative status of modules can

be deduced.

It is more useful to refer to the definition of ‘Competency’ in the Glossary, which defines competency

as having a number of critical qualities:

Consistent

Application

Knowledge

Skill

Workplace standard

Transfer

It would follow that if any of these did not apply to a learning outcome it could not then be a

competency, but rather a module. For example, VET learning outcomes that do not relate to a

workplace standard include pre-vocational modules in English and other foundation skills. Likewise,

if a VET learning outcome had skills and knowledge, but was not transferable, such as a micro-

credential for the use of a specific item of equipment, this too would be a module. Finally, if there

were VET learning outcomes that primarily addressed knowledge and did not relate to skills, these

also would need to be expressed and recognised as VET modules.



An examination of the structure of the Australian Qualifications Framework (AQF) 2013 reveals that

while knowledge and the application of knowledge and skills continue rising throughout the AQF

range (1–10), skills reach their apogee at Certificate IV level. What this means is that all skills are

capped at Certificate IV level … training beyond that level does not involve acquiring more

sophisticated skills but rather the use and/or transmission of the Certificate IV skills in more

sophisticated contexts. In short, what characterises the AQF Diploma levels and higher is primarily

within the domain of knowledge. (Thus it might be said that a dentist practices jeweller-level skills,

but exercises higher levels of cerebral activity) (It also must be acknowledged that while skills tend

to plateau at AQF level 4, they once again trend upwards at AQF levels 9 & 10, but these are well

beyond the range of VET.)

This would imply that units of competency would routinely apply to AQF levels up to Certificate IV,

and would continue to apply to higher levels if there was a need to introduce new skills (albeit that

they were still at Certificate IV level in sophistication). It also implies that if a Diploma or higher

qualification only involves learning outcomes that introduce higher levels of knowledge and

application, but not new skills, these would not meet the definition of competency and would have to

be recognised as VET modules.

VET Modules perform a role that units of competency cannot. It is meaningless to refer to a

“knowledge competency”, as it would not fit the definition of competency and would undermine the

significance of competency as a combination of skills and knowledge. There is an industry need for

outcomes that are primarily knowledge based, and it would be detrimental to try to force such

outcomes to fit the unit of competency structure. In effect, the existence of VET modules protects

the integrity of competencies.

There is a synergy between competencies and modules. Firstly VET Modules could provide

precursor learning for units, either as pre-requisites, or as a means to streamline delivery. For

example, achievement of a module could be an indicator that it was worth the investment in RTO

resources and learner time to embark upon a unit of competency. Secondly, modules could be

delivered in parallel with units. For example, if a cluster of related units shared a similar knowledge

base, this could be delivered as a module, followed by a more efficient delivery of the skills-focussed

units. Finally, modules could be delivered after a unit of competency to promote transfer, support

retention and provide a form of “endorsement” (as in piloting different aircraft) to allow a competent

person to apply their skills in a new situation. Indeed, modules could also provide a kind of RCC

(Recognition of Current Competency) or VOC (Verification of Competency) role to verify knowledge

retention (RCK or VOK).

VET modules have an indispensable place in VET ... there are legitimate VET learning outcomes

that do not involve the acquisition of new skills and therefore could not be described as competencies

or units of competency. These can be legitimately included in accredited courses or as micro-

credentials. It might even be argued that VET modules are necessary to a comprehensive and

inclusive VET sector.

Modules and VET Training and Assessment

What then are the implications for the Standards and RTO practices?

There are no significant implications for training delivery, but it would open up the range of delivery



modes to further embrace on-line learning as this medium provides a sound basis for communicating

and assessing knowledge. There are, however, very significant implications for assessment

judgements. These are important to articulate, as they might not be fully understood by Regulators,

auditors or others applying the Standards to module-based courses.

Modules are relatively simple entities, consisting primarily of assessment criteria grouped into

learning outcomes. These are unlike elements of competency as the assessment criteria are not

bound to the learning outcomes as performance criteria are to elements of competency, but are

grouped into topics for convenience. Unlike the criteria associated with units of competency there

is no expectation or requirement that all must be demonstrated, and some assessors may follow the

traditional approach of assigning a mark value to each assessment criterion and setting an overall

pass mark, usually 50%.

The performance requirements need not be so simplistic, however, and given that a VET module

would usually have workplace or industry application, it would be reasonable to expect that industry

would wish to be more exacting in specifying the requirements for a pass. So, for example, one

might define a profile of evidence based on industry needs in the following terms:

E Specific learning outcomes and/or specific assessment criteria could be designated as

Essential and required to reflect industry requirements for a pass

B A minimum number of learning outcomes and/or a minimum number of assessment criteria

within each learning outcome could be defined as a Balance requirement to reflect industry

requirements for a pass

M A Minimum total or percentage could be specified to reflect industry requirements for a pass

These EBM rules circumvent all of the anomalies that arise from the use of a simple percentage,

and would enable the course developer to ensure that the award of the module had greater

workplace predictive value than a (mere) percentage by ensuring that the performance profile of

each graduate reflected industry needs.

EBM rules could also be set at increasingly more demanding levels to define graded steps in

performance. These rules would constructively shape student learning and ensure that credentials

and grades issued had a high degree of meaning and promote and reward excellence.

The EBM rules could also be set to meet different purposes. For example a set of EBM rules for

each industry sector, or for different micro-credentials or for transition from VET to Higher Education.

This is the idea of ‘multi-grading’, where a body of assessment evidence is interpreted in different

ways for different purposes.

With such an approach, it becomes possible to see how the rules of evidence and the principles of

assessment can apply to modules (Standards, Clause 1.8b). The validity of evidence-gathering can

be supported through mapping assessment tools to learning outcomes and assessment criteria, and

the validity of judgement(s) by ensuring consistent and meaningful rules are applied to the evidence-

based assessment judgement (such as EBM). Sufficiency, authenticity and currency retain their full

meaning. Fairness and flexibility also retain their full meaning, and reliability would be enhanced by

the use of consistent judgement rules. Modules also lend themselves to on-line assessment,

although good proctoring software would need to be employed to ensure authenticity.



The Format of Modules

Given the significant role that VET modules can play, it would be appropriate to redefine modules so

that they are no longer defined as “failed” units of competency. A definition might be:

VET Module describes the retention and application of a body of knowledge to the standard

required in industry, enterprise, education or community. It embodies the ability to transfer

and apply knowledge to new situations and environments. It may be stand-alone or it may

be a precursor, supplement, support or extension of a unit of competency. Modules may

involve a small component of underpinning skills.

Just as units of competency have a formally recognised structure, so too should VET modules. A

suggested structure could be:

Module code: Industry, Industry domain, AQF level, unique code

Module title: A short title stating the area of knowledge

Modification History: Release dates and notes

Application: A longer statement of the knowledge domain, and the typical

workplaces and workers to whom it applies (may refer to

endorsements by specific industry, enterprise, education or

community stakeholders).

Learning outcomes and

Assessment Criteria: Learning outcomes define convenient sub-domains of knowledge;

assessment criteria are specific knowledge items or applications

indicative of the sub-domain.

Prior knowledge: Assumed knowledge base (may refer to previous modules).

Prior skills: Assumed skills (may refer to previous units of competency)

Assessment conditions: Requirements for assessors and assessment.

Judgement rules: EBM requirements for one or more outcome functions (may refer to

specific industry applications, endorsements, or micro-credentials.

A structure such as this would facilitate consistent review for accreditation, consistent application by

RTOs, and consistent audit by VET regulators.

Conclusion

In short, there is nothing in the Standards that preclude the use of modules, indeed there is much to

be gained through the use of modules to reach and service the greater VET market and industry

needs. Currently accredited courses exist that consist entirely of modules and are strongly

supported by the industry they serve. VET modules may also serve as a bridge between VET and

Higher Education, as micro-credentials they might serve as key components of professional

development to cope with the increasing pace of change, and they add significantly to the flexibility

and responsiveness of the VET sector. For example, in higher level courses it is possible to conceive

of a course that would consist entirely of modules that can be delivered efficiently (at a distance) but

then has a capstone unit of competency (which now would include the nascent skills) to address the

application of the knowledge in the workplace as the final expression of the qualification.



After all, VET is Vocational Education (Knowledge) and Vocational Training (Skills); there is a place

for both units of competency and modules in the sector. The next industrial revolution depends upon

it.

The Next Steps …

In the first instance, it is imperative that no precipitative action be taken to abandon VET modules ...

they are an integral and indispensable component of VET.

This paper has offered a number of suggestions to further the meaningfulness and consistency of

VET modules, including:

A new definition of VET modules

A guide to the uses of VET modules

A structure for the specification of VET modules

A strategy to enhance the precision of VET module assessment judgements

It is suggested that this paper provide a starting point for a discussion amongst VET practitioners,

VET regulators, and industry, enterprise, education and community stakeholders to develop a

reinvigorated approach to VET modules so that they retain their significant role in support of VET

and the community they serve.

Russell Docking

Lowden

December 2018



29th October 2018

The Hon. Sue Ellery MLC

Minister for Education and Training

13th Floor, Dumas House

2 Havelock St, West Perth, WA 6005

Dear Minister

An arbitrary decision is threatening quality VET education and training

To give you a little background: the Engineering Institute of Technology (EIT) is both a Registered

Training Organisation and a TEQSA approved higher education provider, based in Perth. We

provide engineering and technology education and training, at Diploma and Degree levels, to

students in over 140 countries.

We deliver on campus and online, making use of a live, online platform of learning to reach local and

globally-based students; we connect them with instructors who are industry experts and based

around the world. Our programs are recognised locally and internationally.

All of our enrolments are fee for service although domestic students embarking on our degree

courses can access FEE-HELP if they wish. More detailed information on EIT can be found on our

website www.eit.edu.au.

Our 11 accredited courses within the vocational education and training (VET) sector have been

accredited (and re-accredited) by the Western Australian Training Accreditation Council (WA TAC)

since 2008. These qualifications do not replicate Training Package awards and are therefore offered

as accredited courses to address industry needs that the training packages are unable to cater for.

We recently submitted one of our courses, Advanced Diploma in Mechatronics Engineering including

Robotics and Artificial Intelligence, and WA TAC have indicated that they will not consider the

application. A number of reasons are given for this, some of which might be considered procedural

which we will address directly with the WA TAC.

However, there are two other critical issues raised as reasons for refusal; these are related to the

application of policy agreed overtime by Ministerial Councils responsible for oversight of the national

vocational education and training system. The first refers to the duplication, at least in part, of a

qualification in a Training Package. The second (which is the focus of this letter) advises that under

the Course Accreditation Standards agreed by Ministers responsible for vocational education and

training in 2012, all courses are to rely solely on units of competence - all modules are to be

removed.

We appreciate that decision making and appeal processes are laid out in legislation and, at least in

this point in the process, you cannot intervene in the decision making process. This correspondence

is addressed to you in your role as the Western Australian representative on the COAG Industry and

Skills Council. It is our view that the decision of the WA TAC highlights how elements of the national

VET architecture, which have essentially been in place since the mid-1990s are dated and actually

work against the operation of a high quality, responsive vocational education and training system.

(Please refer to Appendix A for some background information.)



The WA TAC’s decision, has been strengthened by the national VET regulator, ASQA, who we

understand has made a decision to disallow the use of modules in all new courses they assess for

accreditation, despite legislation still allowing their use.

Modules are, however, vital building blocks within our accredited advanced diplomas and they

benefit our students in a number of ways:

Our student cohort is largely mature-aged professionals who need to consolidate and build on

existing knowledge rather than expand on their trade level skills (which would be perfectly

suited to units of competence).

Modules provide a streamlined articulation into Higher Education courses. (They help close,

rather than broaden the gap between the VET and Higher Education sectors).

Students can be awarded grades (a globally recognised assessment mechanism) rather than

just receiving a ‘competent’ or ‘not yet competent’ – which tends to reward mediocrity rather

than encourage excellence.

Whilst skills are undoubtedly embedded in learning, knowledge is far more aligned with the

modern digital world; especially at the higher cognitive levels of diplomas and above.

Knowledge also ensures that graduates are future- proofed in this rapidly changing

technological age.

The VET sector has gained notoriety in recent years due to the behaviour of a small group of

Registered Training Organisations who have been allowed to operate while providing poor quality

training. Much of the public discussion about this problem has been around the relatively easy

access to government funding, but it can also be argued that the problem was due to the narrow

view of competence (‘explicit’ rather than ‘tacit’ learning) presented in many Training Package

qualifications. This has led to a ‘tick box’ mentality which allows poor quality providers to operate

and meet regulatory requirements.

It works against skilling the workforce which has suffered as a result. At the same time innovative,

quality training providers are prevented from accrediting and providing qualifications which meet the

needs of industry and their employees.

EIT is an agile provider working closely with industry to provide relevant skills and knowledge to

people working in the STEM industries - earmarked as critical to the future of the Australian economy.

Over the last decade the value added to employees who have EIT qualifications is attested by the

firms which employ them.

Our experience, however, is a frustrating and disappointing one and is a result of an environment

being shaped largely at the national level by all governments.

We will continue to work with the WA TAC to ensure that our advanced diplomas can continue

to be offered in their current format, but we would appreciate any support you can offer us,

Minister.

We do believe, more broadly, that our experience shows up some fundamental flaws with the

national VET system which need to be addressed comprehensively by the COAG Industry and Skills

Council. The support we have received from the architects of National Packages does indicate that

this needs to be considered as a matter of urgency.



We would welcome the opportunity to discuss these matters in more detail with you, as a

representative on the Council.

Yours sincerely

Steve Mackay PhD

Dean of Engineering

Appendix A

The national architecture of the vocational education and training sector was established in

the 1990s and was conceived as follows:

VET qualifications would be part of an integrated national qualifications framework covering

senior schooling and higher education alongside VET

VET qualifications within that framework would be competency based and the standards that

underpin those qualifications would, typically, be developed by industry. The VET system was

to be industry led.

VET qualifications could only be issued by registered training organisations that meet certain

legislative requirements, created in a mix of primary and subordinate legislation (that latter now

referred to as the Standards for Registered Training Organisations). Whether a provider was

government, private, industry or community owned was not in itself a consideration in the

registration process

Preference would be given to qualifications developed by approved industry bodies, but in

cases where there was a gap in coverage Registered Training Organisations could have

courses accredited for delivery.

There has been significant change in the Australian economy, particularly in the labour market and

in the nature of work and production, since that architecture was established. It was originally

designed to address the need to restructure the economy through the 1980s and 1990s. Its focus

was high youth unemployment, the need for skill recognition and the upgrading of skills to improve

productivity and enable mobility. In that context, an architecture that was based on standardised

skill outcomes was appropriate.

While that architecture has been the subject of a range of reviews and has been refined over time,

its guiding principles have stayed the same. Over two decades later, the nature of work, driven by

social and technological change, brings into question the validity of those principles. The competency

model adopted in Australia is very task and function driven; making measurement and the alignment

with related documentation (industrial instruments, industry regulation) more straightforward. But the

occupations that have grown most in the last two decades are managerial and administrative,

professionals, para-professionals and technicians. While competence is still critical in these

occupations, achieving it is a function of skill and knowledge.



This shift has been recognised over time by Ministers responsible for vocational education and

training. In 2009, on the advice of the National Quality Council, Ministers agreed to the following

definition:

Competency is the consistent application of knowledge and skill to the standard of

performance required in the workplace. It embodies the ability to transfer and apply skills and

knowledge to new situations and environments.

Sitting behind this definition is the work of the NQC which had concluded that competence:

Is demonstrated to the standards required in the workplace

Comprises the application of specified skills and knowledge relevant to that occupation

Makes appropriate reference to required generic and employability skills

Covers all aspects of workplace performance

Can be demonstrated consistently over time and covers a sufficient range of experiences

(including those in simulated or institutional environments)

Our concern is that the rules around the system do not align with the meaning and intent of

this definition, particularly where knowledge and modules are concerned.

Bloom’s Taxonomy and the Three Learning Domains



Prepared by Dr Steve Mackay

Introduction

Reference to Skills and Knowledge and Bloom’s Taxonomy are widely referred to by the Training

Accreditation Council WA in their reviews and audits; hence they are worth examining in more depth

as far as modules and units of competency are concerned. These extracts are contained in sections

2 and 3 below.

As section 2, indicates:

“Knowledge refers to the familiarity with theoretical concepts and factual information. Skills are the

proficiencies developed through practice. Ability is the quality of being able to do something.”

We believe the critical ingredient attribute with skills are ‘the proficiencies developed through

practice’. This would be noticeable for example, with an apprentice undertaking a Certificate III and

practising the installation of an electrical conduit where many attempts (twenty or thirty or more) are

required before the requisite skills proficiency is attained. An ideal opportunity for rating of an

individual with competency.

Other key distinguishing attributes are:

‘Skills are the proficiencies you develop through training or experience. They refer to the ability to

apply knowledge to specific and practical situations. Skills cannot be developed without practice’.

Bloom’s Taxonomy has three learning domains (extracted from the reputable University of

Minnesota) as is shown in Section 3. Bloom’s Taxonomy is a critical part of design and assessment

within the vocational sector in Australia and indeed, a key part of the Course Accreditation

application.

Contained in section 3 is an extract from Bloom’s Taxonomy which clearly shows the three domains

that training is conducted in. These three components are:

1. Bloom’s Taxonomy - Cognitive Domain - (intellect - knowledge - 'think')

2. Bloom’s Taxonomy - Affective Domain - (emotions - attitude - 'feel')

3. Bloom’s Taxonomy - Psychomotor Domain - (physical - skills - 'do')

It should be noted that Bloom’s Taxonomy clearly indicates that the section that we use in the

cognitive domain is knowledge. Bloom’s Taxonomy for the skills domain is clearly for the

Psychomotor Domain.

The reason why Dr Russell Docking and subsequent auditors recommended and approved the use

of modules rather than units of competency is recognition of the fact that although modules contain

elements of skills – the majority component is knowledge, especially as delivered online. The units

of competency are clearly designed for Certificate II, III and IV level courses where there is a

significant psycho motor component such as in a trade e.g. Electrician or Baker. In contrast, at the

advanced diploma level, knowledge is the major component – hence the need for modules.



1. Knowledge, Skills versus Ability

Main Difference: Knowledge, Skill & Ability

Knowledge, Skill and Ability are qualities we need in order to complete any task successfully.

Knowledge refers to the familiarity with theoretical concepts and factual information. Skills are the

proficiencies developed through practice. Ability is the quality of being able to do something.

The main difference between knowledge, skill and ability is that knowledge is theoretical

whereas ability and skill are practical. In addition, skills are learned whereas ability is inbuilt.

What is Knowledge?

Knowledge is the theoretical understanding of a subject. In other words, it can refer to familiarity

with theoretical concepts and factual information. Knowledge can be self-acquired (through study

or observation). It can also be transferred from one person to another; this is what happens in the

traditional teaching methods.

When we compare knowledge with skills and abilities, the main difference between the three is that

knowledge is purely theoretical. For example, you might know a cake recipe by heart; you know

the ingredients, temperature, methods, etc. Basically, you know how to bake a cake. But the

problem is, can you bake the cake with just knowledge?

What is Skill?

Skills are the proficiencies you develop through training or experience. They refer to the ability to

apply knowledge to specific and practical situations. Skills cannot be developed without practice.

For example, an individual’s social skills are developed through interaction with people – by

observing, listening, and speaking. Skills can only be mastered through trial and error.

For example, imagine you are riding a bicycle for the first time. The first time you get on the bicycle,

you have no skills, but you may know how to ride a bicycle in theory. Most of us don’t master this

skill in the first day itself. It’ll take us hours of practice to be skilled at riding a bicycle.

What is Ability?

Ability is the quality of being able to do something. Abilities are often natural or inbuilt; they can

also be a combination of genetics and learning. Abilities are part of an individual’s qualities and

affect his or her capability to become skilful when learning a new task.

For example, a surgeon must have arm–hand steadiness and multi-limb coordination and a race

car driver needs to have abilities such as stamina, control precision, reaction time, etc.

Definition

Knowledge is the theoretical or practical understanding of a subject.

Skills are the proficiencies you develop through training or experience.

Ability is the quality of being able to do something.



Acquisition

Knowledge is acquired through learning or experience.

Skill is a practiced or learned behavior.

Ability is natural or inbuilt.

Example

Knowledge is knowing how to bake a cake.

Skill is having baking and cooking skills or practice in baking.

Ability having natural abilities like attention to detail.

Augmentation

Knowledge increases with experience.

Skills can be developed with practice.

Ability can be improved to a certain extent.

Difference between Knowledge, Skill and Ability | Definition, Examples, Comparison http://pediaa.com/difference-between-knowledge-skill-and-ability/



Letters of support from industry - for accredited courses structured using modules From Essential Energy: In reference to Essential Energy’s use of the qualifications “Ad. Dip. of Applied Electrical Energy (Electrical & Power Systems)”, both these qualifications have been utilised and at this present time specifically the “Power System” stream with its direct relationship to our industry. The Ad Dip of applied Elec Eng has delivered Essential Energy a paraprofessional cohort that has a broad knowledge and skills base, reflecting our needs and bringing flexibility with its application across a multitude of roles. We would be supportive of the ongoing development of these qualifications that are critical in the delivery of our paraprofessional’s capability for our role as rural/remote NSW Electricity Distribution Network provider.

Regards Alan Turvey Training Strategy & Governance Manager Essential Energy T: 02 65884575 PO Box 5730 Port Macquarie NSW 2444 | essentialenergy.com.au General enquiries: 13 23 91 | Supply interruptions (24hr): 13 20 80

From Sa Power Networks: The Advanced Diploma of Applied Electrical Engineering (Power Industry) is meeting the study requirements we demand for our trade skilled workers to progress to more senior roles and for our non-trade workers who require technical expertise in order to work effectively with Field staff. It brings both parties together so that they are speaking the same language and working within the same operational framework. The 2 year Power Industry qualification is highly relevant for our industry. As our industry is quickly changing we appreciate being consulted about course content with areas like embedded generation and impact of renewables. Both students and leaders report to me that the quality of the content is high and graduates are displaying greater knowledge and competency. I am also pleased to report that compared to the Advanced Diploma delivered by TAFE our students are reporting a higher degree of support and a higher standard of course content and material. Kind regards, Steven Coy Learning & Development Consultant



Comments from EIT VET graduates

A Snapshot of Comments from EIT (Australian) Students They have all completed an EIT accredited advanced diploma and most students continued to work while they studied.

BHP Billiton Device Technologies Anglo Gold Ashanti B & I Kentz Joint Venture

Belco BM Reutech Group PSA Engineering Central Darling Shire Council

Bechtel Genevo Techquip Pty Ltd Chiyoda Corporation

Schneider Electric Debswana Snowy Hydro Noble Contracting GmbH

Black & White Engineering Solutions Pty Ltd Speno Rail Maintenance Australia

These are the Australian companies that employ them – another snapshot: The excellent organisation of content. The responsiveness of facilitators and Instructors was

excellent.

The ease of correspondence with teachers and course coordinator. The abundance of learning

material given for each module.

I've enjoyed the expansion of knowledge that's specific to my trade in helping me on a daily basis

The facilitators adding their own knowledge and stories to help the students understand different

things. This is what makes EIT external leaning special.

Course content and material provided. It helps me in my everyday engineering duties.

I liked the full course and it has helped me in my current job to understand more about civil and

structural works.

The diversity of content and presentation by some of the teachers who were clearly experts in

their fields.

The overall course content was relevant to my area of work.

When we created a traffic light as a project. That was cool.

I liked the time required to complete the modules. It suited my current work/Dad life.

The diploma course provided a comprehensive selection of subjects relevant to the practice of

electrical engineering in the workforce. As a standards and regulatory specialist, I was especially

pleased to notice the emphasis on compliance with standards and regulation throughout the

course. The presentation of the course made it easy to fit around family and work commitments.

The amount it helped me in my work every day. From where i was to where i am now is lengths

and bounds and it's all due to this course.

The webinars every week and the fact the course aren’t self-paced. Every assignment had due

dates and made you stayed focus on completing the course on time



The pace at which we were moving was very good; the course coordinator was extremely helpful.

The course was very useful to my work environment, and the material was enjoyable to read

because it was simplified enough to drive one to delve deeper. The cost of the course is quite

reasonable. The webinar app worked with most of my gadgets including my mobile phones.

Thank you EIT.

Learning new and relevant things for my job has helped in understanding more in my workplace.

The amount of information that was available and the benefits of the information that can be used

in my working environment

The course went through subjects I deal with in my industry so it gave me a greater advantage in

executing my work

Content that can be applied in my current engineering role

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