I attended the information session on the implementation of Victorian Student Numbers yesterday and I left with a distinct feeling that this is being driven by Victoria's insistence on setting itself apart from any potentially national system of education management. The new legislation has been designed, according to the Department of Education and Early Childhood Development, to serve the following purpose. The VSN, which is unique to each student, will be used as a key identifier on a student’s records, and will remain with the student throughout his or her education, until reaching the age of 25. The VSN is nine digits long, randomly assigned, and tied to stable information about the student (name, gender, date of birth).
The introduction of the Victorian Student Number will provide the capability to accurately detect patterns of student movement through, and departure from, the Victorian education and training system. It will greatly improve the collection and analysis of timely and accurate data about education in Victoria.
There are a number of problems with the implementation of this legislation. Problem 1. The definition of whom the number applies to is very loose. For instance, if a Malaysian student in Malaysia is studying a VET program online through a Victorian RTO, that Malaysian student is regarded as a Victorian student. If a Victorian student in Victoria is undertaking training, in Victoria, provided by a RTO based in Qld., then that Victorian is not regarded as a Victorian student. Victorian students who are undertaking training supplied by an enterprise based RTO will not be counted. Victorian students who leave high school and go to university are not counted as Victorian students. Excuse me?
Problem 2. Once again RTO's are being asked to subsidise the State government's need for getting a jump on the Fed's. In the first half of the year we heard that the new National Regulator was coming, but the Victorian State Government, in it's wisdom had decided that it would not allow the governance of RTO's delivering training in Victoria to be managed by the National Regulator, but would require those RTO's to maintain registration with VRQA. Subsequently any RTO delivering training both in Victoria and in another State, must hold dual Registration with both the State and the Federal systems. We have not yet had confirmation of the Registration fee structures under these arrangements.
Problem 3. Both of these requirements mean more data collection and reporting. The reporting needs to be in a format that will upload into the State / Federal systems. The RTO must make amendments to it's information managment systems, its internal forms and processes and it's staff, to satisfy the needs of legislation and government systems. There has been no redress of the costs incurred, discussed.
Problem 4. The Fed's are talking about bringing in their own Student numbering system as soon as they can sort out the privacy implications. What will this mean when it happens? The DEECD asserts that when this happens the Federal system will happily utilise the already established Victorian ystem. Oh really?? Currently RTO's already manage their own internal Student Identification Numbering systems and Apprenticeship/Traineeship numbering systems, and collect and report on CHESSN and TFN's (where students access FEE-HELP). Enough is enough.
I fail to see how a system which doesn't track movements from High School to university can `accurately detect patterns of student movement through, and departure from, the Victorian education and training system.' These additional reporting requirements are a penalty to RTO's which is unreasonable and which impacts on the capacity of smaller private RTO's filling niche or boutique market spots to maintain viability.
What do you think? Have your say and leave a comment below.
A brief email discussion with a colleague yesterday got me thinking again about the value of web 2.0 in an educational business office. My colleague works in a different industry, so the business risks may not be quite the same. Here's a quote from our discussion. “We use skype for talking to our office in the UK so works for us. We also have a policy of letting the staff have access to their social networking sites – yes, very unusual and also something that our new IT guy has been looking at however we seem to be able to keep it under control. Yes, we have hardly any attrition in the call centre and are meeting all our KPI’s so I am more than happy. We also pay them a quarterly bonus – which they love – if they achieve their KPI’s. In return we give them a whole lot of Admin work which they do between calls and very successfully manage to do so – they say that it helps fill in the time and is less boring. The result is that we save on Admin staff. So win win for everyone. See if your call centre is doing that – in fact I think that I have an absolutely outstanding centre here – staff morale is at a high and they continually go out of their way – yet they are on a fairly minimum wage. The other thing that they do is select the hours that they want to work each fortnight and somehow we always manage to cover the hours required. This also minimises sick leave. I just have one guy who is taking too much sick leave (min 2 days a month) and his Mother In Law who is on face book every time I look – I need to monitor this and get her to help more with the Admin stuff. That’s for me or the Team Leader to manage” Wow, great feedback and a proactive manager, but how much could I risk in an RTO space? I know that lots of educational institutions are using twitter & sms & blogs in the educational space, communicating between students and facilitators, and in the marketing arena, but would you allow administration staff in the office that manages student records to use facebook or twitter on the business IT infrastructure? Is anyone else thinking about this? What is your organisation doing?
Attending a policy discussion last night, I was interested to hear one attendee raise the question of Why? "Why are we discussing a new national VET regulator when we already had one (NARA)?" In the communique issued on their website, (7/12/09) the Council of Australian Governments COAG says "COAG today agreed to establish a national regulator for the VET sector. The regulator will be responsible for the registration and audit of registered training providers, and accreditation of courses, and will be established under Commonwealth legislation." I have to admit that after 19 years in the VET sector, sometimes I have forgotten to ask "Why?" Is the establishment of yet another `new' body to do with Statutory Authority or a lack of performance or of acceptance of NARA? We are still no closer to the answers and even with Jennifer Taylor representing DEEWR at the Policy presentation, we could only get a po faced answer of "It's a decision taken by COAG." From the National Audit and Regulations Authority, (NARA) website, we glean the following statement "The new regulator will be a Commonwealth statutory authority." Why is a Statutory Authority necessary? Because a Statutory Authority has the right to enact legislation for specific areas of the law. In Victoria, the Victorian Registration and Qualifications Authority is a Statutory Authority. I would think that a National Regulator must have at least equivalent powers to those of the States it must deal with. The COAG communique states, "The framework for the new national regulator will be negotiated through an agreement between governments by the end of May 2010 and the regulator will be operational from 2011." With the intention of the new statutory authority being up and running by 2011, we are all holding our breath!
Having attended the VRQA & DEEWR `Consultation forum' on the creation of a new national regulator for the VET sector today, I came away with the impression that the majority of the RTO's represented at that forum hold the same concerns as I do regarding the cost of regulation and the failure of regulation to properly ensure quality of training delivery and of RTO's business operations in Australia. I was heartened to hear others expressing concerns regarding the issues of cost and the application of governance. One engaging speaker clearly voiced her concerns over the lack of a standard approach by auditors citing a case where an RTO had an AQTF audit with a compliant outcome, then 6 weeks later had an audit by the funding body which found them non-compliant. In general the comments from the meeting called for: 1) A `No Financial Disadvantage Clause' if the States persist in refusing to align with the National Regulator and RTO's are obligated to hold both State and National Registration. 2) National standards for auditors to be established 3) A mutual recognition of audit outcomes. When an audit has been performed by one authority, should there be the need for an audit by another authority, the findings of the first audit be taken as part of the second audit and that those areas are not re-audited. 4) Clarification around how complaints from students will be handled. Which body will be the authority, State or National, and how will the authority be enacted? The level of concern for RTO's was indicated by the fact that the meeting was well attended, with all seats taken and many extra seats brought in. I'm sure we will all be watching keenly to see how long it takes to get a workable model established, and whether any of our comments are taken on board.
ACPET's website now has a page dedicated to Policy, and the first policy notice that caught my attention is their summary of their report on the uptake of and use of the PPP funding available to RTO's. Guess what it says ... Many ACPET Members are encountering an enormous regulatory burden due to different reporting requirements, systems and timelines. This regulatory burden is a serious drawback of PPP and as an outcome is a disincentive for PPP providers. A commitment is required from the states to harmonise data reporting requirements. As Australia’s tertiary education sector continues to move towards a national system it is no longer acceptable for data reporting anomalies to exist from state to state. I raised the cost of meeting regulatory requirements in an earlier blog, `RTO as Business...', on the 31/01/2010. In that blog I focussed on the costs of insurance to meet regulatory requirements, the ACPET report picks up on the costs of meeting reporting requirements that vary from State to State in what should be a National system. I recently calculated the cost of implementing new reporting capabilities for an SME RTO. Taking into account the need for AVETMISS compliant RTO software, trained staff capable of managing various data systems (the internal RTO system plus the HEIM system, a different data reporting system for each state that they operate in and the QI data system), and the cost of employing a QA officer able to manage the various governance requirements of audit systems, funding systems and reporting systems, this cost burden becomes an effective barrier to SME RTO's. The argument for this cost burden is that improved management through regulated systems leads to continuous improvement while ensuring the client receives a quality product by validating academic and fiscal processes of the RTO. The argument against this cost burden is that the market place will determine quality and that to survive, business's need to be doing all the continuous improvement processes anyway, and a smart business will be integrating QI and fiscal controls appropriate to their size and scope, without having to meet externally imposed system criteria. The imposition of external criteria does nothing to add value to the RTO's product, and the real measure of quality is in the clients response. The collapse of the market for international students is an exemplary illustration of this point and has occured in spite of external (read State & Federal regulatory authorities) criteria being applied. Would it have collapsed sooner if left to market forces and if it had not been falsely supported by claims that the regulatory system we have in Australia ensures that RTO's meet quality standards? What do you think? Leave a comment and add your voice.
Further to my blog of 27 January, one of my managers hit me with a list of questions yesterday that I'm still working through. We have a legacy system in use, it has been around for many years and serves the important functions of suppling market information from our parent company's data, providing a rich seam of data about the business history and enabling seamless marketing back to their members. As a business we are seeking efficiencies in marketing, finance management and continuous improvement analysis. Questions arise around how a data system should interface with other areas of the business especially marketing and finance, and how the system will enable greater efficiencies such as online enrolment and payments. Peole looking at LMS have similar issues, Tony Karrer quotes one of his commentators in his blog this week regarding how ling it might take to find the best LMS for a business: "Research that I cited in LMS Selection Time suggested that the time for the steps on average was:
Gather and Specify Requirements – 5 months Research Vendors Requirements – 4 months Meet with Vendors – 2 months With several people involved. Of course, these were enterprise implementations with many different business units and training organizations involved."
I've been working on our research of systems for well over 12 months and still struggle to answer all the questions. The impact of the AQTF2010 increased requirement for reporting has all of us scrambling for answers. There are a plethroa of new providers coming into the market claiming to have products that meet all the requirements of the AQTF2010, but we still need to ask the big question of "What does the business need to create business improvements and efficiences that deliver better service to our paying clients and not just to the regulators?"
This weeks' news of another international college in the business of providing education for international students, being placed into the hands of receivers, leaves a bad taste in the mouth. Obviously education and training IS a viable industry, and as in all industries, there are players who just want to take the money and run. For those of us whom have invested lifetime careers in the training industry, and whom believe in the benefit of accessible education for all, the feeling of being besmirched by rogues and once again played as the value-less poor cousins of the Higher Education industry is difficult to avoid. The repercussions of this behaviour on the industry as a whole are many. RTO's have lived for many years with regulation and governance, and the behaviour of the few has led to increased regulation for the many, and to increased costs of business. The annual payment of Student Tuition Assurance Scheme fees would be seen by many other industries as outrageous, and yet for RTO's it is an inescapable cost of doing business. Once it only applied if the RTO were seeking the use of Government funding, now under the recently issued Guidelines for 2010, it has become a condition of registration for all RTO's. "Where the RTO collects student fees in advance it must ensure it complies with one of the following acceptable options for: (Option 1) the RTO is administered by a state, territory or commonwealth government agency (Option 2) the RTO holds current membership of an approved Tuition Assurance Scheme, or (Option 3) the RTO may accept payment of no more than $1000 from each individual student prior to the commencement of the course. Following course commencement, the RTO may require payment of additional fees in advance from the student but only such that at any given time, the total amount required to be paid which is attributable to costs yet to be incurred on behalf of the student for tuition or other services yet to be delivered to the student does not exceed $1,500, or (Option 4) the RTO holds an unconditional financial guarantee from a bank operating in Australia for the full amount of funds held by the RTO which are prepayments from students (or future students) for tuition to be provided by the RTO to those students." What other business is only allowed to take payments of no more than $1000.00 upfront? What other business pays tens of thousands of dollars insurance on top of public liability and professional indemnity, for product which is intangible? Yes businesses insure against loss of tangible assets, (stock), but they do not normally insure against their own collapse and inability to supply. Whilst the regulatory authorities have increased their powers to investigate and negotiate the continuance of the College business, there is still little they can do other than react to circumstance. In this particular instance it seem the money is gone overseas and it will be difficult to bring international owners to book in Australia. In the meantime, the extra costs imposed on small to medium businesses have done little to reassure the clientele or to improve business. As noted by my collegue, Mr. Neil Edwards, CEO of Chifley Business School, in his submission to the Bradley enquiry, "the concept of a seamless national regulatory regime for higher education is good. Multiple regulatory processes constitute an unreasonable burden on private providers, unnecessarily compounding the competitive disadvantage against the larger resources and self-evident standing of public universities." and in this instance we can add and self-evident standing of the TAFE system.
19 years in the VET industry has given me a fair idea of what I like to see in an information system. There is a lot of chatter about LMS's and what constitutes an ideal LMS, as in Tony Karrer's recent posting. However as an RTO we have to deal with an overwhelming amount of data, and I like my data to be accessable, searchable, sortable, reportable & reliable. Further, I like to be able to use data collaboratively and to help others to be as interested in data as I am. So what do I mean by the above specifications list? Data to me is any form of information I need. Accessable data means data that anyone in the organisation can find, view and share, preferably held and accessed through one system. Searchable data means data collection in which any element of the data can be searched for. Sortable data means data that is able to be reconstructed in a number of user friendly ways. Reportable data means data that can be extracted and compiled in useful formats. Reliable data means data that is complete and accurate, not half vacant and repeated in more than one place. An ideal data system must be simple. The user interface must be intuitive. The pathways to data elements should be built around a `two click' rule, never more than two clicks to get to the area you need. An ideal data system must `talk' to any other data system it needs to communicate with. The growing requirements for reporting learner statistics to clients, to internal clients for use in evaluation and continuous improvement and for reporting statistics and finance to regulators should not create a major resource crisis in the RTO. An ideal data system will be supported by a vendor who realises that client end users are their most valuable source of continuous improvement feedback loops, and who employs people who are able to interface between users and system builders to create feedback loops that result in not just solutions, but also systems that become second nature to all of us adminstrating in the increasingly complex business of the regulated training environment.
Can you add to or enlarge on this list? What do we need to tell the developers?
1. Corporate Learning is back As the threat of the GFC recedes, corporates will again look to improve staff performance through training and upskilling. 2. Corporate clients will become increasingly aware of the ability to mix government and private funding to obtain training Private RTO's are now accessing previously restricted funding and offering it to their corporate clients in innovative mixes. 3. elearning is back, the elearning industry is touting new ways of integrating elearning into business including the mix of `social' learning via web 2.0 tools, however,
4. S - M RTO's will be continue to be slow to take up the benefits of web 2.0 Social Networking in 2010 as they juggle security issues and resource management 5. The shift in the convergence of regulatory tools between VET and Higher Ed will create financial pressure on S - M RTO's as they re-write policy and process to meet new regulatory demands Regulatory compliance is an effective barrier to new entrants to the market. For micro RTO's and non-accredited training business's, the resources required to maintain currency in complying with evolving standards increase the barricade. 6. The shift in the convergence of regulatory tools between VET and Higher Ed will create a new job market for people with knowledge and skills across both sectors This job market first emerged as Universities began offering VET accredited programs and TAFE's began offering Bachelor degrees over the last 5 years. 7. The shift in the convergence of regulatory tools between VET and Higher Ed will create new openings for RTO's to consider the delivery of Higher Education product With the expense and effort require to manage regulatory compliance, organisations will be seeking to maximise the return on their investment. 8. The needs of the international market for students studying in Australia will shift from provision of courses supporting points for residency to the provision of high quality courses able to compete on the international playing field. The perceived lack of personal security and safety for international students studying in Australia has had a marked effect on enrolment numbers. While there are calls for the Australian Government to supply better safety assurance to students, RTO's may seek to attract a different market. 9. S - M RTO's will increasingly turn to business 2 business networking to leverage the use of industry voice in response to regulatory pressure. As social networking influences the consumer choice, social networking amongst business provides opportunites to strengthen your business within a market niche. Gen X and Gen Y are influencing the way we do business and as they become business owners, they will bring that way of working into with them. 10. Coalitions of complimentary S - M RTO's will emerge to service specific market areas with a range of product. The use of web 2.0 campaigns such as Get Up and the Obama campaign for presidency are becoming mainstream. Complimentary marketing using web 2.0 is ripe for exploration.