Industry Training Review:Summary of submissions received ...€¦ · Web viewThe Plumbing,...

INDUSTRY TRAINING REVIEW:

Summary of submissions received on the Consultation Document -

Proposal to improve the performance of the Government’s

investment in industry training

1

Table of contents

Table of contents 2

1. Introduction and background 3

2. ITO functions and roles 8

QUESTION 1 Arranging training and clarifying expectations.............................................9

QUESTION 3 Increasing expectations of completions......................................................16

QUESTION 4 Skills leadership.........................................................................................22

3. Apprenticeships and traineeships: definitions and funding 31

QUESTION 5 Higher subsidies for apprenticeships........................................................32

QUESTION 6 Extending apprenticeship support.............................................................38

QUESTION 7 Options for apprenticeship co-ordination fee.............................................41

4. Industry training at higher levels and transferability across sectors 47

QUESTION 8 Increasing training at levels 5 and 6...........................................................47

QUESTION 9 Transferring between tertiary sectors.........................................................52

5. Quality assurance 57

QUESTION 2 Standard settings......................................................................................58

QUESTION 10 External moderation and managing consistency of graduate outcomes. .63

QUESTION 11 Quality assurance settings.......................................................................69

Appendix: Submissions received 78

2

1. Introduction and background

1. On 1 August 2012, as part of the ongoing policy review of industry training, a consultation proposal was circulated for public comment. The proposal:

clarified the roles of Industry Training Organisations (ITOs)

increased the performance expected from ITOs

linked industry training to employment and education work-streams to strengthen the dynamics between education, employment and industry

enabled learners to transition more easily between employment based and other types of training.

To guide feedback the consultation paper asked submitters 11 specific questions about the proposed changes to industry training.

2. We have grouped the proposed changes in the consultation document into the following areas:

ITO functions and roles

apprenticeships and traineeships: definitions and funding

industry training at higher levels and transferability across sectors

quality assurance.

The remaining sections of this report briefly outline the proposals in each area and summarise the feedback.

3. Consultation closed on Wednesday, 12 September 2012. A total of 332 submissions were received from:

187 employers (189 submissions)

54 industry associations

23 ITOs (including the Industry Training Federation)

25 tertiary providers (including peak bodies)

9 independent Modern Apprenticeship Coordinators (MACs)

32 other submitters.

Overall summary of responses

4. Responses to the consultation document generally supported the proposals.

3

5. The proposal outlining options for the apprenticeship coordination fee was the most contentious. Most independent MACs were strongly against both proposals to change the funding rates. The MACs contend the proposed changes would give ITOs a monopoly of modern apprenticeship coordination and eliminate independent MACs.

6. The proposal to open up skills leadership to non-ITO organisations also caused some controversy. Most employers’ submissions were against this proposal, while there was only mixed support from industry associations. However, this may have been because the intent of the question was misinterpreted by some submitters as removing the skills leadership function from ITOs, whereas the purpose of the proposal was to open up skills leadership to other organisations.

7. Some of the issues raised, such as implementing a working group on the governance of ITOs, were outside the scope of the proposals in the consultation document.

8. Although we endeavour to provide some evidence of the number of submitters supporting different proposals or voicing the same argument, some caution needs to be taken in interpreting these numbers. Many responders made submissions on one or two proposals only, so the number of responders on many proposals is smaller than the number of non-responders. In addition, of the 189 submissions from employers, 130 came from Competenz-linked employers. Most of these employers made submissions on a standard form letter provided by Competenz. The views of Competenz-linked employers may not be representative of the employers’ views more generally.

Employers

9. Responses were received from a wide variety of employers ranging from large employers with more than 600 employees, to small-owner operators. Employers who responded operate in a variety of industries including construction, care, dairy, energy, engineering, food, maritime, service, tourism, and hospitality.

10. In general, employers supported the proposals. However, they detailed the following areas of concern:

the importance of aligning training with industry requirements

the lack of recognition of the in-kind costs employers bear in training

the importance of retaining current levels of funding for levels 2 and 3 as employers were concerned focus on higher-level qualifications may marginalise foundation levels

Industry Associations

11. There were 54 industry association submissions.

12. Industry associations support ITOs retaining arranging training. They state strong support for ITOs being responsive to industry and being recognised and incentivised for this.

13. Industry associations support increased completion targets. However, they were concerned higher completions should not be at the expense of lower level

4

qualifications. They stressed it was important levels 1-3 qualifications retain their importance and that there will be no decrease in quantity or funding of these. Moreover, the measures adopted for measuring completions should be linked to industry.

14. Industry associations expressed mixed feedback on the skills leadership function proposal. Some support the proposal to make skills leadership more industry focused, while others think ITOs should retain this role or advocate a combination of industry and ITO responsibility for skills leadership.

15. There is widespread support for introducing a higher apprenticeship subsidy rate. Industry associations also strongly support extending apprenticeship support to all apprentices, but this should be balanced with protecting youth involvement in the scheme.

16. Industry associations were split over whether they favoured an incorporated apprenticeship co-ordination fee or a separate fee. An incorporated fee is seen as easy to administer and more cost effective, but there is a concern how this would affect transparency and independent MACs.

17. Industry associations generally support allowing a greater volume of industry training at levels 5 and 6 and increased transferability for learners.

18. Industry associations hold a range of views on how external moderation should be conducted and how to manage the consistency of graduate outcomes. In general, industry associations agree that the whole training system is dependent on high quality, consistent moderation and the moderation system must therefore be simple, robust and reliable. There is also general support for a common currency of learning and skills.

Industry Training Organisations

19. There are 23 ITO submissions. ITOs are generally supportive of the overall direction of the proposed changes.

20. The main points ITOs raised include:

ITOs strongly support themselves retaining the functions of arranging training and setting standards.

ITOs strongly indicate that they do not wish to lose the skills leadership role. They want to remain involved in this role, either in partnership with industry or retaining complete responsibility for this function.

ITOs want to ensure that any changes in completion targets are industry-led and meet industry needs. They suggest flexibility of targets to take into account the realities of industry work flow including different learning situations and learner groups.

ITOs support increased funding for industry training. They also strongly support developing a simple, clear definition of what an apprenticeship is.

ITOs are generally supportive of increasing provision at levels 5 and 6. However, many question why a cap is needed, at all.

5

ITOs are generally supportive of recognising completions for learners who transfer between tertiary sectors. However, many ask how this will work in practice.

ITOs agreed that consistency in qualification outcomes in individual standards is important and that at least some external moderation needs to be retained to ensure industry confidence in the system. However, there were a range of views on how external moderation should be conducted and how to manage the consistency of graduate outcomes. There was also general support for a common currency of learning and skills.

Tertiary Providers

21. There were 25 submissions from tertiary providers.

22. Providers maintain there is the need for a clear distinction between what constitutes ‘arranging’ and ‘delivering’ training. They were concerned that ITOs circumvent the rules restricting them from delivering training.

23. There was mixed feedback on whether ITOs should retain their role as standard setters because of the conflict of interest between ITOs not only setting standards, but also arranging training.

24. Providers generally supported the other proposals. They support a review of unit standards and suggest uptake of unit standards is currently limited by factors such as unit standards being too task specific or detailed. A common currency was also widely supported as this would benefit employers by ensuring more accurate expectations of what an employee can bring to the workplace.

Independent Modern Apprenticeship Coordinators

25. Nine independent modern apprenticeship coordinators (MACs) made submissions on the consultation document.

26. The greatest concerns of the MACs were with the proposal 7, options for the apprenticeship coordination fee. Most MACs rejected both options proposed, as they considered this would give ITOs a monopoly of modern apprenticeship coordination and eliminate independent MACs. They argued this proposal was inadequate given the poor performance of many ITOs and previous accountability concerns over their performance.

27. Responses to other questions also reflected independent MACs concerns over poor performance and accountability of ITOs. In the view of many MACs, ITOs focus on minimising cost and maximising revenue, rather than on supporting quality training. Given the poor past performance of ITOs some MACs questioned whether ITOs should retain their arranging training role. Although there was some support for additional funding of apprenticeships, there was also concern over how of this funding would be spent by ITOs.

Other submitters

28. There were 32 submissions from other organisations or individuals. These came from a wide variety of submitters, including central and local government

6

agencies, consultants, unions, Crown entities, and private individuals. Eight of these submissions primarily address training for emergency management personnel.

29. There are few over-arching themes from submitters in this category. However, many submitters did indicate their overall support for the directions outlined in the proposals. One theme that did emerge across questions was the value placed on training at levels 1-2. There is strong support for ensuring that any changes to the current system do not undermine provision and quality at this level.

Emergency management

30. There are serious concerns about whether the proposals meet the needs of a coordinated emergency management sector. Submitters stated that the proposals do not take into account that in emergency management the majority of trainees are volunteers and their service provides a public good to the community. The aim and types of training are also different compared to workplace training generally is the focus of training is not to increase productivity, but to ensure they are ready for action in the event of an emergency.

31. Several of the submitters support Emergency Management Qualifications’ (EMQUAL) proposal for the creation of standard setting bodies alongside ITOs. These bodies would align training standards, but have no responsibility for arranging and delivering training. Seven submitters support EMQUAL as the best organisation for this role.

7

2. ITO functions and roles

Proposals

ITOs focus on providing excellent service and support to employers and trainees.

Higher expectations of qualification and programme completions for ITOs.

Industry will be responsible for communicating skill needs to Government, with support from the Ministry of Business, Innovation and Employment (MBIE) and the Tertiary Education Commission (TEC).

Overall

32. Most submitters agree with clarifying expectations of service to employers and trainees of ITOs. It is felt this would help to improve the consistency of performance and accountability.

33. In general, submitters support ITOs retaining their function of arranging training. ITOs are seen as best placed to arrange training due to their industry focus and institutional knowledge.

34. Providers and employers commented that the main risks of this proposal relate to the variability of service between ITOs and the extent of ITO coverage across industries and geographical locations. Some MACs questioned whether ITOs should retain their function of arranging training given their previous poor performance.

35. ITOs claim that defining too narrowly services and support could stifle innovation and flexibility.

36. A higher completion expectation for ITOs is also well supported. Submitters state that this would provide many benefits including improving returns on investments in industry training, increasing skill levels and encouraging improved cooperation between ITOs and tertiary providers.

37. Industry associations, employers, tertiary providers and ITOs all express concern that an emphasis on higher-level qualifications might marginalise levels 1 and 2 qualifications. Moreover, employers and industry associations commented that focusing on completions might lead to too much emphasis on qualifications rather than skills that add value. Another risk identified by independent MACs is that this might result in ITOs ‘dumbing down’ qualifications to achieve completions and too much emphasis on short-term targets.

38. There was a lack of consensus on the proposal to open up skills leadership to non-ITO organisations. On the one hand, some said this would improve links between industry and Government and make training more relevant. Independent MACs thought this would lead to improvements in skills leadership. On the other hand, most submitters are concerned over how small businesses or certain sectors would have a voice in this process and how this would be implemented. Many submitters feel ITOs are better placed to continue to represent industry, rather than industry providing skills leadership. ITOs and

8

industry associations note the skills leadership role is neither well-defined nor funded.

QUESTION 1 ARRANGING TRAINING AND CLARIFYING EXPECTATIONS

In your view, what are the benefits and risks for employers and trainees in your industry of retaining the arranging training role of ITOs and clarifying expectations of service to employers and trainees?

Employers

39. The majority of submitters, 160 of the 188 employer submissions, support their ITO and note the value ITOs bring to business. Reasons for this support include: connections between ITOs and individual businesses; cost efficient and effective service provision; and active engagement with employers in facilitating training opportunities.

We value the roles ITOs have in arranging industry training and ensuring a high quality of delivery is adhered to for both on- and off-job learning within the industries we operate in. We strongly value the trainee/apprentice coordination service provided by ITOs which provides effective direction and monitoring for our learners at this level. Downer New Zealand

40. ITOs’ collaborative approach is valued by a wide range of employers, including members from the engineering and food industries, particularly when arranging on-the-job training. Employers emphasise the importance of on-site, employer-led training, as it is efficient, convenient and well-aligned to job requirements. Employers also collaborate with ITOs to develop learning materials.

Working with our ITO, Careerforce, we carry out on-the-job training. We are pleased the consultation document endorses the arranging training function of the ITO, as this is what works best for our sector. TerraNova Homes and Care Ltd

We have written our own learning and assessment material which has been moderated by the Skills Organization (previously ETITO). Spotless Facility Services

41. The main concern about ITOs arranging training is the potential for misalignment between the training provided and industry requirements. In the building industry, the cost and quality of the theoretical components of training are poorly regarded because of the perceived lack of outcomes that result. For trades, employers emphasised that training must be practical and suit the learning styles of trades-people.

Carpentry is a hands-on career and must be taken and taught that way. BB Construction

Most of the time these young students are not “academics” but are hands-on physical workers who learn by doing. Jackson Engineering

42. Another criticism levelled at ITOs and training providers is that they are motivated by financial gain, and in some instances this is attributed to their funding structure. In one submission, the ITO is seen as complicating the

9

employer/employee relationship. In another, the role of arranging training is seen as unnecessary given the employer could do this.

43. Employers asked for greater and clearer expectations for the service ITOs deliver and for increased ITO accountability. Employers of all sizes believe ITOs should facilitate improved communication from training providers in regards to trainees’ progress. Garrison Security said they “seldom get feedback on a tech’s progress”. Downer New Zealand also called for improved transparency and measurement of trainees’ progress.

44. Nine employers reported a negative experience with their ITO, and some employers said service delivery was non-existent.

The maritime industry ITO, being Competenz by default, provides little or no proactive advice to maritime employers of SOLAS ships or for that matter to trainees. KiwiRail Interislander


45. Industry associations support ITOs retaining the arranging training role. Twenty-eight submitters support retention; only one does not support retention. Industry associations stated that ITOs are well placed to undertake this role and that most ITOs are doing a good job of this currently. Associations also say that this role is complementary to the standard setting role. ITOs are seen as the most effective and cost efficient way of delivering this role. Any transfer is seen as problematic.

We see major issues with transferring to anyone else. We are the sole industry body in the Fitness industry, and we fully recognise this role is the domain of the ITO (not us). Fitness New Zealand

46. There is concern that increasing standardisation may decrease ITOs’ flexibility and innovation in meeting needs or force them to provide services that are not needed.

We are well served by and fully engaged by our ITO (Competenz) and … arranging training and their moderating the trainee through their learning is best handled by them. Fire Protection Association

47. Associations acknowledge that some sectors have received variable service from ITOs. It is also noted that, the ITO is the only route into industry training in some sectors. Other associations expressed their confusion at what an ITO’s current role actually is. They suggested that there needs to be a clear definition around what services and support ITOs must provide. This would improve achievement.

48. Industry associations stated that ITOs provide consistent information, service and support, and can be a one-stop-shop for meeting training needs. Industry associations also noted the importance of ITO work with schools, and the need for this to be valued and funded. Several associations noted that they want the flexibility of on-job/off-job training maintained and that the current ITO model does this well. ITOs are also seen as a good way of increasing levels of engagement in training by employers and trainees in the workplace. The

ITOs should retain the process of arranging training in collaboration with industry and according to the specific needs of the employers and trainees in each sub-sector of the industry. Cement and Concrete Association of New Zealand

10

Having the ITO act in a coordinating role is desirable as the diverse skill sets required by a modern productive export sector is much more challenging and sophisticated than when ITOs originally came into existence. Pipfruit New Zealand

49. There is also support for the proposal because industry associations believe it would remove ambiguity between arranging and delivering training. In consequence, there would be a clearer delineation between ITOs and tertiary providers, which would decrease confusion, conflict and competition between the two groups. Dairy NZ said it would be more valuable if ITOs had the broader mandate of recruiting trainees for the tertiary education system as a whole (polytechnic, university or industry training path) and place trainees where they are best suited. There is some support for limiting ITOs’ ability to deliver training.

50. Several industry associations stated that they want a simplified ITO sector with reduced duplication and waste. However, there was also concern expressed about forced amalgamations.

51. Some associations support extending ITO services to employers as well as employees as this would provide benefits across the whole workforce.

Employers need to be upskilled as well as employees. Employers should be able to access Government funded industry training. This would create benefits for employees as well as the businesses. This is particularly important for our smaller owner-manager operations. Horticulture New Zealand

52. Some associations suggested that Government should incentivise and recognise ITOs to respond to industry. They stated that there needs to be a match between government expectations and ensuring ITOs do activities valued by employers. If ITO priorities are Government-led there may need to be specific funding for responding to Government.

53. There is support for retaining employer choice in who to use for training, including the option for the employer to provide theory, or off-job training, on site. There is also support for ITOs having the option to contract an expert, rather than a tertiary provider, for off-job training.

54. Some associations want to see ITOs continue to develop learning materials where ITOs are producing high-quality materials. They support funding for learning material development. However, ITOs should not be able to dictate the learning materials for other programs, even when these other programs use ITO developed unit standards.

55. One industry association asked for flexibility around how this role is performed and by whom. One association suggested that this function be opened up to more training providers, giving industries more options to access training.

We would take the view that this should not be an ‘either or’ situation but rather an option for industry to decide….those industries that are dominated by SMEs, the challenge of individual firms making the arrangements will often prove to be too demanding. In other cases, large employers may be best placed to make these decisions. Flexibility is the key factor here. NZ Shipping Federation

56. Some associations expressed concern that ITOs can be out of touch with industry needs. They are also, at times, seen as being slow to address evolving skills requirements. Additionally, ITOs are sometimes seen as prioritising off-job training at the expense of the on-job training preferred by employers. One

11

association noted that the ITO has not done well with their industry to date. This is largely because they have replicated training and qualifications that industry have developed, rather than building on and supporting industry work.

Risk that the ITO is not always in touch with industry requirements and/or expectations in terms of training. Institute of Quarrying New Zealand

57. Hospitality New Zealand expresses concern about the suitability for small and medium sized enterprises (SMEs) of the current ITO model and its funding arrangements.

The current funding arrangements make it incredibly difficult for SMEs to engage in structured training which delivers national qualifications. That does not mean that the SMEs do not undertake training….What they do not train to is national standards delivered by the ITO. They will be far more likely to do so if the size of the training was more appropriate to the needs of industry, rather than the arbitrary dictates of TEC. Hospitality New Zealand

58. One industry association considers that the ITOs system has major weaknesses. In particular, the ability of ITOs to address high-level technical skills provision in rapidly changing industries is weak. As skill needs outpace the capability of the current workforce, there is a breakdown in the system that expects the trainee to become the trainer when they qualify as a competent tradesperson.

59. A number of industry associations suggested the establishment of an implementation working group to ensure any changes promote performance improvement at a lesser cost. This group would include members from industry.

An implementation working group be established and include members from industry (employers and employees) and others to ensure that change promotes performance and responsiveness to industry needs and preference at the lowest possible of administrative and compliance costs. Business NZ


60. There is general support among ITOs for retaining the arranging training role. Twenty of 23 submitters support retention. ITOs describe themselves as offering continuity, consistency, quality, tailoring, context-specific knowledge, affordability and accessibility. They see themselves as being the most appropriate organisations to arrange training and meet industry needs. This role and the standard setting role are seen as being intertwined. The importance of on-job training and support for trainees and employers, and the general support for the ITO sector from employers and trainees is reaffirmed.

Cost effective solution for our sectors that is affordable and accessible. Aviation, Tourism and Travel Training Organisation (ATTTO)

Arranging workplace-based training with employers is critical for Careerforce and for the success of our trainees. Careerforce

61. Four ITOs support the clarification of ITOs’ support role and the clarification of the definition of arranging training. ITOs feel that these clarifications, along with increased funding, will decrease the ambiguity between arranging and delivering training, and well therefore decrease tension with tertiary providers. One ITO suggested that these changes would offer increased opportunities for collaboration between ITOs and others in education.

12

62. Five ITOs also identified a need for improved consistency and increased expectations for ITOs from both Government and employers. In particular, they support working more closely with, and greater accountability to, industry to ensure industry needs are being met.

ITOs should be responsible for establishing and negotiating transparent service expectations for their employers and learners, because they understand the nature of their industries and employer/learner needs. This ensures their accountability and commitment to achieving agreed training outcomes. NZ Motor Industry Training Organisation (MITO)

There must be a match between ensuring ITOs undertake activities that employers value and Government expectations through investment plan guidance. Forest Industry Training and Education Council (FITEC)

63. The Industry Training Federation (ITF), the peak body for ITOs, and some ITOs called for a principles-based approach to outline Government’s expectations of trainees and employers, which would enable increased ITO flexibility to meet industry needs. Such flexibility might include the ability to contract the most appropriate provider, not necessarily a tertiary provider, for delivery. InfraTrain suggest an annual customer satisfaction measure for ITOs. This could be used by the Tertiary Education Commission (TEC) to measure industry engagement and could be used as a funding measure alongside completion rates.

64. The Plumbing, Gasfitting, Drainlaying and Roofing Industry Training Organisation (PGDR ITO) states that the support function should be adequately funded, as it is crucial for trainee progression. Increased costs for off-job training have limited provision of on-job learning support. Clear expectations of services would help determine appropriate funding levels for service functions and performance management of the ITO.

65. New Zealand Hairdressing Industry Training Organisation (HITO) supports the proposals to provide feedback on trainees’ progress and training and mentoring of workplace trainers. They comment that having a funding stream and clear academic outcomes for the latter would be valuable. Service Industries Training Alliance (SITA) stated that they often receive feedback that tutors are ill-prepared for their role.

66. Two ITOs are concerned that a tight definition of the ITO role could stifle innovation and flexibility. Competenz is concerned that increased monitoring of ITOs could increase the cost to Government. ATTTO is concerned that the new definitions could increase tension between ITOs and providers.

67. There is support for the ITF proposal to establish a Vocational Education and Training (VET) working party to work through the suggested changes with many ITOs indicating they would like to be part of such a process. Competenz also suggests a strategy and vision for the overall VET Sector be developed. The Communications and Media Industry Training Organisation (CMITO) state that it is important that TEC, the New Zealand Qualifications Authority (NZQA), Ministry of Education (MoE) and Ministry of Business Innovation and Employment (MBIE) adopt an all-of-Government approach to industry training.

68. Two ITOs comment on the importance of getting SMEs involved in the training process and the difficulties in ensuring this under current funding. The ITOs describe how they are currently offering non-credentialed training to SMEs to engage and support them to progress to national qualifications.

13

69. Some ITOs comment on employer experience within the ITO process. The Building and Construction Industry Training Organisation (BCITO) says that employers are opposed to an off-site theory/practice split. Electricity Supply Industry Training Organisation (ESITO) supports employers having the right to choose providers independently of the ITO. CMITO supports company-wide training plans for large companies.

70. ITO mergers received some comment. Competenz supports the idea of fewer ITOs and for current ITOs to be rationally grouped together. InfraTrain supports ITO mergers that are based on industry need. For example, InfraTrain would support a broad-based infrastructure ITO.

71. The Skills Organisation (TSO) asked whether the requirement to have a union representative on the ITO board has been superseded by how ITOs have developed and whether this requirement could be removed from legislation.

72. EMQUAL states it has serious concerns about the proposals. It states that many of the recommendations are inappropriate for organisations setting standards across sectors where public good is the focus rather than increased productivity. EMQUAL wishes to cease being an ITO and become simply a standard setting body.

Tertiary Providers

73. Feedback on ITOs retaining their arranging training role was mixed. Some training providers, such as Jupiter Training Resources, which is a trainer within the food and manufacturing industry, strongly support the role of its ITO. Other providers question the quality of ITOs in training arranged by ITOs. Some providers make the point that ITOs prioritise revenue generation and sales over the quality of training. The hairdressing department of Waiariki Institute of Technology notes that once a trainee is placed with an employer by a salesperson of HITO, there are no qualified subject specialists from HITO setting up training plans to suit trainee and employer needs.

ITOs receive one (main) stream of funding and split this between internal (standard setting, quality management, leadership, etc) roles and the purchasing of training and assessment from external agents (PTEs, etc). In our experience, they will always service their internal needs first. Tectra

74. There was general consensus among providers that there should be a clearer boundary between arranging and delivering training. The New Zealand Association of Private Education Providers (NZAPEP), the Waikato Institute for Leisure and Sport Studies (WISS), and Training Systems and Solutions make the point that competition between ITOs and tertiary providers has created tension and hindered outcomes and this is due to the blurred boundary between arranging and delivering training. Independent Tertiary Institutions (ITI) contends there are a number of instances of “industry assessors” being used by ITOs to circumvent the ban on delivering training. Seven providers thought performance would improve if ITOs focus more on what they do best, arranging training.

Is not the development of learning materials, supporting apprentices, and assessing apprentices actually the delivery of training? Unitec

14

75. ITI questions whether a clearer definition between arranging and delivering training will make a difference, as ITOs simply ignore the restrictions on delivering training.


76. Independent MACs were vocal in their criticism of the quality of training that ITOs arrange. In a similar fashion to providers, they are concerned that a focus on profitability and minimising costs comes at the expense of the quality of training.

Competenz’s main engineering certificate (Mechanical engineering general engineering; nominally 270 credits) was at inception roughly one third night-class, one third block-course and the rest workplace assessed. Currently 197 credits are workplace assessed (employer delivered) and around 80 are off job delivered. The ITO therefore is only “arranging” about 30% of the whole cert. Whangarei Education and Business Services

The ITO double fees justifying it by claiming they will provide all manner of additional services some of which their staff can’t provide because they are not trade qualified or don’t have the necessary trade experience or knowledge, and much of this additional compulsory service is of little, if any, use to us. Southern Group Training Trust

77. MACs question whether ITOs should retain their arranging training role given their poor communication with relevant stakeholders, disorganisation and general ineffectiveness in arranging high quality training. MACs claim ITOs usually arrange training at their convenience and the timing of training is sometimes inconvenient for the apprentice and out of synch with industry labour demands.

A painting MA [Modern Apprentice] being scheduled to attend the only relevant block course at CPIT [Christchurch Polytechnic Institute of Technology] only to have the MA turn up and be told it had been cancelled. The ITO forgot to let the employer or the apprentice know, and the MA had travelled to Christchurch to attend it. The same MA is now scheduled to attend his final block course which has foolishly been scheduled for early December, a prime time for painters to be out on the job…while we raised our concern about the timing with the ITO it was ignored.1 Smart Careers and Southern Group Training Trust

This year while we had advised that there would be at least 24 new first year engineering apprentices the ITO saw fit to provide only three Training Manuals which meant the first evening class was a waste of time and effort for all those involved, some of whom travel two hours return to attend. Smart Careers and Southern Group Training Trust

78. Despite these problems with poor performance, Southern Group concedes the arranging training role of ITOs might have to continue because the geographic isolation of trainees and the range of trainees’ needs make it necessary.

Other submitters

79. Only fourteen submitters commented on this question. Several submitters noted that ITOs are best placed to continue in this role, as the current system works well. Increased clarity for employers and trainees about what is expected is welcomed. One submitter hopes that new expectations will be developed with ITOs and industry bodies and be evidence-based. They also note that new definitions, in terms of what support should be provided to learners, would be

1 This happened under Creative Trades, a poorly performing ITO that is now defunct.

15

useful to any organisation that includes a work-based component in their qualification.

ITOs are the best organisations to arrange training as they have the contacts with industry and can broker where training should best take place to meet an employer’s needs. NQF Solutions

80. One submitter suggests that the role needs to be strengthened to complement the sector. Another submitter commented that the ITOs are currently underfunded to perform tasks associated with this role.

81. Three submissions from unions note that there could be greater specification and guidance around this role, while still allowing for a degree of diversity in how ITOs meet these goals. One submitter stated that there is a need for a mechanism to clarify the distinction between arranging and delivering training. They added that ITOs should not deliver courses and instead remain focused on their core roles.

82. One submitter notes that it is important not to mistake the voice of the ITO for the voice of industry. They are concerned that industry voice will be subsumed as ITOs fight for survival in any amalgamations.

‘Industry view’, is not synonymous or representative of ITO views. Plant & Food Research

83. The Tertiary Education Union comments that ITOs should work more closely with ITPs and other providers to meet this role. It suggests that ITOs should not direct how and what is taught, but focus on standard setting and moderation. It states that a distinction between theory and practice is unhelpful. It also comments that ultimately ITOs and providers have the same goals meeting industry and learners’ needs, and the economic goals of the country.

84. Two submitters support the establishment of an implementation working group and signalled their willingness to be involved in it.

QUESTION 3 INCREASING EXPECTATIONS OF COMPLETIONS

What are the benefits and risks for employers and trainees in your industry of increasing the expectations for ITOs of qualification and programme completions?

Employers

85. The majority of employers did not comment on this proposal. Those that did recognise that qualification completions are important, both for trainees and employers. Completions are one way to improve the returns on investment of industry training for the Government and employers.

86. The benefits of qualification completion for trainees were widely acknowledged including trainee confidence, an increased likelihood of pursuing further training and higher skill levels. However, submitters commented that it is important that learners develop commercial competence and the quality of qualifications is maintained.

16

87. Employers commented that a close partnership is required between employers, ITOs, training providers and trainees to facilitate successful completions. Employers acknowledge that there has been success in increasing completion rates in recent years.

With the help of our ITO, Careerforce, we are achieving more training completions than ever before. Presbyterian Support South Canterbury

88. However, a large employer said that the increased onus for completions has fallen on industry, rather than ITOs even though ITO funding has increased.

89. The timing of provision was identified as important to supporting qualification completions. Skyline Enterprises and Framework suggested courses should be timed to suit job or industry requirements, rather than scheduling in accordance with the academic year. Additionally, employers suggested that there needs to be improved recognition of changing labour demands such as seasonal work in the dairy industry. It was noted changing labour demands can affect the incentive and availability of workers to train. To mitigate this, one employer said funding needs to be committed over a five year time period.

Comments from some industries in the Ministry review suggests that ITOs and industry have difficulty dealing with the impacts of seasonal peaks and troughs because trainees are not always available to progress and be assessed against the competency requirements. Although we operate within a seasonal industry, it would appear that the TEC operational policy settings should offer sufficient flexibility for trainees to be put “on hold” to mitigate duration issues. Fonterra

90. Some employers argue poor qualification completions is the result of funding settings. They claim too much emphasis is placed on course enrolments, rather than course completions. Also, funding for training organisations recognises the number of courses on offer and their duration instead of the trainees’ skills.

91. There is a concern that training organisations focus on providing courses that are profitable, rather than what trainees or industry require. Qualifications must reflect employment opportunity, for the trainee’s benefit as much as that of industry.

92. Increased completion targets may be above industry or trainee needs and a widespread concern is that trainees who have only completed low level courses may be excluded from funding. These trainees have skills that are valuable to industry. In this vein, one employer called for fewer rules around qualification completions.

93. There was little feedback on the sharing of standards. However, cost efficiency was welcomed and some employers anticipated using ITO standards. Submitters identified a risk that inconsistency may result if tertiary providers and other ITOs use ITO standards without using standardised learning materials developed by the same ITO who set the standard. Two employers added that ongoing support for adequate literacy and numeracy is important.

94. Two employers said the availability of resources and training providers can inhibit progress, and another called for ITOs to address the lack of training providers outside the main centres.

95. In the experience of the regulated maritime industry, training and certification is mandatory to employment so completion rates are very high. Two employers

17

suggested funding be paid per trainee rather than per qualification, and another stressed that the primary purpose of the MAC should be qualification completion.


96. Industry Associations are supportive of increasing expectations for ITOs of qualification and programme completion. Twenty-four of thirty-nine associations who answered this question agreed with this proposal. Industry Associations stated that this proposal would maintain and enhance completion rates and raise skill level and performance over time.

97. Some associations stated that meeting revised goals will require adequate resourcing and incentives. A focus on outcomes instead of inputs is seen as valuable, but it was suggested that it may be helpful to focus on smaller units rather than whole qualifications. Targets need to be set at an appropriate level.

98. There is concern that higher completions should not be at the expense of lower level qualifications. Level 2 skills are viewed as particularly valuable. This is because they provide foundation skills, pathways and transitions, an entry point for unskilled workers, and access to literacy and numeracy skills. One association stated that they strongly supported achievement-based funding, but only with mandated pre-requisites in lower level skills including literacy and numeracy.

While EMA supports the need for a higher skilled workforce, it feels equal emphasis should be placed on the value to industry of level 3 and 4 qualifications as they contribute significantly to productivity improvement, innovation and provide employees with lifelong skills. Employers and Manufacturers Association (EMA)

99. There is also concern that an emphasis on quality should not be lost in favour of quantity. All qualifications must remain high quality.

Performance linked funding can drive achievement but can also drive standards downwards. Past unethical activity reflects a tendency for organisations to act primarily for their own survival, not necessarily in the best interests of trainees or the industries they are supposed to serve. In principle trainees should be pushed to complete, but not at the expense of standards. New Zealand Outdoor Instructors Association (NZOIA)

100. Additionally, there is a view that the circumstances of industry may have to be accommodated and that any system must firmly reflect industry and business need. Different industries have different needs and these will change over time so the system cannot be too inflexible.

The completion targets for industry training will have to be tempered with the realities around commodity markets and business priorities. Forest Owners Association (FOA)

101. There is concern that these targets may influence ITOs to see themselves as responsible to Government rather than industry. There is also support for the idea that quantitative measures should be linked to industry and not compared with other types of providers. Some industry associations expressed concern about how completions will be measured. There is concern that certain industries could be disadvantaged because of the nature of the work cycle. It is noted training cycles based on calendar years, rather than work cycles may disadvantage the trainees.

18

102. Some associations stated that completions are not an end in themselves. It is more important that employer and trainee are getting what they need. Outcomes should be tailored to industry needs, rather than simply ensuring high completion rates.

It is important that we don’t fall into the trap that completions become an end in themselves. There are many cases when trainees (and employers) may regard completions of qualifications as unnecessary….The principle measure of success in this regard should not be whether or not a particular box (e.g completions) is ticked but rather are the trainee and employer getting what they need? NZ Shipping Federation

103. Various associations noted that Government needed to realise that there were many reasons for non-completion. Those listed included a transient workforce, people only undertaking training to meet regulatory requirements, and the qualification not being fit for purpose. One association noted that cutting funding should not be the only incentive and that there may be more effective ways to incentivise completions. They suggest that funding could be based on the number of unit standards completed rather than an “all-or-nothing” approach. They also suggest a staggered funding approach where funding is received at various points in the apprentice’s training journey.

104. There is support for further consideration of how people in vocational training get their qualifications to ensure training models reflect workplace reality.

…thought needs to be given to how apprentices attain their standards. As this may not be a straight line process the funding mechanism will need to align so as to not disadvantage either the ITO or apprentice. Registered Master Builders Federation

There needs to be short course off job training to provide key technical skills that cannot be attained in the workplace. Courses must be modular to provide the trainee with the specific skills and the employers with productivity gains and value. Modular courses can staircase to qualifications. Pipfruit New Zealand

105. Some industry associations noted that a major risk is over or under qualifying the employee pool. There should be a close match between skill levels and the labour market. One association suggested that it may be necessary to incentivise completing higher level qualifications if these are not directly job related.

We are concerned to ensure that there is a good match between the skills levels acquired through vocational training and those required in the labour market. A responsive vocational system should enable improved matching… Business NZ


106. Twelve of twenty-three ITOs agree with the proposal to increase expectations for ITOs around qualification and programme completions. The benefits are seen as:

better support for trainees

better results monitoring

the creation of clear pathways for learners

better value for money

increased numbers of qualified people

19

meeting industry requirements for increased completions

improved educational performance.

107. Five ITOs noted that there may need to be some flexibility in the targets to reflect the realities of work flow and industry training itself. This includes addressing different learning situations and learner groups. This is especially the case if any comparison with institution-based providers is to be attempted. For industry to buy-in to targets there may need to be incentives to complete higher qualifications, which are not directly job related.

The ITF believes that Government’s focus on progression to higher qualification levels needs to be balanced with the realities of training at different levels and across different industries. ITF

The very different (compared to institutional education) circumstances and requirements of industry training must be fully taken into account, including seasonal employment and impacts of commodity market trends. FITEC

There needs to be a degree of flexibility to enable trainees at all levels to have their needs met, which reflects the complexity and nature of the environments and circumstances in which our trainees learn. InfraTrain

108. There is concern from four ITOs that higher level qualifications should not be pursued at the cost of lower level training including literacy and numeracy training. Entry level qualifications should still be funded as on-job learning and pathways from levels 2 to 4 should be encouraged. Competenz suggested that too much emphasis on completion at higher levels might devalue level 2 and 3 qualifications.

109. Five ITOs stated that completion and progression should not be ends in themselves. These measures could over-emphasise complete qualifications at the expense of usefulness to the sector and learner. This model does not value employment and skill utilisation outcomes. ITOs should not be judged solely on academic outcomes as competence involves learning, practice and experience. There is a risk that quantity is valued over quality.

Achieving the qualification or completing the programme becomes more important than spending the time learning and applying the learning in a way that benefits both the learner and the business. ATTTO

110. There is concern about how completions would be measured. BCITO suggest that the targets should be based on numbers enrolling, not the numbers in training. Three ITOs suggested that completion rates and progression should be negotiated with each ITO to reflect the diversity of sectors. Two ITOs also noted that staircasing through different qualifications is not necessarily linear. People should be able to access qualifications at the level that is needed. TSO suggested rewards linked to performance above a base level and relative improvement over time. Not reflecting the different starting points of sectors in training could, over time, reduce some sub-sector and sector access to training.

111. EMQUAL suggested they won’t be able to meet Government requirements and performance criteria for future funding because their trainees are largely volunteers. Additionally, the 40 credit requirement for funding as well as the expected credit and qualification completion rates poses significant barriers to

20

volunteer engagement with higher levels of training. This will in turn impact the quality and coordination of emergency management.

Tertiary Providers

112. Overall, providers support higher expectations of qualification and programme completions for ITOs. Three submissions stated that a benefit of this proposal would be more qualified staff with greater skills. However, this may also result in staff retention issues as better qualified staff may be more likely to leave.

113. Blueprint for Learning proposed key performance indicators should be set and related to funding to facilitate completions.

114. NZAPEP and WILSS thought more focus on completions would force ITOs to work with providers, rather than compete.

115. The School of Applied Technology for the Bay of Plenty Polytechnic emphasised that completion rates must be coupled with transparency and accountability by the ITOs. They also stressed that the quantity of completions gained must not be to the detriment of quality.

116. Another risk identified was that a focus on completions might result in marginalisation of learners at lower levels. It was also possible that ITOs may pass on the increased onus for completions to employers.


117. Regent Training Centre agreed that more emphasis on completions would lead to more qualified staff with greater skills. They see this as having a positive impact on productivity, rising returns on investment for taxpayers and increasing consistency. However, they also pointed out there is the potential for ITOs to ‘fudge’ results or ‘dumb down’ qualifications.

118. Southern Group Training Trust stated that the content, timing and quality of qualifications must reflect the needs of industry and not be influenced by the ITOs short-term performance pressures.

119. MACs generally made the point that if focus on ITO completions came at the expense of non-ITO MACs this could be detrimental to outcomes as non-ITO MACs typically have better completion rates. To support their submissions, some independent MACs included letters of support from employers and apprentices supporting the retention of their services.

By not engaging independent Modern Apprenticeship Coordinators, this could be detrimental to levels of support and ultimately completion rates. Regent Training Centre Ltd

Given the choice we would prefer to retain the services of our Modern Apprentice Coordinator…[ITOs] have a poor track record in delivering service directly to industry, and have a record of charging for service they do not deliver. Amtec Engineering

My Modern Apprentice Coordinator is trade qualified, understands what it is like being an apprentice, knows the apprenticeship training system very well, and is there to support me when I need it, not when it suits him. Apprentice

21

120. The joint submission by Smart Careers and Southern Group Training Trust noted there could be multiple reasons for non-completion unrelated to performance concerns such as relevance of courses to industry, the difficulties created by challenging economic conditions and levels of numeracy and literacy at the beginning of courses.

Other submitters

121. Fourteen submitters commented directly on this proposal. One submitter supported an emphasis on performance.

It’s time ITOs caught up with the rest of the sector. PTEs and more recently polytechnics have been living in the performance world for some time. Plant and Food Research

122. Three submitters commented that improving completions was good, but that Government should be careful not to introduce perverse incentives that prioritised numbers completing over quality of graduates.

123. Two submitters suggested that there was a need to consider pathways from completion. These should include progression onto level 5 and progression into further tertiary training.

124. Three submitters commented that completion targets should be varied by sector and learner to take into account different settings and training histories. One submitter noted the need for shorter and more specific qualifications. One submitter noted that this proposal would make it harder to reach SMEs.

One size does not fit all however the Government as the predominant funder must ensure NZ is getting value for money. Private Individual 5

125. Another submitter commented that the value of level 2 and 3 qualifications should not be lost in pursuing this proposal.

126. Three submitters from unions stated that they accepted the need for increased completions and noted the progress that has been made towards this aim. However, they expressed concern that the proposal may exclude “marginal” or “risky” trainees. They suggested that this will have negative economic and social outcomes and lead to greater exclusion from training. They also stressed the need for a more strategic view of medium term requirements rather than simply one based on completion targets.

QUESTION 4 SKILLS LEADERSHIP

What are the benefits and risks for employers and trainees in your industry of transferring the skills leadership function to industry?

Employers

127. Many employers disagreed with this proposal. However, the strength of this opposition is mitigated by two factors. First, although 115 submitters disagreed with the proposal, 105 of these submissions came from Competenz linked employers, most of who made submissions on a standard form provided by Competenz. Second, the intent of the question may have been misinterpreted by some employers as the proposal never intended to remove ITOs from the skills leadership function, only to open up skills leadership to other organisations.

22

128. The main reasons employers gave for opposing this proposal are:

ITOs are best placed to communicate with Government on behalf of the industry as a whole

different business ability to engage with Government

many businesses don’t have an industry association to represent them

large players may dominate communication with Government

inconsistent and incomplete skill needs analysis

SMEs lack the resources, time and leadership to effectively identify and quantify upcoming skill shortages.

Industry Associations were not established, nor are they funded, to do the in-depth analysis required to offer sound advice on skills needs. It would be too easy for the loudest voice, or the largest voice, to capture the process leaving the bulk of enterprises, the SMEs, with no avenue to reach government. ITOs have contact with a large number of enterprises and are best placed to represent our skill needs. WYMA Engineering NZ Ltd

129. Downer New Zealand recognise that ITOs are currently undertaking leadership and skills initiatives at the broader industry level, saying:

…ESITO do valuable work promoting vocational career pathways to school students and under-represented groups in our industry, namely women, Maori and Pacific people. We see value in this offering (and don’t have the resource to do this ourselves or collaborate with industry)… Downer New Zealand

130. In contrast, however, Restaurant Brands New Zealand Ltd, KiwiRail Interislander, and Fonterra, three large employers, were all supportive of industry communicating directly with Government. They suggested this offers:

increased authority and responsibility to industry to champion their skill needs

a better understanding by Government of industry relevant training approaches

improved alignment of the training sector with industry requirements

more relevant assessment.

It is important industry provides the areas of skill shortages, this would remove training institutions providing courses where minimal or no employment opportunities exist. Contact Energy/Mighty River Power

Our industry must take the initiative back from the training organisations and become central players in the process of determining the training and assessment outcomes of our staff. KiwiRail Interislander

131. This proposal would allow ITOs to focus more on standard-setting and arranging training. It would give a clearer role definition to ITOs and ITOs could focus more on the training needs of industry, rather than overall educational objectives. One employer is pleased that a path for communication when their ITO does not perform will be opened up.

23

132. Submitters suggested that industry may choose to delegate a leadership function to ITOs if there is no other obvious leader. It is also suggested that ITOs might set up industry discussion groups to communicate with Government and facilitate investment in labour market research capability. Some submitters noted that ITOs are owned by industry so direct involvement already exists.


133. Industry associations are divided over opening up the skills leadership function to industry. Eighteen agreed with the proposal and sixteen disagreed.

134. There is some confusion over what the skills leadership role actually is and there was a suggestion that it requires better definition from both Government and industry. Some associations feel the current system has had mixed results. Industry associations commented that any process should be industry-led, rather than being driven by Government.

135. Some associations are strongly supportive of industry-led skills leadership. These associations stated that ITOs’ current skills leadership role is not sufficiently industry facing. ITOs make decisions about training structures and provision based on their own needs and the needs of providers, rather than consulting with industry.

136. Other associations commented that industry want intimate involvement with the development of standards that demonstrate competence in the workforce and this proposal would reinforce the importance of industry. This proposal would also better align industry directions with Government investment leading to a focus on the sharper end of commercial need. Industry associations stated that successful transfer will require closer alignment of policy across Government.

Industry have businesses to run but are very interested in ensuring we are involved in having our needs heard directly and not via any ‘filtering’ systems. Waikato Engineering Careers Association (WECA)

137. Some associations suggested that Government is currently difficult for small industries to negotiate and this proposal should improve this. It would also serve to remove duplication between industry and ITO work that currently occurs. One association stated that they want the same level of engagement with TEC and MBIE as they currently have with ITOs. Other associations suggested that industry will need funding to undertake this role. The level of funding would be dependent on the level of involvement required from industry.

138. There are questions raised by associations about how industry consultation would actually function in practice. One association questioned whether Government is open to industry needs given that there is conflict with ITOs on National Qualification Framework (NQF) processes and qualifications.

The details of how this will work are quite sketchy with more clarification needed. Print NZ

139. Some industry associations commented that industry should be tasked with identifying its own training needs and then working with ITOs to meet them.

Industry, through their advisory group, can independently determine its training needs and then work together with the ITO to agree on how and what training will be delivered.

24

The ITO needs to be seen as an agent for industry, acting on their behalf in its interactions with TEC and NZQA. Scaffolding Access and Rigging NZ (SARNZ)

140. Industry associations view themselves as critical to the successful implementation of this proposal. In some cases, associations see themselves as more representative and better versed in the skills requirements of the sector than ITOs.

141. Some industry associations stated that industry groups should be involved with skills leadership, but ITOs should not be precluded from participating. Others indicated that they would like to communicate skills needs in conjunction with their ITO. Others suggested that ITO involvement should be optional for industry. One association suggested that ITOs should be monitored to ensure they are undertaking sufficient industry consultation. One association stated that TEC should ensure that ITOs are delivering the skills leadership role and hold them contractually accountable for this.

We have long been of the opinion that leadership needed to come from industry and that whilst the ITO has a role to play, they should be a participant – not a leader. Master Plumbers, Gasfitters & Drainlayers NZ

142. Several industry associations commented that ITOs should retain their skills leadership role, arguing that ITOs are best placed to investigate future skill requirements, are well placed to communicate with Government and are experienced, effective and efficient at this role. They also suggested that removing the skills leadership role removes ITOs from engaging with the sector.

The proposed changes are an unnecessary lengthening of the industry training supply chain. Northland Wood Council

CETANZ see this proposal as a huge step backwards. We would prefer that ITOs continue to carry out this function as they are experienced and currently perform this task well. Civil Engineering Testing Association of New Zealand (CETANZ)

We think transferring leadership to industry is a very dangerous and counterproductive suggestion…. As an industry organisation, we are part owner of the ITO and therefore we already have a direct involvement in skills leadership through the ITO. There seems no reason to change this system that is working for us. Fitness New Zealand

143. Three associations stated that industry will expect ITOs to continue this role.

The Associations operating in this sector believe they have ownership of the ITO and will continue to expect the ITO to provide a leadership role in the labour market and skills needs of the hospitality industry. Hospitality New Zealand

There is considerable concern from associations about how any new process would capture all industry voices adequately and fairly. Associations identified risks around:

capacity of industry

businesses’ desire to have this role

financial costs for industry

‘large budgets’ and ‘loud voices’ dominating consultation

25

industry fragmentation making concerted engagement hard

variable quality of skills intelligence produced, particularly on long term skill requirements

possibility that the proposal may transfer rather than resolve problems identified with skills leadership.

One association asked what the consequences would be if no industry skills leadership occurred. There is particular uneasiness about how SMEs would engage with Government.

We are concerned that if industry is at all fragmented then problems will arise that will impact standard setting, arranging training, and increase cost to industry as a result. The Electrical Contractors Association of New Zealand (ECANZ)

144. There was also some discussion of how MBIE, TEC and other Government agencies would build their own capability and capacity to undertake formal and robust dialogue with industry.


145. ITOs generally agree that greater involvement between Government and industry is desirable. However, how this will be managed is questioned by a number of them.

146. ITOs stated that improved links between Government and industry would benefit all stakeholders in industry training and indicate that skills leadership is being taken seriously. There is a need for a clear mechanism for industry to communicate skills needs to all those with an interest in skills and industry training. ITOs are aware that direct consultation is already taking place in some sectors and attempts to extend and systemise this would benefit industry. ITOs also see that this proposal may also clarify and refine the definition of skills leadership.

147. ITOs identified a number of barriers to achieving the transfer of skills leadership. Eight ITOs expressed concern about the capacity and capability of SMEs to engage in skills leadership. They identified SMEs as tending to lack resources and be highly fragmented. It is suggested that ITOs coordinate these disparate voices.

It is believed that without using JITO as a conduit, the small size of the sectors and fragmentation of businesses, possibly due to the large number of SMEs, skill leadership for them may be a “non event”. Joinery Industry Training Organisation (JITO)

148. A number of other barriers were also identified including:

Government being unable to replicate the penetration into industry that ITOs have

the lack of clear definition of skills leadership

industry participation requiring funding

26

the potential for decreased collaboration between ITOs, sectors and providers

the muddying of where the key responsibility for skills leadership lies; difficulty in mobilising leadership and difficulty in developing processes to ensure skills needs are adequately conveyed

identifying representative voices within an industry or sector; a potential lack of flexibility and responsiveness to meet industry requirements

difficulties for industry in conveying skill need clearly

how ITOs would access skill needs information to inform standards and qualification development.

149. ITOs stated that they should not be precluded from the skill leadership process. Four ITOs said that ITOs have a role to play and this should be recognised, funded and harnessed. They commented that industry is unlikely to take the lead in skills leadership and will look to ITOs to do this. The New Zealand Industry Training Organisation (NZITO) suggested that it may be desirable to allow industry to delegate this role to the ITO if there is no industry led coordination available. InfraTrain stated that industry associations and ITOs should collaborate in the skills leadership role.

The ITF is committed to working with MBIE, industry and other organisations to develop and implement an approach to industry skills leadership that represents value for money for both Government and industry; facilitates representative and industry-led discussions between Government and industry; and that recognises the skills leadership that ITOs will provide their industries through their arranging-training and standard setting functions. ITF

150. Five ITOs suggested that the skills leadership role of ITOs should be retained. They see removing it as being at odds with the strengthening of other areas of ITOs’ responsibilities. They also see losing responsibility for skills leadership as reducing ITOs ability to respond quickly to industry skill need. HITO suggested that retention should come with clear guidelines about the necessity for industry liaison and consultation. Six ITOs stated they will continue their skills leadership support irrespective of where responsibility for it ends up as it is necessary for other roles and it is what industry wants. Three ITOs stated that this will result in duplication of effort as ITOs will still be required to undertake skills analysis.

151. NZITO said that it is presumptuous of ITOs to assume that they are skill leaders for industry. They also suggested that Government’s abilities to access data and analyse labour and economic data at a macro level are important components of its participation. Careerforce queried whether the skills leadership role would be a conflict of interest for ITOs who work with Government contracts. ATTTO commented that removing this role would free ITOs to concentrate on their standard setting and arranging training roles. Three ITOs stated that it is crucial that skills leadership is driven by industry rather than Government.

152. Two ITOs are concerned about ensuring ITO work that has been undertaken in the secondary-tertiary transition space is not lost.

27

Tertiary Providers

153. Providers welcome this proposal. Four providers suggest that this will increase the voice of industry and in doing so ensure training is more relevant. Tectra suggests closer involvement in skills leadership by industry could assist productivity as there would be a close relationship between the skills required to be developed and training.

154. Another benefit identified was to reduce conflict of interest for ITOs from their roles in skills leadership and arranging training.

155. There were important issues raised about how this proposal would work in practice and what the future role of ITOs in skills leadership would be. One of the main concerns was that it might be difficult for small organisations or sectors to be heard if skills leadership is “industry led”. Five providers specified that industry associations were not established or funded to perform skills leadership. However, another provider stated there are 70 industry associations in New Zealand and these organisations provide a coordinated communication path. Eight providers also felt that ITOs were better set-up to reflect all the voices of industry and skill needs, rather than industry representatives.

156. The Waikato School of Hairdressing raised the concern that industry led skills leadership might lead to too much focus on individual business interests, rather than system wide concerns.

157. Providers suggest broad consultation was necessary for this proposal to work in practice given the lack of detail over how industry-led skills leadership would be implemented.


158. Most independent MACs were supportive of this proposal. Some MACs viewed this as a better approach to skills leadership than the status quo due to problems with ITOs connectedness to industry.

159. Advantages of opening up skills leadership to other participants included more transparency and accountability for ITOs from industry, enabling ITOs to focus more on their core roles of arranging training and standard setting, and lower costs.

160. Whether this worked in practice, however, did depend very much on broad consultation prior to implementation.

161. The main concerns raised by MACs were the costs and time this would take for industry to perform this function and uncertainties regarding how industry leadership would be facilitated. Indeed, the prominence of industry in this process could be reduced if this significantly increases training costs or involves a large time commitment.

Other submitters

162. Fifteen submitters commented directly on this proposal. Four submitters noted that the role is currently ill-defined and a clearer definition would be helpful. The New Zealand Council of Trade Unions (NZCTU) commented that there is a risk

28

that skills leadership will “fall between the stones” and that an already inadequate situation will not be improved. They stated that a template around the questions that a strategic approach to skills must address should be developed. They also stated that some ITOs remain well placed to carry out this role.

163. Three submitters advocated ITOs retaining the skills leadership function with appropriate reporting and monitoring work carried out annually to ensure that it is being done well. One submitter noted that a well-run ITO would do this anyway. One submitter noted that ITOs are not separate to industry, but a part of it so ITOs working with Government is industry working with Government. Two submitters noted that whatever happens some of the skills leadership role is tied to the standard setting function and would remain within ITOs’ sphere. Three submitters commented that any transfer would be inefficient, complicate the system and have limited impact on the workload of ITOs.

The industry needs to dictate what is best for their sector, however with so many different focuses within each industry we believe ITOs are well placed to take on that function on behalf of industry. Competency International

When the ITO system of consultation with the industry and the ITOs are accountable to their industry the present system works well. Governments only role should be to fund and audit ITOs to insure they are working and listening to their industry trainers. Gisborne Development

164. Two submitters stated that ITOs are used to addressing the strategic challenges of industry. They commented that ITOs have experience in industry and education. In consequence, they can think strategically about issues facing industry and how skills can address those issues. On the other hand, it was argued industry bodies are much more likely to focus on immediate need. One submitter noted that it was possible that this would lead to skills needs of certain jobs being more narrowly defined and therefore decrease the range of skills a trainee learns. However, submitters also noted ITOs do not have a monopoly on this and it may be necessary to get other stakeholders, including providers, involved.

165. Three submitters identified issues around SME capability and capacity to engage with the proposed process. They identified the risk that smaller or more specialist employer voices could be lost. One suggested that MBIE and TEC would need significantly increased capability and capacity to engage meaningfully with all industry bodies. Another submitter stated that it would be interesting to see whether industry bothered engaging in the process. One submitter asked “why does the Government want this information and what will they do with it?”.

166. Two submitters from unions noted that this proposal will need an “all-of-Government approach”, not just vague expectations. This will include roles in resourcing, consolidation of expertise and methodology of strategic leadership. They also noted that TEC and MoE have a role in ensuring cooperation across the VET sector and that there must be clear lines of communication for all stakeholders. They suggested that the Minister should meet with all stakeholders regularly. They asked for more detail on proposed Government support for the implementation of this proposal. They noted that any definition of industry must include organisations representing the workforce.

29

3. Apprenticeships and traineeships: definitions and funding

Proposals

A more sustainable funding regime that increases the subsidy rate for traineeships and introduces a higher subsidy rate for apprenticeships.

Amalgamating all apprenticeships into the Modern Apprenticeship Scheme to enable the same level of support to be available for all apprentices, regardless of age.

Consider whether to incorporate the modern apprenticeship coordinator fee into the training rate for apprentices or keep it as a separate fee.

Overall

167. There is widespread support among most submitters for a higher subsidy rate for apprentices and for amalgamating all apprenticeships into the modern apprenticeship scheme.

168. The higher subsidy rate would encourage the uptake of more apprenticeships and recognise the higher costs of apprenticeship training. ITOs also suggested a higher rate could possibly decrease tensions between ITOs and providers as this would be mutually beneficial to both groups. However, some MACs questioned whether higher funding rates would necessarily lead to more apprentices.

169. One problem in increasing subsidies for apprenticeships, according to industry associations and ITOs, would be that it might devalue traineeships by creating a two-tier system with apprenticeships more highly valued than traineeships.

170. Even more important were issues around how to define an apprenticeship. ITOs and providers think this should include competency and theoretical knowledge as a core competency, while employers thought it was impractical to define apprenticeships solely by the number of credits. In addition, employers and ITOs suggested that employer in-kind contribution to the cost of training should be recognised.

171. As with the higher subsidy rate, extending equal support to all age ranges would encourage more apprentices. This proposal would also increase flexibility and perhaps positively impact on completions due to higher quality staff as this would grant equal support to more mature trainees who are often regarded by employers as more reliable.

172. The main risks identified by submitters in extending support were the reduced opportunity for youth and that it may penalise seasonal industries.

173. For the modern apprenticeship coordination fee, there is more support for incorporating the fee into the apprenticeship rate over having two separate fees. In general, most of the different groups supported the first option, as it was considered a simpler system, with lower costs. However, MACs were strongly

30

opposed to both options on the basis that it would provide ITOs a monopoly over modern apprenticeship coordination, which would eliminate independent MACs.

174. There is some concern among employers, providers, MACS and other submitters that ITOs would use these funds for their own purposes, rather than on training.

QUESTION 5 HIGHER SUBSIDIES FOR APPRENTICESHIPS

What are the benefits and risks for employers and trainees in your industry of introducing a higher subsidy rate for apprenticeship training?

Employers

175. This proposal is widely supported; only four submitters expressed negative or neutral views. Employers stated that the cost of training apprentices is high and they believe that they would benefit from a higher subsidy rate.

A first year apprentice cost can include the following – four weeks holiday pay, approximately one week sick leave, three weeks trade school, Competenz [ITO] fees [of] about $1,000. A second year apprentice usually costs about the same as a first year but they start to break even. Third and fourth year apprentices then start to be productive. These costs do not include the cost of our time that we invest in training apprentices on the job. WM Ross Engineering Ltd

The cost to train an apprentice can be very high and any proposal to reduce costs and duplication, and provide extra funding, would be welcomed if it meant more money was available to support companies to take on apprentices. SEC Group Ltd

176. Employers support increased subsidy rates because apprenticeships have higher costs than traineeships, require substantially more theoretical knowledge and are highly valued by employers. The proposal would support New Zealand’s production of high-quality trades-people. In turn, this would support succession planning and reach segments of the population with historically low achievement rates.

Investment in trades and training apprentices is vital for the future of the development of trade skills and industry in NZ. IVE Group Ltd

Succession planning within roading is difficult for all companies. It is evident a 15 to 20 year gap has emerged, and encouraging our young people to join the industry training towards qualifications, which provide a variety of lifelong skill opportunities is crucial. Our industry encourages youth to work for us, an area of society which lacks recruitment opportunity in many other areas. Higgins Group Holdings Ltd

177. Employers want funding focussed on training provision, not on ITOs overheads. They are also concerned higher funding for apprenticeships might incentivise training providers to rebrand training schemes lacking industry relevance as apprenticeships to increase their revenues.

…ensure all apprentice funding is directed in a way that drives industry outcomes (productivity, safety, effectiveness) and not as an incentive to establish sub-standard training institutions seeking a revenue stream… Genesis Energy

178. Some employers say that it is impractical to distinguish funding rates through credits and instead industry conditions should be used to guide funding levels. Downer New Zealand requested consistent subsidy rates across ITOs because they are confusing and at times out of proportion.

31


179. Industry associations are largely supportive of introducing a higher subsidy rate for apprenticeship training. Twenty-four submitters agree with the proposal and one disagrees.

180. In general, associations see improved funding as positive, offering better support to apprentices and incentivising faster completions. They also suggested that the increase might incentivise uptake of apprenticeships. However, a higher subsidy must come with targets and be used to improve training outcomes.

This proposal is welcome. It will encourage the revitalisation of this important mode of training. NZ Shipping Federation

181. There is concern from industry associations about the two-tiered funding system and a perceived decrease in levels of funding for trainees. They stated that the support needs of trainees are not less than apprentices and that decreasing funding for traineeships devalues them. There should instead be equal service to all regardless of the qualification being undertaken. They suggested complexity of qualification delivery, in the form of a high level of theory or off-job training, not its size should dictate funding. Some industry associations stated that this proposal is a limited change, which is not flexible enough to meet the often changing needs of different industries. It is also suggested that a higher subsidy rate does not meet the needs of vocational occupations. One industry association expressed concern that the increased funding targets off-job providers.

We do not support any system that de-values the learning path of some trainees. CCANZ would prefer to see a system that strives to provide equal service levels to all trainees regardless of the qualification being pursued. Cement and Concrete Association of New Zealand (CCANZ)

182. There is also concern expressed by industry associations around the definition of an apprenticeship. They suggested industry should determine any definitions used. This is an area that several industry associations suggested could be addressed by the proposed implementation working group. Industry associations are particularly concerned that their current qualifications will not meet the credit threshold for apprenticeships and would lose funding.

We are concerned with the proposed definitions of “trainee” and “apprentice” and want these definitions to have meaning for industry. Industry should be able to determine the level and length of training as required as part of the traineeship and as part of an apprenticeship. To have meaning for industry there needs to be mechanisms for industry input to define “traineeship” and “apprenticeship”. Business NZ

This definition needs to be flexible enough to cater for the needs of different sectors in our industry – and for other industries. CMITO

The definition of an apprenticeship needs careful consideration. It needs to incorporate competency of practical skills built up over time, theoretical knowledge as well as the basics of English and maths. Without a clear definition there is a real risk of devaluing the Apprenticeship brand. The Institute of Refrigeration, Heating and Air Conditioning Engineers (IRHACE)

183. Industry associations stated that they do not want the credit limit for apprenticeships altered dramatically and that there needs to be clarity and consultation around qualifications credit requirements. They stated that one size

32

will not fit all. Some associations stated that 200 credits is too many for an apprenticeship. One Association suggested that 140 credits might be appropriate as it equals two years on-the-job study.

184. There is concern from industry associations that this proposal would lead to higher level training being preferred over level 2, both in funding and quantity of courses. They consider level 2 training must be protected as it provides an entry point for unskilled workers, foundation skills, pathways and transitions. Level 2 qualifications are valued by many employers because they increase the productivity of employees.

185. Some industry associations also commented that the real costs of training to industry should be reflected in the funding model. They suggested that a 30 percent contribution on a higher subsidy would be onerous unless ‘in kind’ contributions are recognised.

Cash contribution to NZQA based training is only part of the equation and the 30% cash cost expected is not taking into account the true investment made. There is no discussion here on contribution such as intellectual property, use of equipment, and manager’s time in workplace training that industry, firms and trainees/apprentices make. Horticulture NZ

There is a sense in the consultation document that the government is seeking to extract 100% of the outcome in return for its investment without sufficient consideration of what industry should have returned to it. Construction Industry Council (CIC)

186. Several industry associations suggested that where a person trains should not impact funding. Industry training should receive funding based on a formula similar to institutional training. They stated that a graduate who meets industry expectations is the most important factor, not where that graduate trained. One association called for an integrated VET system with neutral funding.

An apprenticeship is an apprentice, and we assume that they will be funded equally under these proposals whether enrolled with a tertiary provider or in a training agreement with an ITO. CIC

187. There is also support for a differentiated funding system within the apprenticeship system. This would implement a higher rate targeted at specific sectors and specific professions that are important to New Zealand’s economy or that are more expensive to deliver.


188. ITOs largely support a higher subsidy rate for apprenticeship training. Sixteen out of twenty-three submitters agree with the proposal. ITOs identified the following benefits of this proposal:

increase uptake of apprenticeships

enable ITOs to better support apprentices

improve engagement with employers and learners

encourage employers to commit to high quality/high cost training

33

more adequately reflect the higher level of theory and on-job and/or off-job learning required in these qualifications

enable them to better investigate options for training and fund more off-job training.

189. Two ITOs note that this model would not work in all sectors and that it could devalue traineeships and penalise those sectors without apprenticeship routes. ATTTO commented that longer qualifications are not necessarily better. They suggested apprenticeships and traineeships should both be funded adequately to meet the support needs of learners. SITA expressed concern that a focus on apprenticeships could make qualifications too academic for some industries.

Traineeships could be viewed as “second-rate”. ATTTO

190. There is widespread interest in ensuring that a simple, clear definition of an apprenticeship is developed. Fourteen submitters commented on this. Three ITOs stated that the definition of an apprenticeship should be flexible and could be industry specific, but should not be solely based on length of time served. ITOs consider that the definition should include competency and theoretical knowledge. Six ITOs advocate the Government taking a principles-based approach, rather than a rules/credit based approach to differentiate apprenticeships and traineeships. This would provide flexibility in meeting industry and learners needs.

The Skills Organisation believes that a simple definition of an apprenticeship is desirable, and recommends that any programme of over 100-150 credits at level 4 or higher be classed as an ‘apprenticeship’, and attract a higher funding rate. TSO

The definition should be flexible enough to cater for the needs of various sectors and industries…. to include the modular or pathways approach to apprenticeship. CMITO

We believe that the definition of an apprentice and associated support provided should be flexible and meet a need rather than basing support on ‘time served’ in a qualification. The definition of apprenticeships and the related funding rate therefore need to be based on learner support requirements rather than an arbitrary credit level. ITF

191. Four ITOs rejected a potential 200 credit based definition. There was concern current apprenticeships would lose funding if this model was adopted. A 120 to 140 credit structure was preferred. It was suggested that this was one area the proposed VET working group could consider. Three ITOs asked for the 70 credit per year limit to be reviewed and removed if possible.

192. Four ITOs advocate that employers’ “in kind costs” be included as part of the employer’s contribution to the costs of training. HITO asked whether the 30 percent industry cost would be a percentage of the incorporated MAC fee amount. They suggested that if this was the case the cost could prevent industry recruiting an increased number of apprentices. The Hospitality Standards Institute also recommended the establishment of a single fund for all apprentices. The income generated from this proposed fund by its users could be counted as part of the employer contribution.

193. Four ITOs asked for funding to be allocated on an identical basis to tertiary providers.

34

An apprentice is an apprentice, and we assume that they will be funded equally under these proposals whether enrolled with a tertiary provider or in a training agreement arrangement by an ITO. BCITO

194. Three ITOs suggested that there needed to be a funding review to make it more sustainable and to better recognise the ITO role. FITEC asked for a simple transparent system. The Extractive Industry Training Organisation (EXITO) suggested a differentiated funding rate based on industry. This would take into account relative skill levels and capital costs of different industries. EXITO state that they are finding it hard to attract high-quality trainers with the necessary industry skills at the current funding rate.

195. TSO stated that the existing single, low rate had contributed to some undesirable practices and that a new higher rate would improve quality of services. The Primary Industries Training Organisation (PRITO) stated it would make funding more equitable compared to Student Achievement Component (SAC) funded qualifications. Three ITOs stated that higher funding rates would decrease tensions between ITOs and providers as the funding increase would be mutually beneficial. TSO support having two funding rates. Some ITOs state that there needed to be clear detail around what the new rates would actually be in order for them to comment fully.

196. Eight ITOs stressed the importance of funding at levels 1-3 and that the value of these qualifications should not be undermined. Many jobs peak at this level of skill and there is high industry demand for these qualifications. InfraTrain suggested funding be increased at all levels. CMITO, the Communications and Media ITO, suggested level 2 have the same funding as level 3.

Tertiary Providers

197. Providers are generally supportive of the proposal to introduce a higher subsidy rate for apprenticeship training.

198. Providers suggested advantages could include recognising the higher costs of apprenticeship training, incentivising more apprenticeships, increasing the focus of ITOs on outcomes and greater accountability.

199. Waiariki identified two possible risks of increasing apprenticeship funding. Trainees could be put under pressure to complete before they are ready and a higher rate may not be passed on to the person doing the training.

200. Other issues were definitions of apprenticeship and a lack of recognition by the Government of the in-kind costs of training. Tectra also make the point that pastoral care is more expensive than off-site theoretical training.

[We] urge the Government to better recognise the true cost of training to industry. A 30% contribution based on cash alone ignores the cost of time, materials and facilities – the classroom and the teachers – that we provide to learners. ATC Professional


201. The response to this proposal from independent MACs was more mixed. While generally supportive there were divergent views over whether this would lead to greater uptake of apprenticeships and some concern over the allocation of the extra funding.

35

202. Smart Careers and the Southern Group Training Trust said increasing funding of apprenticeships would not increase the uptake of apprentices. They suggested the money would be better invested in Gateway or Secondary Tertiary Alignment Resource (STAR) programmes. Southern Group also questioned the rationale behind additional funding for apprentices. They said ITOs are already paid more for an apprentice than for a trainee because an apprentice trains to level 4, compared to a trainee that studies up to level 2. Therefore, apprentices attract funding for a longer period.

203. Whangarei Education and Business Services were concerned that any additional funding might go directly to the ITOs without being used for training purposes.

In the fourth year (where there is no off job training to do) the apprentice subsidises the ITO by the full $1065 (including GST) per year. Whangarei Education and Business Services

204. Smart Careers and the Southern Group Training Trust raised other issues including the alignment of funding to the length of apprenticeships which vary between different industries, the national significance of the skills being studied and problems relating to the variability in quality of distance learning. They suggested funding for ITPs, who provide the theoretical training, should be increased.

Other submitters

205. Fifteen submitters commented directly on the proposal for increased funding for apprenticeships. Three submitters support increasing the funding.

206. Three submitters from unions asked for clarification around the definition of an apprenticeship, one suggested:

That the definition of an apprenticeship is flexible enough to take into account the shift away from traditional “time served” measures of apprenticeships to achieving the required skill level and competence that are needed by industry. New Zealand Engineering, Printing and Manufacturing Union

207. One submitter said they support the formal distinction between apprenticeship and traineeship as this offers clarity around the purpose of different programmes. Consequently, the submitter thought there would be better differentiation of support and outcomes. This would support better understanding of the system by stakeholders.

208. One submitter stated that increased funding should have measurable value for trainees and employers. Two submitters from unions noted that increased funding would hopefully drive more off-job training that meets learners’ needs. Another submitter expressed concern that the money will not benefit learners, but rather be lost in ITO overheads. One submitter proposed a cash incentive to employers to take on an apprentice. Another submitter stated funding measures should be applicable to all providers. One submitter stated apprenticeship uptake is restrained not through cost, but as a result of the ability to find the combination of a willing and able candidate, an accessible off-job trainer and a competent on-job assessor.

209. Six submitters stated that increased funding at higher levels should not be at the cost of level 1-3 provision. They commented that they do not want improved

36

apprenticeship provision at the cost of devaluing the importance of achievement at foundation levels. They suggested that this proposal would risk excluding certain groups, particularly those with historically low achievement. Rural Women New Zealand (RWNZ) state that they had concerns that the aged care industry will be disadvantaged because they do not have apprentices.

210. Submitters from unions raised a number of concerns. They noted that the implication of the proposed scheme would be fewer learners in industry training with higher Standard Training Measure (STM) funding and at a higher level of qualification. They asked how this helps other Government targets around achievement, especially Māori and Pacific achievement. They expressed concern about split rates for traineeships and apprenticeships. Unions asked whether the traineeship rate would also be increasing and noted that all rates should lift as improved pastoral care is needed at all levels. Two submitters from unions asked whether this model recognised how learners actually progress through qualifications; they noted that learners may not necessarily progress in a straight line upwards. One union submitter asked about what happens in sectors that do not use an apprenticeship model.

QUESTION 6 EXTENDING APPRENTICESHIP SUPPORT

What are the benefits and risks for employers and trainees in your industry of extending apprenticeship support to all apprentices, regardless of age?

Employers

211. The response to this proposal was unanimous: give equal support to apprentices regardless of age.

212. Mature trainees are described as willing, focussed and more likely to have basic skills and valuable life experience. Gravure Packaging said they have had “great success” with trainees that are over 21 years old. Some industries comprise a wide age range, and this may encourage employers to take on more apprentices. This proposal would recognise the large proportion of trainees who leave school and focus on getting a job prior to moving into a trade level qualification.

people who have failed in their early years develop better and become more settled when in their early to mid 20’s. Active Refrigeration Ltd

213. Some employers noted a need for improved funding of older trainees. Five employers said they have had a total of eight apprentices that were too old to be eligible for the Modern Apprenticeship scheme.

214. This proposal may help address issues raised by New Zealand’s aging population. It would enable all workers to pursue higher learning and this supports employers’ retention of staff. Genesis Energy believes this proposal would provide an opportunity for staff to retrain into new careers and would align the skill set of existing employees to the needs of the business.


215. There is strong support for extending apprenticeship support to all apprentices, regardless of age. Thirty-three submitters support the proposal and one submitter opposes it. Industry associations stated that the proposal would see all

37

apprentices treated equally and receiving similar support. It would also allow employers to recruit from a wider pool. They suggested that this proposal may improve completion rates.

Good idea. We have people of all ages entering our industries and needing training, and our industry desires attracting individuals that are looking for second or subsequent careers. Fitness New Zealand

It’s important to treat all apprentices equally. Print NZ

216. Some industry associations expressed concern that the proposal might have a negative impact on youth employment. There is particular concern about how to reach those not in education, employment or training (NEETs). Some associations suggested that younger apprentices need more support. They suggest a targeted approach that would support groups with historically low engagement and people with special needs. Another suggested raising the eligibility age for Modern Apprentices to 24. One industry association hopes that this would mean that the term ‘Modern Apprenticeships’ would become obsolete in favour of simply apprenticeships.


217. There is widespread support for this proposal: twenty submitters support the proposal. Eight ITOs stated that the proposal would provide equal opportunity and support for all apprentices. Two ITOs believe the proposal would reduce duplicated costs. The proposal is seen as being able to create a simplified system with increased flexibility. Competenz suggested that it would remove tension between MACs and ITOs. PrITO suggested the proposal would particularly benefit those with difficulty in literacy and numeracy. Two ITOs stated that the proposal would improve achievement and completion rates.

EXITO endorses the proposed amalgamation of all apprenticeships into the Modern Apprenticeship scheme on the basis that all trainees who need additional support should be entitled to receive it. EXITO

All apprentices who deserve additional support should be given it regardless of age. ESITO

218. The proposal is seen as being good for industry. EXITO said that employers like the current support given through MACs. Additionally, this proposal would benefit industries that cannot employ younger people because of risk or statutory requirements. PGDR ITO comment that it would provide additional support to level 4 and 5 trainees doing qualifications with major theory components.

219. Competenz are concerned that the proposal may risk discouraging young people from taking up apprenticeships. NZITO commented that young people still need these opportunities. FITEC also suggested that it may make NEETs harder to reach. However, TSO state that apprenticeships would likely continue to be focused on young people. ATTTO are concerned that this proposal might lead to added strain on resources.

Tertiary Providers

220. On the whole, providers support this proposal.

38

221. Providers felt extending support would be a good thing because it improves support for trainees, encourages employers to employ mature people without industry experience and facilitates new career pathways within industry as well as attracting people from other backgrounds.

For the trainee knowing the additional training and support are available will have a positive impact on an older but very capable generation to try something new whilst maintaining an income, contributing to industry and the economic health of the country. Tectra

If people decide to have a change of career or return to work after having a family or illness then an apprenticeship will allow them to do this as they can earn whilst they learn and not incur a huge student debt. Waiariki Institute of Technology

222. This proposal, however, does not come without risks. According to Waiariki, the risk to employers is that mature apprentices may have greater non-work responsibilities increasing the difficulty in attending training outside of work hours, while the risk to trainees is that there are fewer apprenticeships for the young as industry prefers to take on more mature trainees due to their lower risk.

223. The Bay of Plenty Polytechnic also makes the point that a one size fits all approach to funding disregards the “need aspect” of funding.


224. Independent MACs were also positive about this proposal. Regent Training Centre noted that this would allow more staff to participate in industry training and could also have a positive impact on completion rates. The various letters of support from employers and apprentices submitted by MACs also supported this proposal.

225. The only concern raised by MACs about this proposal was that it might lead to ITOs becoming the sole providers of modern apprenticeships.

Other submitters

226. Fifteen submitters commented on this proposal directly. All of them favour it. Submitters noted that this proposal would:

improve equity and offer equal opportunities to all

entrench the idea of life-long learning

provide a more flexible workforce

increase consistency of outcomes and improve completion rates

decrease duplication of work undertaken by ITOs and MACs

streamline administration and provide greater transparency.

227. Two submitters noted that much of their current workforce misses out on Modern Apprenticeship opportunities due to age. One submitter noted that the rising age of school leavers is reducing the pool of candidates for Modern Apprenticeships. One submitter suggested that older apprentices are more likely to complete their training.

39

228. One submitter expressed concern that people aged under 21 years may receive less support than currently. Submitters are concerned that this proposal might penalise industries where there is no apprenticeship model and also industries where trainees are seasonal and therefore are more transient in their study pattern. One submitter expressed concern that the economy will not be able to support jobs for an increased number of graduate apprentices. Another submitter commented that the selection of modern apprentices needs to be more carefully considered.

One of the main issues is selection of apprentices. You need to get the match right and if employers have issues with this they need assistance and advice….Personality traits and relevant work experience are important in selecting who should go where. Private Individual 3

QUESTION 7 OPTIONS FOR APPRENTICESHIP CO-ORDINATION FEE

Which of these two options for the apprenticeship co-ordination fee is more likely to result in better service to employers and apprentices and why?

1. The coordination fee is incorporated into the apprenticeship rate.

2. The coordination fee is not incorporated into the apprenticeship rate, and ITOs are given responsibility for managing apprenticeship coordination contracts.

Employers

229. An incorporated fee is supported by 76 employers, 65 of these are aligned with Competenz. An incorporated fee is seen as simpler, more cost efficient and easier to administer. Several employers noted their support of Competenz, and said this ITO has a track record of effective apprentice coordination. Two employers name the same coordinator from this ITO because he does a “great” and “fantastic” job.

230. Employers’ rationale for supporting an incorporated fund, particularly those aligned with Competenz, is that it will free up more money for them to take on more apprentices, but this was not stated as an outcome of the proposal.

If putting all of the modern apprenticeship money into one fund means that more money is available to support companies and apprentices, then I fully support this option. I am supportive of our ITO, Competenz, they are working well with our company and are providing us with the support that I and the apprentices need. Gillies Metaltech Ltd

I support the “one fund” approach so that more money will be available to help companies take on apprentices. Ensign Engineering Services Ltd

231. The same 76 respondents do not want a second person to coordinate with their apprentice. This is because it risks duplication and adds down time and confusion for the trainee.

There is no point having two people coming to visit our apprentices, it is unnecessary duplication. We find it easier to only have to deal with one person for our needs. Goodmans

40

232. A further 44 submitters, also all members of Competenz, did not explicitly say they want an incorporated fee. They are, however, supportive of their ITO. They also said they want only one point of contact for their apprentice, for the same reasons given above.

233. A further 49 respondents did not comment on the proposal. These employers are equally divided between Careerforce, Competenz and unknown ITOs. Four employers believe the status quo works well.

234. Large employers do not clearly support one option or the other. Four support a separate fee and six support an incorporated fee.

235. A separate fee is supported by 11 employers. One employer states this approach would increase communication. Other employers said this approach would lead to better coordination by the ITO and more accountability for individual apprentices. They suggested that separate funding may benefit smaller employers. They also noted that a separate fee is less likely to be swallowed in ITO overheads.

A separate payment will force co-ordinations to be measured and ensure they are carried out at regular intervals. As a consequence this process will provide an auditable trail where documentation with an apprentice signature demonstrates coordination has taken place. Contact Energy/Mighty River Power


236. Industry associations are split over whether they favour an incorporated apprenticeship co-ordination fee or a separate fee. Eighteen submissions support an incorporated fee, while four support a separate fee.

237. There is general agreement that ITOs should have the responsibility for managing apprenticeship coordination funding. However, there is some support for tying this funding to performance. Any performance measure could include recruiting, retention, completion and offer some incentives for attracting non- traditional learners or those with specific support needs. These incentives should go to those who hold the decision making power to implement change.

238. One association asked that the MAC role not be held by the ITO and suggested that independent MACs could lead to higher completion rates.

We would support ITOs taking primary responsibility for modern apprenticeship as ultimately their performance is measured on the achievements of all trainees. Motor Trade Association (MTA)

239. An incorporated fee is seen as easy to administer and cost effective by the associations that supported it. Some associations suggested that it would offer a simplified funding structure for apprenticeships that would reduce waste and duplication. This proposal is also seen as offering improved flexibility for ITOs to meet industry needs most appropriately. One association stated that this process must be transparent.

240. A separate fee is seen as offering greater transparency and specifically funding the co-ordination role by the Associations that support it. Comment made that there are currently some very good MACs and that industry do not want to lose them through funding being swallowed by general ITO budgets. Those that

41

oppose a separate fee see it as expensive, unnecessarily complex and confusing for employers.

241. One association asked for achievement based funding of MACs to incentivise completions. Another asked for staggered funding to reward recruitment, retention and completion independently. One association suggested that Government funding for MACs and off-job training be paid directly to the providers rather than being routed through ITOs. Another suggested making use of the ITO optional with an annual sign up and the ability to opt out if ITOs do not meet current industry needs.

242. Several associations commented that this was an organisational matter for ITOs and would have little impact on industry.

243. Dairy NZ called for a full system review and said that the proposed changes are too minor.


244. The majority of ITO submitters favour an incorporated fee. Fourteen submitters support this option. Four ITOs commented that it is simple, reduces duplicated costs and provides better value for money for Government. Three ITOs stated that it could decrease administration costs for ITOs, industry and TEC. Two ITOs see this option aligning accountability for qualification completion with funding. Two ITOs stated that it would allow for better systemised coordination and management of contracts and outcomes. Competenz said it would offer consistent support to learners.

Simple is good. Competenz

It is less complex to incorporate the MAC fee into the training rate. Plastics and Materials Processing Industry Training Organisation (PaMPITO)

One fee would be easier and straightforward to administer, and not something employers should notice InfraTrain

245. PGDR ITO support having a separate fee. They commented that this would allow funding at appropriate levels based on number of apprentices receiving additional support. It would also be simpler to administer contracts with MACs contracted by ITOs.

246. Five ITOs, such as TSO, want to retain the ability to contract out Modern Apprenticeship coordination.

The ITF favours the ability of ITOs to contract and harness the skills and innovative approach of these organisations and people [MACs] where they are in the best interests of the learner, employer and industry. ITF

247. Some ITOs are ambivalent. TSO state they have no firm views either way as ITOs have accountability for completions under either proposal. Instead, they focus on the importance of appropriate ITO/MAC contracting arrangements. NZ Marine commented the change would have little effect for either ITOS or MACs. PGDR ITO stated either system is workable.

248. Some ITOs offered suggestions for how apprenticeships could be funded. PrITO stated that the whole MAC service fee needs to be reviewed. InfraTrain suggest

42

prioritising funding for qualifications that are linked to key Government and industry objectives. ITF suggest that the coordination fee should be paid as a ‘per credit’ STM rate rather than the current flat per person rate. Hospitality Standards Institute (HSI) suggested that the fee should be paid on the basis of outcomes not number of people enrolled. Plastics and Materials Processing Industry Training Organisation (PaMPITO) stated that non-ITO MAC arrangements should be ended, and sought clarification as to the exact requirements of the coordination role.

Tertiary Providers

249. The feedback from providers was mixed on the two different funding options proposed. Training Systems and Solutions Ltd, for example, thought incorporating the fee was the best option as it would be simpler to manage, while Tectra wanted the fees to remain separate as this would allow the services of independent MACs to be retained, which they valued.

250. Providers were most concerned that effectively handling ITOs a monopoly of modern apprenticeship coordination might lead to suboptimal outcomes. CPIT identified two risks in particular. First, effective apprenticeship coordination under both options would be reliant on high performing ITOs. Second, the proposed changes would prevent providers from supporting apprentices in the workplace. Tectra noted in their submission that there needed to be a clear separation of funding for provision from internal ITO functions. This necessity would only increase if ITOs receive extra funding.


251. Most independent MACs were strongly against both proposals to change the funding rates. The MACs contend the proposed changes would give ITOs a monopoly of modern apprenticeship coordination and eliminate independent MACs.

We don’t agree with either option as it seems to exclude independent MACs from the funding. This contradicts proposal 4 which states ITOs should focus on their core roles that industry value most-standard setting and arranging training. Regent Training Centre Ltd

252. MACs question the proposed approaches to funding given the previously substandard performance of ITOs. MACs doubt whether ITOs have the capability to effectively manage apprentice coordination due to their poor track record of monitoring progress and completion rates.

ITOs do not appear to be in any fit state to manage exclusively the system with any degree of accuracy…We have, for example, identified MAs as being recorded as still active when we have repeatedly, over a period of 12 months, reported them as completed/terminated. Smart Careers and Southern Group Training Trust

It seems absolutely wrong that these ITOs are now being rewarded for their bad behaviour when we have been absolutely exemplary and done everything by the book. I can provide letters of support from many employers attesting to our services and the fact that they do not wish to return to an ITO monopoly. Job Finders

253. They also raise doubts whether there will be sufficient accountability to ensure that funds received by ITOs will be spent on training, rather than other purposes.

43

Funds given to ITOs for an ostensible purpose once added to the “consolidated fund” of running the ITO will disappear forever…Whangarei Education and Business Services

254. MACs claim they perform better than ITOs in modern apprenticeship coordination. This view is backed up by letters of support from 67 employers and 74 apprentices.

255. The letters of support claim proposals under question seven would produce inferior apprentice coordination through ITOs replacing MACs as apprenticeship coordinators for the following reasons:

ITOs provide services internally

ITOs have a poor performance track record

MACs are located closer to the trainees and have proven capability,

MACs are independent of ITOs and keep them accountable.

My Modern Apprentice Coordinator is trade qualified, understands what it is like being an apprentice, knows the apprenticeship training system very well, and is there to support me when I need it, not when it suits him. Apprentice

Given the choice we would prefer to retain the services of our Modern Apprentice Coordinator…[ITOs] have a poor track record in delivering service directly to industry, and have a record of charging for service they do not deliver. Amtec Engineering

256. Other comments include that funding should be allocated per trainee and that on site/employer training should be subsidised.

Other submitters

257. Eleven submitters commented directly on this proposal. Five submitters support incorporation of the fee and five submitters support separation of the fee. One submitter noted that the critical factor is the employer knowing who is responsible for managing the training process. They added that the payment structure should not impact service level.

258. Five submitters support incorporation as it would be easier to manage, result in less administration and be more transparent. They noted that this would require robust quality assurance especially in the case of extensive contracting out of this responsibility.

259. Two submitters stated that separation of the fee would increase accountability for the coordination role and completions.

260. Three submitters are concerned that independent MACs would be lost under the proposal and stated that they should be different from the ITO. They added that the funds should be ring-fenced for the purpose of apprenticeship coordination.

261. One submitter stated that ITOs have monopolised apprenticeships, industry training and standard setting and the proposal to incorporate the fee would further produce an anti-competitive environment as the ITO would have control of all funding.

44

Modern apprenticeship co-ordination is ‘unique and essential’ in providing a level of ‘trust and access to industry expertise’. Plant and Food Research

There are many benefits but I question the motives of an ITO wishing to be the only supplier of Modern Apprenticeship support. Private Individual 4

45

4. Industry training at higher levels and transferability across sectors

Proposals

Raising the current 10% restriction on training at levels 5 and 6.

Remove disincentives to transferring between industry training and provider courses by recognising continuation of a qualification across subsectors as a positive outcome.

Overall

262. Submitters are supportive of raising the current 10% restriction on training at levels five and six. In fact, many submitters state that this proposal does not go far enough as there should be no cap on training at these levels. This is due to the impacts of raising skill levels on higher-level qualifications.

263. Employers, ITOs and other contributors note that more training at the higher levels would increase skill sets, which in turn would assist productivity and meeting future challenges. They also noted that this encourages more training and better pathways.

264. The most common concern in raising limits on training at the higher levels is that this should not come at the expense of training at levels 2 and 3.

265. There is also consensus that recognising completions for transferring learners is important. It is recognised this has many advantages including increased flexibility and completions, as well as less waste of funding and learning.

266. The main issues revolving around transferability concern monitoring. Employers are concerned that this might increase their costs, while ITOs noted that it is difficult to monitor learning acquired in multiple settings.

QUESTION 8 INCREASING TRAINING AT LEVELS 5 AND 6

What are the benefits and risks for employers and trainees in your industry of allowing a greater volume of industry training at levels 5 and 6?

Employers

267. Twenty employers are in support of an increased volume of industry training at levels 5 and 6. A total of 138 submissions did not comment on this proposal, of these 116 are members of Competenz. Several employers commented that a greater volume of training at these higher levels would be beneficial as this training develops skills in demand such as management capability.

268. Employers welcome the development of career pathways in their industries and said higher learning supports staff retention and development. The benefits of allowing a greater volume of industry training at levels 5 and 6 would be higher

46

levels of skill among technical staff and improved management capability which would increase productivity. There would also be a range of personal benefits for trainees including increased confidence and self esteem as a result of better job performance. One employer noted that more theoretical training post-apprenticeship addresses the gap between trades people and tertiary-qualified employees.

It helps to increase management capability in the print and packaging industries and to ensure a higher level of technical skills amongst technical staff. Broderick Printing and Design Ltd

269. A total of 23 respondents emphasise the importance of funding at levels 1 to 4, saying it is imperative that funding at lower levels is not reduced. Specifically, levels 2 and 3 were mentioned by 10 employers from the care and food industries as being integral to their organisation.

Our caregivers are mostly trained with level 2 (43 credits) and level 3 national certificates…It is vital that the funding rates for entry level qualifications are maintained. The Ultimate Care Group Ltd

270. Employers note that any increase in training at levels 5 and 6 needs to take into account differences between industries and their differing funding requirements. One employer said that the electricity industry would benefit from a removal of the cap altogether. There is concern that higher-level funding may be allocated to industries that do not require it. Dairy NZ suggested allowing more autonomy for ITOs to allocate funding across different levels.

271. One employer wants the capability to train and assess at levels 5 and 6. This is because on-site training at this level benefits both industry and the trainee.

272. Two employers do not believe the funding will increase the numbers that pursue further training.


273. There is general support for allowing a greater volume of industry training at levels 5 and 6 from industry associations. Twenty-nine submitters agree with the proposal; two submitters disagree.

274. Those associations that support the proposal stated that it would be good for industry, as it would increase flexibility to meet higher level skill needs and would mean that certain areas of industry would find it easier to train staff. Associations also stated that there would be career progression benefits to the learner. Some associations also commented that this proposal would combat significant unmet demand for graduates at levels 5 and 6. Much of the need for skills at levels 5 and 6 is in the areas of management, leadership and human resource management.

We know that there significant unfilled demand for graduates at Levels 5 and 6 and that demand will continue to increase as the high technology sector builds through the Advanced Technology Institute’s activities. The Institute of Professional Engineers New Zealand (IPENZ)

275. Associations also noted that there would also be flow-on benefits for lower-level study. Trained managers would be more likely to train their staff and to value the benefits of skills and training in their staff. This would result in improved

47

completions. Greater volumes of higher-level training would support employers to keep pace with technological developments and encourage innovation. This will assist industry with future challenges, including the aging workforce.

DairyNZ has indicated to government and the ITO that it wishes to shift emphasis to level 5 of the NZQF. We see two main benefits in this shift in emphasis: firstly, our research indicates that improved management capability is strongly correlated with increased productivity in the dairy industry and as we have a low base of management capability there are significant gains to be had by incentivising improved management capability through higher uptake of production management and business management diplomas; secondly, we believe managers that are more highly educated themselves are more likely to value training of their staff and therefore are more likely to support their staff through training. We therefore would expect to lift participation and completion rates of lower level trainees once we have raised the level of competency of our managers. Dairy NZ

276. Some associations commented that the restrictions provide no benefit and that provision should be driven by industry needs rather than what they saw as an arbitrary Government cap. Many questioned the need for any cap.

We see little benefit in having restrictions at any level. The key criteria should be whether or not the system is delivering benefits to industry and trainees. It is difficult to see how placing restrictions can do this. NZ Shipping Federation

277. One association suggested that this proposal may encourage ITOs to compete with other established industry qualification schemes and could lead to duplicated qualifications resulting in confusion for employers. One association suggested that the ITO system may not be the best vehicle for delivering higher- level training.

278. There is also concern that the proposal may impact on funding and levels of provision at levels 1 to 4. Many associations stated that there is no current need for skills at levels 5 and 6 in their industries and that they need to continue to build a qualified workforce at levels 2 and 3. There is concern that the proposal may limit choice and decrease ITO responsiveness to changing industry needs and priorities. There is concern that this proposal may over-qualify the workforce in some industries. This may lead to highly qualified people leaving New Zealand for better opportunities overseas.


279. There is strong support for increasing the volume of trainees at levels 5 and 6 from ITO submitters. Eighteen submitters support this proposal. Four ITOs state that there is increasing demand from industry for higher-level skills and that this proposal would better equip ITOs to meet their demand for training at this level. Four ITOs stated that the proposal supports higher-level pathways. NZ Marine suggested that increased targets will encourage graduates to stay in training and to stay connected to their industries. HITO stated that it will increase uptake at this level. TSO said it will help meet Government skills targets. It also supports the greater freedom to design programmes and services at this level. InfraTrain suggested that the Christchurch rebuild may drive skill need at this level.

...supports pathways to higher achievement which in turn aids productivity within technical and management roles. ATTTO

48

280. ITOs are concerned by the cap on provision at this level. Five ITOs stated that there is no need for a cap, as need will drive provision. Two ITOs said that arbitrary limits are inconsistent with government policy. Five ITOs stated that lifting the level does not go far enough and that, instead, it should be flexible and driven by industry skill needs rather than Government targets. TSO suggested that a 20% should be the starting point rather than the end point. HITO suggested that if the cap is reached it should be reconsidered. Competenz stated that any cap should be implemented at sector rather than ITO level.

The need and rationale for a cap on training at Levels 5 and 6 is not clear….We recommend that there is no cap applied and that the arranging of training above Level 4 is flexible and driven by industry. PrITO

No funding cap be applied to level 5&6 programmes. Market forces will determine the volumes of training at higher levels. If industry requires skills at level 5 & 6 then programmes at these levels should also be eligible for funding. PaMPITO

281. Three ITOs also expressed concerns that provision at levels 5 and 6 should not at be at the expense of provision at levels 2 and 3.

Tertiary Providers

282. Providers are generally supportive of the proposal to raise the current restriction on training at levels 5 and 6.

283. Providers stated that the proposal will result in more workers with greater skill levels thereby increasing productivity. Providers also noted this will allow them to respond to industry requirements. This proposal would support continuous professional development and career pathways as well as improving the incentives for ITOs and senior managers to up-skill workers.

Capping training at 10% of total does not allow providers to be flexible and responsive to industry or sector requirements, and provides an artificial barrier to training. Blueprint for Learning

This provides for a more complete pathway and options for continuous professional development. Training Systems and Solutions Ltd

284. ITI suggest this proposal would also support the Government’s Better Public Services targets, but doubt whether lifting the cap would increase participation and completion in higher-level training.

285. The Bay of Plenty Polytechnic outlines the following risks of this proposal:

Risks – assumption that the ITOs are best positioned to support the ‘train the trainer’ model with on site managers & supervisors (from an educational capability/expertise standpoint). Much of this is done quite effectively within current delivery structures. If the 10% cap is raised, providers will still play a role in training (based on current/likely future qualification structure), so could see a sub-contracting arrangement which may not be best use of funding. Bay of Plenty Polytechnic

286. More broadly, five submitters expressed concern that levels 1 to 4 will be overlooked. More emphasis on higher-level qualifications might result in marginalisation of learners at levels 2 and 3. It was noted that lower-level qualifications are vital to business and trainee development.

49

Level 2 and 3 qualifications contribute significantly to the productivity of the businesses we are working with, and the reality is that for many, a qualification at this level is a huge achievement. ACT Safety Ltd


287. Independent MACs agreed with this proposal.

288. In a similar fashion to the providers, Regent Training Centre believe this would be beneficial for productivity by raising skill levels of workers, while Whangarei Business and Education Services noted this will help to address current skill shortages.

Other submitters

289. Thirteen submitters commented on this question directly.

290. One submitter stated that this would produce a more skilled workforce. Some submitters stated there is a real need for qualifications at levels 5 and 6 in their industries while other submitters indicated there is only low-level need for qualifications at higher levels. Three submitters from unions support a rise in the level allowed to 15-20% as this would allow flexibility and would be of clear value to workers.

291. The Tertiary Education Union believes that it will be necessary to recognise the need for strong partnering between ITOs and ITPs and other providers to delivery courses at this level. It said that it has strong reservations about the capacity of workplace training to deliver robust level 5 and 6 qualifications. However, one submitter is concerned that this proposal may result in the duplication of courses already delivered by other providers and that this may lead ITOs to disengage with other providers in the sector.

292. Four submitters commented that this proposal should not be implemented at the expense of levels 2 and 3 training. One submitter commented that industry needs people with a range of skills to perform the tasks that need to be done. They added that over-qualification leads to worker dissatisfaction.

As long as this does not detract from encouraging all support staff to engage in training at a level where they can achieve successfully (e.g. levels 2 and 3). Age Concern New Zealand

293. One submitter said that there should be no arbitrary cap on provision. Industry need should drive the provision of training at all levels.

QUESTION 9 TRANSFERRING BETWEEN TERTIARY SECTORS

What are the benefits and risks of recognising completions for learners who transfer between tertiary sectors?

Employers

294. Eighteen percent of employers commented on this proposal; 31 favourably and three express mixed views. Large employers responded more widely. Their response was similar to all employers with 15 out of 18 generally supportive.

50

295. Employers stated that the benefits for trainees would be having their prior training recognised, and that they would more likely to complete qualifications and complete higher levels of qualifications. One employer noted that trainees could switch to apprenticeships.

296. Transferability supports greater flow of talent between industries and sub sectors and encourages skill transfer. One employer noted that transferability would align with NZQA objectives, and another suggested transferability would be enhanced by outcomes of the Targeted Review of Qualifications (TRoQ).

A basic premise of the NZQA system was for learners to build there [sic] skills and knowledge over time, and that this learning could come from a number of appropriately recognized providers. Framework

297. One employer describes the status quo as legalising an effective monopoly.

The unit standard should not be held back until all the theory training is completed as it currently occurs with some technical institutes. The current actions by these technical institutes are not in the best interest of the apprentice to gain employment. Aspec Construction

298. Employers called for clear guidelines for transferability. They emphasised that they require accurate records of what the employee has learnt during their training as part of a qualification record. Two employers suggested unit standards should be logged with NZQA as they are attained and that NZQA should cross match standards across tertiary providers. One employer suggests transferability is best suited to generic courses.

299. One employer stated that there is an increased likelihood of losing trainees part-way through training.


300. Industry associations generally support recognising completions for learners who transfer between tertiary sectors. Twenty-six submitters support this proposal. Several associations indicated that this is not currently an issue in their sectors.

301. Industry associations stated that this proposal would be good for both industry and trainees. Several associations indicated that transferability already happens in their sectors. Some associations suggested that wider implementation would allow increased flexibility and mobility for trainees and that it would improve retention and completion. They suggested it would enable industry to maintain capability through low cycles and open up sectors to wider employment pools. They stated that the proposal would encourage life-long learning. Furthermore, associations stated that it would not penalise providers or ITOs for things that are outside their control. They suggested that funding needs to follow the learner when they transfer.

The flexibility put forward by this proposal is a good example of how the tertiary sector can be more responsive to the changing needs of industry. Horticulture New Zealand

When business conditions are tight, some earn-as-you-learn trainees are let go, but these conditions are often cyclical and therefore temporary. These trainees should not experience barriers to continuing training…When business conditions pick up and demand for labour and skills increases there should be little barrier for trainees in other parts of the tertiary sector to transfer to the earn-as-you-learn environment. Dairy NZ

51

302. Some industry associations stated that this proposal fits with and would be enhanced by TRoQ. Others commented that it would be difficult to assess progress without unit standards, which they see as endangered by the TRoQ process.

303. There is some concern that this would promote skills development in simulated environments. Many associations are strongly opposed to allowing qualifications with no practical work-based component. Some associations do not support apprentices transferring to a provider to complete their apprenticeship. There is also concern about how industry timeframes and provider timeframes may mesh and whether this potentially would make transfer difficult.

…any such system that enables transfer must be done with Industry approval and not upset the current system that enables employers to be a very strong part of the development of early training on the job. ECANZ

…it needs to be recognised that on-the-job learning cannot be simulated at a provider and we therefore do not support the transfer of apprentices to providers to complete their apprenticeship. Bakery Industry Association of New Zealand (BIANZ)

304. Some associations stated that design and implementation of the proposal is vital. They said that collaboration across the tertiary sector would be necessary and commented that there is a need for well-integrated data systems otherwise any system will be difficult to manage.


305. There is strong support from ITOs for recognising completions of learners who transfer between the tertiary sectors. Eighteen submitters support this proposal. Two ITOs noted that it was not a major issue in their sectors.

306. Three ITOs stated that the proposal would increase flexibility for, and remove disincentives to, trainees moving across qualifications and providers. The proposal would put learners’ needs at the forefront. Four ITOs stated that this proposal would ensure that providers and ITOs are not penalised for things that they cannot control. TSO suggested the proposal could improve outcomes, improve service quality and allow flexible and innovative solutions to meet skills needs, for example, in the Christchurch rebuild. Two ITOs stated it would increase collaboration between ITOs and providers. ATTTO suggested it would reduce the waste of funding and learning that currently occurs when a student transfers. Careerforce stated that this ensures all tertiary education providers who have contributed to a learner are recognised.

Removing disincentives to move would retain learners in the VET sector and result in a training environment that is more responsive to changing needs of employers, workers and students. ITF

Support the recognition of transfers because often events in trainees’ lives that interrupt their training are beyond a provider or ITOs control. PaMPITO

307. ITOs are concerned about how the proposal will work in practice, that is, how learning would be recorded so that learners could transfer easily. Two ITOs stated that it is currently relatively easy to go from a tertiary provider to on-job provision, but the reverse is not true due to ITO flexibility. Increased provider flexibility and collaboration across the tertiary provision sector is likely to be needed. Three ITOs stated that transferability might be more difficult in the

52

current NZQA and TRoQ environment. They also suggested that moving sub-sectors was likely to be difficult under TRoQ. MITO suggested that it may be difficult to monitor vocational learning acquired in multiple settings. Four ITOs commented that any system must be unit/assessment standards-based to ensure transferability. HSI suggested the use of an ePortfolio across providers.

The aim is admirable and we support it – if it can be made to work. Competenz

The ability to transfer between providers and workplaces is important. There is a disconnect between TEC/NZQA and MOE around the currency that will be used for this to work. If unit standards are not used in qualifications what then is actually recorded on the trainee’s Record of Achievement? HSI

308. Four ITOs stated that if the proposal were to be successful it would require the development of well-integrated systems for tracking learners and their learning.

Tertiary Providers

309. Overall, providers who commented on this issue supported the proposal.

310. Providers stated the benefits of transferability are that it would:

respond to trainees’ changing life circumstances or employment situations

increase completion rates

respond to industries’ changing labour demands, for example, as a result of an economic downturn

improve career pathways within industry

allow multi-qualified staff to contribute to industry

recognise that learning and assessment can take place in multiple contexts

reduce tension between on- and off-job training.

Employers can take on apprentices part way through training when they have learnt the basic skills and are of some use to them. Trainees can go into employment sooner if they can transfer their learning from full time training into an apprenticeship. Wairariki Institute of Technology

When the economic situation dips there is a significant dropping of apprentices as industry reduces staff. This leads to a lack of qualified trade’s[sic]people when the economy recovers. By enabling a trainee to complete through a tertiary provider a pool of qualified people is ready. Christchurch Polytechnic Institute of Technology (CPIT)

311. Providers noted more accurate tracking of trainees’ progress will be required if the proposal is to be successful. The Bay of Plenty Polytechnic said the variety of ITOs’ trainee tracking methods would inhibit implementation of this proposal. It also asked how funding would be affected if a trainee left part-way through their qualification.

53


312. Independent MACs were also supportive of this proposal with Southern Group Training Trust and Regent Training Centre noting that advantages included:

supporting the primary purpose of pre-trade courses

ensuring ITPs and EPIs are not negatively affected by positive outcomes, such as a trainee on a pre-trade course moving into an apprenticeship.

313. Whangarei Business and Education Services stated that the benefits was numerous and this proposal would be important in increasing responsiveness to changing labour market demands.

314. There were, however, some concerns with this proposal.

315. Regent Training Centre contended that the risk of the proposal was that ITOs would be less accountable. Apprentice retention rates could fall if the ITO sees returning to polytechnic as a positive outcome when employment is the aim. According to Regent, this would be a backward step for industry.

316. Whangarei Business and Education Services were concerned that cross crediting arrangements could be “time consuming, costly and ineffective”.

In some cases even within the same industry, transferring between disciplines results in trainees having to go back to “year one” because their units already achieved on NZQA for one qualification are not compatible with the units required for the new intended certificate. Whangarei Education and Business Services

Other submitters

317. Fourteen submitters addressed this proposal directly. Some stated that this is already happening in their industries.

318. Most submitters reacted favourably. Submitters stated that the change was long overdue and that the skills and knowledge gained are what is important, not where they were gained. Others said that the proposal provides transparency for employers and reassurance for learners that their learning will be valued and recognised. It also reflects the current job market and peoples’ geographic transiency. Four submitters stated that this did not penalise ITOs or providers for things outside their control.

319. Two submitters stated that there are practical issues around funding incentives for providers to enable this proposal to succeed. One submitter suggested that some units may need to become more relevant.

54

5. Quality assurance

Proposal

ITOs focus on the standard setting function for their respective industries.

Lead qualification developers will manage the process for assuring the consistency of graduate outcomes.

Review of unit standard quality assurance settings will be undertaken with the view that unit standards will be flexible and able to be contextualised to different settings.

Overall

320. There is widespread support for ITOs focusing on the standard setting function for their respective industries. In their development of standards, ITOs are generally regarded as being highly capable at coordinating industries and employers. However, some providers and MACs noted one of the problems is that a conflict of interest arises from ITOs not only setting standards, but also arranging training.

321. Some submitters noted that there are opportunities to improve the current arrangements by:

linking standard setting to compliance involving the standard setter in quality assurance ensuring funding is available improving the performance of ITOs placing more emphasis on developing and updating unit standards.

322. There is some concern that the use of common standards may not meet the needs of particular industries and that standards may not able to be contextualised or made relevant. One submitter did not want the use of ITO training materials to be made compulsory. Another submitter noted that ITOs use the standard setting role to control rather than encourage delivery.

323. While there is support for more and better moderation, there are various suggestions for who should undertake the role, what should happen and how it should be funded. There is support for qualification developers, ITOs, tertiary providers, an independent inspectorate, or NZQA undertaking the role.

324. There need to be objective benchmarks rather than subjective assessment. There are a range of views about what should be moderated, including that:

all unit standards should be looked at,

unit standards in critical areas should be looked at,

sampling of unit standards, or

55

unit standards should be looked at when risk is identified.

325. Moderation and consistency need to be funded, possibly through the credit rebate, a levy, or reporting fees to NZQA. There are concerns, employers have to bear increased costs.

326. Comment was made about the TROQ. Some submitters support the TROQ process because it will rationalise unit standards, reduce duplication of qualifications and focus on learner outcomes.

327. There are concerns about how quality and consistency within and across unit standards will be handled and funded. Standard setting should be connected to the national quality assurance processes with a focus on quality and consistency of qualifications. Unit standards should focus on learning outcomes. Credit values may need to be revised to ensure they are appropriate. Further clarification about standard setting, including the relationship between unit standards and TROQ, was raised by some stakeholders.

328. Some submitters support unit standards as a common currency while others do not. There was a concern that there could be a proliferation of programmes and unit standards. One submitter considers that all programmes should use unit standards. There were also comments about the need for workplace-based training, as well as the place of simulated situations. One submitter considers that the length of time (one year) to change qualification content is too long.

329. Further work could be done to strengthen NZQA’s quality assurance processes relating to employers and trainees. There is a question about how NZQA could approve programmes without industry-endorsed expertise.

QUESTION 2 STANDARD SETTING

In your view, what are the benefits and risks for employers and trainees in your industry of retaining ITOs’ standard setting function and allowing tertiary providers and other ITOs to use ITO-developed standards more freely?

Employers

330. The bulk of submissions, 145 or almost 80%, did not comment specifically on this proposal. Of those that did, 29 employers are broadly supportive of the proposal. Those that support the status quo describe this as a useful mechanism necessitated by the fragmented training industry and the number of employers. ITOs are well placed to coordinate diverse employers, set standards and qualifications based on industry needs. Employers suggest that ITOs do this well. Twelve of the eighteen large employers supported this proposal. However, they stated that industry involvement is required to ensure relevance of standards.

The ITO is proactive in setting the relevant standards within the industry and continue to develop and review these. APN Print NZ

The requirement for sector employers to have a significant say in the setting of standards with the ITO. PSC Enliven.

331. Large employers noted that sharing ITO developed standards would improve cost efficiency, drive standardisation and help create generic standards that

56

apply across industries. In addition, this approach may support employers’ use of training materials from multiple ITOs.

Highly collaborative practices leading to common tools would also suitably lower costs to the ITO (and by extension industry) through mitigating the risk of high costs caused by moderation across a large range of resources. Fonterra

Our industry has several skills common to others eg. petrochemical. If the standards exist it would be more efficient to adopt them than develop and moderate our own. Contact Energy/Mighty River Power

332. Downer New Zealand stated there is a risk that ITO standard setting and sharing could cause duplication. They also noted industry may lack a central point of contact. Another employer stated that they do not want ITOs to impose the use of their training documents and trainers.

333. The ten employers that do not support this proposal describe ineffective services from their ITO negatively impacting trainees and employers. They restate the concern that training providers pursue commercial interests at the expense of trainee and industry requirements. KiwiRail Interislander offers their experience as an example. It stated that Competenz is the ITO for the maritime industry and the statutory training provided by it is, in some instances, twice as long and costs twice as much as qualifications that meet international requirements. KiwiRail Interislander is therefore critical of a funding structure that prioritises the number of courses on offer and said a proliferation of courses have resulted. Many of these courses are irrelevant for trainees, are not linked to employment opportunity and not aligned with industry needs.

The lack of any meaningful ITO has led to the training organizations setting the course duration and content…The training provider is funded on course content and duration and even basic training for ab-initio seafarer is overly complex and time consuming against worldwide standards. KiwiRail Interislander


334. Industry associations generally support the proposal for ITOs to retain their standard setting function. Twenty-nine submitters agree with this proposal. Associations strongly support industry having the right to clearly specify standards within qualifications. They stated that this proposal puts industry, through ITOs, at the heart of standard setting and quality assurance. ITOs should design qualifications with and for industry and should be required to consult widely with industry in fulfilling this role. This gives industry confidence in the qualifications. Some associations noted that TRoQ should ensure high quality consultation occurs. Several associations said that ITOs currently perform this role well and that this is the role industry values most.

Proposal 2 would indicate Government’s wish for industry to define its training needs and we fully support this approach. Print NZ

The NZMPTA supports initiatives to focus ITOs on the roles industry values most, the setting of standards in concert with industry and arranging the training. NZMPTA

ITOs must work closely with industry to ensure the outcome of these standards meets the needs of a number of parties – the employer, apprentice, regulator etc, and that they can be realistically delivered by the training provider. Master Plumbers, Gasfitters & Drainlayers NZ

57

335. Some associations stated that industry should determine skills need and that these should then be conveyed to ITOs who set standards and ensure that these are coordinated with NZQA and NZQF. One association suggested that ITOs and industry should share the standard-setting role. Some associations commented that industries may wish to undertake this role themselves and this should be an option. In particular, there is concern from industries with well established industry qualifications that ITOs were duplicating qualifications leading to confusion for employers and to decreased credibility for all qualifications.

Skills Active has been a follower, not a leader, in terms of standards setting; it has consistently duplicated the standards set by others and represented those on the NQF (we acknowledge this may not be the case in other industries served by Skills Active). Its standard setting work has blurred the picture for employers and trainees leaving significant parts of the sector confused; this has been unhelpful, not constructive. The standards set by Skills Active have at times been woefully low; in particular we have challenged their minimal requirements for people to become assessors and lack of ‘policing’ to ensure even the low standards are being adhered to. Past experience has been that their standards are used far too freely and this has resulted in a lack of credibility. New Zealand Outdoor Instructors Association

On the matter of ITOs using each other’s standards, there is little doubt that the present ‘exclusive’ nature of standard ‘ownership’ has contributed to widespread duplication. This is a matter that should be addressed in the context of the Targeted Review of Qualifications. New Zealand Shipping Federation

336. Several associations support ITO-developed standards being used more freely. They noted that TRoQ addresses shared unit standards and should facilitate this process. They stated that this would improve consistency of delivery and outcomes. Associations also commented that increased contextualisation by providers would provide better potential for programmes to adapt to the increasingly fast pace of industry’s changing needs. This would make programmes more attractive to employees and increase uptake.

…supports the move toward a smaller number of standards delivered in context over the proliferation of situation-specific standards. Where possible, CCANZ supports the use and re-use of standards to ensure consistency. CCANZ

ITO developed standards, (if the development is government funded), should be available for use by all, including other ITO’s, providers and employers. There should be no ownership, just a responsibility to maintain by the developing industry and ITO. ECANZ

337. Some associations identified a possible risk if industry standards are used too widely that they may lose their industry-specific meaning and may cease being used by employers. Additionally, there is a risk that consistency and quality of achievement may be compromised with increased contextualisation. Guarding against this will require robust moderation and quality assurance.

Giving in to desires to genericise specific sector skills has a danger of creating meaningless qualifications that industry no longer values or relates to. Association of Wall and Ceiling Industries (AWCI)

338. One association stated that although ITOs understand the match between industry needs and NZQA rules, sometimes ITOs are forced to make changes to qualifications to meet NZQA requirements. Often, industry does not understand the rationale for these changes. It was also noted that there is rigidity and inflexibility in the current system where ITOs coverage intersects. One

58

association said that standards are not rigorously enforced and that ITOs should take stronger measures.


339. There is strong support for retaining the standard setting role from ITO submitters. Nineteen submitters support this proposal. Six submitters stated that ITOs are best placed to hold this role because of their strong industry links. Nine ITOs commented that industries see this as a critical ITO function. This is because it ensures that qualifications reflect changing skills needs of sectors, contextualise learning, and offer cost effectiveness, ultimately resulting in employees with broad-based skills.

340. There was a range of comment on the standard setting role. Two ITOs stated that ITOs must be the lead developer for all vocational qualifications. Four ITOs commented that ITOs as the standard setter must be involved in all quality assurance. FITEC suggest that standard setting should be linked with compliance. Four ITOs stated that the standard setting role needs further definition and enhancement. Two ITOs said TRoQ should help address this. ATTTO suggested that ITOs should act as a bridge between sectors and VET providers. Competenz commented that ITOs should be funded separately for this role.

341. Two ITOs stated that while it is acceptable for providers to contextualise standards, learners must earn competence according to prevailing industry expectations. TSO support the separation between the standards setting role and offering optional learning and assessment materials. However, BCITO stated that it is its experience that providers want to use ITO generated material, rather than developing their own. BCITO also suggested that the ability to contextualise standards may not aid the adoption of common standards, rather it may retard it. NZITO stated that there are differences between skills learned on-job and those learned in a classroom setting, especially in high capital expenditure based industries. There therefore needs to be a separation between unit standards developed for industry specific skills versus institutional learning environments.

342. PGDR ITO commented that in principle ITO developed standards should be freely available. However, this is complicated by licensing requirements in industries that are heavily regulated. In this case, it may be necessary for the ITO to develop common learning and assessment materials to help achieve national consistency.

343. Four ITOs expressed concern about NZQA and the TRoQ process and how this could impact on the standard setting function. In particular, there is concern that the needs of industry may be lost in the process. There is also a concern that TRoQ favours providers over ITOs. Two ITOs suggested that NZQA need to develop flexibility in their processes around unit standard development to enable ITOs to work more effectively, efficiently and speedily to meet industry needs. TSO also suggested that the interface around NZQA/ITOs/MoE needs to be recognised and enhanced, especially around qualifications expiring.

344. ATTTO suggested there is a risk that ITOs may view themselves as ‘the voice’ of the sector.

59

Tertiary Providers

345. There was mixed feedback on this question. Some providers supported ITOs retaining their standard setting function. Blueprint for learning said ITOs should focus on standard setting. They argue support from ITOs to ensure standards are met allows providers to provide training flexibility and efficiency. Tectra maintained ITOs should act as coordinators of standard setting with cooperation from providers. The TRoQ process was described by Tectra as an excellent example of how ITOs can coordinate without owning the process. The qualifications developed through the TRoQ process were described as appropriate to industry and trainers.

346. Other providers are opposed to ITOs retaining the standard setting function. Four providers stated that ITOs retaining the standard setting function creates a conflict of interest for ITOs and can lead to misuse of power. It can result in ITOs and providers being in competition for the same funding. There was concern ITOs use their standard setting role to control, rather than encourage training delivery. Unitec and Manukau Institute of Technology claim ITOs set standards to benefit their training methods and generate revenue. They suggested the NZQA is better suited to standard setting and ITOs should become just training providers. Despite this tension, the CEOs of the Metro ITPs, the NZITP, and the ITF submitted collaboratively suggesting a VET working party.

The ITO’s should not be both a Training Provider and a Standard setting Organisation. If it does then a continuation of the past misuse of its privileged position as a standard setter will continue, whereby it sets the standards which benefits their training methods and makes it difficult for competitor providers such as tertiary institutions. Manukau Institute of Technology

347. Providers were largely supportive of the proposal to use ITO developed standards more freely. It was noted by one provider that standards are a public good. Some providers suggested the proposal would offer employers greater choice, as providers can better tailor courses to meet skills needs in a variety of settings. However, it was emphasised by some that adoption of ITO materials should be optional and not a mandatory requirement.


348. Independent MACs feedback on this proposal was similar to other providers in that the value of ITOs in standard-setting was acknowledged by some, but there were also concerns about the performance of ITOs in this context. Southern Group Training, for example, stated they valued the role of ITOs as standard setters in consultation with industry. However, they were concerned there were flaws in the consultation process with industry to ensure qualifications were relevant and questioned the quality of materials ITOs developed for training purposes.

349. MACs strongly supported providers being able to use ITO developed standards more freely. Whangarei Business and Education Services noted there were several possible benefits of this including:

potential standardisation and sharing of best practice

the possibility of lower prices through increased competition between ITOs and training providers

60

greater choices for employers.

Other submitters

350. Fifteen submitters addressed this proposal directly. Fourteen submitters support the proposal. One submitter stated that ITOs have mostly done this well. Two submitters stated that ITOs should retain this role because they are a single recognised body that is in and of the respective sectors and can therefore adequately reflect that sector’s skills needs.

This function lies at the heart of ITO’s role in our VET system (and that of comparable international bodies) Ako Aotearoa: The National Centre for Tertiary Teaching Excellence

351. Five submitters stated that they support more flexible use of ITO developed standards as learning occurs best when contextualised to a learners needs. However, they noted quality assurance is an important consideration. One submitter strongly supports TRoQ. Another submitter stated that delivery of training must be moderated and that providers should not be able to deliver training if they did not agree to ITO moderation. One submitter stated that standards would only be used more freely in the short term. Long term, in a competitive environment, providers would seek a point of difference and develop their own materials and certification.

352. One submitter suggested that some providers do not currently believe in the academic rigour and industry relevance of ITO developed qualifications. This has led to them developing their own qualifications. A closer model of collaborative working should address this.

QUESTION 10 EXTERNAL MODERATION AND MANAGING CONSISTENCY OF GRADUATE OUTCOMES

How should external moderation and managing consistency of graduate outcomes be conducted and funded to ensure learners are consistently competent while minimising compliance costs and enhancing collaboration across tertiary sectors?

Employers

353. Less than 20% of employers’ submissions responded to this proposal. Overall no single view dominates about how to conduct moderation. However, employers agree that there should be no additional fees imposed for auditing levies.

354. Employers acknowledge the importance of moderation and consistent graduate outcomes. They noted that poor outcomes can result from quality failures; examples given include ‘leaky homes’ and the CTV building collapse. Employers stated qualification developers must be monitored closely by industry and it was important to have competent moderators.

355. Five employers said industry should be involved in moderation through ITOs and one employer believes ITOs should be funded accordingly. Another employer

61

suggested separate funding for external moderation of unit standard assessment and for management of consistent graduate outcomes.

356. Other suggestions for moderation included:

using industry’s technical advisors as moderators

the provider of the training providing assessment

using an independent Government entity similar to ERO.

357. Suggestions for managing consistency of graduate outcomes include:

break down qualifications to elementary level unit standards

focus funding on high risk, industry-critical standard assessment

redistribute credit rebates from other standards to support the management of consistent graduate outcomes

greater input from NZQA.

NZQA must actively assess the learning standards which providers state their programmes achieve. Gravure Packaging Ltd

358. Contact Energy/Mighty River Power asked for increased collaboration and communication between industry and the NZQA, saying

Industry must identify what the content should be, assist with the delivery of the training and be able to moderate the outcomes, to give it credibility. NZQA needs to have assurance from Industry that skill identification is current and correct and Industry needs assurance from NZQA that assessment is at the standard that industry requires. Currently we see little dialogue between parties involved.

359. Some employers also noted courses should not be assessed by individual skills, but on the basis of the whole course. In addition, there was some concern that moderators should be independent of qualification developers to ensure quality outcomes and that consistency was limited to only the ‘critical’ elements of trades.


360. Industry associations presented a range of views around how external moderation and managing consistency of graduate outcomes should be conducted and funded. Several associations asked for more information on this proposal. Industry associations generally agree that the whole training system is dependent on high quality, consistent moderation and the moderation system must therefore be simple, robust and reliable. Employers must have confidence that all graduates from the same qualification are equal and there must be limited local variation in outcomes. Some associations stated that moderation should be funded.

Funding should be directly available for moderation activities to ensure compliance and maintain skill standards and educational outcomes. Pine Manufacturers Association

361. Some associations expressed concern at the proposal to only moderate “critical” skill standards.

62

We believe that if the word “critical” is narrowly defined, then this will be detrimental to the productivity and skills of workers in our industries. Fitness New Zealand

362. Several associations suggested that ITOs are best placed to have a moderation role. This is because it best sits with the qualification developer. They stated that the current system works well.

A system with strong moderation to ensure consistency of graduate outcomes is best owned by the ITO who leads our industry qualifications. NZ Heavy Engineering Research Association

363. Some associations want clearer accountability around how ITOs manage moderation to ensure it meets industry needs. One association suggested more effort should be put into moderation and this should be incentivised with increased funding. Associations stated that moderation should not be diluted for ITO or provider convenience. One association suggested a stakeholder survey to measure ITOs’ and training providers’ performance in managing moderation processes, as part of the feedback loop with MBIE and TEC. Another association called for moderation to be evaluated across the whole industry training system.

364. There is also some support for moderation being undertaken through collaboration between ITOs and industry organisations/associations. One association suggested the sector body alone should undertake moderation. Several associations stated that it is essential that training in their sectors is moderated by a skilled person from the sector and independently audited. Moderators should be nominated by an industry group or advisory group independent of ITOs and providers. This way there is no funding incentive for the moderator in their decision making and they are not captured by either ITP or ITO priorities. The cost of this should be split between Government and industry.

Collaborate with the industry organisations/associations as industry is ultimately the end user of the training and the good and not so good will soon be identified. Institute of Quarrying New Zealand

It is essential our members are able to have input on the design of the assessment and moderation processes NZ Heavy Engineering Research Association

365. Some associations stated that ITOs must manage the process for ensuring assessment outcomes are consistent and meet the standards required by industry. They stated that ensuring consistency of training is very important in minimising variance in training outcomes. Some associations commented that managing consistency of graduate outcomes should be funded.

366. There is no general agreement on how moderation and managing consistency of graduate outcomes should be funded. There is support from associations for moderation and managing consistency of graduate outcomes to be funded through retention of the current credit rebate. One association suggested a flat levy that would be paid to qualification setters to fund this. The qualification setters would then be responsible for, and accountable to, industry and Government for the spending of it. This would ensure transparency. However, some associations stated that they did not want this function to be funded through a levy. Other associations stated that ITOs funding for moderation and consistency activities should be separate from funding for the arranging training function. Associations stated that compliance costs should be minimised so that employers do not face increased costs. This is particularly important at levels 2 and 3.

63


367. There is a range of views from ITOs on how external moderation and managing consistency of graduate outcomes should be conducted and funded. Five ITOs are interested in further information on this proposal, particularly some cost modelling around the various options. It is generally agreed that consistency in qualification outcomes and in assessment of individual standards is important and that at least some external moderation needs to be retained to ensure industry confidence in the system.

368. Six ITOs stated that if ITOs are responsible for standard setting they should also have responsibilities for quality assurance regardless of who developed particular qualifications. However, they are concerned that it was unclear how this would happen. They also suggested that if programmes are not developed with industry this could lead to problems such as qualifications not being relevant to workplace competence. Therefore, it is vital that industry is involved in programme approval and quality assurance via ITOs. One ITO and the ITF suggested that ITOs be funded to manage quality assurance through a credit rebate based on usage.

the ITF strongly believes that ITOs need to be responsible for and funded for moderation and managing consistency of qualifications, we believe there is a lack of guidelines around how qualification developers will monitor the outcome of their qualification. ITF

PaMPITO believes that ITOs as standard setters have the responsibility for managing consistency of graduate outcomes. Further clarification is sought on the mechanism proposed. PaMPITO

369. Seven ITOs view moderation and consistency of graduates as distinct processes that should be funded as such. The two functions may be funded through different mechanisms.

Moderation and quality assurance activities should be funded as separate activities, with the retention of the credit rebate for external moderation of unit standard asessment and some funding redistributed to manage consistency of graduate outcomes. MITO

370. Four ITOs stated that ITOs need to be confident that all graduates coming out of the same qualification are equal. Two ITOs suggested that graduate outcomes could be assessed by comparing final assessments across providers instead of at an individual level. SITA suggested that graduate consistency could be managed by sampling a range of programme owners and organisations with consent to assess. SITA expressed concern that programmes developed outside an industry developed unit standard model may lack validity and rigour when managing consistency of outcomes. Competenz stated that an external consistency panel, funded by a levy, should be established. They stated that this would ensure consistent application of standards and allow good practice to be shared. Three ITOs suggested that funding for consistency should come from a separate levy.

ITOs need to provide employers with confidence that the same qualifications, although gained through different programmes and pathways, have comparable skills and knowledge and that these align well to job roles in industry. PrITO

371. FITEC stated that ITOs should do external moderation across all qualifications and that moderation should be funded. ESITO said that unit and assessment standards are both good measures and that industry should decide which

64

measure is used when. Two ITOs support external moderation against clear, accessible measures, potentially as part of the NQF. ESITO suggested that providers with moderation systems should only be moderated by the ITO where failures become apparent. EXITO suggested that ITOs should also be required to develop best practice with NZQA and other standard setters.

372. Four ITOs stated that unit standards should be individually moderated and funding retained for this. They stated that any other alternative is impractical. This is because it would be logistically difficult to agree who decides if a unit is critical. There is also concern that if a unit was not deemed critical it would not be moderated and this in turn would lead to a decline in quality and consistency and the undermining of the concept of generic standards.

We hold some concerns that quality control will be limited to what the proposal states as being ‘skills critical to an occupation as identified by industry’. Whilst we consider all outcomes critical, we would need to understand how critical skills will be identified and whether the exclusion of non-critical skills in moderation would undermine quality control. NZITO

373. Two ITOs support external moderation only of standards relating to skills critical to an occupation as defined by industry. This would manage consistency and align with the value placed by industry on standards setting. They stated that it is the simplest of the options and its focus on specific, critical standards would give real and transparent consistency. They stated it was less clear how the other options would achieve consistency.

374. EXITO stated that if unit standards were not compulsory it will present a considerable moderation challenge. They also suggested that there could well be difficulties if ITOs and providers tried to agree on qualifications that adequately suit both learning contexts. MITO stated that wider use of ITO unit standards would ensure increased consistency of outcomes. However, it would also increase moderation costs as moderation would take place across a broader range of assessment materials. Competenz stated that unit standards should be generic where possible and these should be moderated by NZQA. Other units would be industry owned, developed and moderated.

375. Some ITOs raised concerns around quality generally:

Four ITOs asked for a review of the way qualification developers interact with NZQA. They also stated that NZQA quality assurance needs to be reviewed

ATTTO asked whether delivery of training should be moderated in addition to assessments

CMITO does not agree with the use of the term “graduate outcome” as its meaning seems unclear

Competenz expressed concern that moderation costs could be increased if moderation had to occur across a broader range of trainers.

376. Two ITOs suggested retention of the current credit rebate. Additionally, PGDR ITO stated that it is important that funding matches the need for external moderation and that there should not be any cross subsidisation. Two ITOs stated that the current moderation process is costly and a review of that is welcomed.

65

Tertiary Providers

377. Submissions from tertiary education providers address how external moderation and managing the consistency of graduate outcomes should be conducted and funded.

378. NZAPEP maintained the lead developers of qualification should manage the process for assuring consistency of graduate outcomes. Blueprint for Learning, noted that in order for assessments to be credible qualification developers should be independent from ITOs.

379. The independence of external moderation was an area of concern for some submitters. The Bay of Plenty Polytechnic questioned who was providing quality control on the external moderation that ITOs provide. Unitech and the Manukau Institute of Technology stated that ITOs should not internally moderate their own quality and then externally moderate other providers. They argued that ITOs should be externally moderated themselves.

If an ITO is assessing, as well as moderating providers, a) how is that fair, and b) who would moderate ITO assessment practices? Bay of Plenty Polytechnic

380. The submission by the Metro ITPs, NZITP and the ITF emphasised that it was vital for coherent and common quality assurance standards and processes to apply across the system. The problem in this respect, they pointed out, was how to fund moderation as the cost of this could be fairly high in order to achieve national consistency of moderation.

381. Some providers proposed solutions to this problem. Training Systems and Solutions advocated for an independent inspectorate who would visit providers to observe delivery and conduct assessment. These independent inspectors would be managed by industry through funding from a per credit fee. CPIT claimed moderation should be delegated to tertiary providers as there were already established processes in the tertiary sector to ensure high-quality moderation. The ITP sector CEOs contended that NZQA play a role in moderation to ensure greater consistency because of the different stakeholders involved and resulting variability between sectors.


382. In a similar fashion to providers, independent MACs were also concerned with the independence of external moderation.

383. Smart Careers and Southern Group Training Trust were concerned that ITOs moderating their own assessments creates a conflict of interest and inconsistent moderation outcomes. Southern Group Training Trust in a separate submission argued that moderation by ITOs should be optional as employers may prefer industry-based assessors. The use of trade qualified workplace assessors moderated by the ITO worked well in ensuring consistency. Southern Group said this approach worked better than using an ITO assessor because ITO assessors lack trade qualifications and experience.

384. MACs were also critical of the quality of assessments. Southern Group claimed assessments have become increasingly open and flexible resulting in greater inconsistency. Regent Training Centre maintained assessment results must be checked for accuracy in order to prevent self-interest of training providers.

66

385. Quality could be improved, according to Whangarei education and business services, by requiring a final external exam that is the final qualification and assessing previous units on the ”say so” of fellow tradesmen, supervisors or employers. Southern Group suggested moderation should not only be of critical skills, but be expanded to all skills relevant to the qualification as only by doing this do you capture skills necessary to “the essence” of particular trades.

Other submitters

386. Thirteen submitters directly addressed this question. One submitter asked for more detail on the proposals.

387. Two submitters stated the current system works well. They stressed the need for external moderation. They also stated that the ITO should constantly improve and update its moderation processes. One submitter stated that the system needs to be simple, clear and verifiable. Another submitter stated that moderation within industry and across providers is needed to ensure the competence of all graduates. This will require collaboration across tertiary sectors.

388. One submitter noted that they have experienced inconsistencies with the ITO system of moderation. Another submitter stated that moderation and consistency should be owned by the standard setter. One submitter stated that the focus should be more on the front end of the process and focus on assessment delivery and resource development. One submitter supported the focus on key competencies.

389. Two submitters support moderation of all unit standards. They questioned who would decide what a “critical” skill is.

It would be far more robust having moderation done on all unit outcomes as who decides what’s valuable or not, this would be far more consistent for a good outcome worthy of a National Certificate. Private individual 1

390. Two submitters from unions stated that they do not want extensive changes to the moderation process nor to have external moderation diminished. They want all standards moderated, as this is important for credibility. They also support the status quo with an emphasis on high quality standards and the retention of the credit rebate. However, they did not support the introduction of a levy.

QUESTION 11 QUALITY ASSURANCE SETTING

Will NZQA reviewing its quality assurance settings for unit standards incentivise greater uptake of unit standards in providers? What other issues disincentivise the adoption of unit standards? Do you agree that vocational education and training should have a common currency for learning and skills?

Employers

391. Employers regard NZQA unit standards as an effective form of moderation and support their continued use. However, a review is welcomed on the basis that:

67

Too many unit standards on the framework have led to many being undervalued. More rigorous reviews of these will raise the value of them. Downer New Zealand

The proliferation of health and safety unit standards is given as an example.

392. An employer in the care industry supports having an increased ability to contextualise unit standards because many of their staff work and train in geographically isolated locations. In more technical or ‘hard-skill’ industries however, consistency and standards are paramount. Two employers therefore stated that unit standards must underpin all qualifications as an indicator of competency; Scotty’s Construction suggested a national curriculum and Garrison Security advocated a standard exam.

393. Employers stated that the main benefits of a common currency are that it clarifies employers’ expectations of apprentices’ needs and capabilities, and it supports employees’ transferability. The ‘one standard’ approach is more efficient. However, at the moment, resources, training approaches and standards, vary across tertiary training providers. Employers do not want more inconsistency as a result of the proposal and are concerned that the ability to contextualise unit standards will give further license to training providers to produce inconsistent skill standards.

There are too many variations on how the unit standards are achieved… Atkin Construction

The current situation still allows unit standards to be taught in a variety of settings – on job, off job, online, correspondence, night classes, block courses. Don’t change something that is not broken. Wood Robson Ltd

394. Employers said that there is a need to distinguish between generic and industry-specific unit standards in developing a common currency. Foodstuffs support the concept of a common currency for learning and skills at the lower end of vocational training (levels 1 to 4). Two employers suggested industry should work with ITOs to identify which unit standards are applicable across which industries. Training packages can then be developed to suit individual industries using common unit standards.

The ITO’s and other providers need to focus on core skills first and then deal with developing unit standards for the industry specific skills. Gravure Packaging Ltd

395. Employers noted that one disincentive to the uptake of unit standards is the way assessment timetable requirements are currently structured. One employer said the rule that one credit has to be reported in the first month of training is impractical given they conduct integrated assessments covering a range of unit standards.

396. Other disincentives to the uptake of unit standards are:

time is required outside of work hours

the travel time for trainees who live in remote areas

unit standards are too task-specific and should be required to include ‘real world’ job experience

A confusing variety of training programmes

68

delays accessing quality training providers

no recognition of prior learning or current competency

administration is not user-friendly

moderation and quality assessment processes

merging of ITOs

cost and availability of technical resources for an adequate review and update

TRoQ de-emphasises unit standards.


397. Industry associations generally see quality assurance as important. One association stated that quality assurance was not currently a problem for them, but that simplicity is the most important factor in any system going forward. Some associations commented that rationalised unit standards, reduced duplication and focus on learner outcomes, where feasible, is positive. Some stated that TRoQ will aid this. Other associations want consistent use of unit standards across all forms of delivery. This is because industry has had input into designing unit standards and therefore understand them. There is strong support from associations for ensuring consistent quality outcomes of unit standards. One association commented that unit standards must have the same outcomes in all cases if used more widely than by the originating ITO.

Need to ensure delivery and assessment of standards is consistent and meets quality assurance expectations. Northland Wood Council

398. There is a belief that industry-specific components in qualifications should not be removed entirely as this would decrease employer confidence and qualification uptake. It is stated that it should not be necessary for all unit standards to be shared.

Should the targeted and mandated review processes currently under way genericise [sic] the Interior Systems qualifications to a point where they become virtually unrecognisable by stripping out the industry-specific components, it is likely to be to the detriment of the industry which would no longer have any assurance that specific training needs were being met. AWCI

However, care is required during this process to maintain industry technical and critical skills standards. Horticulture NZ

399. Some associations suggested that unit standards need to be strengthened and fine tuned. Unit standards should be:

more robust and flexible

more focused on learning outcomes

more customisable for industry need

more fit for their purpose.

69

Some associations stated that unit standards must ensure that graduates demonstrate commercial competence in the areas covered by their qualifications. That is, verify that a graduate can perform a specified task unsupervised, to a quality finish and in an appropriate time frame. There was some concern that industry training could become too academically focused. Some associations contend that qualifications need to be practical and work as a cohesive whole and that sometimes unit standards make this difficult. There is also support from associations for flexible vocational pathways. One association commented that there should be flexibility to pick units from across the framework.

400. Some associations strongly oppose simulated training. This is because simulated training does not ensure that employers know that all people with the same qualification have received equivalent training and experience, including on-site experience.

Under the proposed changes anyone could run a training course and issue a carpentry certificate to a person who has no onsite experience and gained all their knowledge in a classroom situation only. The Association is adamant that substantial onsite experience during training in carpentry is an essential part of a tradesperson’s qualification which will be recognised and accepted by the industry. Marlborough Registered Master Builders’ Association

401. There is strong support for a common currency across vocational education and training. Some associations stated that it makes qualifications recognisable and understandable for employers and learners. They suggested that it would also improve uptake. There is support from some industry associations for using unit standards as the common currency. Some are, however, concerned that TRoQ made use of unit standards as common currency problematic. One association stated that it is essential for NZQA to work more closely with industry to support the development of a common currency.

We do support a common currency of skill recognition as this makes it easy for employers to easily understand the skills an employee brings to the work place. It is also of obvious benefit to employees to have a common system that recognises their skill. The New Zealand Manufacturers and Exporters Association NZMEA

Unit standards should be the unit of currency from school to provider to industry training. A common currency allows the transferability of skills and allows learners to build on their skills base throughout their lives. And, a common currency gives employers the surety that competent means competent. Baking Industry Association of New Zealand

We believe that NZQA should be required to consult with industry to ensure qualifications and programmes are fit for purpose, meet the needs of industry and provide the ‘common currency’ envisaged in the discussion paper. Registered Master Builders Association

402. Some associations stated that they do not believe that unit standards in their current form should be the common currency for learning and skills. This is because they are fragmented learning and any currency should be seen in the context of a whole qualification. Additionally, unit standards are not the only way of measuring competence. One association commented that unit standards had added confusion in their sector by replicating existing industry qualifications. Another association suggested using assessment standards as the common currency. One association suggested using New Zealand qualifications as the common currency and stated that this would mean that the use of unit standards would be at industry discretion.

70

403. One association stated that quality assurance settings won’t drive change. Another association identified three factors affecting the uptake of qualifications and unit standards: price and funding to buy at that price, contractual requirements, and literacy and numeracy barriers. One association was concerned that quality assurance may become too driven by providers and the international education market at the expense of domestic industry.

It appears that the providers has an undue influence in qualifications size and content. This influence has been dictated by providers’ wish to meet an international education export market. Hospitality New Zealand


404. There is considerable disagreement among ITOs in relation to unit standards and how they should be implemented and more specifically about the value of the TRoQ process. There is general agreement that the concept of a common currency is worthwhile.

405. Several ITOs support robust, flexible and relevant unit standards, which maintain industry involvement. NZITO stated that non industry-specific, portable skills can and should be codified in common unit standards and then contextualised for industry purposes. However, several ITOs noted that it is important to retain the balance between generality and specificity. Unit standards must not be so generic as to have no industry relevance. Certain skills are critical to certain industries and those industries should be able to determine what these standards contain. However, the ability for providers to contextualise is good. Unit standards should be flexible where possible and able to be assessed in a range of settings. However, it is critical that ITOs retain moderation of all standards.

406. BCITO stated that unit standards encompass commercial competence, that is, performing a task repeatedly to a high standard under work conditions. It would be very concerned if that was lost.

407. TSO stated that unit standards currently constrain ITOs developing fit-for-purpose standards and statement of outcomes. They stated unit standard as a term should be phased out and replaced by the terms skills standard or assessment standard.

408. Two ITOs stated that TRoQ would rationalise unit standards, reduce duplication and focus on learner outcomes. It would see everyone working for the same outcome. Four ITOs particularly welcomed the emphasis on learner outcomes. Two ITOs suggested that TRoQ should be strengthened and needs of industry able to determine outcomes. Two ITOs stated that TRoQ recognises industry involvement in qualification development. In particular, they support the Vocational Pathways model.

409. Three ITOs stated that TRoQ was making the use of unit standards more problematic, stating that there is a disconnect between these proposals and TRoQ. There is concern that non-unit standard outcomes would not be documented on a learner’s record of achievement. NZITO said that this is a significant structural change for NZQA and providers. Thus, it will need careful management and may require some reversal of TRoQ outcomes.

71

Alignment of NZQA policy, especially around the Targeted Review of Qualifications and the requirement for qualifications to be non-unit standard based in some instances would be a potential barrier to this proposal. NZITO

Consideration should be given to making unit standards and off-job or on-job assessment, when industry determines this is necessary, as compulsory for all providers delivering qualifications ESITO

410. ITOs list a number of concerns around how unit standards are currently being handled:

HSI stated that if unit standards were lost, this would dilute the influence of industry in linking skill standards to qualifications and graduate outcomes.

CMITO stated that it dislikes the process that has been used to rationalise qualifications, as it ignores industry, and does not want it applied to unit standards. Instead, NZQA should clearly outline its requirements and let industries use these as it goes through qualification and unit standard review. NZQA and TEC processes should align with industry requirements and be easy to administer from an ITO perspective.

Three ITOs asked how NZQA would approve programmes without using industry endorsed expertise to ensure it delivers identified outcomes and questioned whether this would just be replicating the work undertaken to develop unit standards if they did use such expertise.

Two ITOs were also concerned that TRoQ risks encouraging a proliferation of programmes delivering the same qualification and additional costs associated with vetting multiple delivery methods.

SITA stated that there could be confusion if ITOs use different criteria for developing and assessing qualifications to ITPs and PTEs. ATTTO stated that all trainers in the VET sector should use the same system for funding and performance measures as this would reduce funding confusion.

411. Two ITOs stated that quality assurance needs to be reviewed with a view to developing clear guidelines for lead qualification developers on how the outcomes of qualifications will be monitored. Two ITOs stated that NZQA quality processes need to be improved for employers and trainees. Additionally, funding for all quality assurance functions should be assessed to ensure it is appropriate.

412. There is strong opposition to many skills being learned in simulated environments. Two ITOs suggested that on-job and off-job skill acquisition are not the same, even if they appear to be. PaMPITO stated that skill standards should be learned and assessed in suitable settings. They commented that there needs to be a balance with on-the-job needs so that qualifications retain their work focus. Two ITOs stated that industry should be able to specify the context of assessment for industry specific skills. InfraTrain stated that practical skills must be assessed in a practical setting.

413. Two ITOs stated that a common currency is good practice. Eight ITOs support unit/assessment standards being the common currency across the vocational training sector and applied in different settings. PrITO also support the use of unit standards in sub-degree level programmes to continue common currency idea.

72

EXITO suggested that unit standards should be incentivised to become the common currency. BCITO stated that the common currency is good in theory, but hard to implement practically in the current environment. They asked about how consistency will be established and maintained.

414. Three ITOs said current measures are unlikely to be successful in encouraging uptake of unit standards unless they are more closely aligned with NZQA policy.

415. Many ITOs supported the establishment of a working group.

The ITF recommends that NZQA establish a working group consisting of industry, ITOs and providers to evaluate NZQA policy around unit/assessment standards being component parts of qualifications and to incentivise use of unit/assessment standards across the VET sector. ITF

Tertiary Providers

416. Providers support a review of unit standards. Indeed, the ITP sector CEOs observed that a review of unit standards was vital for preserving the integrity of the standard-setting process.

417. Different providers highlighted problems with unit standards. Waiariki Institute of Technology and the Waikato School of Hairdressing note that unit standards become quickly outdated, are too restrictive and inflexible. The Bay of Plenty Polytechnic said unit standards are too task-specific and detailed resulting in them being unsuitable for many trainees.

418. In order to incentivise greater uptake, the ITP sector CEOs suggest NZQA needs to focus on skill outcomes that are adaptable. This theme of greater flexibility as a solution to many of the unit standards problems was taken up by other submitters. Tectra maintain that greater flexibility is required of NZQA in standard delivery and interpretation. Another submitter, who wishes to remain anonymous, pointed out that it was necessary to consider how students needing a common skill across a range of situations will be catered for alongside those operating in only one context.

419. Ten providers support a common currency. Eight providers see benefit for employers of more accurate expectations of what an employee can bring to the workplace. Three providers described transferability as essential. To be valued, however, this must be collaboratively developed and focus on learning outcomes.


420. Only a few independent MACs commented on this proposal. The main problems identified with unit standards by Southern Group Training Trust, Regent Training Centre and Whangarei Business and Education Services was the duplication of unit standards, lack of resources and variability between standards.

421. Southern Group suggested unit standards could be improved by having greater industry involvement in the development of standards, more careful writing of each unit standard and narrower delivery methods. They also noted that mature workers who are unfamiliar with unit standards require additional support. Whangarei Business and Education Services suggested that unit standards

73

could be improved by having generic unit standards which were distinct from industry specific standards.

Other submitters

422. Thirteen submitters commented directly on this proposal. There were few common themes.

423. Three submitters stated that industry must be involved in determining the criteria for unit standards. The development of these must not be Government-led. One submitter stated that achievement of a unit standard should genuinely reflect the capability of a learner to use relevant skills in an authentic setting. Three submitters support more flexible unit standards that could be taught and assessed in a variety of settings.

424. Four submitters are opposed to simulated training, stating practical skills must be learned on site. This is because simulated training does not faithfully recreate the workplace situations in which skills will be used.

425. One submitter suggested three things that would improve unit standard uptake: revising settings for course approvals, actual need in the workplace for unit standards based education, and a common understanding of what is being provided. Another submitter suggested better recognition of prior learning would encourage people to continue study. One submitter suggested that a common currency would encourage uptake.

426. One submitter stated that alignment between ITO quality processes and NZQA and ITP quality processes is very important for maximising employer and learners’ experiences. The Tertiary Education Union called for a review of tertiary sector quality assurance overall.

427. Another submitter supports the NZQA review, stating this should be done in concert with all users. The basis for the review should be what best suits the learner, not what best suits ITOs or providers. Two submitters expressed concern that there was a mismatch between TRoQ and the use of unit standards as a common currency. Two submitters stated that ITOs should be properly resourced to promote and implement vocational pathways.

428. One submitter suggested a move from task-based standards to skills-based standards. Another submitter stated that assessment and unit standards both have a place within the qualifications framework. One submitter stated that standards should reflect new qualifications outcomes and not remain at the sub-task level.

429. One submitter does not support the use of unit standards as a common currency. This is because unit standards are too fragmented and specific.

74

Appendix: Submissions received

ORGANISATION ABBREVIATION TYPEEMPLOYERS Abel Engineering Abel Engineering Employer

Active Refrigeration Ltd Active Refrigeration Ltd Employer

AdMark Visual Imaging Ltd AdMark Visual Imaging Ltd Employer

Advanced Engineering Solutions Advanced Engineering Employer

AF Southgate & Sons AF Southgate & Sons Employer

AFS Total Fire Protection Ltd AFS Total Fire Protection Employer

Air Fluid Otago Air Fluid Otago Employer

Airtech NZ Limited Airtech NZ Limited Employer

AJ Grant Engineering AJ Grant Engineering Employer

Alan Poulsen Ltd Alan Poulsen Ltd Employer

Aldridge Hydraulics Ltd Aldridge Hydraulics Employer

Alert Engineering Ltd Alert Engineering Ltd Employer

Alliance Group Alliance Group Employer

Alloy Yachts Alloy Yachts Employer

Alteration Specialists Alteration Specialists Employer

Amcor Packaging NZ Ltd Amcor Packaging Employer

AMT Mechanical Services Ltd AMT Mechanical Services Employer

Andrew Lawson Builder Andrew Lawson Builder Employer

Angus Robertson Mechanical Angus Robertson Mechanical Employer

Anzco Food, Green Island Anzco Food, Green Island Employer

APN Print NZ APN Print Employer

Aspec Construction Aspec Construction Employer

ATI Engineering Ltd ATI Engineering Employer

Atkin Construction Atkin Construction Employer

ATNZ ATNZ Employer

AW Fraser Ltd AW Fraser Ltd Employer

BB Construction BB Construction Employer

Begg Security Group Ltd Begg Security Group Ltd Employer

Bennetts Plumbers 1979 Ltd Bennetts Plumbers 1979 Ltd Employer

Bleeker & Weith Bleeker & Weith Employer

Broderick Printing and Design Ltd Broderick Printing And Design Ltd

Employer

BUPA Care Services BUPA Employer

Canterbury Steel Structures Ltd Canterbury Steel Structures Employer

CCT CCT Employer

Chillzone Ltd Chillzone Ltd Employer

Christchurch Steel Ltd Christchurch Steel Employer

Chubb Chubb Employer

CMP Rangitikei Limited CMP Rangitikei Limited Employer

Coastal Welders Coastal Welders Employer

Cold Aire Cold Aire Employer

75

ORGANISATION ABBREVIATION TYPEColor Communications Inc Color Communications Inc Employer

Commercial Signs Print and Promotions Commercial Signs Employer

Community Connections Community Connections Employer

Contact Energy/Mighty River Power Contact Energy/Mighty River Employer

Coombridge Industries Ltd Coombridge Industries Ltd Employer

Couplands Bakeries Couplands Bakeries Employer

Craig Rogers Building Ltd Craig Rogers Building Ltd Employer

Culham Engineering Company Ltd Culham Engineering Employer

DC Repairs Ltd DC Repairs Ltd Employer

DF Transales Ltd DF Transales Ltd Employer

Dow Agro Sciences Dow Agro Sciences Employer

Downer New Zealand Downer NZ Employer

Eastbridge Ltd Eastbridge Ltd Employer

Eastside Refrigeration Ltd Eastside Refrigeration Ltd Employer

Endevour Precision Automation Engineering Ltd

Endevour Engineering Ltd Employer

Energy Products International Energy Products International Employer

Ensign Engineering Services Ltd Ensign Engineering Services Ltd

Employer

Excel Builders Ltd Excel Builders Ltd Employer

Falcon Manufacturing Group Limited Falcon Manufacturing Group Limited

Employer

Farra Engineering Ltd Farra Engineering Ltd Employer

Findlater Sawmilling Ltd Findlater Sawmilling Ltd Employer

Fire Protection Compliance Ltd Fire Protection Compliance Ltd

Employer

Fire Security Services Ltd Fire Security Services Ltd Employer

Fleet Engineering Fleet Engineering Employer

Fletcher Building Fletcher Building Employer

The Fletcher Construction Company Ltd Fletcher Construction Employer

Fonterra Fonterra Employer

Foodstuffs (NZ) Limited Foodstuffs Employer

Framework Framework Employer

Fulton Hogan Fulton Hogan Employer

Garrison Security Garrison Security Employer

Garry Gray Engineering Ltd Garry Gray Engineering Ltd Employer

Gavin Lowe Energy Solutions Gavin Lowe Employer

Genesis Energy Genesis Energy Employer

Gillies Metaltech Ltd Gillies Metaltech Employer

Gisborne Olympic Pool Gisborne Pool Employer

Goodmans Goodmans Employer

Gravure Packaging Limited

Gravure Packaging Limited

Employer

GW Davies Heating Engineers Ltd GW Davies Heating Engineers Ltd

Employer

Haack Construction Ltd Haack Construction Employer

Haua Engineering (Rotorua) Ltd Haua Engineering (Rotorua) Ltd

Employer

Heslops Engineering Ltd Heslops Engineering Ltd Employer

76

ORGANISATION ABBREVIATION TYPEHeat Treatments Ltd Heat Treatments Ltd Employer

Higgins Group Holdings Ltd Higgins Group Employer

High Pressure Equipment NZ Ltd High Pressure Equipment NZ Ltd

Employer

Howard Howard Employer

HPAC Energy Centre HPAC Energy Centre Employer

Industrial Tube Manufacturing Co Limited Industrial Tube Manufacturing Co Limited

Employer

Inghams NZ Pty Enterprises Ltd Inghams Enterprises Ltd Employer

Installation and Piping Services Ltd Installation and Piping Services Ltd

Employer

Integrated Hydraulics Limited Integrated Hydraulics Employer

IVE Group Limited IVE Group Limited Employer

Jack Links New Zealand Limited Jack Links New Zealand Limited

Employer

Jackson Engineering Jackson Engineering Employer

Jackson Enterprises Jackson Enterprises Employer

J.M.P. Engineering Ltd JMP Engineering Ltd Employer

John Jones Steel Ltd John Jones Steel Limited Employer

Kawerau Engineering Ltd Kawerau Engineering Limited Employer

Ken Anderson Building Ltd Ken Anderson Building Employer

Kernohan Engineering Ltd Kernohan Engineering Ltd Employer

Kevin Hyde Engineering Kevin Hyde Engineering Employer

KiwiRail KiwiRail Employer

KiwiRail Interislander KiwiRail Interislander Employer

KiwiRail Interislander KiwiRail Interislander Employer

Knight Precision Engineering Knight Precision Engineering Employer

Longveld Ltd Longveld Ltd Employer

Lyttleton Engineering Lyttleton Engineering Employer

Mach3 Industries Ltd Mach 3 Industries Ltd Employer

Marinetec Engineering Ltd Marinetec Engineering Ltd Employer

Mercer Stainless Ltd Mercer Stainless Ltd Employer

Metalcraft Engineering Company Ltd Metalcraft Engineering Ltd Employer

Metalspray Engineering Ltd Metalspray Engineering Ltd Employer

Milfos International Milfos International Ltd Employer

Milmeq Ltd Milmeq Ltd Employer

MJ Custom Engineering Ltd MJ Custom Engineering Employer

MS Coombes Ltd MS Coombes Ltd Employer

Nelson Forests Ltd Nelson Forests Ltd Employer

New World Waikanae New World Waikanae Employer

New Zealand Aluminium Smelters Ltd New Zealand Aluminium Smelters

Employer

No company name No company name Employer

No company name No company name Employer

NRG Home Electrical NRG Home Electrical Employer

NZ Electrical Contracting Ltd NZ Electrical Contracting Ltd Employer

NZ Wood Mouldings NZ Wood Mouldings Employer

NZPC NZPC Employer

77

ORGANISATION ABBREVIATION TYPEOtago Sheet Metal and Engineering Ltd Otago Sheet Metal and

Engineering LtdEmployer

P & W Engineering Ltd P & W Engineering Ltd Employer

Palmers Mechanical Limited Palmers Mechanical Limited Employer

Pan Pac Forest Products Limited Pan Pac Forest Products Limited

Employer

Parade Hydraulics and Engineering Ltd Parade Hydraulics and Engineering Ltd

Employer

Patience and Nicholson NZ Ltd Patience and Nicholson NZ Ltd

Employer

Phoenix Steel Limited Phoenix Steel Limited Employer

Presbyterian Support Central Presbyterian Support Central Employer

Presbyterian Support South Canterbury Presbyterian Support South Canterbury

Employer

Profab Central Engineering Ltd Profab Central Engineering Ltd

Employer

Proform Plastics Limited Proform Plastics Employer

Progressive Engineering Co Ltd Progressive Engineering Ltd Employer

PSC Enliven PSC Enliven Employer

Reefton Engineering Reefton Engineering Ltd Employer

Restaurant Brands New Zealand Ltd Restaurant Brands Employer

Name withheld Name withheld Employer

Roberts Engineering Roberts Engineering Employer

Roger Hogg Builders Ltd Roger Hogg Builders Ltd Employer

R.R. Bramley and Co RR Bramley and Co Employer

S.A.F.E Critical Engineering Solutions Safe Critical Engineering Solutions

Employer

Salvation Army HomeCare Salvation Army HomeCare Employer

Scotty's Construction 2002 Ltd Scotty's Construction 2002 Ltd Employer

SEC Group Limited SEC Group Limited Employer

Shape Technology Limited Shape Technology Employer

Sharland Engineering Sharland Engineering Ltd Employer

Sheet Metal Specialists Sheet Metal Specialists Employer

Skyline Enterprises Ltd Skyline Enterprises Ltd Employer

Southern Colour Print Southern Colour Print Employer

Southland Security Centre Ltd Southland Security Centre Ltd Employer

Spectrum Care Spectrum Care Employer

Spotless Facility Services Spotless Employer

Spotless Facility Services Spotless Employer

Stainless and Alloy Fabricators Ltd Stainless and Alloy Fabricators Ltd

Employer

Stark Bros Ltd Stark Bros Employer

Summerset Group Summerset Employer

Taege Engineers Ltd Taege Engineers Employer

Taunton Engineering Ltd Taunton Engineering Employer

Tauranga Engineering Ind. Ltd Tauranga Engineering Employer

Taymac Taymac Engineering Employer

Taymac Stainless Taymac Stainless Employer

Te Pari Products Ltd Te Pari Products Ltd Employer

Tegel Foods Ltd Tegel Foods Ltd Employer

78

ORGANISATION ABBREVIATION TYPETennant Engineers Tennant Engineers Employer

TerraNova Homes and Care Ltd Terra Nova Employer

Texco Steel Ltd Texco Steel Employer

TH Barnes and Co Ltd TH Barnes and Co Employer

The Animal Health Board The Animal Health Board Employer

The Ultimate Care Group Ltd The Ultimate Care Group Employer

Thermal Solutions Ltd Thermal Solutions Ltd Employer

Thompson Construction and Engineering Thompson Construction and Engineering

Employer

Tidd Ross Todd Ltd Tidd Ross Todd Ltd Employer

Todd Augers and Equipment Todd Augers and Equipment Employer

TracGrip Hydraulics and Equipment Ltd TracGrip Hydraulics and Equipment Ltd

Employer

Tru-Test Group Tru Test Group Employer

Valley Industries Ltd Valley Industries Ltd Employer

Waitapu Engineering Ltd Waitapu Engineering Ltd Employer

We Can Precision Engineering Ltd We Can Precision Engineering

Employer

Westland Milk Products Westland Milk Employer

WM Ross Engineering Ltd WM Ross Engineering Ltd Employer

Wood and Thomson Engineering Ltd Wood and Thomson Engineering

Employer

Wood Robson Ltd Wood Robson Ltd Employer

Woolston Engineering Ltd Woolston Engineering Employer

WYMA Engineering NZ Ltd WYMA Engineering NZ Ltd Employer

YMCA of Auckland Inc YMCA of Auckland Employer

Total 189 INDUSTRY ASSOCIATIONS The Association of Wall and Ceiling Industries

AWCI Industry Assoc

Baking Industry Association of New Zealand

BIANZ Industry Assoc

Beef and Lamb NZ Beef and Lamb NZ Industry Assoc

Business New Zealand Business NZ Industry Assoc

Cement and Concrete Association of New Zealand

CCANZ Industry Assoc

Civil Engineering Testing Association of New Zealand

CETANZ Industry Assoc

Construction Industry Council CIC Industry Assoc

Dairy NZ Dairy NZ Industry Assoc

New Zealand Disability Support Network NZDSN Industry Assoc

The Electrical Contractors Association of New Zealand

ECANZ Industry Assoc

Electricity Engineers' Association of New Zealand

EEA Industry Assoc

Employers and Manufacturers Association EMA Industry Assoc

Federated Farmers Federated Farmers Industry Assoc

Forest Industry Contractors Association FICA Industry Assoc

79

ORGANISATION ABBREVIATION TYPEFire Protection Association FPANZ Industry

AssocFitness New Zealand FitnessNZ Industry

AssocFlorists New Zealand Incorporated FLONZI Industry

AssocFood and Grocery Council FGC Industry

AssocForest Owners Association FOA Industry

AssocHorticulture New Zealand HorticultureNZ Industry

AssocHospitality New Zealand Hospitality New Zealand Industry

AssocThe Institute of Quarrying IoQ Industry

AssocThe Institute of Professional Engineers New Zealand

IPENZ Industry Assoc

The Institute of Refrigeration, Heating and Air Conditioning Engineers

IRHACE Industry Assoc

Maritime New Zealand Maritime NZ Industry Assoc

Marlborough Registered Master Builders' Assn Inc

Marlborough Registered Master Builders' Assn Inc

Industry Assoc

Master Plumbers, Gasfitters and Drainlayers and Masterlink Limited

Master Plumbers Industry Assoc

Maintenance Engineering Society of New Zealand

MESNZ Industry Assoc

Motor Trade Association MTA Industry Assoc

New Zealand Institute of Quantity Surveyors

NZIQS Industry Assoc

New Zealand Pine Manufacturers Association

The Pine Manufacturers Industry Assoc

NZ Association of Registered Hairdressers Inc

NZARH Industry Assoc

NZ Heavy Engineering Research Association

HERA Industry Assoc

NZ Recreational Association NZRA Industry Assoc

NZ Retailers Association NZ Retailers Association Industry Assoc

NZ Shipping Federation NZSF Industry Assoc

The New Zealand Council for Christian Social Services

NZCCSS Industry Assoc

New Zealand Home Health Association NZHAA Industry Assoc

The New Zealand Manufacturers and Exporters Association

NZMEA Industry Assoc

The New Zealand Milking and Pumping Trade Association

NZMPTA Industry Assoc

New Zealand Outdoor Instructors Association

NZOIA Industry Assoc

New Zealand Security Association NZSA Industry Assoc

The Petroleum Exploration and Production Association of New Zealand

PEPANZ Industry Assoc

Pipfruit New Zealand Pipfruit NZ Industry Assoc

Plastics New Zealand Plastics New Zealand Industry Assoc

Print NZ Print NZ Industry Assoc

Registered Master Builders Federation RMBF Industry

80

ORGANISATION ABBREVIATION TYPEAssoc

Road Transport Forum NZ RTFNZ Industry Assoc

Roofing Association of New Zealand RANZ Industry Assoc

Scaffolding Access and Rigging NZ Inc SARNZ Industry Assoc

The Northland Wood Council NWC Industry Assoc

Waikato Engineering Careers Association WECA Industry Assoc

Furniture and Cabinetmaking Association FCANZ Industry Assoc

NZ Marine Transport Association NZ Marine Transport Association

Industry Assoc

Total 54INDUSTRY TRAINING ORGANISATIONS Aviation, Tourism and Travel Training Organisation

ATTTO ITO

Building and Construction Industry Training Organisation

BCITO ITO

Careerforce Careerforce ITO

Communications and Media Industry Training Organisation

CMITO ITO

Competenz Competenz ITO

Emergency Management Qualifications EMQUAL ITO

Electricity Supply Industry Training Organisation

ESITO ITO

Extractive Industry Training Organisation EXITO ITO

Forest Industry Training and Education Council

FITEC ITO

New Zealand Hairdressing Industry Training Organisation

HITO ITO

Hospitality Standards Institute HSI ITO

Industry Training Federation ITF Peak Body: ITO

InfraTrain InfraTrain ITO

Joinery Industry Training Organisation JITO ITO

NZ Motor Industry Training Organisation MITO ITO

NZ Marine NZ Marine ITO

New Zealand Industry Training Organisation

NZITO ITO

Plastics and Materials Processing Industry Training Organisation

PaMPITO ITO

Plumbing, Gasfitting, Drainlaying and Roofing Industry Training Organisation

PGDR ITO ITO

Primary Industries Industry Training Organisation

PrITO ITO

Retail Institute Retail Institute ITO

Service Industries Training Alliance SITA ITO

The Skills Organisation TSO ITO

Total 23TERTIARY PROVIDERS

ACT Safety Ltd Act Safety Ltd PTE

Name withheld Name withheld PTE

AMS Group Ltd AMS Group Limited PTE

81

ORGANISATION ABBREVIATION TYPEATC Professional ATC Professional PTE

Blueprint for Learning Blueprint for Learning PTE

Christchurch Polytechnic Institute of Technology

CPIT ITP

Crown Institute of Studies Crown Institute of Studies PTE

Ignite Learning and Development Ignite Learning and Development

PTE

Independent Tertiary Institutions Independent Tertiary Institutions

Peak Body: PTE

New Zealand Institutes of Technology and Polytechnics CEOs, Metro Group of Institutes of Technology and Polytechnics CEOs

NZITP, Metro ITP ITP sector CEOs

Jupiter Training Resources Ltd Jupiter Training Resources Ltd

PTE

Manukau Institute of Technology MIT ITP

New Zealand Institutes of Technology and Polytechnics, Metro Group of Institutes of Technology and Polytechnics, Industry Training Federation

NZITP, Metro ITP, ITF Peak Body: ITP

New Zealand Association of Private Education Providers

NZAPEP Peak Body: ITP

New Zealand Travel Information Limited NZTI PTE

Rapid Results Rapid Results PTE

Sadler and Associates Sadlers PTE

School of Applied Technology, Bay of Plenty Polytechnic

BoPP ITP

Tectra Tectra PTE

Training Systems and Solutions Ltd TSSL PTE

Unitec Unitec ITP

Waiariki Institute of Technology Waiariki Institute of Technology

ITP

Waikato School of Hairdressing Waikato School of Hairdressing

PTE

Waikato Institute for Leisure and Sport Studies

WILSS PTE

Total 25INDEPENDENT MODERN APPRENTICESHIP COORDINATORS

Apprenticeship and Trade Services Apprenticeship and Trade Services

MAC

Engineering Taranaki Consortium ETC MAC

Gisborne Development Gisborne Development MAC

Job Finders Job Finders MAC

NorthTec Northtec MAC, ITP

Regent Training Centre Ltd RTC MAC, PTE

Southern Group Training Trust SGTT MAC

Smart Careers and Southern Group Training Trust

Smart Careers MAC

Whangarei Education and Business Services

Whangarei Education and Business Services

MAC

Total 9OTHER

Accident Compensation Commission ACC Government

Age Concern Age Concern Other

Ako Aotearoa National Centre for Tertiary Teaching Excellence

Ako Aotearoa Other

82

ORGANISATION ABBREVIATION TYPEAuckland City Council Civil Defence and Emergency Management

Auckland City Council CDEM Council

Competency International Limited CIL Consultant

Private individual 1 Private individual 1 Individual

Department of Conservation DOC Government


Dyslexia Foundation of New Zealand and the Certified builders from Auckland with Learning Disabilities

DFNZ and the Certified builders from Auckland with Learning Disabilities

Other

Engineering Printing and Manufacturing Union

EPMU Union

Cobalt Communications Cobalt Communications Consultant



Local Government New Zealand LGNZ Government

Ministry of Pacific Island Affairs MPIA Government


New Zealand Council of Trade Unions NZCTU Union

Northern South Island Regional Rural Fire Committee

Northern South Island Regional Rural Fire Committee

Other

NQF Solutions NQF Solutions Consultant

NZ Mountain Safety Council NZ Mountain Safety Council Other

Palmerston North City Council PNCC Council

Plant and Food Research Plant and Food Research Crown Entity

Post Primary Teachers Association PPTA Union


Rural Women New Zealand RWNZ Other


Site 2 Site 2 Other



Stronger Christchurch Infrastructure Rebuild Team

SCIRT Government

Tertiary Education Union TEU Union

Timaru District Council TDC Council

United Fire Brigades Association UFBA Other

Total 32GRAND TOTAL 332

83

Industry Training Review:Summary of submissions received ...€¦ · Web viewThe Plumbing,...

Documents

Transcript of Industry Training Review:Summary of submissions received ...€¦ · Web viewThe Plumbing,...