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Industry Training Programme Approval Rules Consultation - Summary of Feedback
The New Zealand Qualifications Authority (NZQA) received constructive feedback following consultation with the industry training and wider tertiary education sector during May – June 2012 on the proposed Industry Training Programme Approval Rules.
The proposed Rules have been developed collaboratively with a working group of representatives from industry training organisations. Feedback received has been generally in support of this approach to developing the Rules. The majority of respondents consider that the proposed criteria would provide adequate assurance of the educational integrity of the Industry Training Provider Programme.
Background to the Rules
The proposed Rules arise from the development of new requirements for approving and listing qualifications at levels 1-6 on the New Zealand Qualifications Framework which separate the qualification from the programmes of study and programmes of industry training leading to them.
These Rules are developed under the new section 253 of the Education Act 1989 whereby NZQA is to develop Rules to regulate its quality assurance activities.
Summary of Feedback
NZQA sought responses to 6 questions that focussed on topics ranging from implementation dates through to coverage of the proposed Rules. A total of 14 responses were received which represented:
- 14 Industry Training Organisations (ITOs)
- Two Private Training Establishments
- One Institute of Technology and Polytechnic
- The Industry Training Federation
NZQA carefully considered the feedback and has made some minor changes to the Rules as a result. The following summarises the specific feedback and issues raised in response to the consultation questions.
There were 4 questions relating to the content and clarity of the Industry Training Programme Approval Rules and the whether the criteria would provide adequate assurance of the educational integrity of the industry training programme.
Definition of an Industry Training Programme
A number of respondents sought clarification on whether the definition of the Programme as proposed was in conflict with the Industry Training Act 1992. In developing the draft Rules, the working group had sought to provide flexibility in the components included in an Industry Training Programme in order to “future proof” the Rules. Hence the proposed definition included an option for components other than assessment standards.
NZQA have amended the definition to reflect that it is training for the purposes of the Industry Training Act 1992 rather than to specify the type of components it may comprise.
This position supports the current requirements for assessment standards but enables flexibility should there be relevant changes to the Industry Training Act following decisions arising from the Industry Training Review.
The suitability, use and interpretation of the word programme for the Rules was commented on by many respondents. It was thought it may be confused with the criteria for Programmes of Study. However, the term Programme is referenced in the Education Act and is the correct term to use.
September 2012 Implementation
A majority of respondents did not support the September 2012 implementation date for the proposed Rules. Instead, most suggested implementation in January 2013 to coincide with new financial budgets and to allow time to prepare new Industry Training Programmes.
One submission stated an immediate implementation would provide ITOs with certainty on the programme criteria and several others supported the September date without any supporting comment provided.
NZQA agrees with the proposal in the feedback to implement the Rules from 2013 rather than the initially proposed date of September 2012. The date will be confirmed in subsequent communications.
Submitters were invited to make other comments on the proposed Rules and the processes included within them. Submissions generally focused on issues pertaining to implementation of the Rules. One submission commented on a wide range of other quality assurance matters not directly related to the Industry Training Programme Rules.
The main areas of commentary are summarised below:
a. An NZQA Implementation Plan and Service Agreement
An implementation plan for the proposed Rule which specifies NZQA’s timeframes for processing applications was among the most significant feedback and shared by a majority of submitters. Based on the feedback, provision of planning information would instil greater confidence in NZQA because in its current form, the proposed rule is:
[unclear] as to what service level agreements NZQA are committing to in terms of processing times.
Further, it was suggested that a service agreement should be a precursor to operationalising the proposed Rule and the fees it will attract.
It was suggested the implementation plan should include a transition period to enable both NZQA and the industry to ‘learn as they go’ before any fees for the service were imposed. This would enable the sector and NZQA to work in partnership during the transitional period where industry will be learning to prepare and submit the Industry Training Programme approval documentation and NZQA analysts will be learning exactly what evidence is needed in the programme approval process in order to approve an application. A number of ITOs have offered to pilot the new guidelines and processes prior to full implementation. NZQA is developing an implementation plan and will work with these organisations in developing the first programmes and testing new guidelines and processes.
b. NZQA Capability and Industry Knowledge
A number of submitters questioned whether NZQA staff assigned to processing applications for approval of Industry Training Programmes had relevant and appropriate levels of industry knowledge and proposed using industry expertise or the relevant ITO for this purpose.
NZQA considers there are sufficient provisions available to ensure Industry Training Programmes are credible to industry. Industry Training Programmes are created from unit standards which have been developed by the standard setting body in conjunction with industry and approved by NZQA. A new requirement has been added to the Rule to require a programme developer, who is not the qualification developer, to consult with the qualification developer as the programme is developed. It is not expected this situation will arise very often but brings this Rule into line with the proposed Rules for approval of programmes of study. As well, NZQA seeks specialist expert advice if it considers it necessary.
Some respondents expressed concern about the potential for long turnaround time frames for approval of Industry Training Programmes. This reinforces the need for transparency and clarity around NZQA time frames. As one submitter noted:
the September timeframe for implementation was ambitious when considering the implications of not yet having enough time spent on training staff and learning with the organisations involved about the process.
Some respondents requested to be involved in the development of associated templates, guidelines and other supporting information in the same consultative way that was employed in the development of the proposed Rules.
c. Incentives and Sanctions Regime
Development of an incentives and sanctions regime for industry training organisations, similar to that for education providers, was a key request to NZQA. This is largely because, as one submission indicated:
[T]he proposal as it stands makes no reference to the incentives and sanctions framework which was promoted by NZQA as a significant positive outcome for ITOs from the EER framework, which imposed considerable costs on ITOs in comparison with the previous audit model.
NZQA has previously undertaken to develop an incentives and sanctions regime for ITOs and is planning for this to be developed in due course in conjunction with industry training organisations.
d. Rules to Apply to Programmes Developed towards NZ Qualifications
Submitters suggested that the proposed Rules be only applied to programmes developed towards New Zealand qualifications, which would most commonly be as a result of a mandatory review of qualifications. This would remove the need for industry training organisations to develop programmes towards National qualifications yet to be reviewed.
NZQA has determined that where there are no current approved programmes for National qualifications, Industry Training Programmes will not be required until the related New Zealand qualifications are listed.