Submission on addressing the issue of overlapping provision

Posted By TEU on Nov 17, 2009 |

Submission of the

Tertiary Education Union (TEU) Te HautūKahurangi o Aotearoa

to theTertiary Education Commission

on the consultation document

Addressing the issue of overlapping provision

30th September 2009


The New Zealand Tertiary Education Union (TEU) Te HautūKahurangi o Aotearoa is the largest tertiary sector union in this country.”  Our membership currently sits at approximately 11,500 members, covering all types of TEOs in the sector.”  A significant proportion of our members within the ITP sector are directly involved in the provision of trades training and work closely with ITOs in the management and delivery of workplace training.”  Our members therefore have considerable interest in how the relationship between these organisation types is viewed by TEC as the funding agency, and of course have a particular interest in any proposals that seek to reduce funding for this part of the sector.

Overlapping provision

The issue of overlapping provision between industry training organisations and ITPs has at various times been a vexed one.”  In its Briefing to the Incoming Minister 2005 the TEC defined overlapping provision as:

“…friction that exists at the interface between TEO funding and delivery systems, and is focused upon unnecessary competition and duplication between the industry training and Student Component funding and delivery systems”.

A further definition of overlapping provision was provided in the Cabinet policy paper Proposals to manage overlapping provision of industry training in the tertiary sector 10th of September 2007:

“Overlapping provision occurs when ITPs (and some private training establishments) manage industry training that is comparable to ITO-managed industry training”

Whilst some historical confusion about the distinction between roles of ITOs and ITPs has occurred (particularly regarding responsibility for the delivery of training), current legislation regulating the sector is clear that ITOs manage training plans for trainees, but are not responsible for the delivery of training.”  This is explicitly the function of ITPs, who provide opportunities for skills development as part of a broader educative process.

Subsidy rates

The two funding systems (STM and SAC) serve two different purposes: the first enables ITOs to manage the delivery of training, and the second allows ITPs to (in this instance) provide industry-based education and training, usually arranged by ITOs that meet the needs of various industry sectors.

We can only conclude therefore that the proposal to reduce SAC funding levels is premised on the erroneous belief that the management of training which ITOs provide requires the same level of resources as the education that ITPs deliver.”  Both are vital parts of the process of successful industry training, however the purposes that each are required to serve are fundamentally different.”  Generally the level of workplace training arranged by ITOs focuses on practical skills acquisition, with less focus on the kind of educative processes associated with more formalised learning settings.”  Given this, one would expect that costs associated with arranging and monitoring the delivery of this type of training would be at a lower cost.

Where ITPs are involved in managing training plans (such as CPIT’s Managed Apprenticeships), this occurs within a broader vocational education and training context that offers the learner a much wider range of learning opportunities than is usually possible in a workplace learning environment.”  In this context the learner is supported by experienced teaching staff, a breadth of pedagogical knowledge, strong industry links, and an extensive educational infrastructure.”  The proposal to reduce SAC funding levels therefore attempts to reduce the industry-based learner’s experience within an ITP setting to a very limited transaction, and fails to acknowledge these additional investments.

Similar regulatory framework – reporting and performance measurements

The definition for reporting requirements is somewhat unclear.”  As it is currently written, it could be applied to learners outside of the parameters of the Industry Training Act.”  We do not believe that this is what is intended; therefore we support clarification of the wording along the lines of that suggested by ITPNZ in their submission.

Whilst the TEU supports the need for similar reporting and performance measures of industry-based training, we are of the view that those currently used by ITOs are inadequate.”  This view is supported by recent research exploring the available data for assessing the contribution of industry training, which notes that current datasets are incomplete, limiting the usefulness of this information[1].

Qualification type

The TEU supports linking of industry training to nationally recognised qualifications and allowing flexibility for TEOs to include additional material as appropriate.”  We note that the review of NZQA qualifications framework may change this proposal.

Qualification size

The TEU supports the proposal for a 20 credit minimum training package being applied to ITOs, ITPs and PTEs.

Health and safety and regulatory compliance learning

The TEU supports the proposal that funding for ITOs be subject to the same funding restrictions for health and safety and regulatory training as ITPs.

Industry cash contribution and fees

The TEU supports the proposal that ITPs be required to charge a reasonable fee for service to industry towards the cost of industry training.”  Such a practice acknowledges that industry directly benefits from training and should therefore contribute to its cost.

Fee course cost maxima

As we do not support the proposal to reduce the level of SAC funding for industry training, we do not support removal of the FCCM for industry training.

However if the TEC proceeds with the SAC proposal, we would see this aspect of the overall proposal being necessary to counter loss of funding.

[1] Mahoney, P. April 2009 “Industry training – exploring the data.””  Ministry of Education

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