HSU National welcomes the opportunity to provide a response the discussion paper Industry Engagement in Training Package Development – Towards a Contestable Model. At the outset we wish to reaffirm our commitment to the current bipartite, independent and industry-led system of training package development through the twelve Industry Skills Councils (ISCs). We also wish to flag our concerns that in seeking to dismantle the ISC system, the Government is addressing a problem that does not exist.

While the Discussion Paper references concerns about the “quality of VET training” as one of the key reasons for reform, this catch-all criticism conflates industry concerns with the quality of training delivery with the quality of training development. While it is true that there are legion problems with the former, the same cannot be said of the latter. According to the National Centre for Vocational Education Research (NCVER), of the minority of employers who were dissatisfied with the VET system (16.9 per cent in 2013) nearly 60 per cent reported poor quality or low standard of training delivery as the reason for their dissatisfaction. Conversely, prior to the introduction of training packages and their development through the network of ISCs, most employers were concerned about course content. The same turnaround has been seen for students. In 1997, as training packages were about to launch, nearly a third of TAFE graduates were dissatisfied with the quality of their training, by 2011 it was only 1 in 10 students. To be clear, we are not saying that the current training package development process is perfect, however we wish to make the point that policy change of the scale suggested in the Discussion Paper must be carefully assessed and have a sound rationale—neither of which the Government has demonstrated.

Rather than addressing each of the Discussion Paper’s focus questions this Submission states our position on the ISC model and outlines what features need to be kept if changes to this model are inevitable; raises our concerns with the policy direction proposed in the Discussion Paper; and provides our view on the three proposals.