The discourse of compliance

A common repertoire emerging from the narratives was of policy creating major changes to quality assurance, or ‘increased compliance’. As described by interviewees, the effects included: burgeoning workloads due to increased paperwork; increased data collection, auditing and testing; new rules; and an unprecedented pressure for outcomes.

As an LLN specialist with over 20 years’ experience in the field, Gayle’s reflections on changes in quality assurance were common to other participants. Concerned with the level of increased accountability within VET, she stated:

Accountability is seen as the major driver rather than individual outcomes. We are working in very different parameters in our social world and political contexts. We do need to be accountable but we haven’t seen any evidence that all this accountability is proving better outcomes.

Eve’s experience of increased accountability was similar:

I think there have been significant changes in policy and practice. When I first started in TAFE the emphasis was on doing what you wanted in the classrooms as long as the students were learning; there was nowhere near the emphasis on compliance. I can see the need for some level of accountability—but they’ve pulled it too far the other way. The quality of teaching suffers.

David believed that increased accountability was detracting from the time he could spend with students. He commented:

Look, you spend a lot of time on your record keeping; your accountability. Having to keep up with your accountability actually takes away the time you can spend assisting students.

I understand why there’s coding and descriptors2 and all those sorts of things. I do understand but it’s time consuming; it takes away from the actual face to face teaching you know.

2_{It has become commonplace that, as part of auditing, references to course/unit codes and descriptors are} systematically checked.

Gayle, Eve and David’s concerns with compliance expectations were directly related to a set of policy reforms that had led to the installation of a national VET regulator, the Australian Skills Quality Authority (ASQA), in 2011, and the increased expectations of quality assurance imposed by the state government (ASQA, 2015; Department of Education and Training, 2016a, 2016b; Department of Education and Early Childhood Development—Higher Education and Skills Group: Contract Notification, 2014). The result was more paperwork, not only to justify the appropriate use of state government funding, but also to ensure national consistency in VET course delivery.

The majority of participants had had recent firsthand experience preparing for audits. Commenting on the level of preparation required for an audit, Joanne, a coordinator within an ACE institution, stated: ‘The amount of compliance paperwork to support what goes on in the background is so much more’. Others, such as Anne, were reacting to more than just the increase in paperwork; it was the actual auditing, conducted by external government bodies such as HESG and ASQA that concerned them. Anne stated: ‘We’ve had two audits this year which is a lot and next year we’ve got re-accreditation.’

As well as more frequent regulatory and funding audits, institutions were also subject to regular site audits, often with minimal notice. With regard to the latter, Elise expressed concern that ‘everything is so straightened and everything has to be done so quickly and fast and teachers are so concerned about doing the audit trail and stuff like that’. Fran, a teacher in ACE, expressed similar sentiments:

One of the things that happens when we get audited is that you are told which files to pull out and you go, ‘Oh shit!’ The teacher might have left and you’ve got to fix up the files.

Participants expressed concern that, not only were LLN teachers subject to more audits to comply with both funding and regulatory specifications, but the rules around auditing were constantly changing, making it difficult for teachers to keep up to date. Belinda highlighted this in her comment that:

Things are constantly moving, there are new rules and whole new terms. This way there’s a new rule and that way there’s a new policy. So you’re on the hop the whole time, so the pace is faster and things change more readily.

Eve was concerned that even when the auditing rules were provided, different auditors interpreted them differently. She explained:

It’s time consuming because there are no clear guidelines on what the auditors will or won’t accept. It varies quite frankly from auditor to auditor. It means that there is a lot more over-assessment, more documentation and constant checking of processes and redefining it.

There was also a perception that increased paperwork requirements were being duplicated in vocational classes, particularly for students enrolled in embedded LLN support programs. Casually employed by a rural TAFE, Don articulated this in his claim that:

Both the ... department and our department quite separately do this testing. There’s a lot of duplication going on here. It’s very time consuming and then, when you mark these for each student, where is the forward analysis? ... Why are we gathering it? Ultimately to satisfy the auditors.

Although burdened by increased compliance requirements, some participants reasoned that increased scrutiny and quality assurance may have enhanced their teaching practices. Carmel’s view was that:

The whole auditing and compliance has forced us into changing practices about assessment ... that’s been good for practice but other things have been made inflexible. Things like writing assessment tasks have changed over the years for the better in fact. Some of that has actually been more rigorous and better.

As has been shown, the discourse of compliance was prominent within participants’ narratives. A range of common themes emerged, including: that compliance had resulted in greater emphasis on paperwork, increased audit activity, uncertainty as to when audits were being conducted and what auditors’ expectations were. Questions were also raised about the underlying purpose of increased compliance.

Notably absent from participant’s narratives was the term ‘quality assurance’. With one exception, there were no references to quality or quality assurance in relation to auditing mechanisms and methods of data collection. This is in stark contrast to documentation circulated by regulatory bodies, which states that ‘ASQA aims to improve the quality of outcomes in the VET sector’ (ASQA, 2015, p. 1) and that the Victorian Registration and Qualifications Authority (VRQA3 ) seeks ‘to strengthen the quality of Vocational Education and Training in Victoria’ (VRQA, 2015, p. 1). In a National Centre for

3_{Some Victorian VET institutes, in particular, ACE organisations, are governed from a quality assurance} perspective by the VRQA.

Vocational Education Research (NCVER) report, Misko (2015) identified quality in VET as being the level of excellence in training delivered by public and private RTOs that included both quality management and regulatory frameworks. According to Misko (2015), ‘an efficient and streamlined regulatory system’ should not be ‘overly burdensome’ (p. 13) and should encourage quality of provision of VET training and education, yet this was not the perception of LLN teachers involved in this study. Further discussion around participants’ perceptions that their roles and professional practices have become dominated by regulatory measures (compliance), leaving significantly less time to maintain quality systems, is provided in Chapter 5.