Henrietta Cook from The Age has written a good article about the intersection of funding for schools and private providers, with a focus on Sports Education and Development Australia (SEDA) and SEDA’s Registered Training Organisation TEPA.
The article focuses on a damning 2013 report from the Victorian Registration and Qualifications Authority (VRQA) into SEDA. It seemed SEDA was basically unaware of its obligations as a provider at that time but I would expect they have tidied up their act in response to the audit. The quality of their delivery as assessed by the VRQA is not my main concern and neither do I have an issue with innovative models of delivery that represent an alternative to schools. What I am concerned about is the funding that sits behind the model and some of SEDA’s practices.
Some quick background: SEDA is registered by the VRQA to deliver the Victorian Certificate of Applied Learning (VCAL) which is the vocational counterpart of the Victorian Certificate of Education (VCE). SEDA has been in operation since 2006 and was set up as a re-engagement program using sport as the vehicle around which the curriculum could be constructed. So far so good. SEDA advertises and promotes its offering and then partners with schools or other training organisations – SEDA does all the delivery but students may be enrolled in a school or even a TAFE. Those partners enter results and issue certificates and also collect the government funding, a small proportion of which they retain as an administrative fee while the bulk is passed on to SEDA. Students at SEDA may be enrolled into other registered training which attracts funding beyond what would be available to a school, for example, for delivering VCAL.
I first became aware of SEDA when I was approached by them six years ago to see if our school would be a SEDA ‘partner school’. They approached us again on two further occasions. I rejected the offer because the model concerned me deeply. I would have been accepting students for enrolment who may have lived anywhere in the state. We wouldn’t have known those students. They would never have visited our school and we would have had no intention to deliver a program for them. Our school would simply have been a conduit for moving money to SEDA directly out of the government schools funding pool, the Student Resource Package. That didn’t seem right to me.
I can imagine many situations where a school may initiate a partnership with a private training provider to deliver a program for their students. It’s common in Vocational Education and Training (VET) although this is covered by standard contactual arrangements. Schools might also see a need to establish a partnership with a TAFE or a private provider to deliver a program for disengaged students. But this was none of these. The program was conceived by SEDA. They initiated the partnership with schools and they did all the delivery. And this is not just a single site, it’s a large scale operation on around 50 sites around the state. Surely at that scale its obvious it’s not an arrangement between a school and a private provider to address localised issues.
It was also very clear in 2011 that SEDA was no longer offering a re-engagement program. This was borne out when two of our school students received letters from SEDA and one of their peak sporting body partners promoting enrolment at SEDA. Of further concern to me at that time was that the student names and addresses had been provided by the peak sporting body, which held those details because the students were involved in talent development programs with the sporting body.
I thought there was a potential privacy issue there. I was also concerned about the potential for double dipping into education and training funding given that SEDA was partnering with schools to access the SRP and with a TAFE, which could potentially have provided access to funding from the Victorian Training Guarantee.
These concerns aside, the audit report showed SEDA engaging in practice that would seem unusual, especially for a so-called re-engagement program. For example the students enrolled in a Year 1 (Year 11 equivalent) Foundation VCAL course with SEDA (so presumably the lowest performing, least engaged students) were enrolled not only in Foundation VCAL (for which the host school or TAFE partner would be funded for a nominal 395 hours of delivery) but also in Certificate 111 in Community Activity Programs (586 hours), Certificate 111 in Education Support (645 hours) and a Certificate in General Education for Adults (150 hours). Each of these certificates would deliver additional funding. So 1776 nominal hours of delivery. Impossible to deliver, especially remembering that Certificate 111 is the equivalent of a Year 12 VCE subject.
I don’t expect this pattern of delivery is confined to one provider. One way of doing this amount of delivery would be for a form of ‘layering’ in which the highest level certificates are delivered and then ‘backmapped’ against the requirements for the lower level qualification, while claiming funding for delivery of all certificates. Nothing illegal there. Just not the way things should work. If governments are looking for ways to stamp out abuse of training funding they should be looking at this type of practice wherever it is carried out.
I also find it unusual that an organisation like SEDA, which is registered to deliver VCAL, would choose to use another organisation to enter results in the Victorian Curriculum and Assessment Authority’s database and to issue certificates for them. SEDA is registered to do this so why use another organisation? I have presumed, perhaps incorrectly, that it allows for separation of the entities so that funding can be accessed by different sources. There would seem to be no information publicly available that identifies the sources of funding SEDA accesses, beyond the charge it levies on its own students of up to $4000 per student so there is no way for us to know exactly what is going on in that space.
I took my concerns to the education department on two occasions and for a time I was kept informed of developments in this area. I was never too sure how seriously the department viewed the matter. I also understood it was difficult for the department to isolate one program and one provider when there was a range of activity going on between schools and other organisations, not the least of which was the VET activity many schools engage in through partnerships with TAFE.
According to The Age article SEDA students don’t know which school they are enrolled in, or which TAFE. They understand, quite naturally, that they are enrolled with SEDA. But the effect of this is that a school in Geelong, for example, could be hosting SEDA enrolments from kids living anywhere from Sunshine to Colac. None of them would ever set foot on the school grounds and the school would have no idea who they are. How is that a genuine use of the limited funds government sets aside for schools? And what sort of a precedent does it set for other private providers or TAFEs to enrol their students in a school and access SRP funding? Is this the future of public education? Public education funds being available to organisations other than schools?
There is a source of funding for community based VCAL models – the Victorian Training Guarantee. SEDA should be entitled to run their program (presuming they’ve addressed the compliance issues identified by the VRQA) but it’s questionable whether they should be accessing schools funding to do so.
The education department has recently issued new guidelines for schools seeking to engage with private providers. The obligations on schools have been ramped up significantly. This is good. In an environment where the department is working very hard to ensure that its staff operate with integrity at all times, the integrity of its own funding model should be maintained as well.