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Frequently asked questions

  • Auckland is at Alert Level 3. The rest of New Zealand is at Alert Level 2.

    For more information on Alert Levels, including health advice and travel restrictions, visit the NZ Government website Unite for Recovery .

    For learning providers, visit the Ministry of Education website for information regarding COVID-19. 

    For students, visit the StudyLink  and Ministry of Education websites, or speak to your learning provider for more information on the support package and how to apply.

    For support with mental health and wellbeing, please visit the Mental Health Foundation and NauMaI for online tools and guidance.

    Stay up to date
    For answers to questions about Student Allowance and Living Cost payments refer to the StudyLink  website.

    For health advice, refer to the Ministry of Health website .

    Face Coverings can help reduce the spread of COVID-19. Staff and learners should check on campus for any face covering requirements.

    For more information on wearing face coverings , visit the NZ Government website Unite for Recovery .

  • As one organisation, we need a single academic regulatory framework to ensure academic integrity, quality, and consistency across the network. Te Pūkenga Academic Regulations will:As one organisation, we need a single academic regulatory framework to ensure academic integrity, quality, and consistency across the network. Te Pūkenga Academic Regulations will:

    • give effect to our Charter
    • ensure our services work well and respond with excellence to the needs of Māori ākonga and their whānau, and to the aspirations of iwi, hapū and Māori hāpori throughout Aotearoa
    • ensure the integrity, consistency, and quality of teaching, learning and assessment across the network.

    The procedures that sit under the high-level principles in the Regulations will be developed in collaboration and consultation with the network through 2021 and 2022. This mahi will begin in July and will include the involvement of working and reference groups to support the development of a set of unified policies (where needed), procedures and key forms. If you would like to be involved in this mahi, let us know. Email us on academicregulations@tepukenga.ac.nz and tell us which procedures you are interested in being involved with.

    Te Pūkenga academic regulations provide the overarching framework under which all teaching, research, learning, and support activities will be delivered; however, not all sections or procedures will be relevant to workplace learning which is subject to a training agreement. So yes, where appropriate, the regulations will apply to delivery managed by the TITOs/Work-based Learning Subsidiary.

    Each subsidiary currently has different approaches to recognition of learning with a range of limitations on what can be awarded at what level. The draft Te Pūkenga regulations recommend that there be no limits on either Credit Recognition and Transfer (CRT) or Recognition of Prior (experiential) Learning (RPL) at any level of delivery except where based on specific, documented, and clear legal, academic or industry requirements, e.g. regulatory body requirements. This aligns with New Zealand Qualifications Authority (NZQA) guidelines on recognition of learning. A working group is framing up the RPL approach and a CRT working group will be set up to work on the CRT approach for the network.

    Te Pūkenga Academic Regulations will come into effect on 1 January 2023. A range of support mechanisms will be developed before then to support network partners transition to and implement the regulations in a way that ensures our learners are not disadvantaged by the move to a unified academic regulatory framework.

    Potentially yes. Te Pūkenga grades include competency-based and achievement-based grades which may be different to the grades you currently award. A scoping project is planned to identify for each network partner what changes will be required, and the supports needed to implement Te Pūkenga grades.

    Potentially. Changes to programme documents may be needed to align with Te Pūkenga regulations (e.g. grade tables, credit recognition). The Academic Delivery and Innovation team (ADI) will be considering ways to facilitate this process as well as any required reporting to NZQA.

    We are compiling a Te Pūkenga glossary of terminology which will be made available on the Te Pūkenga website in due course; all projects and workstreams will be contributing to this document. At this stage, the glossary is not yet available to the network; however, if you have any questions around terminology or definitions, email us at academicregulations@tepukenga.ac.nz.

    The Regulating for Excellence development team reviewed a number of combined academic statutes, including the TANZ statute, and got feedback from across the network to inform the draft document. However, the final document looks quite different in that it is comprised of high-level statements of principle without the regulatory statements and clauses you usually see in academic regulations. These statements will be incorporated into the associated policies, procedures, and key forms and we will be looking at best practice across the network as we commence work on the associated artefacts that support the framework.

    The academic regulations that applied at your point of first enrolment will apply through to the point of your graduation. e.g. - if you first enrolled in the Bachelor of Applied Management at Wintec in 2021– you will complete your degree under those regulations.

    There may be changes within procedures and processes from January 2023 but fundamentally you will be completing under the regulations that were in place when you first enrolled.

  • The Reform of Vocational Education (RoVE) aims to create a strong, unified vocational education and training system that is fit for the future of work and delivers the skills that learners, employers, and communities need to thrive.

    It includes seven key changes, one of which is the creation of Te Pūkenga – New Zealand Institute of Skills and Technology.

    The new system puts learners back at the centre and it will have a stronger focus on employers: delivering the skills they need, providing more support for those in work-based training, and ensuring greater consistency in vocational learning across the country. 

    Learners will receive more support while they are training, and their knowledge and skills will be more relevant to what industry needs. They will be able to move more easily between regions and between on-the-job, on campus, and online training.

    The changes reflect the Government’s commitment to Māori-Crown partnership.

    New Zealand needs to be ready for a fast-changing future of skills, learning and work A single, strong vocational education system will help improve well-being for all New Zealanders and support a growing economy that works for everyone.

    The world of work is changing significantly. Vocational education needs to adapt to stay ahead of these changes as well as supporting learners, employers, and their communities in a changing environment.

    We have long-term skills shortages across a number of industry sectors and the current vocational education system doesn’t always meet the needs of learners, employers, or regions.

    The current system has also under-served some groups of learners, such as Māori, Pasifika, learners with disabilities, and learners with special learning needs. 

    ITPs are now working together instead of competing with each other. On 1 April 2020, they became subsidiary companies of Te Pūkenga, and each has a new board of directors.

    In the short term, most of the changes will be invisible – learners should experience no changes to their fees or study programmes throughout 2020. 

    ITOs became transitional ITOs on 1 April 2020. Over time, their role of supporting workplace learning and assessment will be transferred to vocational education providers.

    This transition will take some time and will be carefully managed so that there is no interruption to training for work-based learners. Work-based learners will be advised about any changes to their study and learning due to COVID-19 by their employers and ITOs.

    A key priority of vocational reform is to better recognise the needs of Māori communities and acknowledge that Māori are significant employers with their own social and economic goals. 

    The changes will prioritise learners who weren’t well served by the previous system, including Māori. 

    A group has been set up to make sure the changes reflect the Government’s commitment to the partnership between Māori and the Crown – Te Taumata Aronui. This will give Māori community and employer views on tertiary education, including vocational education and training.  

    No. Vocational education and training will continue to be offered by Te Pūkenga subsidiary ITPs and Transitional ITOs across New Zealand.

    ITPs will continue to use their current trading names. From 1 April they have a new company name to describe their legal status as limited liability companies. 

  • The changes are being introduced gradually and carefully. Learners won’t notice any changes in 2020 other than those which relate to the New Zealand Government’s Alert Level 4 measures.

    Learners will still be able to complete their qualifications through their chosen provider, and the provider’s name on qualifications will stay the same. 

    They will be able to enrol in another course, including courses that last for more than one year. 

    Support services will stay the same, fees will stay the same and learners’ relationships with organisations such as StudyLink will stay the same. 

    As the changes are introduced, learners will have more access to high-quality learning in the workplace as well as on campus. It will become easier to move between learning in the workplace, on campus and online. 

    It will also be easier to transfer to another part of New Zealand to learn, without it affecting the qualifications learners are training for. 

    Industries will be more involved in setting the standards for what learners study, to make sure they gain the relevant skills that employers want. 

    There will also be more support to help learners achieve their goals.

    People living in remote parts of New Zealand will have more opportunities to learn online. 

    One of the aims of the changes is to prioritise learners who weren’t well served by the previous system. These learners include Māori and Pasifika, who make up a growing part of the future working population. 

    The new system aims to give Māori and Pasifika learners better access to quality education.

    Over time, it will become easier for learners who have enrolled in study to transfer to another part of the country. Learners will be able to live close to whānau, giving and receiving support from family while they study.

    The changes also give Māori business and iwi development a much stronger voice. 

    One of the aims of the changes is to prioritise learners who weren’t well served by the previous system, including learners with disabilities and learners with extra learning needs. Inclusiveness will be at the core of the new system. 

    The changes will make vocational education more accessible for people who have disabilities or need extra learning support. 

    There will be stronger ties between education providers and schools, and between providers and employers. This will help people with disabilities or extra learning needs to get into education and training, and to find jobs. 

    At the moment, Industry Training Organisations (ITOs) are responsible for making sure people with disabilities are not discriminated against. When vocational providers take over work-based learning, this will become their responsibility. 

  • The changes are being introduced gradually and carefully. Subsidiary ITPs are in the process of developing responses for the Alert Level 4 operating environment.

    International students can keep studying towards their goals with the same study arrangements, the same fees and the same visas . Their courses and qualifications will continue to be recognised. 

    International students can continue to enrol to study as planned subject to Alert Level 4 restrictions. 

    Approved visas and study arrangements will continue. Courses and qualifications will continue to be recognised.

    Students will be able to complete any study or training they start. 

    As the new system is introduced, international students will have more access to high-quality learning in the workplace as well as learning on campus. It will be easier to move between learning in the workplace, on campus and online.

    It will also be easier to transfer to another part of New Zealand to study, without it affecting the qualifications students are training for. 

    Industry will be more involved in setting the standards for what students choose to study, ensuring they gain relevant skills that employers want. 

    There will also be more support to help all students achieve their study goals. 

  • How will the changes affect employers now?

    Learners who are on an apprenticeship or being trained at Industry Training Organisations (ITOs) or Institutes of Technology and Polytechnics (ITPs) will be able to continue training with little change for the next year or two. 
    There will be no disruption to the pipeline of skilled workers, and learners can keep enrolling to train.

    How will the changes affect employers in the future?

    The Reform of Vocational Education aims to help employers hire people who are well-trained and ready for work – and to get people into work more quickly.
    Under the changes, apprenticeships and on-the-job training will continue to be a priority. They will not be replaced by on campus learning.
    Industry and employees will have greater influence over the courses and training offered, to ensure learners gain the right skills for the right jobs.
    Six industry-governed Workplace Development Councils (WDCs) have been created to give industry a strong leadership role in vocational education and training.
    The councils’ responsibilities will include giving investment advice, identifying current and future skills needs, developing qualifications, and setting standards.
    Regions will also be given more say in planning for the work skills they need.
    The transition and integration of many different parts to a new cohesive system will be gradual and carefully managed.

    Will Te Pūkenga only cover vocational training at Levels 3-5, and where do degrees stand in new operating model?

    As it does currently, Te Pūkenga network will continue to deliver qualifications from Levels 1 through to Level 10 of the New Zealand Qualification Framework (NZQF).

    We understand the need to support underserved learners but how do we make sure we don’t create a two-tier system? 

    We already have a two-tier system with underserved learners not succeeding due to how the system is structured. The reforms are aimed at eliminating this so everyone has an equal chance of success.

    For digital learning, how will Te Pūkenga support learners in remote locations?

    We are very conscious that we need to cater for all types of learners and situations. This is an example of how some learners are currently disadvantaged and we will be addressing this to ensure the learner is not disadvantaged. These learner needs have been captured in the learner personas that we have developed.

    How will Te Pūkenga serve Māori and Pacific learners better?

    The Ākonga at the Centre research project developed by the Learner Journey and Experience team at Te Pūkenga culminated in the Te Rito research which provides insights into the current experiences of Māori, Pacific and disabled learners in vocational and applied learning. A series of 20 learner personas accompany the reports to deepen our understanding of the needs of learners and those supporting them. These personas (together with the employer personas) create a significant number of opportunities to help the codesign working group to develop the new service concepts.

    Can learners make their learning profiles public to employers eg. LinkedIn?

    They can if they choose. However, while giving learners autonomy on what they want to share, their data and privacy must be controlled and protected. The information needs to be in a format that is valuable to both parties but not in a format where either party and their data can be abused.

    What is the connection between community facilitators and the Matauranga Innovation Hub and Adaptive Skills framework? 

    Community facilitators will be recruited from the network as they understand iwi and their community. They will not provide an individual service to everyone but will be in the community connecting and exploring opportunities for all learners and employers. A good example of this working in practice is the work that Dale Williams (former Mayor of Otorohanga) did some years ago to match the unemployed youth in his district with employers’ skills gaps.

    What’s being done in terms of Recognition of Prior Learning? 

    Recognition of Prior Learning has been around for many years. The main constraints come with the validation and evidence of the learning and this can often be a challenge. The ‘My Teacher My Way’ concept is about the use of an evidence-based assessment and the “Pathway Planning and Lifelong Learner Record” concept includes a record of skills that can be validated as they are developed (making the recognition of prior learning pathway easier in the future). 

    Are women a group that we can better support with learning and training?

    We don’t create the right environment for some women - middle aged Māori women and women in construction are good examples. Looking at where the world of work is heading, we need to upskill our existing workforce, grow capability and lift productivity, rather than solely relying on young people entering the workforce or creating more low paid jobs.  

    How do you provide better access for mature learners?

    Second chance/returning learners are one of our learner personas where we are identifying what they need in order to be successful. 

    How will the right trainers/training content be identified for each industry? 

    Through WDCs, employers will be involved in the development of the qualification and skills standards required. Through Te Pūkenga, employers will be involved in developing the programme and content that will deliver the qualification. Support will also be provided to employers and those who support them (eg. training advisers) to help them teach better.

    Can people be mentors, verifiers, trainers, accessors and what can/can’t they do? 

    There are currently numerous models used across the VET system on how each of these functions is undertaken. Often these arrangements have been developed over many years to reflect how an industry or a particular employer prefers to operate. The key is to ensure we have the right people undertaking their roles to retain the integrity of the system as each of these (mentors, verifiers, trainer, accessors etc) have specific requirements. 

    How will Te Pūkenga support and monitor workplaces that are not good places to work? 

    One of the new service concepts is “A Good Place to Work” which is about supporting employers to develop a good working environment and a great learning experience so the learner thrives. The learner personas help us understand what different learners need to succeed, while the employer personas help us understand what employers need.  Between the two we can help develop a good place to work that reflects the individual needs of both the learner and employer.

    In addition moderation is used to ensure consistency and standards are met so that all learners in the workplace reach the same standard.  Both the WDCs and Te Pūkenga will carry out moderation. We also expect that over time, as more employers use the VET system, they will develop a reputation for being a good place to work.

    Will there be skill-based or unit-based outcomes in the future?

    The legislation requires skill standards, therefore a skill-based requirement will remain. Skill-based standards can be delivered though either unit standards or by larger groupings of standards (sometimes called specifications). Through WDCs and in consultation with their tertiary provider industry will help determine the best way these skill standards are developed to suit their sectors.

    What is happening in terms of simplifying programmes?  

    There is a large piece of work currently underway focussed on unifying common programmes to simplify the system. There is also the ability to develop more targeted and smaller ‘bites’ of learning (eg. micro credentials) that would suit those employers where a larger qualification is not required.

    What is the scope of international education? 

    This area is still uncertain. However, we are aware there is work being undertaken by Education New Zealand including how we could export and deliver our expertise internationally if we can’t bring students to New Zealand. 

    How will this change be achieved when employers are so time-bound?

    We’re conscious that these changes will require employers/industry to have multiple relationships, however we need a system that does not create more work for employers. For example, industry and employers may now have to interact not only with Te Pūkenga (as the provider), but potentially multiple WDCs, Regional Skills Leadership Groups, Centres of Vocational Excellence (CoVEs) and possibly Private Training Establishments and Wananga. As employers/industry time is precious, we are working with these other entities to optimise employers/industry’s time.

    Employers often don’t want their apprentice to go to a block course, and the apprentice can’t do their learning online. How can we reach a balance?

    We know the ‘one size fits all’ model does not work. The “My Learning My Way” service concept reflects that and talks to the learner needs as well as the employer needs by providing greater flexibility in when and how learning takes place. Employers, particularly those with few staff, often cannot afford to have their staff absent from the workplace for extended periods of time so we have to find other ways to ensure the learning is available. Online may be an option in certain circumstances but, where practical elements are required, a different approach will be necessary. As an example we are currently trialling with a couple of polytechs and Industry Training Organisations how this could be accommodated with a ‘drop in centre’ type model that is accessible after hours and on weekends. We are also piloting in Ara Polytech how industry support can be more closely integrated into a programme of study.

     How will Te Pūkenga ensure the continuity and consistency of training providers and what they are teaching?

    The consolidation of programmes ensures the same content is taught throughout New Zealand. A programme can be completed once and shared, rather than having multiple versions. They will be developed by using “communities of practice” and with a consistent teaching (Ako)framework with appropriate teaching support (including support for employers). The moderation functions of WDCs and Te Pūkenga internal QA/moderation will help delivery to be consistent.

    Will small providers and organisations have a voice in the set up as it gets larger? 

    One of the concerns from industry is that their voice will be lost or diminished with RoVE particularly due to the larger groupings of sectors within WDCs and a large organisation such as Te Pūkenga. We understand that and have an employer representative on Te Pūkenga executive leadership team (Deputy Chief Executive Employer Journey and Experience) to ensure the industry/employer voice remains strong. We will be retaining the current employer/industry relationships that exist in ITOs and polytechs but with some 25 entities coming together we need to develop an industry/employer (and community and iwi) engagement framework.

    What about the challenge of apprenticeships and funding themselves / taking leave to do training? 

    This can occur when small businesses don’t always have the capacity to have one of their workers off site for an extended period - a problem we have identified in our learner and employer persona research. While employment arrangements are private to the employer and employee, the ‘My Learning My Way” service concept is an opportunity to deliver the training in a way that suits both the learner and employer and reduce the imposition block courses etc might have on the business.

    How are learners prepared to be ‘work ready’ with soft skills such as timeliness, attitude, numeracy and literacy and pastoral care?

    These soft skills have been built into services concepts and identified in the learner personas. We know employers value these skills and the learner (eg. apprentice/trainee) is an employee first. We will be looking to incorporate these skills in our development and some of our current pilots include a greater connection with industry/employers to assist with transition from tertiary education into work. This has also been identified as an issue for school leavers and students’ readiness for work.

    What will happen to students already part way through a training programme?

    There is no change to existing programmes or apprenticeships. Existing students will continue their current programme through to its completion.

    Why are ITOs operating as different groups under Te Pūkenga?

    Initially the ITOs transition to a work based learning subsidiary as business divisions. This is an interim step as they transition over the next 18 months. From 2023, that subsidiary will be integrated into Te Pūkenga. However, the ITOs will start working together and with the polytechs immediately and there are already initiatives underway to work more closely together even before ITOs have transitioned.  

    Is it compulsory for ITOs to transition to Te Pūkenga or do they have a choice?

    In consultation with their sectors ITOs need to decide whether they transition wholly or in part to Te Pūkenga. They have other options also such as transitioning, wholly or in part to a PTE(s) or Wananga, or set themselves up as a PTE. All transition plans have to be approved by TEC.

    How are existing contracts that ITOs and ITPs hold being transitioned?

    The contracts (eg. that support arranging training) will be novated to the ‘receiving’ entity, Te Pūkenga, to ensure continuity of service.  Employment agreements for ITO staff transitioning into Te Pūkenga transfer under the same terms and conditions.

    What will Training Advisor roles look like? 

    Initially at least the Training Advisor roles will look very much as they do now. However, given that Te Pūkenga is a ‘provider’, there is scope for the training advisor role to expand to help support/teach where appropriate (note that ITOs are not allowed to teach and can only arrange the training).  Should Te Pūkenga decide to develop this option it will need to build its capability to ensure this works well and complements the training being carried out in the workplace by the employer.

    What is the role of Private Training Establishments (PTEs) moving forward? 

    There is no impact on PTEs - they stay as they are and will continue to play a vital role in the new system as providers.

    How are Workforce Development Councils structured?

    There are six WDCs structured by industry groups in line with the six Vocational Pathways (that are used in secondary schools):

    1. Waihanga Ara Rau - Construction and Infrastructure
    2. Toi Mai - Creative, Cultural Recreation & Technology
    3. Maku Tangata – People, Food & Fibre
    4. Services
    5. Toitu te Wairoa – Community, Health, Education & Social Services
    6. Hanga-Aro-Rau – Manufacturing, Engineering and Logistics
    How will qualifications and skill needs be identified for each industry?

    Industry and employers will work with their Workforce Development Councils (WDC) to identify the qualifications and skills that their sectors need. WDCs will be responsible for developing qualifications in collaboration with others, which will be and registered on the New Zealand Qualifications Framework. Te Pūkenga and other providers will develop a programme of study/learning (with associated resources) to meet the requirements of each qualification. We will work with industry, employers, and communities to ensure that how the programme is developed and delivered suits their needs.

    How can we get involved with WDCs for the development of trade apprenticeships? 

    WDCs are currently developing their own operating models, including their employer/industry relationship process.  You can find out more on the Tertiary Education Commission website www.tec.govt.nz/rove/workforce-development-councils/

    How will the employers voice be heard in the new qualifications that are being undertaken, and the scaling down from 3000 programmes? 

    The industry and employers will, through the WDCs, determine what their qualification and skill needs are, and providers will be funded to deliver those programmes. Te Pūkenga, will determine how those programmes are put together and will consult widely with employers/industry and staff as programmes are developed or changed.  

    How will trade apprenticeships remain flexible and how do skills get standardised between employers?

    Workforce Development Councils will set the skill standards (qualifications) in consultation with industry. Te Pūkenga will develop the programme to deliver to the qualification and we will work with industry to ensure as much flexibility is built into that to accommodate the employer and learner needs.

    How do we build in other requirements that are not captured in the qualification eg. Health and safety, compliance etc.  into the same programme to save everyone’s time? 

    As work sites often have unique health and safety requirements and are site specific, they need to sit outside the qualification. Although, some health and safety elements can be built into a qualification - such as using equipment safely, general health and safety awareness etc. With compliance documentation, there is an opportunity to contain that information in a digital format and avoid cumbersome paper-based systems. There is a trial underway with a mobile platform that contains such information.

    How will Te Pūkenga connect with kura and schools and future learners?

    Our connection with kura and schools is critical to create a clear vocational pathway from secondary school through to tertiary education. We recognise that these conversations need to begin at intermediate level. Te Pūkenga is working with the Ministry of Education on how to connect with the secondary school system to reflect the options and opportunities offered by a vocational career.

    There are good programmes operating within schools to support industry eg. great training grounds like STAR, Gateway, Trades Academy and the Pathways Advisory Group. What will we do to keep these programmes alive? 

    Yes indeed and the more we can mainstream these programmes and integrate them into the school system, the better chance we have of establishing vocational pathways that are more transparent and accessible and seen as a genuine career option.  

    How do we change the perception that trades are not higher earning? 

    We need to change the perception that a vocational education pathway is inferior to the university pathway. This is something of an intergenerational prejudice that goes back many years and has created a parity of esteem issue where a vocational qualification is not considered as valuable as an academic one. Such cultural positions can be difficult and slow to change and we have a long way to go to reach the likes of Germany and Switzerland where a vocational qualification is considered equal to a university one. It will help if the NZ Qualifications framework truly reflects the complexities/competencies involved in some apprenticeship qualifications whose graduate profiles align closely to a bachelors degree, yet they are ranked at Level 4 on the NZQF and degrees at Level 7. We hope the current review of the framework addresses some of these anomalies to stop reinforcing the current prejudices.  

    How is a learner’s soft skills captured by the employer? 

    That information will be included in the learner profile that is captured within the Pathway Planning and Life Long Learner Record concept. As an example we are trialling a mobile platform that contains a record of skills that:

    • you say you have
    • others say you have and can validate(ie the soft skills mentioned)
    • an independent party can only validate (in real time) eg. quals, health and safety certification, drivers licence etc.  

    How does Te Pūkenga get funded? 

    Under VOTE Education, we are funded by the Tertiary Education Commission (TEC) based on the number of learners in the system. A new unified funding system is being developed but is yet to be announced.

    How does the Apprenticeship Boost work? 

    It is currently paid monthly through the Ministry of Social Development, starting at $1000 per month for a first year apprentice, then reducing to $500 per month in the apprentice’s second year. Learners needs to show progress in their qualification otherwise the funding is at risk. 

    What’s the risk of dropping out when the Apprentice Boost programme drops back from funding after the second year? 

    We hope that doesn’t happen. The decision was to target funding at the first two years of the apprenticeship, as this is the period where employers and apprentices require the most support. Statistics show that once an apprentice gets past the first18 months or so the success rate for completing their apprenticeship improves significantly.

    Will that funding to aligned to completions and progress? 

    The Apprentice Boost funding is dependent on the apprentice progressing in their learning. We expect the rules are likely to be similar (ie a learner must show progression through their programme) when the new unified funding system comes into effect.

    Will employer/industry contribution for work based training continue? 

    This contribution remains and can come from numerous sources such as the employer, apprentice or other party (eg. parent). The Government is currently partly funding this contribution through fees-free.

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