CASA Exams? Cert IV? MEAs? Licence Diplomas? What exactly is going on here?

Before diving into responses to the common questions below, lets attempt to give a general overview of the current situation. 

A lot is going on here, and not all of it seems to comply with regulatory guidance, unfortunately. More disturbingly, training organisations may have been using methodology which actually contributes to the industry-wide confusion and wide spread of misinformation. So, in the interest of clarity and “setting the record straight”, let’s break it down into what should be happening, the complication, and what in fact is happening. Then, we’ll offer a solution.

How *Should* Licencing Work?

In the first place, it is important to note that there are two (2) authorities with whom all training organisations must comply in the aviation engineering sector, CASA and ASQA. In summary, CASA is responsible for the approving and issuing of licences and related items (e.g. Category licences and Type ratings). Meanwhile ASQA is the governing body of the VET sector, which includes all trade related competencies and qualifications (e.g. “MEA” units and Aeroskills qualifications). 

Each of these two bodies has their own set of requirements which must be satisfied for the issuing the above-mentioned outcomes. CASA outlines these requirements in their Part 66 Manual of Standards, while ASQA outlines theirs in the Standards for Registered Training Organisations (RTOs) 2015. These independent sets of requirements have no relation to one another. 

Now, moving on to the requirements of each, which can be summarised as follows: 

• Obtaining a VET qualification requires you to complete the relevant UOCs (“Units of Competency”, or “MEAs”), of which the practical (performance evidence) and theoretical (knowledge evidence) are described in each UOC. All assessments are to be conducted in accordance with ASQA’s requirements. 
• To obtain a licence, CASA requires you to sit the relevant Part 66 examinations (modules) and obtain the required practical experience (more on this shortly), as outlined in the MOS. All assessments are to be conducted in accordance with CASA’s requirements. 

The confusion starts to arise from the aforementioned practical requirements outlined by CASA in the MOS. To obtain the correct practical, CASA uses (i.e. borrows) UOCs (“MEAs”) from the VET sector. Anyone undertaking a Certificate IV or Diploma in Aeroskills will be familiar with these so-called “MEAs”. Likewise, exclusions generated from CAR31 licencing will also reference certain MEAs which need to be completed to have the exclusion lifted (this is not the full story regarding exclusions, but many will be familiar with the term “MEA”).

Now, it is important to understand that to satisfy CASA for the grant of a licence, CASA is only really interested in the practical side (performance evidence) from the specified “MEAs”. As far as CASA is concerned, the theoretical requirements for issue of a licence are covered by the CASA Part 66 Modular exams. In short, presenting CASA with the appropriate modular examination results and correct selection of “MEA” units (both as outlined in the MOS) will result in the granting of a licence outcome, assuming other aspects are met (i.e. time-based experience requirements, etc).

The trouble here is that a UOC (“MEA”) cannot be issued by an RTO unless it has been properly assessed, in accordance with the RTO standards. This includes assessing all knowledge evidence and performance evidence. The fact that CASA is only interested in the performance evidence for licencing does not change this VET requirement. In fact, the performance evidence by itself is meaningless, and a full UOC (“MEA”) can only be assessed as complete if both performance evidence and knowledge evidence are assessed in full. Full, in this case, means that all items specified in the UOC are assessed and that the candidate is deemed to be competent against all items (not only a percentage thereof). In fact, if you were to look up any MEA unit, you’ll see the use of such words as “all” and “must” when referring to the required parts of the evidence.

In summary of what “should be happening”. If someone intends to get a CASA licence, they will need to pass their appropriate CASA part 66 modular examinations (based on chosen category) and complete the relevant “MEAs” (based on licence category). To complete the relevant MEAs will require satisfying the performance evidence (through practical experience) and also satisfying the knowledge evidence of each UOC in full. 

It is worth noting that theoretical aspect is (should be) assessed twice. Once is done through the multiple-choice CASA modular examinations (which is effectively a limited sample of CASA mandated topics), and the second is through the knowledge evidence of each “MEA”, each of which must be assessed in full under the requirements of ASQA.

It is important to note that if someone is only after a Certificate IV in Aeroskills (with no intention of a licence outcome), they fall entirely under the VET sector and need only to complete the relevant “MEAs”. They are not, in any way, required to sit any CASA Part 66 modular examinations. So long as they satisfy the performance evidence (through practical work) and the knowledge evidence (through any means compliant with the RTO standards) of each required unit, they can be awarded the Certificate IV qualification (or any other VET qualification).

The Complication: We Have to Assess Theory Twice

The problem stems from the theoretical side needing to be assessed twice, once under CASA and once under ASQA (albeit with very different standards).

CASA mandates a very strict invigilated, assessment method. Specifically, this is the three-answer multiple-choice questions, averaged at 75 seconds per question, with a specified number of questions per module. The pass mark is set at 75%. In some modules, essays are also required. Note that, in almost every case, the number of questions is not enough to cover every single topic listed in the MOS. In fact, CASA really is only after a knowledge sample, and are satisfied if at least 75% of the questions asked are answered correctly. 

ASQA, is very different in their assessment requirements. They require every single item listed in the UOC to be assessed, with a 100% requirement.

In fact, they do not specify “100%”, but merely state that the completed assessment is either “satisfactory” or “unsatisfactory”. A “satisfactory” result can only be achieved if the student is demonstrably competent against each item specified. Thus, the assessment requirements of evidence gathering are significantly stricter than from CASA. However, ASQA allows far more flexibility in the assessment methodology, including verbal questioning, open-book assessments, etc. Thus, the actual formal assessment procedure is significantly more lenient than with CASA. Nevertheless, as two different systems are involved, two separate assessment processes need to be satisfied.  

So Then, How does Aircraft Engineer Licencing work Today in Australia in Practice?

The eagerness to “do away with too much assessment” has led to training organisations choosing to use the CASA based modular examinations to cover the knowledge evidence requirements of the UOCs.

In other words, the CASA based examinations (compliant with the requirements of the Part 66 MOS) are used in an attempt to satisfy the requirements of the ASQA assessment standards. This is in breach of the VET regulations for several reasons:

• CASA does not require all items to be assessed, while ASQA does require assessment of all items.
• CASA deems 75% to be a “pass”, whereas ASQA requires competency to be achieved against all items.
• There are many cases where topics listed under a UOC are not covered by a CASA module.

To provide a direct example, let us turn to MEA148, “Apply mathematics and physics in aviation maintenance” (Reference: https://training.gov.au/Training/Details/MEA148). A training organisation may choose to use “passes” in CASA Modules 1 and 2 to provide the necessary “knowledge evidence” for MEA148. 

Let’s then compare the items from the knowledge evidence of MEA148 which directly correlate to CASA Modules 1 (Mathematics) and 2 (Physics). The eleven parent topics listed are:

• Arithmetic
• Algebra
• Binary and other applicable numbering systems
• Logarithms
• Geometry
• Trigonometry
• Matter
• Mechanics
• Thermodynamics
• Optics
• Wave motion and sound

If you consider all the topics listed (accounting for child topics), at a conservative count, there are at least 150 topics or sub-topics which are stated in the UOC. Under the rules of assessment from ASQA, you would expect at least 150 questions to be correctly answered to satisfy this knowledge evidence. In some cases this may be more (since one question may not be sufficient), but even for argument sake, let’s leave it at 150.

Now compare that to the requirements for the total evidence provided from a CASA Module 1 examination (total of 32 questions) and CASA Module 2 examination (total of 52 questions). Even if a student were to achieve 100% in both these CASA examinations (total of 84 questions), it would still be impossible to satisfy the ASQA assessment requirements of the UOC. Furthermore, CASA only requires 75% for a pass, which equates to 63 correct out of 84. Thus, a “CASA pass” in each module could provide evidence for as few as 63 of the 150 topics required under ASQA – i.e., a little over one third of that which is required by ASQA. 

A further problem: The ‘Cert IV Pass’

A further problem, compounding the misunderstanding in industry is the so-called “Cert IV pass”, incorrectly endorsed by some training organisations. There is false (and unfortunately widespread) information which suggests that achieving at least 50% in a CASA examination is adequate to satisfy the knowledge evidence of the UOCs for a Certificate IV.

Consider a Certificate IV in Aeroskills (avionics) (MEA40618 – https://training.gov.au/training/details/MEA40618?tableUnits-page=1&pageSizeKey=training_details_tableUnits&pageSize=100&setFocus=tableUnits) which requires MEA148.

As shown above, there would be at least 150 topics to be assessed. Now consider that a student has achieved 50% in each of CASA Module 1 and Module 2 (i.e., “Cert IV Passes”). They have therefore answered 42 questions correctly out of the 84 required by CASA. Yet, they have only answered 42 questions correctly out of the 150 required by ASQA. This is only a little more than one quarter of the required total. There is no way that either of the above two scenarios can be considered compliant under any circumstances. 

What’s the best solution to the complexity of AME Licencing in Australia?

Why the question mark? Well, this is a potential solution.

There may be others which could be even more effective. But the most important criteria, irrespective of the solution chosen is that compliance is met under both CASA and ASQA regulations. Let’s consider a compliant solution to MEA148 and CASA Module 1 & 2 scenario mentioned above.

Complying with the CASA regulations is relatively simple. As outlined above, the candidate would need to complete the CASA modular examinations in module 1 and module 2, achieving at least 75% in each.

Complying with the ASQA regulations would require that the candidate is assessed against all the knowledge evidence and practical evidence as outlined in the MEA148 UOC. The practical evidence will be achieved through experience in the workplace, with documented evidence provided by the candidate. The knowledge evidence can be demonstrated by an ASQA compliant specific workbook type assessment in which all UOC knowledge evidence criteria are addressed. This may seem like significant workload but remember that the assessment requirements mandated by ASQA are significantly more flexible than those of CASA. A typical workbook-type assessment could be open book and untimed, allowing the candidate ample opportunity to thoroughly work through the UOC assessment criteria. 

Some may argue that this is over-assessment, as the same (or related) content is being assessed twice (once under CASA and once under ASQA). This is indeed true, but it is also a requirement. So long as the two independent authorities set their own rules of assessment, both need to be met. Furthermore, a counterargument to the over-assessment is in that the CASA assessment requirements are by no means exhaustive. Rather, CASA is after a “sample set” which may, in many cases, completely miss certain topics. This is essentially under-assessment. Under ASQA, however, complete topic assessment is mandated.