Response by the South African Qualifications Authority to the

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Recognition of Prior Learning

Very lit tle is sa id about RPL ex cept that the d epartments agree tha t it needs approp riat e incent ives and a ssessm ent procedures. There is mention made of SAQA’s RPL policy, in relation t o the Short Courses on page 36, i.e. …short course learnin g may be a valuable route to the acq uisit ion of cred it s t owards qualifications regist ered on the NQF through t he Recognition of P rior Learnin g(RPL). QCs will need t o encourage t heir aligned ETQAs to fashion RP L prot ocols relevant to their sect ors on the basis of SAQA’s RPL policy. This seems t o point t o agreement with the principles and approach of the S A A RP L policy. Q The Criteria and Guideli nes document for t he implem ent ation of RP L is mentioned in the footnot e on p.34, linked to t he stat ement ind icated in 1.1 abov e. There is no clarity on whether RPL will b e und erta ken only for ‘a ccess’, (i.e. adv anced standing, placement, et c) or for ‘credit and certificat ion’. T he form er seems to b e the case if one accepts t he follow in g extract from t he Consult ative Document: …but also assisting learners to nav igat e the articulat ion column in ord er to p rogress in a lea rning pat hway or across pathways. This also d oes not ta ke int o account the RPL already is and will continue to be und ert aken in t he w orkpla ce – for cred it a nd certificat io n of those parts of t he qualification or where app ropriat e, t he whole qua lificat ion where learners meet t he req uirement s. There is n o statement as to who shoul d take respon si bility for drivin g the systemi c i mplementation of RPL. There i s also n o discussion of incenti ves or funding to su pport implementation. Leadership in relat ion t o RPL implem ent ation is key to it s successful implementation. I f there is agreement ,

42 then syst emic solut ions for implem ent ation problems must be thrashed out , including possibly looking at regionalisa tion of RPL services, subsidy arrangement s for public inst itut ions, target ed funding for project s, ca pacity buildin g at career centres of the DoL. S A A is committed to ensurin g that Q through these st atement s the two departm ent s on RP L a re not just paying ‘lip- serv ice’ t o the object ives of the NQF and that ad equate consid eration is given t o the imp lem entat ion issues at the next level t o ensure a cost-effective and sustainable syst em of RP L a cross sect ors and bands. The two major prob lems for imp lementation are indicated. (a) Policy incoherence and la ck of implementation

Despit e the fact that the current legislat ive framew ork prov ides for RPL implem ent ation and that provision for RPL is sp elt out in the v arious act s, it is evident that imp lem entat ion is limit ed. The legisla tiv e fra mework is indicat ed in t he following: (i) A Programm e for the T ransformation of Higher Educa tion, number 3 of 1997: • “The higher education system must be t ransformed t o red ress past inequa lities, to serve a new social ord er, to meet pressing na tional needs and t o resp ond to new realities and opp ortunities” (p .2). • “The Ministry (of Education’s) vision is of a t ransformed, democrat ic, non-ra cial and non-sexist system of higher education that o Promot e[s] eq uit y of a ccess and fa ir cha nces of success to all who are seeking t o reali se their p otentia l t hrough higher educat ion, w hile erad icating all forms of unfair discrimination and advancing red ress for past inequa lit ies” (p. 5). • “The M inistry (of Education) strongly sup port s d ev elopm ental work and pilot p rojects w hich will help instit utions t o d evelop criteria t o assess

43 appli cants’ prior learning and experie nce, so that those w ith clear pot ent ial t o succeed in higher education can be admitt ed ” (p .15). (ii) The Further Education and Training Act (No 98 of 1998) indicat es t he following: • “ Access to the FET band can be gained through the General Education and Training Cert ificat e (GETC) or eq uiv alent qualification corresp onding to NQF level 1, a s w ell as by other m eans, e.g. via recognition of p rior lea rning (RP L) p rocesses” (p.4). In sp it e of these p rov isions the follow ing fa ct ors hin der RPL implem ent ation. While som e inst itutions m ake every effort t o work a round these restrictions, others use them as rea sons for not implem entin g RP L: • The matriculat ion with endorsement as a blanket ent ry req uirement for all ent rants to higher educat ion, w ith lim ited options for ‘Senat e’s discretionary exemption’, but without clea r b enchmarks or guid elines as t o how HE p rov iders should go ab out t his is sue; • The 50% resid ency clause that requires of lea rners t o complete at least 50% of their qualification at a pa rticula r instit ution, regardless of w hether they meet the requirements for m ore (or a ll) t he crit eria for a qualificat ion. In a comment submitted t o S AQA rega rding t he Criteria a nd Guid eli nes for t he Implementation of RPL, Dr T erry Volbrecht of the Cape T echnikon made the point that he was surprised t hat the NS B regulat ions d o not seem to sup ersede t he old regulations gov erning entry t o further and higher educat ion. • The FET public sect or is silent on RP L implementation (except in the FET Act , 98 of 1998). • This is p roblemat ic a s 30,9% of p ot ent ial HET learners have achiev ed an FET qualification but hav e not ent ered H ET (2001,Stat s S A). The FET public sect or is still almost primarily relia nt on forma l examinations. Public FET instit utions do not aw ard q ualif ications, the DoE has that resp onsibility. T he DoE ha s not facilitated t he recognition of prio r learning for learners wanting t o a chiev e credits t oward s a Nat iona l Senior

44 Cert ificat e, a matriculation with endorsement certificate or even the old N3 certificate through alt ernative forms of assessment . Likew ise, U malusi has been silent on t his matter. • The HE in stitut ions, while seemingly unwilling t o underta ke RP L for ‘credit ’ and ‘certificat ion’, hav e found the nationa l academic and funding policies ‘w orking against’ RP L implementation. (b) I napp ropriat e funding, subsidy st ructures and the capa cit y building of resources and staff It is ev ident that these are p rov ided as reasons for not being ab le to implem ent RP L, part icularly in public institutions of lea rning.



Cen tre for the Evalu ati on of Edu cati on al Q ualification s (CEEQ)

The Consultativ e Document acknowled ges t he nationa l importa nce of the function of foreign qualification evaluation and hence the necessity for a bod y such a s CEEQ. It furt her indicat es that this is an appropriate function for S A A. It is reasonable t hen t o assume t hat the p rop osals that S AQA has Q alread y d ev eloped for ensuring the legal p rov isioning of CEEQ incorporat ed int o the legislativ e rev iew process. w ill be It is int eresting that t he

departmental task t eam did not see it s way clea r to acknowled gin g S AQA’s foresight in ensuring the preserv ation of this function when it beca me apparent tha t the HSRC w as no longer int erested in retaining it.

It is imperativ e that the jurisd iction and reporting lines of SAQA in terms of t he functions of CEEQ are clearly estab li shed. The relationship between the QCs and CEEQ and the processes for reaching a greement w ill need t o b e clea rly spelt out so t hat a situation d oes not a rise w here the ev aluations of CEEQ are disrega rded a nd hence und ermined at a different lev el. CEEQ has a considerable role t o p lay as a part ner in meet ing the objectiv es of the NQ F and hence in NQF processes. This role is expla ined in S AQA’s Strat egic Plan for the M TEF p eriod 2004 – 2007. The supp ort of the two departments and their act iv e advancement of this role w ould be necessary. S A A sees a s part of the future role of CEEQ that it rend ers supp ort to Q standards sett in g b odies in t he establishm ent of in ternationa l compa rab ility as part of the q ualifications design process. The exp erience a nd persp ective of CEEQ on the relationship between domestic and internat io nal qualifications is key to ensuring equiv alence of foreign qua lificat ion holders in the South African cont ext. This would entail the esta blishment of a formal relat ionship between the QCs a s co- ordinat ors of SGBs and S AQA. It w ould be help ful to know w hether t he two depa rtm ent s hav e considered this a sp ect of the w ork of CEEQ.


A 10-level NQ F bett er facilitates the ev aluat ion of foreign qualifications in that it creat es a b road er range of more specific equivalency options. However thousa nds of certificat es hav e been issued since CEEQ changed ev aluation form ats in 1999 t o b ear reference to the current NQF Levels of South African qualifications. Consid eration w ill hav e t o be giv en to how to address this problem. It ma y require that cert ificat es are re-evaluat ed . This has obvious resource implicat ions and could giv e rise t o legal issues. A further p oint that must be considered is that there has been instability for two years, resulting from the initial report of the NQF Focused St udy tea m which indicat ed a preference for a 10-lev el fram ew ork. This has posed a particular challenge to CEEQ in respect of reaching unambiguous ev aluation decisions e.g. whic h sp ecific consid erations underlie the decision to compa re a German Diploma w ith an honours and not a ma ster’s degree. Furthermore b ecause the numb er of lev els is not decided there are no clear, agreed level descript ors. Although different sets of level descript ors could be useful for the w ork of CEEQ, the extension of the dev elopm ent p eriod for these, as well a s for the conversion from eight to ten levels and the resulting re-peggin g of qua lifications, are likely t o have a problematic effect on t he work of CEEQ in t he int erim.



N ation al Learners’ Recor ds Database (NLRD)

The r ecognition of th e NLRD as a nation al r esour ce The Consultat iv e Document d oes acknow led ge the v alue of the National Learners’ Records Databa se (NLRD), stat ing t hat: this unique databa se must be progressiv ely maintained a s a national source of HRD d ata and an inv aluable reposit ory of information for use by a ll p art icipants in the national learning system. (pa ge 40) The NLRD is ind eed unique in that it is a large databa se t hat is complet ely operational and dynamic, funct ioning a s the elect ronic m anagement information syst em of the NQF. Its value in comm ent in g on the state of educat ion and t raining cannot be und er- estimated. The current focus is on the p opulation of the database and the d ev elopment of useful rep ort s, ba sed on that data. Already the NLRD has a record of all registered stand ard s a nd qualifications i.e. what is av ailable for learners in Sout h Africa. It ha s a subst antial numb er of lea rner a chievement s which is growing d aily a s records from ETQAs a re loaded. prov iders t oo is growing. S A A looks forw ard to the cont inuing ev olution of the NLRD as one of South Q Africa’s most powerful t ools in human resource dev elopm ent. The Consulta tive Document recognises that considerations of the fund ing of the NQF a re not rest rict ed t o the funding of S AQA but need to include all partners. In this respect, the Consultativ e Docum ent d oes not d eal with the implications of maintaining this nat iona l resource, remaining silent on t he allocation of ad equate resources t o the NLRD. The “data pa rtners” of the NLRD require urgent attention, if their capacit y is to be built t o the p oint w here they ca n supply the t yp e a nd qua lity of information that is need ed in order for the NLRD to fulfil it s mandate The list of accredit ed

48 completely. T his pa rticula rly ap plies t o the information that ETQ As, pa rticula rly SET As, supply t o the NLRD: m any of t heir IT syst em s a re not yet d evelop ed to the point where accurat e and complete in form ation can b e st ored, and t hus supp li ed t o the NLRD. Given that these are young structures, t his matt er, in most cases, is receiving the dedicat ed att ention of the mana gement of the SET As. In order for the data partners to receive the a ssist ance they d eserv e, urgent attention must b e paid to funding and allocat ion of human resource is sues to the NLRD at S AQA. T his also a pplie s t o t he furt her d ev elopm ent and maintenance of the database system itself: Release 2 of the NLRD will be implem ent ed w hen all of t he consu ltat iv e questions concerning t he next phase of t he NQF hav e been resolved e.g. 10- lev el fram ew ork. The NLRD will, as is currently the case, exa ctly mirror the shape and “business rules” of t he NQF. The quest ion of gathering a comp let e set of furt her ed ucation and t raining information also req uires att ention. T his includ es a cont inuat ion of t he init ial conversations that have alread y t aken pla ce between UM ALUSI and those managing FETMIS (at the Depa rtment of Education). The links between these organisat ions and the SETAs need s t o b e fully explored and responsibilities clea rly identified .



Resourcin g It was

The cr eati on of three qu ality assur an ce coun cils is not a new idea.

considered in the early debates on th e NQF and was rejected pri maril y becau se i t was consi der ed that it w oul d cr eate an unn ecessary layer of bur eaucr acy, adding to th e costs and complexi ty of the system. The concern a bout complexity seems t o hav e dim inished since the Consult ative Docum ent acknow led ges that the new proposals suggest a more complex syst em, in contra st to the int ended out come of the Focus Study T eam p rocess for a stream lined, (suggesting less complex) and strengthened syst em. How ev er t he concern ab out costs are st ill valid. S A A has considered t he costs of t he prop osed syst em. Q This a nalysis is

attached as Annexur e C. The intention is not t o debat e the a ccuracy of t he predictions but rather t o point out that cost s for the proposed system will be higher than is current ly t he ca se. Governmen t’s budget for SAQ A is n ot suffi cient to sustain SAQA’s curr en t acti viti es. The p rop osals do not suggest that a ny of the functions that SAQA current ly performs should not be perform ed but only that t hey should b e performed elsewhere. It is appar ent then th at the idea to distribute of th e fin an ces currentl y spent on SAQ A by govern ment acr oss th e system, to fin an ce oth er par ts of th e interdependent N QF system is unrealistic. functions will be necessary. Add itional commitment from gov ernment to financially resource those b odies that will be required to carry out these



Transitional arran gements

The at tention giv en to the d emands t hat will b e p laced on the t ransition and the transit ional arrangem ent s themselves is captured on less than a half a page of text on page 44 of the Consultat ive Document . Giv en the legal implications of the proposals (some 20 pieces of legislat ion will require cha nges), one would hav e exp ect ed a deeper consid erat ion of these implications and the t imefra mes required for the new concept s and complex relationships t o be fully und erstood and effectiv ely communicated before any meaningful changes can be mad e. It is als o approp ria te to d efine what S A A means by t ransitional Q arrangement s. The references to tra nsitional arrangements in the Consult ative Document seem to apply to the longer-t erm t ransitional arrangement s i.e. a fter the consultation period and final decisions a re mad e. SAQ A’s vi ew is that transiti onal arran gements sh oul d inclu de th e peri od of ti me between th e r el ease of th e Con sultative Document an d when decisi ons are finalised. Giv en the instab ility that was creat ed by the Focus Stud y rep ort and S AQA’s report of t he difficulties that resulted, it is unforgiv able that the depart m ental Task Team did not see its way clea r to try and stab ilis e the syst em by giv ing reassurances about how issues w ill b e managed in t he int erim, what structures will ma ke key decisions that hav e a long t erm imp act (t hese decisions cannot wait indefinit ely!) and who w ill d ea l w ith difficult ies and how . There is a sense that this team, like the Focus Study T eam, did not give any considerat ion to the impact of their recommendations and the consequences of radica l y different p rop osals on an imma ture syst em, let a lone on the morale of staff who are exp ected to continue d eliv ery of their legislative mandat e a nd at the same time, manage a n unstable syst em on a daily basis.

51 These proposals exacerb ate t he instability that is already rife. To take one examp le, there are a ccredit ed ETQAs t hat are non-sta tut ory b odies. These organisat ions have been through a monitoring, and in some cases, an auditing p rocess. As a result they are keen t o imp rov e their systems to ensure good q uality assurance pra ct ice. H owever t he proposal that non- stat utory bod ies should not b e ETQ As has now creat ed a p roblem for t hem! They a re exp ect ed as accredit ed ETQ A to fulfil t heir quality assurance funct ions whil e S at the same t ime, t heir future a s ETQ As is t hreat ened. or at w orse, t o hav e not a nticip ated. It is this kind of

uncertainty a nd inst abilit y that t he Task Team seems at b est, t o hav e ignored



An option for consi der ation

Throughout t he docum ent there are references that indicate t hat t he NQF is not at risk a nd that it is necessary for South Africans t o pla n for it s further dev elopm ent . Examp les of t his cla im are as follow s: • • The objectiv es of the NQ F env isa ged in the S A A Act , 1995 command Q overwhelmin g public supp ort and must b e upheld (pa ge 2) The next phase of NQF implement ation must build on the strengths of t he first phase (pa ge 10). The fina l p ara graph of the Consultat iv e Document acknow led ges that there hav e been t ensions a nd difficulties, caused p rima rily by the fact that S AQA and some ot her key stakeholders hav e been ex cluded from the discussions to date. There is t he re-assurance that “from now on all p rocesses connect ed with the transit ion must b e publicly know n and t ransa ct ed with full transpa rency.” (pa ge 44). S A A fully a grees that the inclusion of S AQA and Q key st a kehold ers in transit io nal pla nning is critical. Howev er before m aking any further decisions, we w ould a rgue that the time has come for a ll key rolepla yers t o sit around the t able a nd toget her • • Agree on the principles gov erning the ed ucation and t raining system that we want in the future identify what the real prob lems are that face the t ransformation a genda in educat ion and tra ining and not the perceived problem s that suit one or other a genda. In other word s let S AQA, which is t he mandat ed body resp onsible for the NQF and the b ody, w hich has the b enefit of ov ersight of the syst em as a w hole, provide an insight ba sed on direct experience. • • • debat e a nd decid e on exactly what the b est long t erm archit ecture should be clea rly out lin e t he role of each p layer in t he system discuss fully and pla n for the required resourcing for such a syst em

53 • plan t he t ransition and communicat ion strategy ca refully within realistic timeframes

We need to brin g closure to this thr ee- year r evi ew ph ase of SAQA an d the N QF. This is necessar y to en d th e poli cy uncer tai nty and resour cin g instability for SAQA an d the NQF. Gi en that t he NQF is not the only vehicle for v transformation of educat ion and training, it is necessa ry that the Depart ment s of Education and Labour work closely w ith S AQA t o exercise strategic leadership of the NQF implementation process. As the option presented here will require time (six t o tw elv e months) t o resolve the issues flagged and to reach decisions, it is im porta nt that the momentum that has b een achiev ed with the NQF is monit ored and speed ed up . This will r equire an agreed and funded NQF strategi c plan by th e Departments of Edu cation and Labour, and SAQ A to ensure that all th e r elevan t N QF processes dealin g with the national imper atives are working effectively an d efficien tly. Even when the final decisi ons are made, these will n ot be abl e to be i mplemen ted overnight. SAQ A will therefore have to be appropriately and adequ ately su pported and resourced over the tr ansitional period in the same w ay as in th e peri od leading u p to the fin alisation of the decisi ons.

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Description: Response by the South African Qualifications Authority to the