National Qualifications Framework

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National Qualifications Framework
30 July 2008
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CATHOLIC INSTITUTE OF EDUCATION
July 30/08
INTRODUCTION

The CIE would like to thank the Portfolio
Committee on Education for the opportunity make a
submission on the National Qualifications
Framework Bill 2008   CIE supports the aims of
redesigning the National Qualifications Framework
and recognizes the gaps in the current framework
which have acted as barriers to transformation in
skills development.   We note that all these
amendments will require adequately funded
councils in order to make the National
Qualifications Framework operate. We are
concerned that the Bill before Parliament does
not include the amendments to the GENFETQUA act
which were part of the earlier departmental
public participation process.   We will use this
opportunity to raise substantive questions while
also providing Motivations for amendments.
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CATHOLIC INSTITUTE OF EDUCATION
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GENERAL

Catholic Institute of Education The CIE is the
Education associate body of the Southern African
Catholic Bishops Conference. It directly serves
350 Catholic schools and also provides services
to the public schooling sector as a whole.
Currently Catholic Schools educate 170 224
learners and employs 6225 Educators. We are
committed to providing quality education that
produces qualified and skilled South
Africans. 21 Skills training centres are linked
to the Institute. Some of the larger centres have
trainer over a 1000 learners since
1997.   Overriding Concern The NQF in its present
form has not addressed the countrys skills
needs. Will the new framework go further to
address these needs? The Framework Bill is in
danger of rearranging the current framework and
responsibilities without providing clearer
mandates to authorities. It meets the objectives
in s2 of organisation and governance of the NQF
but is rather lacking on the point of further
developing the NQF.
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GENERAL
We would recommend that further consideration is
made to looking at designing a National
Qualifications Framework (NQF) for lifelong
learning.   Motivation The current framework
bill does not explicitly state this and when
compared to international developments in NQFs
this may potentially be a shortcoming for South
Africa.   A means for the measuring the volume
of education and training required to achieve the
national standards must be created. We would
recommend that the concept of notional education
and training time be adopted within a relatively
flexible framework.   Motivation Adopting a
notional education and training time for
measuring volume, we hope to see real
developments in the field of recognising prior
learning.   Design rules (rule of combination)
are recommended as a way to govern the structure
of the qualifications.   Motivation This would
provide the framework with a template for the
combination of individual national standards into
part qualifications and full qualifications and
will allow learners to diversify their knowledge
and skills base.
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CATHOLIC INSTITUTE OF EDUCATION
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CONTEXT AND CHALLENGES
Transforming an education system which was very
divided and unequal was a mammoth task, perhaps
more mammoth than we ever imagined. Bringing
about equity and improving school quality have
therefore been key imperatives of education
policy in South Africa. The intervention
efforts that have been made thus far, have done
away with the racially differentiated system, but
reproduced a class differentiated system, where
socio economic factors have become a major
determining factor of the quality of education
for the schooling system. In other words, the
quality of education for the poor still remains
poor.
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CATHOLIC INSTITUTE OF EDUCATION
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CONTEXT AND CHALLENGES
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CATHOLIC INSTITUTE OF EDUCATION
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CONTEXT AND CHALLENGES
It is increasingly clear that the outcomes-based
curriculum reform, which we initially embraced so
enthusiastically, did little to enhance quality
in the system. South Africas economy is
stronger now than at any time in the past 20
years. It expanded by about 5 in 2005, and has
continued to grow at around 5 a year over the
period. Up until fairly recently business
confidence has been strong. The shortage of
skilled workers is a major challenge to economic
growth in South Africa. Closing skills gaps,
improving equity, and achieving greater labour
market efficiency and higher levels of
productivity underpinned the national
qualifications framework. But this has not
workedto date.
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HISTORICAL CONTEXT
The NQF was introduced as a key mechanism for
overhauling the racially divided and unequal
apartheid education system. It was introduced
through the first piece of educational
legislation passed after the advent of democracy
in South Africa. The South African
Qualifications Authority (SAQA), the body
established to implement the NQF, explains that
it was intended to completely transform the
disparate education and training system. The
NQF had very broad support across the political
spectrum and was strongly associated with the
transition to democracy, being symbolic of the
development of a single education system for all
South Africans.
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HISTORICAL CONTEXT
At the heart of the construction of the NQF has
been the desire to take an integrated approach to
education, training and skills development in a
variety of settings, including formal education,
training and skills development institutions and
the workplace. Despite this broad consensus,
and the aims associated with the NQF in South
Africa, the policy has been a failure. Within a
very short time period indeed, signaling
government awareness that the approach seemed not
to be working. In 2002 and 2003, two different
government teams tabled proposals to make
substantial changes to the national
qualifications framework.
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NQF REVIEWS (2001 2003)

• Stakeholders, including the sponsoring
  government departments made representation which
  included the following concerns
• The proliferation of NQF bodies and structures
  especially for standards generation of quality
  assurance, leading to confusion and duplication
  of effort and responsibility.
• The architecture of the NQF, embracing policies,
  regulations, procedures, structures and language,
  is experienced as unduly complex, confusing, time
  consuming and unsustainable.

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CONTEXT AND CHALLENGES
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NQF REVIEWS (2002 2003)

• Denudation of Governments authority over NQF
  policy and regulations leading to conflict
  between some stakeholder interests and confusion
  over Government policy.
• Misplaced application of the stakeholder
  principle leading to failure to give experts in
  qualifications design and quality assurance their
  due.
• Lack of recognition of the diversity of
  approaches and practices within the education,
  training and skills development system resulting
  in the design of an NQF architecture with a one
  size fits all approach.

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WHAT THE NQF BILL DOES

• The authority of government over all NQF
  statutory agencies has been affirmed.
• The current system of standards generation and
  quality assurance has been reviewed and
  streamlined within three Qualifications and
  Quality Assurance Councils (QCs).
• Education and labour market interests,
  independent occupational and professional bodies,
  need to be appropriately represented by experts
  and knowledgeable individuals on the bodies
  responsible for standards generation and quality
  assurance.

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WHAT THE NQF BILL DOES

• There is recognition that various forms of
  learning are required in an integrated education,
  training and skills development system. The
  balance of the various forms of learning will be
  determined by the purpose of the qualification.
  Quality assurance and accreditation of providers
  and assessment should be based on the mode of
  provision required for each form of learning.
• Standards of occupational or professional
  competence required for registration by, or
  membership of, a recognised occupational or
  professional body are the business of that body
  in terms of its own rules, Act or international
  convention, and these requirements should advance
  NQF objectives. NQF structures will foster close
  collaboration with occupational and professional
  bodies in order to advance NQF objectives and
  achieve compatibility with NQF standards.

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COMMENTS ON DEFINITIONS
We recommend replacing the definition of learning
with lifelong learning means the acquisition of
appropriate education and training over the
lifetime of persons of all ages and circumstances
to fulfil their personal social and economic
potential.   If the above recommendation is
accepted, we would then add the following
definition Education and training means the
instruction of knowledge, understanding, values,
skills, competence and experience.   In recent
legislation such as the Child Justice Bill,
Parliament has moved away from using the term
Minister. Instead they have opted to use the
member of cabinet responsible for ..., we are at
the moment not for or against this move but would
like to raise this as a consideration for the
drafters of this Bill. If the term Minister of
Education is not being used, then this Bill
should read the Member of cabinet responsible for
Education and the Member of cabinet responsible
for labour. We would recommend that the
definitions read   MOC Education means the
Member of cabinet responsible for Education MOC
Labour means the Member of cabinet responsible
for Labour.   Motivation This is necessary to
avoid further amendments to the Act if government
leaders change the structures of government and
the departments.
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CATHOLIC INSTITUTE OF EDUCATION
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COMMENTS ON THE PREAMBLE
Comments on the Preamble and Explanatory
Memorandum   We would recommend that the first
paragraph be changed to read WHEREAS the
advancement and recognition of lifelong learning
is an essential attribute of a free and
democratic nation and a prerequisite for the
development and well-being of its
citizens.   Motivation We would recommend that
lifelong learning is the focus to ensure that the
framework is internationally comparable.
Literature on international framework in
particular the Scottish Credit and Qualifications
framework and the European Union NQF are both
based on the recognition of lifelong
learning. There is a need to provide clarity in
legislation that lifelong learning is the goal
and not just learning as defined presently. There
are many opportunities to be gained from adopting
a lifelong learning approach. (Belgium example)
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CATHOLIC INSTITUTE OF EDUCATION
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COMMENTS ON THE BILL
We would recommend rewording the following
clauses as follows.   5(3)(b) ensuring that South
African qualifications meet appropriate criteria,
are internationally comparable and regionally
integrate-able and   Motivation This is
recommended in order to ensure that South African
skills are interchangeable with skills in the
region to ensure social mobility.   28(k)(i)
conduct or commission and publish research on
issues of importance to the development and
implementation of the sub-framework in
consultation with the Minister Or Member of
cabinet responsible for   Motivation Certain
quality councils have in the past taken on
research functions which have been questioned in
terms of the potential for duplication. By the
departments admission some of the research
undertaken by a QC were in effect unnecessary as
a similar study was being conducted by the
department. In addition to this research is
conducted in Universities which receive public
funding and these should be integrated into the
considerations for this framework. We would not
recommend that councils conduct no research but
rather that in consultation with the Minister
councils are able to identify gaps in research
and where research is already being done, partner
and work with the relevant body.
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CONCLUSION
We thank the Committee for the opportunity to
make comments to the Bill and hope that these
recommendations are both useful and acceptable.
We recommend that the committee seek clarity from
the department if the current Higher Education,
Skills development and GENFETQA Acts define the
quality councils in line with this Act. Where
amendments are necessary to these Acts, these
should come before Parliament. Our long road to
transformation has only begun. One alternative is
for us to remain prisoners of our history, the
other is to become agents of its making.
Transformative leadership is needed to help us
acknowledge our dilemmas openly, and inspire us
to transcend them. - Mamphela Ramphele (Laying
Ghosts to Rest.)