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Occupation-directed training: proposed changes in the DHET Green Paper
Mon, 16 Apr 2012 16:02
Article by Suzanne Hattingh
The Department of Higher Education and Training (DHET) published three documents for public comment that contain far-reaching proposals for training for workplace competence:• Green Paper for Post-School Education and Training (published on 11-01-2012)
• Government Gazette on changesto the SETA Grant Regulations governing the skills levy
(12-01-2012) • Government Gazette on the Proposed Qualifications Sub-Frameworks for General and Further Education and Training, Higher Education, and Trades and Occupations (23-12-2011)
The Green Paper gives a critical and very frank appraisal of the skills development system. It confirms the weaknesses and concerns that have been raised by informed commentators over a number of years. Employers and most key stakeholders should welcome the proposals in the Paper, which aim to remove bureaucratic obstacles and streamline processes to enable all parties to focus on developing the skills required to support economic growth and job creation.
2. Purpose and content of the article
The purpose of this article is to inform employers, training providers and interested parties about the proposed changes and to encourage critical engagement on crucial issues that affect workplace-based training.
This article highlights key issues in the Green Paper relating to the education and training (E&T) of employed people in the workplace context that generally happens in the environment of the Sector Education and Training Authorities (SETAs). The article also makes recommendations on streamlining processes and improving implementation. The DHET will consider the comments received from key stakeholders and the public on the proposals in the Green Paper to develop the White Paper, and where required, approved changes will be captured in acts and regulations. (Page numbers in the Green Paper are provided for easy reference and indicated as [GP].)
The article covers the following areas:
• Improving access to post-school E&T
• Strengthening FET colleges and private public partnerships, and creating Community E&T Centres
• Refocusing and improving the SETAs
• Prioritising PIVOTAL programmes
• Changes to discretionary and mandatory grants
• Simplifying and improving quality assurance
• External assessment to streamline assessment processes
• Changes to requirements relating to the NQF alignment of training.
3. Improving access
The central theme of the Paper is improving access to and success at post-school learning sites, and strengthening bridges to the world of work in order to address the needs of the youth who are not employed or in some form of E&T. (A 2007 study found 2.8 million people between the ages of 18 and 24 in this situation, which has since worsened due to the economic slowdown [GP 4]). The bleak future for millions of young people has serious economic and social consequences for South Africa. Quality learning that develops workplace competence will assist in addressing these critical needs and contribute towards economic growth and social development.
4. FET colleges, Community E&T Centres and private public partnerships
Further Education and Training colleges must be strengthened and expanded so that they can play a greater role in addressing the need for post-school E&T. Own experience in capacity building of FET colleges across the country confirms the assessment in the Paper that “FET colleges are varied and diverse but, with some notable exceptions, they are mainly weak institutions” [GP 10].
The DHET has established a task team to study alternative institutional forms to address the needs of out-of-school youth and adults, in the form of Community Education and Training Centres, which would absorb the Public Adult Learning Centres. Such institutions should facilitate lifelong learning in communities, and offer routes to enable the development of skills, including literacy and numeracy skills [GP 31-32].
The DHET also recognises the contribution of private providers in increasing the participation rate in post-school E&T and developing scarce skills. The Paper argues for greater and better alignment and partnerships between the private and public sectors, albeit within a clearly defined regulatory framework [GP 49-50].Comments/recommendations:
• FET colleges should play a crucial role in skills development, especially as many are located close to previously disadvantaged communities. The Paper recognises the need to improve the management and teaching capacity of colleges [GP xi]. Corrective action requires a multi-faceted approach that also includes improving the quality and workplace relevance of training, and increasing the ‘market value’ of college qualifications. Relationships with industry must be improved to encourage employers to provide opportunities for workplace experience to learners and to increase the employment rate of college graduates.
• Private providers should accept the invitation from the DHET to form alliances with FET colleges to strengthen their capacity and to create win-win partnerships.
5. Refocusing and improving the SETAs
The Paper stresses the need to improve the efficiency and effectiveness of the SETAs to ensure that training provision is directed towards identified sector, cross-sector and occupational needs. Their role in skills planning must be expanded to focus more on labour market analysis in order to improve the match between the supply of E&T and labour market needs. The SETAs have to play a stronger role in improving the articulation between educational institutions and the labour market.
They should encourage, facilitate and fund private sector employers to provide workplace-based learning, especially through apprenticeships, learnerships and internships. SETAs should also do more than currently to monitor and evaluate the impact of skills interventions in their sectors [GP 63].Comments/recommendations:
• These improvements to the SETAs will be widely welcomed. Refocusing them on the priority areas described will hopefully also reduce the bureaucratic red tape that most SETAs have subjected employers and training providers to.
• There have been many calls over the years for uniform SETA processes and requirements, as the diversity frustrates employers and training providers who often have to work with more than one SETA. The DHET should promote uniformity among the SETAs, where reasonable. Current best practices among SETAs should be identified and adopted by all SETAs.
6. PIVOTAL programmes
The Paper prioritises Professional, Vocational, Technical and Academic Learning programmes, which are a key pillar of the National Skills Development Strategy (NSDS III). PIVOTAL programmes lead to an occupationally-directed qualification and are delivered by a college or university – and must include supervised practical learning in a workplace. These programmes will require a model of cooperation between a SETA, a higher or FET institution and an employer to ensure that curricula and courses are relevant to labour market needs [NSDS III, par. 3.1].
Examples are apprenticeships, learnerships, internships, skills programmes, as well as professional placements, work-integrated learning and work experience, provided that they result in qualifications.
The Paper requires SETAs to ring fence 10% of mandatory grants for such programmes to encourage employers to provide work-based opportunities [NSDS III, par. 4.2]. Government departments and state-owned enterprises are also required to improve their role in on-the-job skills development, especially in learnerships, internships and work experience for graduates.
• Comments: Employers must take note of the clear message from DHET regarding on the prioritisation of PIVOTAL programmes leading to qualifications. SETAs will be directing their funding accordingly. The draft SETA Grant Regulations provide details on the PIVOTAL grant and requirements for reporting on such programmes [par. 9 and Section E: PIVOTAL Training Report].
7. Discretionary grant
The Paper proposes that the discretionary grants paid by SETAs from the skills levy should only be paid for programmes that lead to a full qualification or an occupational award; they should not be paid for short courses or for the provision of a limited number of unit standards that do not lead to a qualification or award.
In addition, a defined minimum percentage of the discretionary grant should be made available to support public providers (mainly colleges and universities of technology) so that they can offer occupational qualifications and awards. This grant could also be paid for workplace experience that is required as part of a qualification or after completion of a qualification, e.g. for internships [GP 66].
The suggestion in the Green Paper on reducing the mandatory grant has already been incorporated into the draft SETA Grant Regulations of 12 January 2012, which reduce the mandatory grant paid to employers for submitting their Workplace Skills Plans (WSPs) from 50% to 40% [Grant Regulations, par. 4(3)].Comments/recommendations:
• Employers will only be able to get more than the 40% mandatory grant if they implement PIVOTAL programmes and/or provide work experience opportunities to access discretionary grants. Employers should still be able to access discretionary grants for ‘short courses’, but only if they are building blocks towards a qualification or occupational award. (The Government Gazette on the Qualifications Sub-Framework for Trades and Occupations [par. 26] proposes two types of qualifications in the Occupational Qualifications Framework: National Occupational Qualification (a full qualification of 120 or more credits) and National Occupational Award (from a minimum of 25 to a maximum of 119 credits).
• While the DHET focus on qualifications is understandable, the reality is that short courses are generally more appropriate for building the competence needed to perform specific work processes. Employers can continue to implement them, but can only access the grant for unit standards-aligned programmes. The Green Paper agrees that many such short programmes “have meaning and value in the workplace ... (and) must be recognised, perhaps as occupational awards ... or as part qualifications, and our system of occupational awards must have space for this type of programme” [GP 74]. The requirements for occupational awards and part qualifications should not be so rigid that they do not allow for customisation of short programmes for unique workplace contexts.
• One of the unintended consequences of the Paper’s emphasis on qualifications is that it will further encourage employers to artificially align training to qualifications – simply for compliance sake. This practice is exacerbated by the B-BBEE codes that enable employers to achieve higher scores for implementing learnerships and other programmes leading to qualifications. Unfortunately, an estimated 80% of employers who attend workshops on implementing learnerships have no real commitment to learnerships. They simply implement learnerships for B-BBEE points, resulting in programmes with limited value for learners and the employer.
• Employers and training providers should take note of the importance of structuring short programmes as building blocks to a qualification, as has long been encouraged by SAQA and most SETAs.
8. Mandatory grant
The changes proposed in the Paper to the mandatory grant are aimed at ensuring that the WSP and Annual Training Report (ATR) reflect real priorities and trends, and ensure more reliable data on skills and skills development [GP 65]. The ATR should not be assessed against the WSP, but should indicate all the training that has taken place in the workplace (whether SETA-funded or not).
Employers should get the mandatory grant if their WSP and ATR contain comprehensive information on the company and the training planned and delivered. The grant will no longer be used as a ‘steering grant’ towards SETA priorities or NQF-aligned programmes [GP 66]. These changes have already been incorporated into the WSP/ATR templates in the draft SETA Grant Regulations, which no longer require employers to indicate whether training is aligned to the NQF.Comments/recommendations:
• The changes to the WSP/ATR templates are welcomed as the accuracy of the data provided by employers in the current templates is widely questioned. Employers generally take a compliance approach to these reports and often distort information to present a picture that is favourable to the SETAs in order to qualify for grants. Furthermore, most SETAs do not have the capacity or expertise required to scientifically analyse the data provided. The proposed changes should encourage employers to focus the training of staff on business priorities rather than on SETA or national priorities, especially since the column for indicating information on NQF-alignment has been removed from the templates in the draft Grant Regulations.
• DHET should ensure that these forms are as simple as possible, and must discourage SETAs from overburdening employers by requiring additional information. All SETAs should be required to provide shorter templates for organisations with less than 50 employees as some SETAs already do. These changes should contribute to improving the submission rate that has generally been unacceptably low.
9. Quality assurance
The Paper strongly criticises the quality assurance system of the SETA Education and Training Quality Assurance bodies (ETQAs) for contributing towards a ‘compliance’ culture that focuses on quantity and throughput rather than on learning and impact [GP xiii]. “... there is serious doubt that the quality assurance bodies have improved the quality of provision ... In many cases quality assurance by SETAs has been reduced to meeting bureaucratic compliance requirements that have little to do with the quality of provision ... The almost complete absence of monitoring and evaluation within the system has made it very difficult to identify and address shortfalls. The perception is of a system that continues to repeat errors on a regular basis” [GP 65].
The Paper indicates that “SETAs will continue to play a defined role in quality assurance” [GP 64], but reminds us that the NQF Act of 2008 repealed the regulations under which SETAs were accredited to conduct quality assurance [GP 17]. The newly established Quality Council for Trades and Occupations (QCTO) will have overall responsibility for quality assurance in the sub-framework for trades and occupations, assisted mainly by professional bodies .Comments/recommendations:
• The intention to streamline the quality assurance system will be widely welcomed. The ETQA function should be removed from the SETAs to allow them to focus on the areas described in point 5 above. If the SETAs retain a quality assurance function, it will perpetuate their bureaucratic approach and the proliferation of diverse systems as SETAs (unconvincingly) argue that they need unique systems to accommodate sector differences.
• This recommendation is in line with the statement in the Paper that the central problem is that SETAs are expected to do too many things, and this “has led to a tendency to lose focus on areas of critical importance within their sector and their mandate. Various pieces of research have established the problems with this, and it is clear that SETAs, in the main, support the idea of a consolidated mandate” [GP 63].
10. External assessment
The Paper proposes strengthening external assessment systems for national qualifications as a priority to “substantially reduce the need for detailed accreditation processes of providers” [GP 77]. The Paper is highly critical of the complex quality assurance system that requires provider accreditation, registration of assessors, constituent assessors and moderators, as well as verifiers – all essentially quality assuring the achievement of the same learning outcomes, but with results that are often “of questionable value” [GP 17].
The Paper foresees that the QCTO will use external assessment as an indicator of poor performance, and then investigate institutions where learners consistently perform poorly, followed by remedial or capacity building measures where required [GP 78].
• Comment: The Paper’s recognition of the “questionable value” of the quality assurance system of the ETQAs will surely be welcomed by all – except those who have made a living from maintaining the multi-layered system.
11. NQF alignment
The Paper clearly promotes the view that not all training has to be aligned to the NQF, lead to qualifications, or be delivered by accredited providers [GP xiii]. The Paper states that training does not need to be rigorously quality assured if it is meeting the needs of learners, employers, government departments or other organisations [GP 16].
“No providers should feel compelled to develop programmes against unit standards, nor should any quality assurer require their use” [GP 74]. “Only providers offering national qualifications or (occupational) awards should have to be registered.
Government departments must also be made aware that alignment with unit standards is not a requirement for training, as this appears to be a common misconception” [GP 36]. The Paper acknowledges that “unit standards tend to fragment knowledge and militate against the coherence necessary to address the mastery requirements of specific professions” [GP 16].Comments/recommendations:
• This is a welcome approach as many problems are experienced around NQF alignment: for example, when there are no unit standards, or available qualifications/unit standards are not relevant to the required workplace competence, or where the learners are interested in acquiring the practical skills but not the credits. Artificial alignment to satisfy bureaucratic accreditation requirements over-burdens learners with paper work and increases the cost of training, without building the desired workplace competence. Other consequences are the distortion of provision in order to meet unit standard requirements, and programmes that develop competence in unit standards rather than competence in job performance.
• The SETA and donor conditions for funding only unit standards-aligned training have made it difficult for many developmental and community projects (e.g. child welfare and HIV/AIDS organisations) to obtain local and international funding. All stakeholders should support the call by DHET that strong signals must be sent to government departments and donors that not all training needs to be aligned and vigorously quality assured.
12. Concluding comments
All stakeholders, especially employers, are encouraged to engage with the issues raised in the Green Paper and to submit comments to the DHET by 30 April 2012. It is hoped that the Department will be bold enough to support the many positive recommendations in the Green Paper aimed at improving the quality and relevance of education and training to the benefit of learners and employers, and ultimately the economy and the broader society.