By Suzanne Hattingh
1. Introduction
The Department of Higher Education and Training (DHET) published the proposed Qualifications Sub-Frameworks for General and Further Education and Training, Higher Education, and Trades and Occupations in the Government Gazette on 23-12-2011.
This article only covers the sub-framework of the National Qualifications Framework (NQF) that deals specifically with trades and occupations. The proposals on the sub-framework have far-reaching implications for training for workplace competence, together with the Green Paper for post-school education and training, published on 11-01-2012.
2. Purpose and content of the article
The purpose of the article is to inform employers and training providers about the proposed changes and to encourage critical engagement on the occupational qualifications that will be registered on the sub-framework. Please keep in mind that the proposals in the Government Gazette on the sub-framework have not been approved by the DHET. (Paragraph numbers indicated are from the sub-framework document and page numbers in the Green Paper are indicated as [GP].)
The article covers the following areas:
? The role of the Quality Council for Trades and Occupations (QCTO)
? Occupational qualifications and occupational awards
? Three types of unit standards and part qualifications
? The work experience component of qualifications
? External assessment for the award of qualifications
? Documents with specifications for occupational qualifications
? Articulation and coherence in the NQF.
3. The role of the QCTO
The QCTO was established in terms of the Skills Development Act in 2008 to oversee the design, development and quality assurance of qualifications required for the practise of trades and occupations [par. 4 and 9]. The QCTO will perform the same role in relation to the Occupational Qualifications Framework (OQF) as the existing Quality Councils: Umalusi (for General and Further Education) and the Council for Higher Education.
? Comment: The rationale for the establishment of the QCTO is clear, but we should recognise the difficulty of getting new institutions, systems and processes fully operational - and for them to acquire legitimacy among key stakeholders.
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4. Occupational qualifications
The sub-framework introduces two types of qualifications to be registered on the OQF. The National Occupational Qualification will be the main qualification. It is a full qualification of 120 or more credits, and will be associated with a trade, profession or occupation (or specialisation within an occupation). Occupational Awards will be the second type of qualification in the OQF, with a minimum of 25 and maximum of 119 credits. Occupational qualifications will be based on occupations listed in the Organising Framework for Occupations (OFO), and could be on all 10 NQF levels [par. 29].
Comments/recommendations:
? The Green Paper recognises the need to develop trade and occupational qualifications that have currency in the labour market, but supports retaining existing qualifications: "(trade and occupational qualifications) should build on the existing trade test and apprenticeship system, as well as qualifications quality assured and certified by SETAs, which have gained credibility and respect ... the focus of the QCTO should be on consolidating qualifications offered by SETAs which have gained credibility, eliminating qualifications which have proved ineffective, consolidating one-year qualifications into more rational packages of qualification types, and developing new qualifications where necessary, especially for artisans' [GP 73].
? Introducing occupational qualifications with a unique structure is a very costly and disruptive solution to improving the relevance of existing qualifications for developing the competence required for workplace performance. A more feasible option would be to redesign existing and widely accepted occupational and professional qualifications, and to add components to build the desired occupational competence. We already have such models in learnerships/ apprenticeships and in the training of human resource, legal and other professionals, which require graduates to complete structured work experience in addition to their formal education.
? The learnership/apprenticeship model promotes the integration of knowledge, practical skills and work experience in a way that effectively builds occupational competence - if implemented correctly. A great deal of money and effort has been spent on developing learnerships based on existing qualifications, and it would be a massive waste if the good work that has been done is not incorporated into the sub-framework. Another major disruption affecting learnerships and apprenticeships would seriously undermine the confidence and participation of employers.
4.1 National Occupational Qualification
An example is the qualification with the full title: "National Occupational Qualification: Chemistry Technician (Chemistry Laboratory Analyst) Level 5?, with "Chemistry Technician? as the occupation, and "Chemistry Laboratory Analyst? the specialisation in that occupation [par. 26-27].
Comments/recommendations:
? It should be recognised that it will take some years for these new qualifications to gain the same status in the minds of learners, their parents/sponsors and employers who have come to value degrees with recognisable titles: Bachelors, Honours, Masters, etc. We should not make the mistake of assuming that because the occupational qualifications might be conceptually sound, they will automatically be valued and widely accepted by all interested parties.
? We must also accept that such a major change in the qualifications landscape will be resisted and viewed as disruptive by employers and other key stakeholders who have had to adapt their systems and processes to many changes in the skills development landscape since 1998.
4.2 Occupational Awards
The Green Paper strongly proposes retaining skills programmes that work: "There are well-recognised programmes based on unit standards - substantial skills programmes that have legal weight, and allow individuals to do specific work, such as work underground in mines, or do certain work in tourism and banking. These programmes have meaning and value in the workplace, and a lot of time has been devoted to them. They must be recognised, perhaps as occupational awards, and our system of occupational awards must have space for this type of programme' [GP 74].
Comments/recommendations:
? Skills programmes have become valued for building occupational competence and ways should be found to accommodate them in the OQF. The negative reaction from employers to changing things that work should not be under-estimated, particularly as the Green Paper recognises the critical importance of employer participation in addressing the country?s skills shortage.
5. Three types of unit standards
Occupational qualifications will be designed to include three different types of unit standards, i.e. knowledge, practical and work experience unit standards [par. 10]. Each type of unit standard must cover a minimum of 20% of the total credits of the qualification, with the remaining 40% allocated according to the need of the particular occupation or occupational specialisation [par. 35]. The knowledge and practical unit standards can be taught and assessed in an integrated way [par. 37].
Comments/recommendations:
? The QCTO qualifications model correctly recognises the three components of occupational competence as: conceptual knowledge/theory, applied knowledge and practical skills, and work experience. However, separating them into three different unit standards in occupational qualifications will inevitably lead to fragmentation. The learning towards these unit standards will generally happen in at least two entities, a training provider and an employer - and possibly a third provider specialising in practical skills training. We do know that learning is most effective if these three learning processes are integrated and occur close together. Separating the three components will make it more difficult to achieve the desired integrated learning experience that translates theory into practice to build occupational competence.
? Changes introduced in the design of qualifications must factor in the direct and indirect costs for training providers and employers - and inevitably for learners. This includes the design of new learning programmes aligned to the qualification, redeveloping learning materials, retraining facilitators to deliver the learning programme, retraining/reregistering assessors against new unit standards, and even changes to IT systems for record keeping. This will consume time and money that could be spent far more effectively on actual skills development.
? Contrary to the objective in the Green Paper that "the proliferation of unit standards must stop' [GP 74], the occupational qualifications model will increase the proliferation of new unit standards, while many of the more than 11,000 existing ones will remain active for many years.
6. Part qualifications
The curriculum components of each type of unit standard constitute "part qualifications?; for example, all the knowledge unit standards in a qualification would together be recognised as a "part qualification?. "Any one, two or three of these curriculum components can be separately, nationally assessed and certificated, in which case they will be registered on the NQF as part qualifications alongside the full qualification/s of which they are a part' [par. 46]. Other learning achievements that will be recognised on the OQF as part qualifications are National N-Certificates (N4-N6) (NATED or N-courses) and the Foundational Learning Competence prescribed for all occupational qualifications at Levels 3 and 4 [par. 47-48]. The NQF is already adapted to register part qualifications, as reflected on the SAQA website.
Comments/recommendations:
? There are practical benefits to "part qualifications? as it allows for one training provider to deliver only the knowledge unit standards, and another to cover the practical unit standards. However, the obvious disadvantage is the fragmentation of learning, especially if there are extended periods between the delivery of these "parts?. It could also create obstacles to learners who will have to find institutions where they can complete the different parts of the qualification. This will be particularly problematic if they cannot complete the work experience component. It will result in "partly qualified? learners who will be no closer to gaining employment than before enrolling for learning programmes. This is a very real possibility as current estimates are that "approximately 65% of students at colleges are unable to find workplace experience, which is required to complete N diplomas' [GP 26].
? The flexibility proposed in the separate assessment/certification of part qualifications seems positive, but could present practical problems when considering the following issues: Is it desirable to certify someone as competent in the practical unit standards, without requiring competence in the knowledge unit standards? Would this not be contrary to one of the key objectives of the NQF, i.e. to ensure that learners understand what they are doing and why? The same argument applies to certifying someone as competent only for the work experience unit standards. How can a person be competent in the work context, without the appropriate practical skills? Should the knowledge unit standards then always be included in all part qualifications? Creative solutions are needed to resolve these issues.
7. Work experience component of occupational qualifications
7.1 Work experience unit standards will make up at least 20% of each occupational qualification. (The percentage allocation is described in point. 5 above.)
Comments/recommendations:
? The importance of work-integrated learning is not disputed: "Most successful vocational or occupational learning takes place as a result of an integration of theoretical learning, workshop-based practical learning, and learning in the workplace' [GP 36]. However, including work experience as an integral part of occupation qualifications is likely to encounter numerous obstacles that are described below. An alternative approach would be to retain work experience as an essential component of formally recognised occupational competence - after achieving a qualification. This model is already used in the legal, engineering and other professions where the industry recognises the qualification, but awards professional recognition only after the completion of specified work experience. This approach would mainly involve adding a work-experience requirement to existing occupation-directed qualifications, thus avoiding the costly and time consuming work of developing new qualifications. This does not preclude the revision and refinement of existing occupation-directed qualifications to improve their workplace relevance.
? The occupational qualification model gives employers shared responsibility for the completion of qualifications. This is not their business. While large employers may have the motivation and internal capacity to oversee and assess the prescribed work experience, it is unlikely that medium sized and smaller employers will be willing and/or able to meet the requirements in the curriculum specifications for work experience.
7.2 Opportunities for work experience
Comments/recommendations:
? The DHET, SETAs, FET colleges, and learners in particular, recognise the great difficulties in finding employers who are willing to provide opportunities for work experience. This problem is likely to increase - despite the incentives through discretionary grants. For the majority of employers the overall cost in terms of production, manpower and time will simply outweigh the benefits of guiding and assessing learners in accordance with the curriculum requirements. This is even more so since they will now also have to meet "workplace approval requirements for the work experience components (and the) requirements for the assessment of the work experience component' that will be specified in the curriculum [par. 40].
? This will inevitably reduce the number of opportunities for learners to gain work experience, especially in rural areas, smaller towns and poorer areas where there is little economic activity and few employers willing/able to undertake this responsibility. Large numbers of learners will end up in a vicious circle: they cannot find employment because they do not have a qualification, but because they cannot complete the work experience unit standards, they cannot obtain an occupational qualification.
8. External assessment for the award of qualifications
All occupational qualifications will be assessed externally through an appropriate nationally standardised integrated summative assessment. The QCTO will issue occupational qualifications to learners who successfully complete these assessments [par. 42 and 49].
? Comment: This is a welcome change and should eliminate much of the current multi-layered assessment, internal/external moderation and verification processes in occupation-directed training.
9. Documents with specifications for occupational qualifications
Three documents are described in the sub-framework: the Occupational Qualifications Document, Occupational Curriculum Document and Occupational Assessment Specifications Document.
? Comments/recommendations: These documents do not promote the objective "to simplify the NQF where possible' [GP 73]. They also do not reflect innovative thinking on new ways of streamlining quality assurance; the documents essentially rephrased and regrouped components from the burdensome quality assurance processes created by the ETQAs. A critical review is needed to explore simplified alternatives to avoid costly and time consuming administrative and bureaucratic processes that will frustrate all and delay implementation. The number of documents should be reduced to eliminate paper work and minimise duplication of information in separate documents.
9.1 The Occupational Qualifications Document describes the learning required for occupational competence in terms of the three types of unit standards described above.
9.2 Each occupational qualification will have an Occupational Curriculum Document that describes
:
o Specifications for the three learning components, with internal assessment guidelines for each
o Provider accreditation requirements for knowledge and practical skills components
o Workplace approval requirements for the work experience components
o Foundational learning competence that is a pre-requisite for the awarding of the national occupational qualifications on NQF Levels 3-4 (optional on NQF Levels 1 and 2)
o Other pre-requisites for commencing the occupational qualifications.
The Green Paper recognises the importance of the curriculum: "Finding the appropriate system for developing curricula, and the development and management of assessment and certification, will be an important part of simplifying and improving the quality assurance system. ... Outside of the higher education system most national qualifications would be improved by having a nationally specified curriculum' [GP 77].
Comments/recommendations:
? Curriculum centralisation on national level should promote the quality and consistency of learning and assessment. The curriculum document should only cover what is absolutely essential in relation to learning and assessment, while making provision for customisation for unique workplace contexts and diverse skills needs in organisations. It must make allowance for the diversity of competence requirements within occupations and the fluidity between occupations. This will make provision for business practices in the rapidly changing work environment where employers increasingly require staff to work with fluid job descriptions and to perform functions that cut across occupational categories in the OFO.
? "Our ability to develop curricula nationally would be increased by institutionalising capacity for curriculum, under the auspices of the Quality Councils' [GP 77]. Such capacity building is essential as curriculum development is a specialised activity. Lifting it to the national level should replace the current costly and time consuming consultant-driven approach to curriculum development for occupational qualifications.
9.3 Each occupational qualification will have an Occupational Assessment Specifications Document to enhance the consistency and credibility of the external assessment process. It will describe the following:
o External assessment strategy, i.e. the method to be used
o Key occupational outcomes linked to the occupational tasks to be assessed
o Points at which assessment must take place
o Criteria for the registration of assessors and internal moderation
o Eligibility for learners to access external assessment.
Comments/recommendations:
? The information in this document should be integrated into the curriculum document to avoid a proliferation of documents.
? Questions arise from the comments in point 6 above on the registration of separate curriculum components as part qualifications: How will these be dealt with in the assessment specifications? For example, will there be specifications relating to the assessment of knowledge and skills for situations in which only the work experience is assessed as a part qualification? Could work experience be assessed without any assessment of the underlying knowledge and skills?
10. Articulation and coherence in the NQF
The Green Paper argues for improved articulation between the different components of the system to address incoherence and inconsistency in the functioning of parts of regulatory system [GP xii]. It recognises that "there is as yet little integration across different types and sites of provision. It is still difficult for students to move between colleges and universities, between different universities, between schools and post-school institutions, and between educational provision and the world of work' [GP 14].
? Comment: The introduction of distinctive occupational qualifications is unlikely to improve articulation, especially into higher education, despite explanations to the contrary. The more unique the occupational qualifications are, the more difficult it will be for learners to get recognition for their learning achievements when they apply for enrolment for degrees. We should not assume that because articulation looks good on paper, that it will be accepted by people in institutions who make value judgements based on pre-conceived ideas about the quality and status of qualifications.
11. Concluding comments
The drive to improve the system and qualifications for developing occupational competence is welcomed. While the sub-framework with its occupational qualifications model might be a conceptually sound ideal to strive towards, it appears that these have been developed in isolation, and without due consideration of the broader context into which they will be introduced. Concrete proposals are needed on how to accommodate existing qualifications, models and programmes that work and enjoy wide credibility within the sub-framework. In addition, there is a need for a critical analysis of the potential obstacles and unintended negative consequences of implementing the proposed changes, with practical solutions to overcoming them.
Finally, the benefits of the proposed changes should be balanced against the inevitable disruptions and delays resulting from far-reaching changes, the anticipated resistance of employers to yet another major change in the skills development system, potential opposition from higher education institutions, as well as the direct and indirect costs of development and implementation.
