National Qualifications Framework

1. National Qualifications Framework 30 July 2008

2. 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.

3. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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 country’s 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.

4. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.

5. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.

6. CATHOLIC INSTITUTE OF EDUCATION July 30/08 CONTEXT AND CHALLENGES

7. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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 Africa’s 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 worked…to date.

8. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.

9. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.

10. 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. CATHOLIC INSTITUTE OF EDUCATION July 30/08 NQF REVIEWS (2001 & 2003)

11. CATHOLIC INSTITUTE OF EDUCATION July 30/08 CONTEXT AND CHALLENGES

12. Denudation of Government’s 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. CATHOLIC INSTITUTE OF EDUCATION July 30/08 NQF REVIEWS (2002 & 2003)

13. 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. CATHOLIC INSTITUTE OF EDUCATION July 30/08 WHAT THE NQF BILL DOES

14. 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. CATHOLIC INSTITUTE OF EDUCATION July 30/08 WHAT THE NQF BILL DOES

15. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.

16. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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)

17. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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 comparableand 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.

18. CATHOLIC INSTITUTE OF EDUCATION July 30/08 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.)