National Qualifications Framework Bill Presentation to Portfolio Committee on Education 30 July 2008 SAOU Curriculum Services

Focus of the SAOU’S comments The objectives of the NQF (Legislator’s intention) versus the rest of the Bill Representivity of the SAQA Board and Quality Councils Responsibilities of the Ministers SAOU Curriculum Services

SAOU Curriculum Services Objectives of NQF Create an integrated national framework for learning achievements Facilitate access to, and mobility and progression within, education, training and career paths SAOU Curriculum Services

What the objectives mean: Intention of the Legislator An integrated system of national qualifications which will make it possible to let all learning achievements of individuals count towards their progression within and between education, training and career paths. SAOU Curriculum Services

Approach: SAQA Act versus NQF Act A Programmes Approach NQF Bill: A Systems Approach SAQA Qualifications developed and registered NSB’s & SGB’s 10 Education & Training provided ETQA’s & Providers 9 8 7 6 5 4 3 2 1 SAQA QUALITY COUNCILS QCGFET QCHE QCTO 10 ? 9 8 7 6 5 4 3 2 1 SAOU Curriculum Services

Why the NQF under the SAQA Act has not performed as expected SAQA did not use the powers which it had in terms of the Act to generate the necessary involvement of the role players and stake-holders in standard setting The universities in particular did not provide the expertise which is required for the setting of standards at the ten levels The level descriptors were ineffective and did not make the equation of qualifications pos-sible SAOU Curriculum Services

SAOU Curriculum Services Why the NQF under the NQF Bill (Act) will not perform ito the objectives The Bill does not give SAQA the powers to ensure the co-operation of the Quality Councils The Bill’s description of the NQF, specifically the levels, does not provide sufficient detail For SAQA and the QC’s to reach agreement on the level descriptors, the descriptors will have to be reduced to that which is acceptable to the three QC’s. This will make the equation of qualifications questionable. The Bill does not emphasise the importance of the academic disciplines in the setting of standards SAOU Curriculum Services

An integrated framework requires a common knowledge core SAOU Curriculum Services

Proposal 1: Objectives, Design of NQF, Functions of SAQA The objectives should envisage the NQF as a national framework of co-ordinated sub-frameworks for learn-ing achievements (not integrated) If the objectives remain unchanged (integrated frame-work), then in order to ensure their achievement: The Bill should give SAQA more authority over the QC’s, OR The Bill should indicate the levels which apply in the case of each sub-framework; The Bill should determine criteria for the formulation of the level descriptors or state that the Minister will determine such criteria; Section 14(1)(g) should determine that SAQA will perform this function subject to the criteria determined by the Minister; and The Bill should determine that expertise in the basic knowledge disciplines should be involved in all standard setting activities. The SAOU proposes the first option SAOU Curriculum Services

Proposal 2: Representivity of SAQA and the QC’s The Bill addresses only the composition of the SAQA Board (not the QC’s) Teachers are important role players and should be represented on the three QC’s (representation on the SAQA Board is less important) Teacher unions represent teachers; the NQF and/or the QC Amendment Bills and Skills Development Bill should therefore ensure representation of the teacher unions on the QC’s SAOU Curriculum Services

Proposal 3: Responsibility of Ministers Section 9(1) determines that the Minister has executive responsibility for the NQF, SAQA and two QC’s, while the Minister of Labour has executive responsibility for the third QC. Section 8 determines that the Minister must discharge his responsibilities in consultation with the Minister of Labour. The question that arises is whether this is acceptable ito the Constitution and whether it could possibly impact negatively on the functioning of the NQF system The SAOU proposes that legal advice be obtained on these questions. SAOU Curriculum Services

SAOU Curriculum Services In summary: The objectives should envisage a co-ordinated rather than integrated framework. If they were to remain unchanged, the framework should be described in greater detail with the emphasis on the importance of academic disciplines in the setting of standards. Teacher unions should be represented on the Quality Councils Experts should advise on the viability of two Ministers being given executive responsibility for the NQF and/or parts thereof SAOU Curriculum Services