1. PRESENTATION ON THE NQF BILL TO THE PORTFOLIO COMMITTEE ON EDUCATION The South African Institute of Chartered Accountants 30 JULY 2008

2. SAICA is the pre-eminent accountancy body in South Africa 2 A voluntary, non-statutory professional body representing 28 000 Chartered Accountants in South Africa Confers the designation CA(SA), which is protected by the Chartered Accountants Designation (Private) Act SAICA was the first ETQA accredited by SAQA SAICA registered the first learnership through FASSET with DOL: 9 500 learners at 900 accredited workplace providers with 1 600 registered assessors SAICA is the only professional body in South Africa recognised by the Independent Regulatory Board for Auditors SAICA is the only professional accountancy body in South Africa recognised by a number of leading international institutes of accountants

3. The CA(SA) designation is achieved through a rigorous academic, training and assessment process Education: 13 accredited higher education institutions Training: 900 accredited workplace providers Professional examinations 3 BCom Certificate in the Theory of Accountancy (honours equivalent) Minimum of 3 years Ongoing formative and summative assessment 2 exams 1st exam set by SAICA 2 nd exam set by SAICA or IRBA

4. We commend the drafters of the Bill on the following … We commend the drafters of the Bill on the following … 4 A balanced and comprehensive definition of “professional body” and “professional designation” Significant improvements regarding the role of SAQA and the QCs, as well as the pre- eminence of this Bill in cases of conflict with other legislations (sections 14, 28 and 35) Recognition of the role of professional bodies (statutory and non-statutory) in education, training and skills development (section 30) Providing for consultation and cooperation with professional bodies (sections 14(1)(i) and 29) As a QC will have a distinct nomenclature for its qualification types - it will enable a professional body such as SAICA to develop or register its ‘professional qualifications’ via the relevant QC Registration of a ‘qualification’ on the NQF (section 14(1)(h)) is required for a SETA to establish a learnership – this will enable a professional body to structure the workplace learning component of its qualification into a learnership

5. We have three main areas of concern … Registration of professional designations on the NQFQuality assuranceTransitional arrangements 5

6. The registration of designations on the NQF may limit the role of professional bodies in protecting the public interest A qualification is a statement of competence which, once achieved, requires no further actions or input, while a designation is not a permanent status - it is subject to on-going requirements and may be revoked due to non-compliance with any specified requirements If not registered on the NQF, a designation may then not be afforded such protection as offered by the NQF, but ultimately a designation is a brand that has to be built and managed Registration of a designation on the NQF may limit a professional body’s public interest function - members who have been removed from the register will retain the “designation” by virtue of the recording of its achievement on the NLRD 6 Many other international frameworks do not require the registration of designations

7. The proposed QCs may lead to a fragmented approach to the quality assurance of education and workplace-based learning The Bill defines one of the objectives of the NQF as enhancing the quality of education and training – however, the distinction between the quality assurance function of the HEQC, the body responsible for higher education and the QCTO, the body responsible for quality assurance of “… learning in and for the workplace” will fragment education and training quality assurance initiatives Many professional qualifications do not fall neatly into the category of academic qualifications or vocational qualifications and it is unclear what the ambit of the respective QCs will be in this regard The Bill provides for professional bodies to register designations on the NQF, but the proposed Skills Development Act provides for SETAs to establish learnerships if the learnership would lead to a SAQA registered qualification associated with a trade, occupation or profession – this may preclude professional bodies from participating in learnerships 7

8. The proposed transitional arrangements conflict with the provisions of the draft amended Skills Development Act In terms of the amended SDA, skills development providers accredited by a SETA ETQA will be recognised by the QCTO during the transitional period – there is no reference to professional body ETQAs in this regard Currently professional body ETQAs accredit providers in terms of regulations issued under the SAQA Act, and in terms of the NQF Bill this arrangement will continue until the regulations are repealed by the Minister 8

9. Recommendations Establish a fourth sub- framework for professional qualifications To be administered by its own QC or one of the three other QCs Insert the words ‘professional qualification’ in section 31 to allow professional bodies to choose what to register on the NQF This will enable a professional body that registers either a professional designation or a professional qualification to be recognised by SAQA and to give effect to the spirit and intent of the Skills Development Act by participating in learnerships Section 28(i) should be amended to provide for full delegation of quality assurance by QCs to recognised professional bodies This will enable professional bodies to perform the requisite quality assurance functions in respect of their own designations 9 OR

10. SAICA subscribes to the spirit and intent of the NQF SAICA remains committed to participating in national, legislative structures to enhance the quality of education and training and to redress past unfair discrimination in education and training and will continue to engage constructively with these structures 10