1. National Qualifications Framework Bill
Presentation to Portfolio Committee on Education
30 July 2008
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2. 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
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3. 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
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4. 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.
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5. 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
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6. 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
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7. 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
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8. An integrated framework requires a common knowledge core
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9. 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
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10. 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
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11. 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.
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12. 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
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