Initial Soundings Paper on
Vocational Qualifications
A NIACE Response
Published February 2003
NIACE is the national organisation in England and Wales with a
broad aim to advance the interests of adult learners and potential learners. Our
strategic plan commits us to supporting an increase in the numbers of adults
engaged in formal and informal learning and at the same time to widen access to
learning opportunities and the acquisition of skills and competences to those
who do not traditionally take part in education and training.
NIACE works with all the many interests active in the education
and training of adults. It undertakes advocacy and policy work with national,
regional and local agencies; provides information and advice to organisations
and individuals, carries out research and development projects, organises
conferences, seminars and training courses, publishes journals, books and
directories, and co-ordinates a major national promotion of education and
training for adults through Adult Learners’ Week.
1. The proposed vision
1.1 NIACE welcomes the proposed vision set out in the
document, and looks forward to its realisation in the coming years. In
particular we welcome:
The implication that individual vocational qualifications
will recognise the acquisition of both knowledge and skills.
The encompassing of work preparation skills within the
definition of a vocational qualification.
The focus on ‘vocational learning’ rather than ‘vocational
education and training’.
The explicit commitment to flexibility and responsiveness,
though NIACE would prefer these to be related to both ‘employer needs’ and
the needs of individuals.
The reference to supporting ‘individual learners’ rather
than to ‘employees’.
1.2 We look forward to the development of a genuinely
‘revitalised’ and easily understood framework which can be genuinely inclusive
in the recognition of vocational achievements. We hope that the concept of
‘vocational’ will continue to be interpreted in the creative and
learner-focused sense in which it is used in this opening statement.
2. Role and responsibilities for developing vocational
qualifications
2.1 NIACE views the concepts of ‘skills gaps’ and
‘qualification needs’ as different from each other. While we would want Sector
Skills Councils to be responsible for identifying skills gaps, we would want a
wider range of organisations, including NIACE itself, to be involved in
research and information on qualification needs. This is because, as the
proposed vision itself makes clear, ‘needs’ are related both to employers and
to individual learners, as well as communities.
2.2 In order for qualifications to be developed and updated
quickly, a more flexible and devolved regime of accreditation is needed that
enables this updating to take place by awarding bodies themselves within an
overall framework of accreditation overseen by the regulatory authorities. In
order to be responsive to local and sector needs, it will be necessary to
permit a variety of outcomes to be achieved within named sets of
qualifications. The concept of ‘equivalent value’ rather than ‘identical’ in
comparing these different achievements will be a useful addition to the
criteria for approving qualifications.
2.3 In order to encompass the range of needs of individuals
and employers in a future framework of qualifications, it will be necessary to
build the following features into the framework:
The conceptualising of qualifications as large repositories
of related achievement sets, within which rules of unit combination for
individual certification opportunities can be identified.
The development of a system of credit accumulation and
transfer which permits different achievement sets to be compared with each
other by level and size.
The development of rules for exemption and credit transfer
between qualifications which will enable the explicit ‘interlocking’ of
routes to achievement across qualification boundaries.
The development of a standardised unit format for
representing learner achievements (both skills and knowledge) for all
vocational qualifications and the establishing of a national unit databank
in a web-based format.
The development of an electronic transcript of achievement
which can record and present learner achievements on all vocational
qualifications in a standard format.
2.4 The lessons from the National Qualifications Framework to
date are that current structures and procedures have over-emphasised rigour at
the expense of responsiveness to need. In particular, NIACE would wish to see
the development of far more responsive and flexible vocational qualifications
targeted at adult learners. This may mean the development of separate
accreditation criteria for these qualifications from those general
qualifications targeted at 14 to 19 year olds in full-time education.
3. Ensuring vocational qualifications meet the needs of
individuals and employment
3.1 In order for national occupational standards to inform the
development of future vocational qualifications, they need to be less rather
than more specific. The more general the presentational form of these
standards, the more they will be able to be adapted to meet ‘local and sector’
as well as national needs. NIACE would prefer to see the development of
vocational qualifications that demonstrated, through procedures overseen by
SSCs, that they were ‘related to’ national standards, rather than adopting
these standards verbatim into the qualifications themselves. This would have
the added benefit of extending the life expectancy of these standards.
3.2 We see no reason in principle why a vocational
qualification should not contain an element that is locally or sectorally
determined. Indeed, this facility already exists in the design criteria for
Higher Level Vocational Qualifications. The proportion that may be so
determined may vary across different sectors and different levels. It would
therefore seem appropriate for SSCs to develop general guidance on local or
sectoral variations permitted for vocational qualifications related to their
standards. This facility to vary the structure of a qualification in response
to local or sectoral need would be an important component of maintaining
future ‘vitality’ and responsiveness within the national framework.
3.3 NIACE sees a unitised, credit-based system of
qualifications as providing the design basis for ensuring that both new
entrants to the workforce and existing employees are able to have appropriate
skills and knowledge recognised. As long as individual qualifications permit a
variety of both skills and knowledge to be recognised through flexible
assessment methods it should be possible for individuals both inside and
outside existing employment to demonstrate the acquisition of relevant
achievements.
3.4 In order to ensure that vocational qualifications are
cost-effective to deliver and assess by a variety of different types of
provider, the current requirement that a proportion of all achievements on
vocational qualifications should be externally assessed should be dropped.
NIACE would also welcome the more rapid development of electronic forms of
assessment, where these can produce valid evidence of achievement.
3.5 NIACE sees no reason why all training should lead to a
qualification. However, we do see opportunities for employers to map their
training programmes against national standards in order to ensure that they
could provide a basis for progression towards certificated achievement, if the
employee chose this option. The new IT Skills Framework developed by e-skills
UK provides an interesting model that could be extended to other sectors.
3.6 The development of unitised, credit-based qualifications
will enable links between qualifications to be made more explicit through
exemption and credit transfer arrangements. If qualifications become seen as
‘holding frameworks’ within which a wide range of individual achievements can
be certificated, then the establishing of progression routes to named
qualifications will demand an explicit ‘pathway’ planning procedure for
individual learners as part of the process of registration and induction on
each qualification.
3.7 As NIACE’s primary focus is on adult learners, we will
trust our colleagues in other organisations to comment on the needs of 14-19
year olds.
3.8 NIACE supports the view that units of qualifications
should represent coherent and worthwhile opportunities for recognising learner
achievement. The value placed on them should formally be identical to that
placed on a whole qualification, ie each unit should be capable of
certification at a designated level, and should bear the imprimatur of the
regulatory authorities. If the procedures and criteria for accreditation of
qualifications were consistent with this status, then the currency of learner
achievement could be re-located to unit certification, and vocational
qualifications could be defined in terms of a set of rules of combination,
expressed in terms of credit achievement for designated units. This
‘compositional’ approach to the achievement of vocational qualifications would
mark a significant step forward in developing a more flexible and responsive
system of qualifications.
4. Quality Assurance
4.1 The key area on which regulation should focus is the
systems employed by awarding bodies to provide qualifications through approved
centres. In particular, their approaches to assessment will need to be quality
assured. NIACE would not wish to see regulation focusing too closely on the
content of individual qualifications. Indeed, if unitised qualifications are
to continue to be responsive to changing employer and individual needs, then
awarding bodies will need to be able to update individual units of
qualifications without submitting them for a detailed process of accreditation
by the regulatory authorities.
4.2 One way of enhancing the final quality of the
qualifications offered to learners would be to create a more open and shared
process of development of individual qualifications, in which all interested
parties were involved. This could be managed primarily through a web-based
facility, parts of which could be password protected, which would allow a wide
range of interest groups to contribute to qualifications development. In order
to work effectively, the regulatory authorities would need to own such a
facility, and would need to create clear structures and procedures within
which interested parties could contribute to this development. Such a facility
could play an important ongoing role in the continuous updating and
improvement of qualifications in response to changing demands.
5. Funding
5.1 One of the ways in which funding mechanisms could be
utilised to help learning providers respond more effectively to identified
need would be to base funding arrangements on the delivery of good quality
learning programmes, rather than on the offer of approved qualifications!
5.2 NIACE believes that credit-based funding mechanisms can
facilitate greater responsiveness in the qualifications system, though we do
not see a direct connection between credit systems (which relate to the
measurement of learner achievement) and ‘bite-sized chunks of learning’ (which
relate to arrangements for the provision of learning programmes). Thus, for
example, Ufi offers some learndirect courses with a notional learning time of
less than one hour. But a credit system based on the measurement and
certification of achievement at one hour intervals would be patently sclerotic
in structure and would create a nightmarishly bureaucratic and costly regime
of assessment. At the other end of the spectrum (and again the experience of
Ufi is relevant) qualifications that require lengthy commitments of time and
effort by both learners and providers before achievements can be recognised
tend to de-motivate learners and lead to high levels of ‘non-completion’.
NIACE offers the following responses to the question of how responsiveness
might be promoted through the use of credit:
It is not ‘credit-based funding mechanisms’ that will
facilitate greater responsiveness in the qualifications system. However,
‘the funding of credit-based qualifications’ will produce this
desired responsiveness. This is more than a semantic quibble. The concept of
‘credit’ needs to be seen as an integral feature of the design of
qualifications, not a characteristic of funding regimes.
Linking funding to the credit values of individual units of
qualifications and to the credits achieved by learners, will enable a
rational and open relationship to be established between the funding of
programme delivery and the funding of individual learner achievements. This
is because the definition of credit established in England, Wales and
Northern Ireland in recent years combines within it concepts of both
learning and achievement which make it uniquely appropriate to support
funding regimes that incorporate both these elements.
Thus a concept of credit will be essential to any funding
regime that seeks to stimulate individual learner achievement as well as the
provision of more flexible learning opportunities. Neither a unitised
qualifications framework nor a modularised curriculum framework can do both
of these things. But in order to have the effect of supporting greater
flexibility and responsiveness in the qualifications framework, the concept
of ‘credit-based qualifications’ rather than ‘credit-based funding’ needs to
be developed.
5.3 Funding arrangements for new qualifications could be
enhanced by explicitly encouraging the piloting and testing of new
qualifications for a designated period (perhaps one or two years) prior to
formal submission for approval within the NQF. Awarding bodies would still be
charged with responsibility for conducting assessment and issuing
certification in ways that did not undermine the quality of fully accredited
qualifications. Again, the use of credit certification might provide a useful
mechanism through which innovation and response to rapid change could be more
easily accommodated within the NQF through an explicit period of piloting and
trialling of new qualifications.
5.4 If occupational standards are conceived as general
benchmarks of skills and knowledge to which more specific opportunities for
assessment and certification could be related (see above); and if credit-based
qualifications included within their design criteria the concept of
‘equivalent value’ for different units of assessment that were related to the
same broad standards; and if the accreditation criteria for vocational
qualifications mirrored those of Higher Level Vocational Qualifications in
allowing a proportion of local or sectoral flexibility in the outcomes of the
qualification, then employers could ensure that a proportion of each
qualification offered to its employees, could be customised to meet their
needs; would be subject to the quality assurance arrangements of an awarding
body; and would be related to national standards. This would seem to create
the necessary safeguards to enable funding to support the needs of employers
(including SMEs) to actually make use of vocational qualifications.
5.5 NIACE sees no reason why unit funding should not be made
available to all learners providing each unit is itself a coherent and
assessable set of learning outcomes (ie not simply a convenient
sub-division of a whole qualification) that provides a worthwhile goal for the
learner, and that learners have the right to demand certification for each
individual unit achieved.
6. Communications
6.1 The key messages that need to be communicated about
vocational qualifications are that they are accessible, relevant to both
current and potential future employment, different from school-based
qualifications, and are capable of being achieved through a variety of
different methods that can be fitted in and around the other commitments of
adult learners.
6.2 All other aspects of a future communications strategy for
this new vocational qualifications system should reflect this key message.