Maintaining the momentum of reform
A NIACE position statement on the Framework for Achievement
Published: November 2005
| In November 2004, the Qualifications and Curriculum Authority (QCA) launched its proposals for a new Framework for Achievement (FfA) with support from both the Learning and Skills Council (LSC) and the Skills for Business (SfB) network. NIACE supported these proposals enthusiastically, believing they put forward proposals for the reform of our qualifications system that would have great benefits to learners, to providers and to employers. One year later NIACE is concerned that the impetus for implementation of the FfA proposals seems to be losing some urgency. We therefore wish to reiterate our position of support for the QCA proposals, and to share our views on the importance of developing a new qualifications system with other stakeholders in the reform process. |
1. NIACE and adult learners
NIACE is the key national organisation in England and Wales that represents the interests of adult learners. We are interested in the needs of adult learners wherever and however they learn. We are committed to the principle that all learners should have the opportunity for all their achievements in learning to be recognized.
We support the development of the FfA because it offers the opportunity for the development of a single framework of awards within which all the formally-assessed achievements of adult learners may be recognised. NIACE is acutely aware of the fact that the majority of adult learners on publicly-funded provision in England are not working towards a qualification within the current National Qualifications Framework (NQF). We are also aware of the very high rates of failure and drop-out for adult learners on qualifications in the NQF.
We therefore wish to see the development of a more inclusive framework that is capable of offering much more sensitive mechanisms for recognising the achievements of many more learners in a way that is responsive to individual needs. We believe the proposals for the FfA have the potential to realise these ambitions.
2. The case for reform
NIACE supports wholeheartedly the case for reform of our qualifications system set out in the Skills Strategy White Papers of 2003 and 2005. We would have welcomed an unequivocal commitment to the development of a single qualifications system in the 2005 14-19 White Paper, but now feel it is important not to lose the impetus for reform located clearly within the Skills Strategy.
NIACE views the development of the FfA as one of the key strands of reform within the Skills Strategy. It cannot be seen in isolation from these other strands, and some of these other reforms will be dependent on its success. The Skills White Papers make a very clear case for the need for ‘a step change’ in a number of areas if we are to modernise our system of post-school learning, and the development of the FfA needs to be seen as part of this step change.
NIACE would wish to see a reiteration of this commitment to radical reform of our qualifications system asserted by government at this juncture. The evidence to support this view of reform was well laid out in the 2003 White Paper (and in the previous Cabinet Office Strategy Unit papers on Adult Skills in the 21st Century). We seem to be in danger of losing this impetus to reform, and of narrowing our vision of what is needed, and what is achievable. NIACE believes such a loss of impetus would have adverse effects on our capacity to deliver on the Skills Strategy.
3. The scope of reform
NIACE re-states once again its support for the scope of the reforms envisaged within the FfA. We wish to re-emphasise the explicit intention of the Skills Strategy that reform should focus on ‘our qualifications system’ and not simply on ‘the NQF’. A reform agenda that simply updated existing qualifications within the NQF, rather than addressing the much wider need for reform of awards both inside and outside the NQF, would not deliver on the expectations of the Skills Strategy and would not address one of the fundamental divisions in our current system affecting both learners and providers.
In taking forward the reform process, NIACE believes that the experiences of awarding bodies and providers outside the NQF must be given due weight. It would be a mistake at this juncture to limit the perspective of the reform agenda simply to those organisations working within the NQF. If we want (as the Skills Strategy says) a qualifications system that is more flexible and responsive to the needs of a much wider group of learners, then we need to look at and learn from provision and awards developed outside the current scope of the NQF for some of these models of flexibility and responsiveness.
4. The importance of credit
NIACE has long argued for the importance of a system of credit accumulation and transfer as a critical design feature of any framework for recognising learner achievement. We have previously supported the call for establishing a National Credit Framework, and have been active in stimulating the development of Open College Networks (OCNs) and the National Open College Network in pursuit of such a system. We remind colleagues of the long-standing recognition of the importance of credit systems to widening participation and social inclusion voiced most clearly in Helena Kennedy’s Learning Works report of 1997.
Some years a go NIACE argued that we should look beyond the idea of ‘a credit framework’ to the concept of ‘credit-based qualifications’. One of the reasons for our support for the FfA is because it proposes the integration of a system of credit accumulation and transfer within a regulated national framework of qualifications. Our view is that qualifications need credit if they are to be responsive and inclusive, while a credit system needs qualifications if it is to create a meaningful purpose to the process of credit accumulation and transfer.
We recognise that the development of a credit system within the FfA has profound implications for the current operational models of many awarding bodies. Such a system needs to be developed slowly and carefully, and needs to engage the support of the awarding bodies that will operate it, as well as the learners, providers and employers who will be able to take advantage of it. Nevertheless, this single feature is essential to the reform process. The development of a Framework without an explicit commitment to credit accumulation and transfer as the driving force behind inclusion, flexibility and responsiveness would simply not deliver on the expectations of the reform agenda set out in the Skills Strategy. It would also exclude from the reform process the hundreds of thousands of adult learners who have earned credit for their achievements outside the NQF every year for the past two decades.
5. Learning from others
NIACE notes that the FfA proposal is unique. We know of no other proposed Framework that seeks to embed a system of credit accumulation and transfer within a regulated framework of qualifications in which awards are offered through independent commercial bodies. We believe that the proposed model for the FfA is fit-for-purpose for the aims of the reform agenda, and we urge policy-makers to support the development of the FfA through the considered process of tests and trials that QCA and its reform partners now wish to take forward.
Notwithstanding the unique features of the FfA, it will be possible to learn from the experiences of others in taking forward its development. We have already noted above the wealth of experience that exists in the operation of credit systems outside the NQF, and we hope this will be built on explicitly within the continuing process of reform. In particular we hope that the FfA will draw on the concrete example of Access to Higher Education Certificates as a functioning example of credit-based qualifications in England, Wales and Northern Ireland. Similarly, we note the importance of the parallel development of credit systems in Higher Education and we hope these two processes of reform will be taken forward in tandem.
Fortuitously, we now also have access to evaluative studies of both the Scottish Credit and Qualifications Framework (SCQF) and the Credit and Qualifications Framework for Wales (CQFW) as well as a significant OECD comparative study of national qualifications frameworks. The evidence from all these studies confirms the suitability of the FfA model for the expected outcomes of the reform process. To be successful, a national qualifications framework must have a sound legislative basis and be capable of supporting a system of credit accumulation and transfer. The FfA is such a framework, and NIACE is at one with the OECD in the view that alternative ‘descriptive’ or ‘enabling’ frameworks such as the SCQF and CQFW, though valuable in their own context, are simply not fit-for-purpose in terms of the qualifications reform agenda in the Skills Strategy.
6. What next?
It is now almost 20 years since NIACE first began its advocacy for the development of credit systems. We are delighted by the explicit commitment to the development of such a credit system within the two Skills Strategy White Papers and in the current remit of the reform partners. We believe that QCA and LSC (with support from the SfB network) are the right partners to continue leading the reform process, and we are keen to see a clear confirmation of the direction for reform from government. We recognise the importance of developing an approach to reform that involves other key stakeholders, including awarding bodies, and that this has to be seen as a long term process of change. However we do not believe the reform process can proceed through piecemeal incremental changes to the existing NQF. That is why we want to see government, as the sponsor of the reform process, confirm its commitment to the development of a new and different Framework as part of a conscious strategy for qualifications reform.
We are concerned that failure to re-state the clear objectives of the reform process at this juncture will result in a dissipation of the strong support for the FfA proposals that was established through last year’s consultation process. The case for establishing a system of credit-based qualifications, which now stretches back well over a decade, has been made by many different organisations before QCA and LSC received their recent remit. To lose the focus for reform now would be to ignore not only the wide support for development of the FfA, but the concrete experiences of thousands of people and organisations in the post-school sector with many years experience of the practical implementation of credit systems.
Notwithstanding this urgency about the direction of reform, we recognise that the process of development of the FfA needs to be considered, rigorous and well-planned. (Indeed the engagement of stakeholders and development over time are two of the other success criteria for such reforms identified in the OECD study referred to above). We support the proposal for a two-year period of testing and trialling of the FfA from 2006, and believe that if the outcomes of this period indicate that ‘initial development’ of the FfA cannot be completed by 2010, then this deadline should be extended.
During this first two years it will be essential to ensure that the FfA is extended to Wales and Northern Ireland, and NIACE would wish to see QCA’s regulatory partners drawn into the development of the FfA during 2006-07. We also hope that the current remit for reform (due for review in 2008) is revised to ensure that replacement qualifications for GCSEs and A Levels become an explicit part of the FfA in the future. NIACE has waited a long time for this particular reform to be taken seriously by government and we would rather see a regulated credit system developed over a longer period than a ‘descriptive’ credit framework developed in the near future.
Conclusion
NIACE now seeks comments on our current position from other organisations with a commitment to these reforms. In particular we recognise the challenges in the reform agenda to many awarding bodies currently operating within the NQF, and we invite comments from these stakeholders on our position. Our intention in so doing is both to re-affirm our support for the reform process, but also to identify those impediments to taking forward the development of the FfA that will need to be addressed within the next period of implementation.
We are interested in hearing from other people and organisations that share our analysis of the objectives of qualifications reform and who recognise the importance of these next few months to the reform process. As always, NIACE will maintain an independent view of these reforms, but at this juncture we wish to see the proposals for the FfA put forward by QCA, LSC and SfB given due support from government and sufficient time to prove themselves as capable of delivering a more flexible, responsive and inclusive qualifications system for all learners, including the adults whose interests NIACE seeks to represent.
