Measuring and recording student achievement

Proposals for National Credit Arrangements for the use of Academic Credit in Higher Education In England.

A response to the UUK/SCOP Consultation Document from NIACE
Published: November 2005

General

NIACE welcomes the publication of this consultation document, and is pleased to have the opportunity to offer our comments on these proposals. We have long supported the benefits of credit systems to adult learners, and we welcome the current commitment of government to stimulate the development of credit systems in Higher Education and through the Framework for Achievement.

We are aware of government’s concerns that the development of credit systems in HE and the FfA should proceed on the basis of shared credit principles and – as appropriate – shared operational criteria. NIACE is very disappointed that the FFA is not referred to explicitly within the consultation paper. It is clearly important that these two initiatives are closely linked.

The following sections of our response follow as best we can the questions in the document. We found the structure of the document difficult to use, and in particular the relationship between the eight proposals in the document and the eight questions asked of respondents remains unclear to us. We have therefore included an initial section on the proposals themselves, in addition to our responses to each question.

Proposal 1: Credit is awarded to a student/learner in recognition of designated and achieved learning.

This is close to a useful definition. It contains the key phrase ‘credit is awarded’ that NIACE sees as critical to the operation of credit systems. This definition of credit as an award is an essential pre-requisite to all subsequent uses of the term credit within the document. The term ‘designated and achieved learning’ seems cumbersome. The important feature of this term is the concept of achievement. NIACE would prefer to see the term ‘achievement’ or even ‘designated achievement’ used here, as the term ‘learning’ is ambiguous. Is learning something undertaken or something achieved? The answer here is clearly the latter – in other parts of the document it is not so clear which usage of ‘learning’ is being used.

Proposal 2; The award of credit recognises achievement of the required minimum learning outcomes of a programme or module/unit; higher levels of performance do not result in any additional credit

The first ‘slippage’ in the concept of learning as something achieved occurs here. The term ‘programme’ clearly relates to ‘learning undertaken’ rather than ‘learning achieved’ and needs to be omitted here. The proposal also introduces concepts of ‘level’ and ‘performance’ which either need to be considered later in the paper or omitted from these proposals as understood. This is the only reference in the paper to the concept of unit and it needs to be made much more explicit within a revised proposal. NIACE suggests the following re-wording:

The award of credit recognises achievement of the learning outcomes of a unit

Proposal 3: Matters relating to compensation for or condonation of failure remain at the specific discretion of each institution.

Fine, but the proposal needs to be absolutely explicit in stating that neither condonation nor compensation can result in the award of credit. As both concepts are only relevant where credit is accumulated towards a qualification, this is not problematic. Thus a qualification within the FHEQ could be achieved either through the award of credit or through the award of credit with compensation or condonement for those units of the qualification not achieved through the award of credit.

Proposal 4: Whilst all learning may be expressed in terms of credit values, not all credit can or will necessarily be accumulated towards a specific programme or award.

We think we agree with this proposal, but again it is not expressed very clearly. Can credit be accumulated ‘towards a programme’? And if (as proposals 1 & 2 confirm) credit is an award then this seems to suggest that credit cannot be accumulated towards the award of credit. And again we’ve lost the concept of ‘achievement’ in the concept of ‘learning’ expressed as credit value. We think this proposal could be expressed more clearly, perhaps in two separate proposals:

All achievements within units may be expressed in terms of credit value

Credits may be awarded for the achievement of any unit, but credits need not be accumulated towards a qualification

Proposal 5: Each HEI, in agreement with partner organisations where appropriate, has the authority to decide what (volume and/or level of) credit, offered by a learner, it will formally recognise; whether this is for the purpose of entry to a programme of study; and/or for accreditation towards the achievement of the learning outcomes of any programme of study.

NIACE has no problem with the principle buried within this difficult-to-understand proposal, but we think it misses an essential point, and once again confuses achievement with learning.

The essential point is that, while each individual HEI should have the freedom to determine how many and what level of credits may be recognised for entry to or ‘accreditation towards the achievement of’ a qualification (NB NOT a ‘programme of study’) this must be a consistent and comprehensive commitment for each individual qualification offered by the ‘receiving’ institution. So it would be perfectly reasonable for an HEI to say ‘we will accept x credits at y level’ towards the achievement of qualification z. However, we suggest that it would not be reasonable for an HEI to say ‘we will accept a credits from University b, but only c credits from University d’ towards the achievement of the same qualification

Proposal 6: HEIs should publish a credit description of each of its programmes (and where appropriate its component modules/units)

NIACE would support the principle that, if there are to be things called ‘HE credit arrangements’ then these should be applied consistently across all HEIs. However the above proposal once again confuses achievement with programme delivery and also implies that a ‘credit description’ could be developed for a qualification without necessarily doing the same for the units that make it up. NIACE’s view is that the operation of a credit system must be built around a clear definition of a unit, and that units need to be seen as the building blocks of all qualifications. We suggest an alternative to the above proposal:

All HEIs should publish the credit value and level of all the qualifications they offer and all the units that make up these qualifications.

Proposal 7: The nomenclature of the FHEQ levels should be revised to align with the NQF (and the emerging Framework for Achievement)

NIACE agrees with this proposal, and notes the implication that any credit arrangements need to be seen as an integral feature of the FHEQ, which we see an essential pre-requisite of the success of any credit arrangements in HE. It would also substantiate many of the above points we make in relation to the distinction between qualifications and programmes of learning.

Proposal 8: Following the ministerial adoption of the Framework for Qualifications of the European Higher Education Area, the ‘Dublin (qualification) descriptors’ should be regarded as reference points within the FHEQ

NIACE has no strong views on this proposal.

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The questions

1. Would national credit arrangements for HE in England better be organised as:

These seem to be both incomplete and rather eccentric definitions of the distinctions between ‘a system’ and ‘a framework’. NIACE would prefer to see the arrangements for credit integrated into an updated FHEQ (perhaps becoming an FHECQ?). The new Framework should include the technical specifications that would support an operational system of credit accumulation and transfer, plus guidelines to HEIs on the application of the specifications of the Framework to this system.

2. Should national credit arrangements for English HE be integrated with the Framework for Higher Education Qualifications (FHEQ)?

Yes, otherwise the existing exercise would be meaningless. The HE sector already has a perfectly adequate set of credit specifications, developed by the EWNI Credit Bodies. However these lack the necessary authority to support a comprehensive set of credit arrangements across the sector, and these are what NIACE hopes will be a positive outcome of the current initiative

3. Should the primary basis of national credit arrangements for England be:

NIACE would not support the adoption of the ECTS credit system. It is based on an outmoded concept of credit as a measure of ‘learning input’ rather than achievement, it is incompatible with the conceptual basis of the new European Qualifications Framework, and NIACE would wish to see ECTS and ECVET systems combined within a revised EQF to form a new European Qualifications and Credit Framework. The continued existence of ECTS in its current form is an impediment to this aim, and it would be a backward step if it were to be adopted by HE in England,

Having said this the above summary of UK HE credit systems misrepresents the definition of credit and once again confuses the process of learning with learner achievements. Credit does NOT ‘represent the learning associated with 10 notional learning hours’ it represents the value of those learning outcomes that can be achieved in 10 notional learning hours. The distinction is critical, and indeed is clearly made in the existing EWNI Credit Bodies guidelines. The above representation of credit value confirms once again the confusion that runs through the whole document about the distinction between learning and achievement.

This confusion is also evident in the representation of 120 credits as ‘a full-time equivalent undergraduate study year’. It isn’t, though it may represent the value of those achievements that a learner might achieve in a full-time year of study. NIACE has no strong views about how such values might be established, but it is clear that credit must value achievements rather than learning time.

4. Should national credit arrangements for English HE include guidance and recommendations on the use of level descriptors?

Yes. Indeed it seems rather strange to ask this question separately from the above proposal on the levels of the FHEQ. What is needed is a set of level descriptors that can be used to enable the credit values of units to be consistently determined, plus guidance on how these descriptors should be applied, and how the level of a qualification within the FHEQ might be determined through the use of rules of combination for the units that constitute it.

5. a) Should national credit arrangements identify the typical credit values for the main HE awards?

b) Should these credit values be expressed as a minimum total credit typically associated with the award of each main qualification?

NIACE assumes that the integration of the proposed credit arrangements with an updated version of the FHEQ will answer these questions. However we note once again the problem of language within the question. If credit is an award (proposal 1) then credit isn’t ‘associated with’ the award of a qualification, credits are constituent parts of the qualification itself.

6. Should national guidelines on credit provide an indication of expectations about the volume of credit typically associated with the level of the award for those HE awards that span different levels of study?

This question reveals a problematic misconception about the relationship between credits and qualifications, and it leads once again to a convoluted language that could be simplified if we conceive qualifications as being ‘made up from’ rather than ‘divided into’ credits. This may then be represented as follows:

An HE qualification may be made up of credits from a level (or levels) below that of the qualification itself.

7. Should national guidelines on credit recommend use of the NICATS level descriptors as reference points to assist in establishing credit levels?

NIACE is aware that the NICATS level descriptors are to be reviewed and updated as part of the process of preparing for implementation of the Framework for Achievement. We believe that HE should be represented within this process and that the level descriptors that emerge should be endorsed for use within both the FfA and the FHEQ.

8. Are there any additional comments/observations you would like to make?

NIACE would welcome a chance to discuss the UUK/SCOP proposals and to explain our position. We have set out our position in a recent discussion document, and this is referenced below.

Wilson, P. (2004) Devilish Details: Developing the new Framework for Achievement, NIACE, Leicester

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