Ako Aotearoa's submission on the Targeted Review of the Qualifications System
Ako Aotearoa's submission on the NZQA's Targeted Review of the Qualifications System
1. Thank you for the opportunity to comment. As the National Centre for Tertiary Teaching Excellence with a mission to support the best possible outcomes for tertiary learners, Ako Aotearoa has a vital interest in New Zealand’s tertiary qualifications and how their structure supports good and relevant teaching and learning.
2. We note that this consultation document has been developed in collaboration with a range of interested bodies and find it somewhat extraordinary that we were not asked to contribute. An early approach was in fact made to NZQA on this in July 2008, but we received no response. We trust that there will be opportunities for further discussion in the future.
3. We are generally supportive of the changes proposed and the rationale for doing so. Indeed we have commissioned our own stock-take of qualifications for new tertiary teachers in New Zealand. This work was initiated as a result of our concerns about the confusing proliferation of qualifications (around 100) in this discipline area and the resulting lack of sustainability of many of those offered. We expect this work to be completed in February.
4. There is no doubt that the current pre-degree tertiary qualifications system in New Zealand fails to meet the intentions of the Education Act. Proliferation of qualifications is a significant part of this problem (although as elaborated below, it may be a symptom of deeper issues). In the end, in our own work and in the wider context of this review, the key purpose of change must be relevance and value to learners and their communities, not the reduction in number of qualifications per se.
5. In the first instance, it is important to be clear about whether the proposed New Zealand Qualifications Framework is primarily an information repository, a policy steering / regulatory mechanism or both. The background research to the consultation document suggests that at present the Register isn’t really fit for either purpose. Ideally it should meet the needs of both.
6. We would make some initial comments which go towards addressing some of the ambiguities in the consultation paper. We are far from confident that the authors of the consultation paper have really focussed in on the underlying issues that need to be addressed if this review is to be a success. Without a clear understanding of the underlying drivers, there is a real risk that this qualifications review becomes a cosmetic “tidy-up” exercise and a regulatory compromise, rather than principle-driven change that is designed to support effective tertiary teaching and learning.
7. Firstly, the distinction is made in the consultation paper that National Qualifications are standards-based while New Zealand and provider qualifications are course-based (p5 and elsewhere). Many New Zealand and provider qualifications are in fact prescription- based and are arguably equally standards driven. Furthermore, just because a qualification is standards-based doesn’t mean the programme leading to it cannot be delivered as courses integrating work addressing a range of unit standards. The issue is as much more about the nature of the standards being used than it is about a contrived distinction between standards and courses.
8. One of the key considerations for providers about unit standards based qualifications, especially at level 4 and above has been that they are built exclusively on a competency-based model of standards. This is not recognised anywhere in the consultation paper. It is indisputable that competencies are vitally important parts of any vocational qualification. However, they are, by definition, limited to the acquisition of existing skills in prescribed environments.
9. As it works towards transforming its economy, New Zealand will increasingly need citizens equipped with the analytical, synthetic and creative skills who can work beyond the confines of competency and have the ability to develop new skills and adapt to new environments. In other words, they must have a range of capabilities1 beyond defined competencies. These capabilities include the “soft skills” such as communication and team work that employers see as critical attributes for their potential employees.
10. The word capability is used several times in the consultation document in the context of defining educational outcomes, but it is not clear whether it is being used in the precise sense described in the preceding paragraph. In our view it is vital that this issue is explicitly addressed in any redevelopment of qualifications and capability-based standards are developed to build on competency-based standards where appropriate.
11. When some of these issues have been raised in the past, a standard response has been that unit standards are assessment standards and that they are not curriculum documents. This is a flawed argument. The reality for many National Qualifications is that they are so tightly packed with detailed performance criteria that they are de facto curriculum documents. As a result, there is little room to develop learners’ capabilities within the programme of study and, even where there is, little incentive for learners to extend themselves in these areas when they are not explicitly linked to the acquisition of credits.
12. Our responses to the questions in the consultation document are therefore framed in the context outlined above.
1 We support a unified outcomes-based qualifications framework. Well written outcomes-based descriptions of qualifications with clear graduate profiles are much easier to understand by both learners and prospective employers providing they are written from the dual perspective of these stakeholders (and not from the provider’s perspective). They also facilitate transparency of assessment. Ideally such information should be linked to careers databases and, in particular to careers pathway information. We also note that in some overseas jurisdictions it is accepted practice to provide indicative wage / salary ranges that graduates might expect on successful completion of qualifications. This option might well be explored.
2 - 1 Support for the use of existing quality assured qualifications. It would seem illogical to do other than build on the considerable investment that has already been made in qualifications development. The inadequacies of the present regulatory environment do not necessarily mean that all work to date is invalid.
2 – 3 Support for the option of a percentage range within which local components could most usefully be added. This option, if implemented effectively, best allows for the principles of autonomy and accountability for institutions. It is also likely to be the cheaper option in terms of implementation. Up to a 30% quota for local content would seem a suitable percentage, but this will vary with field or domain.
2 – 4 There are significant issues around the moderation of assessment against local content. There are critical risks around maintaining academic standards in a funding system that is moving to reward course and/or qualification completion. We need to have confidence that moderation issues are addressed effectively by providers around their local content. We make the assumption that moderation of national components of qualifications will be maintained or enhanced.
3 The impetus for qualification review should be primarily driven by industry bodies. The value of prescribed periodic review for all qualifications is questionable. National standards setting bodies, in consultation with providers, should be in the best position to make judgements about whether a qualification remains fit for purpose. If providers have sufficient autonomy to adjust the local components of qualifications in response to demonstrated local needs, it may well be that qualifications may have extended shelf-lives: too often we fail to distinguish between the need to adjust curriculum and the need to revise qualifications. In the past there have been market drivers to default to the latter option: often simply to maintain apparent points of difference. We would hope these market pressures are likely to lessen as a result of these proposed changes.
3 – 5 Review of provider accreditation. The context for this question is not clarified in the consultation document. If NZQA has confidence in its new self-assessment and external evaluation and review processes, why should accreditation review be necessary?
4 - 1 We strongly support the change to strengthen and standardise qualification outcome statement requirements. This is critical. Learners need the best possible comparative information about the value of the qualifications in which they are considering enrolling. A unified qualifications framework should be the authoritative data source for all pre-degree qualifications and receive an appropriate level of investment to establish and maintain it. In order to be sufficiently informative, there needs to be scope for outcome statements for local components of qualifications to be varied by provider.
4 - 2 We do not support the use of national outcome statements as a means of regulating local content. Local content should be negotiated between providers and local employer and community groups as appropriate. Outcome statements should be used to provide accurate information about qualifications: their purpose should not be subverted into a device for regulating local content.
4 – 3 The development of meaningful outcome statements about educational pathways requires university participation in this review process. Diploma level qualifications should provide access to university study with appropriate credit recognition. Some faculties in universities have made significant progress on this already, but it has generally been done on a provider-to-provider basis. NZQA needs to facilitate the general principles for the development of these pathways in collaboration with CUAP.
5 We support proposals for a mandatory pre-development assessment stage, but they must be timely. Such proposals have the potential to fit in well with the business planning processes of TEOs. However, to do so, they must be conducted in a timely fashion to allow for the flexibility of response that is necessary for New Zealand’s redeveloping economy.
6 We support the proposal to strengthen recognised industry involvement in qualification development. The critical question here is around who is the “recognised” industry. Where a qualification is being developed with a local component to meet local employment needs, it will follow that local potential employers must constitute the “recognised” industry. There is not necessarily a tension between a national view of a qualification for 70% of content mediated by the ITO and a local view (which could be informed by the ITO, the regional branch of industry associations and the provider’s own industry advisory body) for the remaining local component. This gives an ideal opportunity for the provider to facilitate discussion between local and national industry perspectives, plus those of other stakeholders (e.g. economic development agencies) for the benefit of its local learners and their communities. In the medium to longer term, the adequacy of industry involvement must be measured by the employability and career progression of graduates from the qualification concerned. We would expect providers to be continually monitoring this as part of their self-assessment informing their own organisational development.
7 Clear information about the status of qualifications: again, this is strongly supported. We believe that NZQA has (and always had) a moral obligation to do this. It is important, however, from a past graduate’s perspective to identify the reason for a qualification’s closure. Completion of any qualification is a very significant personal investment: if a provider qualification is closed simply because it has been subsumed into a more flexible National Qualification, this is quite different from a closed qualification where the competencies are now obsolete. We would note in passing that, by their very nature, qualifications that have a significant capability component tend to have a longer “shelf-life” than qualifications purely based on competencies.
For the Ako Aotearoa Board
10 November 2009