“A well-articulated system is one in which there are linkages between its different parts; there should be no silos, no dead ends. If a student completes a course at one institution and has gained certain knowledge, this must be recognized by other institutions if the knowledge gained is sufficient to allow epistemological access to programme(s) that they want to enter.” (Minister of Higher Education and Training, Dr BE Nzimande, 15 February 2013).

This is a good introduction to the Draft Policy, providing a clear explanation of what the focus of the policy should be. “Epistemological” is somewhat out of place, but I guess it makes the statement sound more academic. I will comment only on paragraphs and principles where I feel that there might be room for improvement. It is not much, seeing that the Draft Policy is well researched and rather elaborate. Extracts from the Draft Policy are given in quotation marks.

“6. This articulation Policy will facilitate movement of learners between and within the three sub-frameworks of the NQF, and between institutions and also within institutions in order to enable access, progression and mobility.”

Comment: Paragraph 7 lists important reasons why the current ETD system does not promote or support an integrated NQF. To this can be added:

• Inability or unwillingness of QCs to cooperate and recognise curriculums and qualifications on different levels and fields in the NQF.
• Critical differences in the curriculum formats of especially HE and Occupational Learning (OL), making it impossible to achieve a smooth flow in learning from one to the other and to determine equivalence between HE and OL qualifications.
• Rigid value systems in QCs which lead to them being rather reluctant to discuss, listen to or accept the suggestions of other QCs.

“22. The scope of this policy extends to regional qualifications frameworks and bilateral agreements between countries to recognize each other’s qualifications.”

Comment: South Africa is probably the only country in the world using the OT curriculum format, making the determination of equivalence and cross-region/cross-country recognition almost impossible. The OT curriculum does not meet the generally accepted requirements for a curriculum, includes information that does not belong in a curriculum because it does not relate to a standard of learning and contains substantial duplication of the same information.

“Principle 8: Address exclusionary practices: Arrangements for articulation must not unfairly advantage or disadvantage either the students entering courses and programmes of study with credit transfer or those students who enter directly without credits for prior learning. The education and training system must be accessible to individuals who are out of work so that they can have the best possible opportunity to get into work or so that they can engage in productive labour in self­ employment opportunities.”

Comment: The current OL curriculum format makes it almost impossible for unemployed people to achieve an occupational qualification. There are other ways in which to gain practical experience and unemployed learners should not be handicapped with requirements (such as summative assessments in the workplace) before they can achieve qualifications. South Africa is not a developed country with low unemployment rates and we cannot adopt systems in use by such countries.

“Principle 13: Simplicity: The system must be a simple one with simple rules so that the educational and skills pathways are easily understood and accepted. Programmes must articulate and not institutions.”

Comment: Specifying that institutions must not articulate can convey the wrong message or, perhaps even create confusion about what is meant by articulation. Institutions must articulate because they develop learning materials and learning event plans and offer learning. Perhaps the statement “Programmes must articulate and not institutions” should be rephrased. Perhaps all the principles dealing with articulation should be supported with a clear elucidation of what is meant by articulation in the context of the document. Articulation means fitting the promotion of quality learning into a relevant context that applies on all levels and in all fields of learning. It is my impression that the concept is not used the same across the document, i.e. inconsistently.

“Principle 19: The curriculum must be modularized to enable and enhance the opportunities for people who work and learn to do so seamlessly and exit a module/short course with credits. This arrangement will also simplify the time­tabling process in TVET and CET colleges to accommodate two or even three sessions per day.”

Comment: This is an important principle because it promotes lifelong and efficient learning.

“38. Articulation affects learners not qualifications.”

Comment: A statement like this should be clarified. I, for one, do not agree with the statement. In fact, the same paragraph continues by discussing standards, not learners. Already at this stage in the document it was stated that articulation affects programmes and learners but not institutions or qualifications. I believe there are too many contradictory and questionable statements without elucidation.

“43. (i) Work with other government departments to remove outdated policies and legislation which hampers articulation.”

Comment: Excellent.

“54. The entry points for NQF level 2 must be clarified between SAQA and the QCs, and the sub-frameworks amended to ensure articulation routes can be implemented. It is proposed that the entry point for NQF level 2 pathways must be either Grade nine (9) or the General Education and Training Certificate (GETCA). The GETCA especially must ensure articulation pathways into TVET programmes offered at CETs and into the skills development programmes offered through the SETA skills development system.”

Comment: I am using this paragraph to illustrate a point that applies to quite a number of determinations. This paragraph related to NQF level 2 learning only. What would be the case with all the other levels of the NQF? In a Draft Policy that applies to the entire spectrum one should not refer to a single occurrence or level without indicating how or where it fits into the whole. Paragraph 57, for example, contains excellent suggestions. However, it relates to OL and TVET only, leaving HE hanging in the air.

Recommendations.

1. The guidelines and principles of articulation should at least encourage, if not insist on a curriculum format that lends itself to determining equivalence and supporting a CAT system.
2. All role players should accept the guidelines and principles set by DHET to achieve an integrated NQF.
3. All three QCs should accept and support SAQA as the coordinator of articulation between the three sub-frameworks of the NQF.
4. The Minister should provide SAQA with a measure of authority to ensure compliance with the guidelines and principles of articulation. Without teeth SAQA will achieve nothings and the QCs will continue operating in isolation.