One can probably site many obstacles in the way of an articulated NQF and not everybody will agree about which obstacles are the most important. Obviously the very fact that we have three sub-frameworks is already a problem although it can also be seen as a solution. After all, there are differences between the three sub-frameworks that call for different approaches to especially quality assurance.

An important difference between the sub-frameworks is the difference in curriculum format, brought about by the differences in levels, learning emphasis and target groups. However, we need to overcome these differences if we are to achieve an integrated system that is articulated to the education and training needs of the country. This brings me to a number of obstacles that we should address if the Articulation Policy is to make a constructive contribution to the quality of education and training in South Africa.

1. The Draft Articulation Policy sites the conceptual and organizational incongruities in the post-school education and training system as an important barrier to articulation. The main reason for it being a barrier is the difference between standards, as expressed in curriculums, between Higher Education (HE) and Occupational Learning (OL). HE curriculums and Technical and Vocational Education and Training (TVET) curriculums are sufficiently similar to achieve articulation. The question, therefore, is how the OL curriculum format can be adapted so that it will also fit in with the HE and TVET curriculum formats without damaging the unique content needs of the OL system. The following are suggested:
2. Ensure that the level descriptors for HE, TVET and OL are the same and that the three QCs accept them as such. There is, as far as I know, only one recognised set of level descriptors. However, when looking at the curriculums registered on the NQF there is a clear difference in interpretation between HE, TVET and OL. Articulation should start here, which will facilitate the determination of equivalence between HE, TVET and OL qualifications.
3. The knowledge modules (KM), practical skills modules (PM) and work experience modules (WM) in OL curriculums must be logically grouped together so that they will be comparable to HE and TVET modules or units of learning. This means that each set of KM, PM and WM should together form an exit level outcome that can be compared to HE and TVET exit level outcomes in order to determine equivalence. There is no doubt in my mind that that was the original intention but somewhere those responsible for writing curriculums started writing KMs, PMs and WMs separately and independently.
4. A second deficiency of writing KMs, PMs and WM separately, as if they constitute separate and individual learning interventions with different learning content, is that it would be necessary to develop separate learning materials for each KM, PM and WM for what should be one exit level outcome. This was not the original intention. Some Qualification Development Facilitators (QDFs) might still approach it correctly.
5. A particular knowledge module should provide the learner with knowledge that she or he will need to achieve foundational competence in a particular skill, expressed as an exit level outcome. The practical module following on the knowledge module should describe the foundational competence and serve as the foundation for the learner to achieve reflexive competence, which is expressed in and achieved through the work experience module. This is not the case if KMs, PMs and WMs are not logically grouped together to achieve a specified exit level outcome.
6. Moving away from the above, articulation will not be achieved if work experience is regarded as a requirement for certification in OL. Reflexive competence can seldom, if ever, be achieved during formal education and training. HE understands this, which is why it is not a requirement in HE curriculums. TVET sometimes have such requirements although it is seldom captured in a curriculum. Therefore, gaining workplace experience should not be a prerequisite for certification in OL.
7. Workplace experience and the resulting reflexive competence should be the responsibility of each employer, i.e. the industry. Employers or individual learners who completed qualifications without the burden of workplace experience can be tested by a separate assessment body, for example professional bodies or trade test centres, to qualify for a “level” or “status” certificate, after a period in which they gained work experience. These workers can, in addition to qualifications, achieve proficiency certification, for example: associate – expert – developer – master, or: technician – associate – practitioner – chartered practitioner – master practitioner, etc.
8. Removing the workplace experience component from the OL curriculum will dramatically reduce the burden on learning institutions, who seldom have the capacity to offer such training and the industry, who should focus on manufacturing or other income generating activities rather than training. It will, furthermore, provide substantially more open access to learning opportunities to the unemployed who otherwise will often not be able to complete their studies because they cannot gain workplace experience.
9. In terms of format, removing the workplace experience module from the OL curriculum will eliminate most of the unacceptable duplication that is currently typical of all occupational curriculums.
10. In terms of determining equivalence, removing the workplace experience module from the OL curriculum will enable SAQA and the QCs to more realistically compare HE, TVET and OL qualifications, thereby facilitating transferability of qualifications and credits from one learning sector to the next, including qualifications achieved abroad.
11. The CHE and Umalusi should also be more accommodating and less rigid about recognising occupational qualifications.
12. All role players, including the three QCs, SAQA and DHET should accept the merits of learning programmes smaller than full qualifications. Even single unit standards, or modules if you can’t accept unit standards, should enjoy recognition and respect. This implies that credits for less than a national qualification should be read into the NLRD, as was done for the last fifteen years. This will promote lifelong learning and the CAT system. Many of the objectives of the National Development Plan (NDP) and most of the objectives of the National Skills Development Strategy (NSDS) can be achieved by means of less than full qualifications. For example, mentoring and coaching in a multitude of contexts can be achieved by offering short courses focusing on just mentoring or coaching or a combination of the two. Credits should be granted for such courses and they should count towards full qualifications of which such learning programmes are learning outcomes.
13. I firmly believe that we are wasting time and a shocking amount of money by trying to find an alternative for the unit standards approach. The approach is a most flexible and logical process, ARTICULATED to the education and training needs of South Africa. After all, the Draft Articulation policy specifies that there should be no silos, no dead ends in education and training. Principle 19 of the Draft Policy reads “The curriculum must be modularised to enable and enhance the opportunities for people who work and learn to do so seamlessly and exit a module/short course with credits.” What is necessary is that the unit standards should be reviewed. The environment changes and with it the knowledge and skills needs in many fields of learning.
14. A greater measure of quality assurance in exams (summative assessments) is needed. This applies to all three sub-frameworks of the NQF, and, therefore also to all three QCs. Like universities and TVET Colleges, OL institutions should also prepare and conduct their own formative as well as summative assessments.
15. The Assessment Quality Partners (AQP) concept creates distrust between learning institutions and the QCTO. It would, therefore, be extremely difficult to implement successfully. To begin with, it is a requirement for OL only, which will create suspicion amongst HE and TVET colleges and QCs about the quality of learning and authenticity of assessment results, thereby becoming a barrier to lifelong learning and CAT. Secondly, with the curriculums not structured in uniform modules or exit level outcomes, AQPs will find it difficult to prepare exam papers and assignments that are aligned to the standards. This might well lead to legal action by learners and learning providers against AQPs. The problem is compounded because there is no policy on who may develop learning materials, which will lead to different learning institutions offering different content for the same curriculum. AQPs should rather be quality assurance bodies, like the old ETQAs, with the difference that they should have much better quality capacity and an Apex QA Body monitoring their standards and conduct. SAQA can become the Apex QA Body, thereby not creating new financial burdens for the state, or at least not much. One of the functions of SAQA as the Apex QA Body should be to act as an ombudsman between learning institutions and QCs.
16. The CHE/HEQC should accept their responsibility for quality assurance of HE institutions and not pass the buck by requiring HE institutions to quality assure one another. This applies to compliance as well as performance quality assurance. The current situation is unacceptable for obvious reasons of competition and lack of trust. Umalusi does this as does the QCTO, even though they do not have sufficient capacity. Many countries with well-developed education and training systems, such as Sweden, Denmark, Austria, the Netherland and the UK make use of neutral and approved private quality assurance bodies to do quality assurance. Why can’t we do the same?

To summarise, the following are necessary to ensure an effective Articulation Policy:

• Reduce the differences in curriculum formats for HE, TVET and OL.
• QCs should have mutual respect for one another and cooperate.
• Accept and recognise learning programmes smaller than full qualifications.
• Compliance and performance quality assurance should be conducted by independent private quality assurance bodies that have no vested interests in any learning institutions. QCs can do quality assurance if they are sufficiently capacitated with experts in quality assurance.
• An Apex QA Body should ensure that there are no obstacles against articulation between the different role players.