I fear that there are many Development Quality Partners (DQPs), Assessment Quality Partners (AQPs) and Qualification Development Facilitators (QDFs), not to mention the Quality Council for Trades and Occupations (QCTO) who will be angry at me for writing this. Therefore, please respond and tell me how stupid I am – if you can. The problem is that we, the learning providers, are the ones who are supposed to develop learning materials and to offer the qualifications once they have been registered. The learning materials must be aligned with the curricula and that is where the problems hit you in the face. I will not use a specific qualification as an example because it then might well be seen as an attack on a specific QDF. The QDFs that I know are great people, so I don’t want to hurt any of them.

To begin with, one will find that different people submit different evidence for prior learning should they be interested in recognition of prior learning (RPL). It is, therefore, unlikely that such candidates will have evidence that covers all the assessment criteria or learning outcomes in a qualification. That is why a holistic approach to RPL should be followed, meaning that the RPL assessor should judge against the purpose of the qualification, not rigid criteria.  Specifying in the curriculum that internal assessment criteria should be used for RPL makes the process inflexible with the result that the achievement of the qualification through RPL would be extremely difficult.

Secondly, any occupational learning process follows a logical growth path, beginning with a number of exit levels outcomes to be achieved. The achievement of each exit level outcome requires knowledge, practical skills and workplace experience. One should not have any of those three elements, typically expressed as modules, standing alone. The reason for this is that competence starts with practical competence, followed by foundational competence and then, after some time has lapsed, reflexive competence. This growth path needs to be supported by relevant knowledge.

Thirdly, for some reason knowledge modules, practical skill modules and work experience modules are treated as if they are separate units of learning when each group of three should be one unit of learning. The result of this is that, what in the old unit standard-aligned qualifications constituted one unit of learning, consisting of theory, (simulated) practical and workplace practical work are now regarded as three separate units of learning. Because of this the new QCTO qualifications often contain only about a third of the learning content of the old qualifications, leading to too many credits being given to too little learning.

The ideal would be to have an equal number of exit level outcomes, knowledge modules, practical skills modules and work experience modules. It is possible to have, for example, more than one knowledge module that apply to the same skills module or work experience module, but then this should be indicated, for example by using sub-numbers. What is not acceptable is that there are knowledge modules that do not fit in with any practical or work experience module. The same applies to practical modules and work experience modules. Believe me, there are such qualifications already registered on the NQF.

Learning should follow a scaffolding or building blocks approach (they are not the same). It, however, is not possible to develop learning materials that achieve this if the logical line knowledge module – practical skill module – work experience module does not exist. Of course creative learning materials developers will “invent” their own modules, or content, to close the gaps, thereby offering more than what the curriculum requires. This, however, creates new challenges, for example that summative assessment testing knowledge or skills that are not in the curriculum.

In closing, you cannot achieve exit level outcomes without satisfying knowledge and skills requirements in a logical, systematic and complete way. If you don’t believe me, try to develop logical and well-structured learning manuals for some of the new qualifications – you will quickly stumble upon obstacles.

Non-fiction is normally represented as fact. It is assumed that the information in such books are accurate and, hopefully, well-researched. Unfortunately writers sometimes regard their perceptions as the only truth. Everybody has the right to write a book about her pet subject, believes, militancy, fanaticism, paranoia, etc. However, a writer who claims to have done scientific research when it is clear from the contents of the book that this is not the case not only does damage to the perceptions of her readers (if they are gullible enough to believe what they read) but also to her reputation as an authority in a particular field. The following are mistakes in collecting and using data for a book that can render your book worthless and your integrity questionable.

1. Not satisfying your problem statement. The problem statement of a non-fiction book is often captured in the title or at least in the introduction. You must satisfy your problem statement if you claim to have done research. It serves no purpose collecting evidence, coming to conclusions and then not deriving any findings and recommendations from your conclusions.
2. Using biased and superficial sources of information. You can never come to an objective conclusion if your target group is not a representative sample of the population. Using only sources that agree with your preconceived opinion is unscientific and dishonest. Using sources of information that cannot give you expert information is sometimes necessary. However, you cannot come to any valid conclusions if you don’t consult experts and well-researched documents as well.
3. Bending the facts. The conclusions that you come to need to originate logically from the facts that you consider. You should not come to conclusions from only one or two sources of information. Your information needs to be corroborated by as many different reliable sources as possible. This is called triangulation.
4. Being vague about your sources of information. Writing “many people to whom I spoke said that…” or “my research showed that…” creates the impression that you are either not writing the truth or you are embarrassed, for whatever reason, to acknowledge your sources of information, especially the people to whom you spoke. You need to give proper recognition to your sources so that you readers can see (and judge for themselves) if your arguments and conclusions are realistic and valid.
5. Racism. The opinions of other people are not the only ones that can be labelled racist. Your opinion can also be racist even if you don’t think so. It does not help camouflaging your racist attitude behind innocent-sounding terminology. The writer of a book that I recently read wrote: “How dare a white person write a book on a black person?” My goodness.
6. Perceptual errors. We all make perceptual errors. However, when you deliberately make such errors to achieve your personal (negative) objectives you are misleading you readers and destroying any credibility that your research might otherwise have had.
7. Name dropping. It is necessary to recognise your sources of information, but it is unprofessional to just list names of important people without any indication of how they contributed to your book. You need to write what the “important person” said or wrote and then come to one or more conclusions on how what they said or wrote impacts on your problem statement.
8. Going on an ego trip. Don’t write a book as if it is your memoirs if it is not. You research should focus on answering your problem statement or hypothesis, not about how clever or important you are. It is also not the right time to gain political points by complaining (actually boasting) about how much your suffered, how poor your parents were, how unfairly life or other people treated you. A “me, me, me” attitude only shows that you suffer from an inferiority complex. It does not contribute to the quality of your research.
9. Repetition. Repeating the same argument over and over again does not make it true. Claiming on every tenth or so page that you did intensive research will not make your readers believe you if the contents of your book are clearly shallow, biased, vindictive, questionable, one-sided, subjective, negative, etc.
10. Generalising. Don’t write statements like “Everybody feels that…” or “The only people saying so are…” unless you can substantiate your claims with viable, valid, authentic and corroborated facts.

In closing, once you have finished writing your book you should ask yourself what positive contribution the book will make and to whom. You should have the courage to admit that it is your opinion and not an objective and scientifically researched piece of work if you did not do proper research. If your motives were negative, for example selfish gain, jealousy, hate, sucking up to somebody or some (often political) organisation, etc. then you should not have written the book to begin with.

RPL should never be a complex process. There are a number of steps (we propose thirteen to fourteen steps) that can be followed in any field of learning and on any level. You should read my book entitled “The Concepts and Procedures Governing the Recognition of Prior Learning” if you wish to offer RPL in occupational and vocational learning or “A Holistic Approach to the Recognition of Prior Learning” if you are involved in RPL on higher education (academic) level.

Different people have such vastly different prior exposure to any field of learning that it is not realistic to mark an RPL portfolio according to a checklist based on a curriculum or other standard. That is why a holistic approach should be followed, meaning, amongst other things, that you should determine if the candidate achieved the purpose of the qualification or part qualification for which recognition is sought. It is a subjective form of assessment and the assessor must be an expert in the field of learning. Keep in mind, however, that RPL is not credit for life experiences if it is not relevant to the qualification or part qualification.

Even when a holistic approach to RPL is followed, you will find that candidates seldom achieve all the requirements for a qualification or part qualification. This can, and should be corrected by means of top-up learning. Top-up learning, in turn, requires that the RPL assessor do a gap analysis while assessing the portfolio of evidence. Top-up learning should be planned to close the gap.

Private learning providers can make a substantial contribution to RPL assessment by TVET colleges and HE universities and colleges by, for example, training lecturers in RPL, providing universities and colleges with RPL assessors and facilitators, doing the administration of RPL projects, and many more. However, TVET and HE institutions must make sure that the private providers are expert in RPL in the field of learning in which assistance is needed before they close agreements with them.

RPL candidates, their parents, sponsors and employers mostly pay for RPL. However, if RPL is regarded as equal in status to formal learning as is suggested in legislation (The NQF Act No 67 of 2008, the Skills Development Act No 97 of 1998 and the Skills Development Amendment Act No 37 of 2008) and the Articulation Draft Policy, then surely funds should be made available from the National Skills Fund for RPL.

RPL should be cheaper than formal learning. However, it is not always the case because RPL often requires lots of preparation, the availability of expensive equipment and is mostly offered to an individual. Even if offered to a group, individuals will still submit different portfolios of evidence which requires special preparation, different marking methods and different top-up learning content.

RPL can make a substantial contribution to transformation and redress, especially because it provides people who were denied access to formal learning or, for whatever other reason, did not receive formal recognition for knowledge and skills, an opportunity to enter lifelong learning.

We are often asked by potential learners if they cannot do RPL rather than formal learning because it is cheaper and faster. Judging from their comments at conferences on RPL one gets the impression that organised labour is often under the impression that people can be issued with certificates and degrees without learning. RPL is not a quick and easy route for an individual to get something for nothing. Also, RPL is not an alternative to formal learning. RPL cannot replace formal learning and an individual can only obtain credits or a certificate if they did gain relevant knowledge and skills previously.

In closing, it is not the individual only who benefits from RPL. Learning institutions, communities, the economy and the country at large can benefit from it. It is, therefore, important for the government, the industry, learning institutions and quality assurance bodies to support and promote RPL.

RPL is an important element of an articulated NQF because of its strong impact on the credit accumulation and transfer (CAT) system. This is supported by paragraph 36 of the Draft Articulation Policy which reads as follows: “Both recognition of prior learning (RPL) and credit accumulation and transfer (CAT) are enabling mechanisms for articulation and must be primary focus areas when designing the articulation apparatus and mechanisms.”

RPL is often used to allow people access to further studies even if they are not issued certificates. This is a simple way in which to allow people who could not study further because of “dead end” qualifications an opportunity to re-enter lifelong learning.

An efficient post-school education and training system requires a high level of articulation within and between the sub-frameworks, learning programmes and institutions. RPL, if recognised by all three Quality Councils (QCs), can play an important role in bridging the gap between occupational learning (OL); technical, vocational education and training (TVET) and higher education (HE).

It should be possible to accumulate credits on any of the three NQF levels and transfer such learning from one level to the next higher level. In support of this argument, paragraph 6 of the Draft Articulation Policy reads as follows: “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.”

RPL can play a crucial role in promoting democracy, social justice and participation in the economy. Credits, certificates or just recognition of prior learning in any other form can and should lead to the redress of historical injustices, promotion in jobs, filling of vacant positions and access to further learning.

Paragraph 12 of the Draft Articulation Policy confirms the legitimacy of RPL as a method by means of which credits can be accumulated. ”SAQA is also mandated by the NQF Act, to develop policy and criteria, after consultation with the QCs for RPL, assessment, and credit accumulation and transfer (CAT) (NQF Act, Section 13 (1) (h) (iii). The QCs are mandated to develop and implement policy and criteria for assessment, RPL and CAT, taking into account the policy and criteria contemplated in the NQF Act.”

RPL will be a fully recognised way in which to accumulate and transfer credits and qualifications if all institutions established, accredited and/or registered in terms of the Higher Education and Training Act, The Continuing Education and Training Act and the Skills Development Act  recognise each other’s certificates to the extent that learners can continue their studies effortlessly from one level to the next higher level at public and private higher education institutions, technical and vocational education and training (TVET) Colleges, community education and training (CET) colleges, private colleges and workplace training centres and skills development centres. A measure of bridging training might sometimes be necessary. However, bridging training should not be so elaborate that it actually turns prior learning into formal learning.

There is one stakeholder that needs to rethink their attitude towards RPL in general and private learning providers in particular. They are organised labour and they are currently an obstacle in the way of people obtaining formal recognition for their prior learning. I’ve been at three conferences where representatives of trade unions clearly demonstrated a misunderstanding of the purpose and nature of RPL. They are under the impression, or perhaps pretend to be under the impression, that RPL is a way in which to obtain qualifications without learning. RPL is evidence of PRIOR learning – learning did take place, only in the past. Members of trade unions openly show their aversion against private learning providers. They don’t understand that the leaders in RPL are currently private learning institutions and that many public learning institutions actually still, overtly or covertly, resist RPL.

Equivalence should play a key role in the recognition of prior learning. Qualifications offered by different learning institutions are almost never exactly the same. RPL should provide for this, for example by giving credits for certain exit level outcomes while others still need to be achieved through bridging training before a full qualification can be recognised. Even just similarity between qualifications should be taken into consideration, for example by granting the students credits for an exit level outcome that is not offered by the learning institution considering RPL (principle 17). This is yet another reason why learning programmes smaller than national qualifications should also be recognised and credited.

To achieve principle 17, principle 18 (There must be a core curriculum for each subject in learning programmes) also needs to be accepted. Credits for the core curriculum must be achieved either through RPL or bridging training while other curriculums for subjects (the old elective unit standards come to mind) may be different from the qualification of the learning institution considering RPL.

In closing, the following are necessary for RPL to contribute to the articulation of the integrated NQF:

• All three QCs and their constituent learning institutions should agree on the nature and purpose of RPL and accept the process as a way in which to facilitate lifelong learning across HE, TVET and OL.
• A holistic approach to RPL should be followed. This means that RPL should describe the principles and values of human development and lifelong learning. As such it should consciously support the social purposes of RPL in relation to access, equity and redress, and strive to implement assessments in a manner that promotes dignity, confidence and educational opportunities for all candidates without eroding learning standards.
• Organised labour needs to review their agenda with RPL and discuss their attitude towards private leaning providers with them in order to facilitate mutual trust. SAQA or APPETD can arrange and act as facilitator for such discussions.

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.

“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.

In a response to a contribution on Thursday last week Sylvia Hammond mentioned a number of disruptive activities that is causing serious damage to all private learning providers, such as making use of anyone else’s training material or intellectual property without the permission of the originator, obtaining material and not paying for it, employing facilitators and not paying for their services, taking money and not providing the materials or service. This made me decide to write about something that has been bothering me for a long time already.

I am currently reading a book with the title How South Africa Works and Must do Better, written by Jeffrey Herbst and Greg Mills. They wrote that, when unhappy, trade unions strike, the government make new laws and businesses invest offshore and stop employing people. In a nutshell, everybody seems to use disruption to get their way.

This article is about how disruption impacts on the achievement of National Skills Development Strategy (NSDS) and National Development Plan (NDP) strategic objectives and how role players in ETD misuse and protect themselves against the disruption.

It is not wrong to use disruption to gain a competitive advantage. However, what is wrong is when the disruption creates more damage than good for the community.

Today many new businesses gain a competitive advantage by offering their customers a new and different business experience. They often use new technology while at the same time setting new standards for expectations, conditioning customers to think differently, thereby offering them a new experience. This is constructive disruption. What we often have is destructive disruption.

The unit standard-based occupational learning qualifications are being replaced by curriculum-based qualifications. So far the new curriculums that I saw are most certainly not an improvement on the old ones. Furthermore, the concept of having learning providers do formative assessment while external bodies are made responsible for summative assessment can, in my opinion, destroy occupational learning in South Africa.

Some private providers and SETAs misuse the confusion about the education and training system to gain a monopoly in certain fields of learning for themselves. For example, private providers will arrange workshops or communicate directly with their clients, telling them that current qualifications are no longer valid and that they offer the replacements, even though the new curriculums are not even registered yet. Or they will disregard the credits for qualifications and offer a one year qualification in 21 days because they know the quality assurance bodies (do they still exist?) can and will do nothing to stop them. Or they “invent” new learning programmes by grouping a number of valid and expired unit standards together and then calling it a fancy name.

It looks like quality assurance bodies sometimes use disruption to dodge doing their work. Applications for accreditation are lost, they deny ever receiving it, ask for the same materials again, set new criteria halfway through the process, give negative feedback without even reading the applications. Accreditation, that should not take longer than five days, takes as many as five years.

Then there are those who sell “fully aligned” learning materials at prices that are so low that the person who purchases the materials should have known that it is a hoax – they actually get what they deserve. The learners, however, are stuck with the disruption.

More damaging than even students who riot, set campus buildings and works of art on fire, destroy monuments, etc. are people who pay or accept bribes.

I can continue sighting examples of disruption in private and public learning that will make you weep. Well, not really because I am sure you all know what is going on. The point is; if the quality assurance bodies, the government departments, organised labour, private and public learning institutions and the industry continue disrupting the educational system for any reason other than to promote and protect the interests of the learners, the entire system will eventually collapse.

In closing, dust the ring binders off in which you filed the NSDS and NDP and see how many of the strategic objectives listed in them will never be achieved because of the disruption of the ETD system.

Many learning institutions often resist quality assurance of education and training because of the attitude of quality assurance bodies; excessive demands on the time and funds of the universities or colleges; the perception that such bodies violate the academic autonomy and freedom of the learning institutions, fostering a compliance culture; managerial and political intrusion in academic matters as well as fear that quality assurance might damage the good reputation of the university or college. In short, role players in education and training do not trust one another.

I cannot think of a system where the interrelated elements are more tightly linked and interdependent than the issue of trust. Without trust no education and training system can ever deliver quality learning and without quality learning people will not trust one another. Even more, all stakeholders in education and training are equally responsible for ensuring that quality learning takes place and for demonstrating that they can be trusted.

Everybody must work hard and focus on the achievement of the best quality learning results possible. It does not matter where one starts with who is responsible for establishing a culture of trust; the end-result will be the same.

Quality assurance bodies need to demonstrate to learning providers that they can be trusted to play a professional supportive role rather than to adopt a punitive stance or to promote motives other than the promotion and protection of the interests of the students. The role of quality assurance bodies is crucial in improving mutual trust in education and training provision, as they also influence mobility and lifelong learning.

Learning institutions need to demonstrate to quality assurance bodies and the students that they are serious about providing quality education and training. It is only reasonable to expect that quality assurance bodies and students will adopt a trusting attitude to education and training providers who show that they are serious about investing in the youth of the country, who deliver a professional service and who treat their students with integrity.

Students need to show learning institutions and their employers or future employers that they are sincere about gaining knowledge and skills that will prepare them for a future career and lifelong learning.

Employers need to gain the trust of students by supporting them financially and by allowing them time and opportunities to study if they are already employed.

Co-operation is a prerequisite for trust and trust is a prerequisite for co-operation. It is vitally important if we are to establish a healthy quality culture in education and training that the different role players must trust one another. The value of co-operation and trust are lost in a system where quality assurance is regarded as a form of punishment. Even worse, co-operation is not even possible where universities and other learning institutions are misused for the promotion of political agendas.

Setting the example is important for the establishment of a culture of trust. The quality assurance manager, educator, employer or government official who expects students to be trustworthy should set the example by trusting them and by being trustworthy.

Any role player in education and training who does not demonstrate trust creates confusion, uncertainty and fear. All measures to decrease or eliminate fear promote trust. All trust-building measures also prevent or at least reduce fear. Unfortunately it seldom works to expect other role players to demonstrate trust first before you will respond in kind. All role players should act in a manner that instils trust without waiting for anybody else to set the example.

Open communication is a prerequisite for trust. Trust and open communication can only be established if all who are involved in education and training are willing to work hard and to focus on quality education and training.

In closing, trust is the foundation of quality education and training. Trust can be broadly linked to all the other elements of a healthy quality culture and everybody who is involved in education and training, be it as students, educators, quality assurors, employers or government must co-operate in the promotion and protection of the interest of the students.

Yes, we are living in interesting times and the world economy is in serious trouble. Private ETD providers are struggling. It is alleged that corruption in government on all levels has finally caught up with those who are involved; government is rerouting National Skills Funds, which is supposed to be used for occupational learning and job creation, to universities; government is said to have instructed their departments and parastatals not to give contracts to any business who are not at least 80% black owned, regardless of their BB BEE status; quality assurance bodies still do not perform as required, etc.

Ironically corruption is escalating because many private ETD providers seem to think that they will survive through bribery. Some government officials are capitalising on this new opportunity to earn lots of money easily and fast. Only last month a senior government official visited me. She told me that she had Rm1.7 left in her skills development budget. She had to spend it before the end of the financial year and she would like me to submit a tender for the training. I’ve had many such offers over the years and I know how they work. They will not ask you for a bribe directly, but if you don’t offer some kind of “finder’s fee” you will not hear from them again. They make the same offer to a number of providers and the one who offers the bribe gets the contract. Needless to say, I never heard from her again.

All government officials are not corrupt. The other day at a church function (nogal) a man asked me what I do for a living. I told him that I own a private training company. He then asked me if I do business with government. I replied that most of our clients are government departments. He responded by insinuating that my business (read I) must be corrupt if I do business with government. I did not even try to convince him that many government officials are still honest and concerned about quality. End of discussion.

Fortunately there are still people in government who are honest and who care about quality. Yes, we also lost some clients. Ironically some of those who expect a bribe come back accepting that we will not pay them a bribe. They still want quality training. Then there are those, and they have been our clients for many years, who do not even think in terms of a bribe. They use our services because they know that they will receive quality.

One SETA, who some years ago decided not to give us any further learnership contracts because we are not sufficiently back owned, even though we have a level 4 BB BEE rating, gave the contracts to black owned providers, some of them not even accredited, on condition that we help them.

An interesting result of this is that the status of our certificates increased substantially. We even get learners who ask if they can swop their certificates, issued by other learning providers, for Mentornet certificates. Of course we don’t do this, but it is good to know that our certificates are valued.

One gets to know people in government, especially quality assurance bodies, D HET and SAQA, who have lots of integrity. They respect us and we respect them. Birds of a feather, you know… I wish I could mention a few names, but with things being as they are one can well set them up as targets for those who work in the dark.

In closing, this year is already a difficult one. All businesses, including private ETD providers, will need to be really creative if they are to survive. Perhaps those who join the corrupt might perform well, but they might also end up in jail. And once you start being dishonest there is no turning back. If you still feel that you can only survive by being corrupt, then go ahead. The choice is yours.

It is interesting to see how different countries or groups of countries adopt different strategies to ensure good quality education, training and development (ETD). Some seem to achieve remarkable success while others just don’t seem to make it, or care. Then there are those where political agendas ruin the ETD system of the country. South Africa currently faces immense obstacles of which many of you are probably aware. In this article I will suggest a strategic approach that should help us perform better. Others might be interested in my suggestions even if only to feel good about how well ETD is conducted in their countries.

To begin with, quality assurance should rest on a strategy that is articulated to the needs and context of the country. This should start with a strategy for early childhood development and gradually progress to youth development and adult education and training. All of this should fit into, or form part strategies of what one can call a community development strategy. Development should start at an early age already and the stronger the foundation is the better will the end-result be.

Coherence is one of the most important prerequisites for an integrated national strategy for quality assurance. Quality assurance bodies and learning institutions on all levels should have the same frame of reference. The worst possible situation is where different quality assurance bodies are in competition with one another and where individuals in quality assurance bodies set their own quality criteria without consulting anybody and without there being anybody to monitor and control the process. Coherence can be achieved by developing a national quality framework which is supported by lower level strategies right down to the individual learning institutions.

A strategic approach to quality assurance is served best if top-level quality assurance bodies initiate the process by formulating policies and procedures to be supported by lower level quality assurance bodies in a chain reaction that ends at the ETD provider level. This does not mean that higher level quality assurance bodies are exclusively involved in strategy formulation, while lower level quality assurance bodies and ETD providers are exclusively involved in the implementation of strategies. There is, however, a shift in emphasis with higher level role players being more involved in strategy formulation while lower level role-players are more involved in the implementation of strategies.

ETD strategic planning should support human resources development and employment strategies on all levels. This can be achieved if ETD strategies are demand-led on national and industry levels. The quality assurance system should be aligned with the overall strategic goals of the country as well as the industry. This is achieved by determining skills needs at least in cooperation with the industry, i.e. employers if they don’t specify their skills needs, and transforming such skills needs to human resources development strategic objectives, which are integrated with the overall strategic objectives of the organisation.

Government should not dictate skills needs because it can easily lead to the manipulation of the ETD system to achieve political goals. The industry should decide what their scarce and critical skills needs are and government should have bodies, a system and a budget in place to satisfy the needs. Skills needs are the demand for ETD that the industry brings to the attention of learning institutions either directly or via quality assurance bodies. Demand-led quality assurance is a good example of a strategic system where the education and training strategy supports the strategy for the economic growth of a country. It normally aims at transforming the education and training system so that it offers the highest quality and value, and equips young people and adults for employability and personal fulfilment.

A demand-led quality assurance strategy means finding an optimum skills mix to maximise economic growth, productivity and social justice and to consider the policy implications of achieving the level of change required. Government policy and the resulting legislation can easily become an obstacle in the way of demand-led education and training. In their book entitled How South Africa Works (Pan Macmillan South Africa 215: 88) Jeffrey Herbst and Greg Mills wrote that organised labour and the government strategies that do not support skills development and employment can lead to small businesses doing everything in their power not to employ people, while big business invests offshore to protect themselves against uncertainties.

Implementation is the process by means of which the quality assurance strategy is put into practice. It is essential to establish and uphold key principles that underpin the implementation of the planned actions in order to ensure effectiveness in achieving the goals and objectives which have been planned. Such coherence may be achieved in many ways. Funding incentives, the provision of procedural guidelines at the local level, building the capacity of key players on quality issues through ETD, or a combination of internal quality systems at provider level with external inspections, for example, may be used.

In closing, the following are requirements for a quality assurance in ETD:

1. A system of mutually-supportive quality assurance strategies at government, provincial or regional, quality assurance body and ETD provider level.
2. Coherence in terms of standards and quality criteria on all levels.
3. Employers that bring scarce and critical skills needs to the attention of government.
4. A government that supports the provision of quality ETD rather than to misuse ETD to achieve political objectives.
5. A system of monitoring and control to prevent individuals and bodies from misusing quality assurance for purposes other than quality ETD.
6. Legislation that promotes and supports quality ETD.