Submission - National Qualifications Authority
Submission in response to the Discussion Document of the National Qualifications Authority of Ireland: Towards a National Framework of Qualifications
General comments
A key function of this framework is that it should "facilitate the availability of opportunities for access, transfer and progression" for all learners. The standard typical learner has little problem negotiating a route through to qualification. Problems arise, however, (in proportion to the degree of divergence from the usual route) for learners who have not stayed on the beaten track, or who have dropped out at some previous point in their educational career. These learners should be a focus of concern in developing a framework that will function well for all stakeholders.
Besides the issue of prerequisites to entry, the framework must allow for the possibility that a minimum knowledge or skill level normally assumed may not have been attained by all learners, and that consideration needs to be made to ensure that such non-standard learners will not be disadvantaged to a degree that would jeopardise their attaining award standard.
The concerns of "non-standard/minority learners" (ie individuals with a disability, or whose first language is not English or from an minority ethnic background) need to be addressed in any set of guidelines that arise out of the framework and therefore need to be considered at the establishment phase of this framework. An intercultural system needs to be designed to meet the needs of all learners. The Framework should enable the implementation of systems to mainstream equal outcomes for all learners irrespective of difference.
Question 1:
Principles underpinning the establishment of the National Framework of Qualifications.
Yes the framework needs to be grounded in a set of principles that are clearly articulated and accurately described. All of the principles referred to should be included.
The principles as presented are rather vague and could be presented more clearly. For example, as bullet points with each point elaborated more fully "this would make them more easily accessible and useful as reference points." These principles need to be useful if they are to underpin the establishment of the framework, and in order that a set of guidelines can be erected - using these principles as foundation -further down the road, which will be meaningful to all stakeholders.
The Framework should be constructed in such a way that will promote the principles of equality and inclusion within the education system.
The "Transparency" principle:
The key phrase here is "The framework needs to be understood by and accessible to all"..in order to support informed choices and realistic expectations on the part of learners etc.
This principle will support the further principle of equality of access for learners from minority ethnic backgrounds including Travellers, or who may have literacy difficulties.
The "Equality" principle:
This principle states: "It is vital that the framework be learner-centred, accessible to all learners and able to cater for all types of learning" and further states that: "Prerequisites for entry to awards need to "promote equality of opportunity and be made clear to learners."
This principle is of crucial importance for learners, particularly to learners from non-standard or minority backgrounds. It could, however, be elucidated further. In particular the concept of "equal opportunity" could be elaborated such that it clearly covers more than access alone and includes the learning experience itself and the learning outcomes for these individuals. This is vital for individuals from diverse backgrounds for whom access to learning opportunities and experiences in the learning context often fall short of satisfactory, and for whom equality of learning outcomes is rarely evident.
The principle should be stated in a way that firmly puts the locus of responsibility on the system or provider to become "learner-centred" rather than on the individual learner to fit with whatever learning opportunities become accessible." Prerequisites for entry do indeed need to".."promote equality of opportunity and be made clear to learners and [other] stakeholders", but so also is the learning experience itself and the outcome of such experiences answerable to the equality principle. This principle is particularly important in the context of establishing core standards to be acquired by learners, in terms of their relevance, appropriateness, means of measurement and assessment.
The "Relevance" principle:
The key point here is "The framework must also be relevant to the social, cultural and educational needs of local communities if all types of learner are to be catered for. This could be worded in such a way that offers unambiguous commitment to the principle of inclusion.
The "Comprehensiveness" principle:
This principle states "the framework needs to cater for all types of learner in a comprehensive way". Besides the issue of prerequisites to entry, the framework must allow for the possibility that a minimum knowledge or skill level normally assumed may not have been attained by all learners, and that consideration needs to be made to ensure that such non-standard learners will not be disadvantaged to a degree that would jeopardise their attaining award standard.
This principle could be worded in such a way that offers unambiguous commitment to facilitating and supporting the "non-standard" learner.
The "Flexibility" principle:
The statement that "The framework must be capable of facilitating changing needs and evolving contexts. The framework itself needs to be subject to review" is pivotal to the workability of the framework in the longer term. In the light of the increasing diversity evident in Irish society today, we need to build a framework that is flexible enough to accommodate this change and all that it entails (the word "inclusive" is again notable by its absence here). Given the rapidly changing social context here in Ireland and the diversity of cultural and other background factors for learners that will be availing of education and training opportunities in Ireland in the future, we need to ensure that individual curricula can adapt as can the central framework itself." The possibility that future changes will be needed to accommodate needs not yet appreciated must be woven in at the outset."
Chapter 6
Question 2: Process guidelines
Consultation:
If all stakeholders are to be consulted this should include the learners themselves. In view of the fact that minorities are often excluded by default as much as by design, it is important to ensure that the views of minorities are heard in this consultation process." The many existing or emerging groups who represent the needs and interests of minorities can fulfil this requirement, and should be involved in this consultation process. The guidelines should be drafted in such a way that ensures that this will in fact take place.
Inclusiveness:
The statement that "All learners should find that the framework has an award or sequence of awards relevant to their needs" is of considerable importance. The framework should ensure that all learners capable of achieving an award should be able to locate a route appropriate to their learning needs. This is not only a matter of access but of support for the needs of individual learners who may otherwise be excluded or experience discrimination, for whatever reason, on an individual basis.
Chapter 7:
We agree that the issues of access, transfer and progression are cornerstones of the framework, and we feel that the response should emphasise the importance of the principle of equality of opportunity in terms of access, participation and outcomes that support progression for all learners in this context. Besides clearly defined pathways there has to be a set of clear principles to ensure that standards are measured in such a way that supports equality of participation and outcomes for learners from all backgrounds.
Chapter 8:
The involvement of the sector is good and necessary to establishing core standards. Flexibility of approach in relation to entry standards is needed." The potential for facilitating progress on an individual basis with built-in flexibility should be emphasised, and a modular approach is preferable. It is essential to ensure that outcomes based on standards should be measured in a way that eliminates or minimises the possibility of discrimination or bias against the non-standard learner. Programme providers should have to account for any under-representation of minority groups. Portal awards are of particular significance in this regard." Methodologies for measuring knowledge, skill and competence should be scrutinised in regard to appropriateness for these "under-represented" learners. There is a responsibility to establish procedures for the assessment of learning that are equitable and reflect a commitment to the principle of equality for all learners, and the responsibility to fulfil this function vests in the awards councils.
The framework should address the issue of diversity in terms of learners' backgrounds and life experiences recognising that learners' cultural, language and other background factors can be an asset as opposed to an obstacle to attaining educational award standards.
An awards framework should clearly place responsibility on programme providers / institutions to make clear unambiguous information available to prospective learners as to entry criteria, transfer possibilities, award recognition and progression opportunities for continuing education and suitability for employability in the relevant sector.