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Submission to the Australian Qualifications Framework
Strengthening the AQF Consultation Paper August 2010
COPHE’s Response
COPHE has already engaged with the Secretariat on the AQF Review, and provided a previous submission. We endorse the need for a strong and clear Framework to support the quality of Australian education, and understanding and acceptance of the qualifications from national and international communities and employers.
However specific significant issues remain with the July Consultation Paper, and the draft Policies. COPHE cannot support these documents in their present form.
1. Role of TEQSA
The detail of the AQF needs to be developed in conjunction with the role of TEQSA; the draft AQF paper endeavours to set rigid, inappropriate and detrimental regulatory standards in isolation from the eventual regulator.
Recommendation: that AQF continue todevelop the levels’ criteria and descriptors, but leave issues such as the nomenclature of degrees, the interpretation of “typical” notional duration to TEQSA; phase the implementation of the AQF with that of TEQSA. This would allow the regulator to consider issues such as delivery modes, international comparisons, practicum experience and other professional requirements, and the views of external accreditation bodies when evaluating individual providers and courses, including nomenclature and notional duration
2. Non award enabling, pathway, & qualifying programs
COPHE raised this issue in our previous submission and consultations, and whether they should be included in a revised AQF.
At present there are many Bachelor enabling programs that are self accredited by those institutions with such powers, including universities. Enabling programs are recognised under the Higher Education Support Act 2003, and more are being introduced to support the government equity participation targets following the Bradley Review. They fulfil a necessary social and academic need in preparing students from non traditional backgrounds for tertiary study. NSAIs cannot currently access accreditation of such programs.
Most enabling, pathway and qualifying programs do not receive credit towards the degree; this enables them to be pitched at pre-university level, matched to the needs of the students, and with better eventual outcomes. (We are aware of one such access program where the institution has reduced the level of the content and assessment tasks, with better outcomes in both the progression to the Bachelor programs, and also the success rates in those programs).
Enabling courses for undergraduate programs are not explicitly accommodated in the AQF, even though they are defined under HESA [1] and may attract government support (FEE-HELP etc). Current government interpretation is that an enabling course may give limited credit towards the HE qualification, but this should not be its main purpose. It would therefore be inconsistent to accredit them at level 5.
It is imperative that enabling programs are not compromised in the AQF Pathways and Linkages Policy (which we believe is deeply flawed and further comment on later).
MCTEE recently endorsed national accreditation standards for international Foundation Programs. http://www.aei.gov.au/AEI/ESOS/NationalFoundationPS.htm
Many of these are accredited as non award, although some are accredited as Certificate IV. Most would be regarded as AQF level 4, but do not receive credit transfer towards the degree. Concern has been expressed by some of our members that the off shore pathway programs offered, reflecting the needs of students and different cultures, will often vary from the program they offer in Australia.
To achieve the Bradley low SES participation targets, the HE sector is already developing more enabling programs that target the needs of particular groups. There are currently no external accreditation mechanisms for such programs, and to date most State/ Territory authorities have been reluctant to accredit award courses at Cert IV or Diploma level that are not based on a VET Training Packages. They are likewise reluctant to accredit as a HE Diploma, as they do not fit HE Diploma criteria.
The HE sector would benefit from a clearer accreditation mechanism for enabling and qualifying courses, which are at present non award, outside the AQF. We suggest that somewhere in the AQF it is noted that enabling courses for Bachelor (level 7) should meet the level 4 outcomes, and Masters and Doctoral qualifying programs should meet level 8 outcomes. This would give more certainty and transparency to these programs, and guidance for accrediting authorities. The duration and standard of compulsory enabling programs should be considered by a regulator when assessing the notional duration of a course, eg a 3 year Bachelor degree + Masters qualifying (which may have common features with a level 8 Honours year or Grad Cert) leading to a 1 year Masters.
3. Notional Duration of qualifications
While we do not object per se to the concept of notional durations, we argue that these need to be interpreted flexibly, and exceptions allowed where the accrediting authority deems appropriate. In VET, qualifications have been developed through Industry Skills Councils to meet the needs of the industry; and in practice durations within the same qualification level can vary enormously. The notional duration also needs to recognise the principle of competency based training, where students can progress at different rates.
The AQF claims to have been charged with “cleaning up the mess” over variation in Masters degrees, however, we think there has been a gross over-reaction. While no reputable institution would support a 6-month stand alone Masters, many of one year duration are well established, recognised internationally, and endorsed by external professional accreditation bodies. The relevant criteria is not the duration of the preceding Bachelor degree, but the knowledge, skills and experience of the student, as well as the industry and professional recognition of their degrees. A 3 year Oxbridge degree would be regarded internationally as having superior graduate outcomes to most 4-year degrees elsewhere.
Many existing one-year Masters are recognised for official accreditation by state and national bodies such as the NSW Institute of Teachers and equivalents, Institute of Engineers, Australian Nursing and Midwifery Council, CPA Australia, Australian Computer Society and various health and fitness industry bodies. These provide valuable professional development to meet the needs of Australian industry.
Lengthening some of these Masters to 2 years would also render them uncompetitive internationally, with adverse consequences on the international education sector, and also the skilled migration program which supports many of the professional occupations on the Skilled Occupations List [2].
The AQF needs to recognise current Australian and international practice, as well as professional body accreditation, and allow more flexibility in the notional duration of Masters programs.
4. Pathways and Linkages Policy
The draft Policy requires minimum base levels of credit transfer, which are inappropriate and unrealistic. If implemented, they will compromise academic quality, and lead to unnecessary student failures. They will require nothing less than a complete restructuring of the great majority of Bachelor degrees, with doubtful academic outcomes, and possible inefficiencies, such as the unnecessary lengthening of degrees to accommodate the mandatory credit transfer.
COPHE supports flexible pathways that enable access to continuing education, and encourage students to move between levels and traditional sectors. However institutions and accrediting authorities need flexibility to be able to best match:
· the learning needs of the students, to enable them to succeed at each stage
· coherent and existing degree structures that lead to positive individual development and employment outcomes
· the specifications of professional national and international accreditation bodies.
One of the strengths of Australian HE is its plurality to meet varied individual, professional and national needs. Some dual sector institutions embed VET qualifications within the degree structure, and students are able to move seamlessly between stages. Other HE institutions offer dual qualifications with TAFE to enhance theoretical basis and professional standing, while providing at the same time the practical skills for immediate employability.
The existing VET competency based training structure has been developed in consultation with industry; internationally this process is well regarded, and is being copied elsewhere. The outcomes of competency based training are fundamentally different to those of HE, although they may be complementary in particular occupations.
COPHE vigorously opposes the imposition of the proposed credit transfer base levels in a blunt “one size fits all” approach, which seems to be driven by ideology, without due recognition of the benefits of the existing flexible arrangements. Even within the same field, and within the same dual sector institution, a Diploma does not always attract one year’s credit towards the corresponding Bachelor degree; the institution and accrediting authority recognise the different outcomes between the two qualifications.
COPHE would support a document in the form of a Good Practice Guidelines with desired or indicative base levels of credit, which allows institutions, accrediting authorities and professional associations to have flexibility in structuring courses to meet their respective needs and those of their students, rather than attempting to regulate in an excessively prescriptive manner.
We suggest also some consideration be given to indicating an appropriate maximum quantum of credit transfer; we have seen an advertisement from a VET provider promising 2 years advanced standing from a one year Diploma of Business towards a Bachelor degree.
The draft Policy mandates a base level of 33% credit for a Diploma towards a Bachelor degree. For many 4 year professional Bachelor degrees, this would represent 1½ years of the degree. Such credit would not be accepted by professional registration bodies, and would not be accommodated within existing degree structures.
For example, many Medicine degrees (MBBS) are classified as Bachelor level, whether they are direct or graduate entry. What is meant by a qualification in the same discipline? Does the draft Policy require that a Diploma in a health discipline would command 1½ years credit, and any Diploma in any field, one semester credit towards a 4 year graduate degree? Or 2 and 1 years credit respectively towards a 6 year direct entry Medicine degree? We have to think it unlikely this would be acceptable to the Medical Board of Australia, which is entrusted with protecting the consumer in this instance. There are many other inconsistencies with professionally accredited degrees in other fields.
We regard the draft AQF Qualifications Pathways and Linkages Policy as fundamentally flawed on this point, quite unacceptable to many of our members, and not in the best interests of the quality of Australian education, the community or our students. We urge further genuine consultation on this point.
Extract from AQF draft Policy
2.2 Base levels of credit transfer for completed AQF qualifications will be awarded to students, as follows.
2.2.1 Qualifications in the same discipline:
Completed qualifications at level 4 will result in 10% credit towards level 7 qualifications
Completed qualifications at levels 5 and 6 will result in 33% credit towards level 7 qualifications
Completed qualifications at level 7 will result in 50% credit towards levels 5 and 6 qualifications
2.2.2 Qualifications in a different discipline:
Completed qualifications at levels 5 and 6 will result in 10% credit towards level 7 qualifications
Completed qualifications at level 7 will result in 10% credit towards level 5 and 6 qualifications.
(Note: Level 4 Certificate IV; Level 5 Diploma; Level 6 Advanced Diploma, Associate Degree; Level 7 Bachelor Degree)
5. Nesting of Graduate Certificate, Diploma and Masters Degrees
At present many HE providers offer Graduate Certificate and/or Diploma awards within a Masters degree. This suits the professional development of many domestic and international students who may not wish initially to commit to, or be accepted directly into a full Masters. It also provides an exit qualification for those students who do not complete the Masters degree, for one reason or another. Often the awards share common subjects and assessments.
There are reports that the AQF could restrict such flexibility within such course structures. COPHE strongly opposes any restrictions; as contrary to the objective elsewhere of flexible pathways which encourage ongoing education and mobility between AQF levels.
CONTACT DETAILS
Council of Private Higher Education Inc.
Suite 244
813 Pacific Highway
Chatswood NSW 2067
Executive Officer – Adrian McComb
Phone (02) 8021 0841 Fax (02) 8021 0843 email amccomb@cophe.edu.au
[1] "enabling course" means a course of instruction provided to a person for the purpose of enabling the person to undertake a course leading to a * higher education award, but does not include:
(a) a course leading to a higher education award; or
(b) any course that the Minister determines is not an enabling course for the purposes of this Act.
[2] http://www.immi.gov.au/skilled/general-skilled-migration/pdf/new-list-of-occupations.pdf
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