AQF Submission June 09

COPHE Submission on the Proposal for Strengthening

the

Australian Qualifications Framework

The Council of Private Higher Education (COPHE) supports the timeliness of a review of the AQF and appreciates the opportunity to make this submission. We note that the AQF has been in place with minor changes since 2001 and acknowledge that it has served Australian education well. Since 2001, industry needs and international benchmarks have evolved. The original AQF brought a consistent approach to training and education awards, and facilitated recognition and articulation between sectors. These now need to be updated and promoted further. In particular and as observed in the paper, there is room to improve the consistency of the descriptors across sectors.

The Council of Private Higher Education (COPHE) is an association whose members are independent institutions in the higher education sector. Its role is to provide a voice for private higher education providers that are not public universities, to raise their profile and promote public policy that recognizes the contribution made to higher education by the private sector.

The COPHE constituency sits unambiguously in the higher education sector, offering courses taught and accredited as equivalent in level to those offered by public sector universities. Universities in Australia are self accrediting and the majority of COPHE member institutions, accredited for higher education by state and territory jurisdictions, are non self- accrediting institutions (NSAIs).

While some COPHE members may be dual-sector, the primary focus of the Association, and its members, is policy that impacts higher education.

In considering our response to the Strengthening the AQF Proposal it occurred to us that our NSAIs are probably much more familiar with the AQF than their self- accrediting public university counterparts, a situation driven by the fact that each course offered by an NSAI must be carefully matched to the AQF through on-going accreditation cycles.

Objectives that COPHE members would endorse include:

Improved transparency and recognition of what qualifications mean amongst employers, trainers and within the general community
Greater mobility of students within and between conventional sectors to provide flexible responses to changing technology and labour market needs, through clearer articulation pathways and recognition of total learning
International alignment of qualifications and descriptors to enable global recognition and portability, for the benefit of individuals, industries and our own domestic, international and transnational education sectors
An accreditation mechanism for courses that currently sit outside the AQF as “non award”, particularly some HE pathway and enabling courses, some of which receive Commonwealth funding where offered by universities. At present such courses may be self-accredited by institutions with such powers, but non self-accrediting providers have no accreditation mechanisms and therefore cannot offer them. Proposed new Foundation Program standards are very limited in scope.
A genuine single and consistent national accreditation and quality assurance system for post school training and education, not the 8 different interpretations currently experienced by the sector.

We note that the MCEETYA Protocols for Establishing Australian Universities state “Australian Universities are self- accrediting and deliver higher education qualifications that comply with the Australian Qualifications Framework”.

A key and overarching concern for our members who are NSAIs is that there is no mechanism to accredit courses outside of the AQF and the ELICOS and Foundation Program standards (proposed). Accreditation is required for CRICOS listing (to enroll international students) and to receive Commonwealth HELP funding. Universities presently can accredit such non award courses.

It may be a case of ambiguity in the interpretation of the MCEETYA protocols, however many awards offered in the university sector are either not compliant with or non existent in the AQF.

Proposal 1

The objectives of the AQF are aligned with the policy goals which it is designed to underpin and support.

Question 1

What changes should be made to the existing statement of objectives of the AQF to reflect national education and training goals?

We believe the objectives as currently stated are still relevant, but may be made more explicit to support the general objectives above, in particular clearer RPL and international recognition and portability.

A prior question however would deal with how the AQF objectives can be known, recognized, and acknowledged by self-accrediting institutions, and not just non-self-accrediting institutions!

The latter find ignorance among senior university staff at times; for instance,

· External Review Panels of various jurisdictions for accreditation or re-accreditation;

· Registrars and Deans of Universities who contact NSAIs when their graduates apply for post-graduate enrolments;

· AUQA Auditors who ask NSAIs “who accredited your degrees?”!

As noted above, the MCEETYA National Protocols require institutions which offer Australian higher education qualifications to comply with the AQF higher education titles and descriptors. Yet, according to Gavin Moodie (“Don’t let Masters slip down”, The Australian 19 November 2008):

“All Australian universities extensively breach the Australian Qualifications Framework. That's not news, as universities mostly ignore the framework. But it demonstrates a systemic failure of quality assurance and the lack of national maintenance of standards in higher education. … The Australian Universities Quality Agency has consistently declined to assess the standard of Australian degrees or even the relative standards of the Australian higher education system, although this is one of its objects. However, the agency claims to assess universities' compliance with the national protocols for higher education approval processes, including compliance with the AQF. Some of its reports occasionally comment on a university's compliance with the AQF … [this] contrasts with the approach of state and territory higher education accrediting bodies, which are much more vigilant and consistent in applying the AQF. The state bodies accredit non self-accrediting higher education institutions, most of which are private … which puts them at a clear disadvantage vis-a-vis the self-accrediting but non-complying universities.”

Having said that, the AQF objectives are actually very useful in practice for curriculum development in the NSAIs both

· in level of content; and,

· in ensuring that attention is paid to the generic skills and attributes in appropriate subjects within a course.

Where the AQF objectives could be more useful on a cross-sectoral basis is in credit transfer. By cross-sectoral, we here mean transfer between either

· VET and HE, or

· NSAIs and SAIs.

Credit transfer has bedeviled tertiary education informally for many years, and formally for almost twenty years with attempts by the former AVCC to unravel the issues (one such being led by Professor Gus Guthrie in the early 90s). The AQF Proposal rightly draws attention to international developments, particularly the Bologna process, which are affecting institutions and individual students within Australia.

Our view would be that if it was only Australia that was affected, then let us continue to stumble on with a variety of interpretations of the actual meanings of credit points, but with post-secondary education becoming more global with more than lip-service being paid to memoranda of understanding, it is now important that there should be more genuine opportunities for mobility within Australia.

In this regard too it would be useful if there were common parlance among the jurisdictions within Australia.

The release of the Draft AQF National Policy and Guidelines on Credit Arrangements is therefore a welcome development. Common parlance among the jurisdictions within Australia, not only for the meaning of different forms of credit”, but also for such other common terms as “subject”, “course”, “award”, and even “registration” will start to address the significant challenges in credit transfer. This must not be interpreted as an attempt to impose uniformity on universities which prize their autonomy, but a recognition of the increasing mobility of students within the post-secondary environment in Australia.

Proposal 2

The AQF is redesigned as a framework of qualifications based on a taxonomy of learning outcomes and explicit reference levels with a measurement of the volume of learning

Proposal 2a

A learning outcomes classification or taxonomy is developed as the basis for the qualifications descriptors in the AQF.

Question 2

Should an explicit taxonomy of learning outcomes be used consistently to describe all qualifications in the AQF?

Yes, while capturing the features of the various levels and qualifications.

For NSAIs the more explicit the taxonomy the better, because an explicit taxonomy enables them to be more confident of the

· standards of performance of their students, and

· levels of achievement of their awards.

This is so because NSAIs often

· have nested undergraduate awards (HE Diploma, Associate Degree, Bachelor Degree), and

· admit VET Diplomates from

o their own courses if dual sector and/or

o TAFE Institutes or other VET providers, especially with the recent rapid increase of articulation arrangements in connection with FEE-HELP for VET.

Pertinent to this question are also

· potential development of TEQSA, and

· the currently circulating AUQA discussion paper, “Setting and Monitoring Academic Standards for Australian Higher Education”.

Question 3

If an explicit taxonomy of learning outcomes is used, will students and employers be better served by Option A or Option B?

Proposal 2b

AQF qualifications are organised within the AQF by an explicit reference levels-based structure.

We would prefer Option A because it is difficult in practice to distinguish, let alone separate, the recognition of generic skills from their context within a subject or course. Furthermore, given the rather limited view of competences at the VET level arising from the Competency Based Assessment processes associated with the Training Package movement, one could question why the post-Herbartian triad of “knowledge/skills/attitudes”has been changed, since the generic skills are very dependent on the attitudes of the teachers and the ambience of the institution.

Attitudes make the difference if genuine attempts are to be made to help students acquire generic skills, particularly if these skills and attributes are not formally measured or unless sophisticated assessment processes have been developed to recognise them.

Furthermore, if the international trend is to Option A, then it should be supported.

Question 4

How could explicit level descriptors for each AQF level enhance Australian qualifications and their use?

Consistent with the objectives above, we believe they would enhance transparency for students, providers and employers, leading to clearer recognition and articulation, and international recognition and portability.

In order to enhance Australian qualifications and their use, the issues which surround credit transfer need to be addressed. This is particularly so in a country like Australia where the majority are self-accrediting institutions and where only limited use is made of external examiners and institutional benchmarking (always, or nearly always, excepting those programs where professional bodies determine who can be licensed or registered to practice in a given field.)

In practice, credit transfer can be confused with

· advanced standing,

· recognition of prior learning (RPL),

· recognition of prior experience (RPE).

The last, for example, can come into play in admission into Graduate Certificate programs in fields where there was not previously much opportunity, or need, for the acquisition of formal qualification in order to practice in that field. Computing was once such a field, design may be now.

The assessment of applications for RPL and RPE, like any form of assessment, must be

· faithful to the standards of the field, and

· fair to the student in that

o making them repeat something that they already know is a waste of their time and money, but

o giving them credit for something which they do not know at a sufficiently advanced level is doing them no favours because it can be setting them up for subsequent failure.

The extent of advanced standing, if any, can depend on whether the subject(s) in question is/are

· core or elective,

· from VET or HE.

With the latter there should be a difference in kind and not just extent, but the issue can be complicated when the skills base in a given subject is both deeper and broader at the VET level than the comparable HE subject. For example, some Typography modules at the VET level in graphic design diplomas can be more demanding in terms of knowledge and skills than their counterpart subjects in graphic design degrees.

The conceptual framework of the pertinent theory should provide a critical depth in the HE subjects, but it is not always obvious. The clarification and elaboration of these in an indicative format would make the AQF levels more useful.

Question 5

What number of explicit reference levels would best illustrate and encompass the increasing complexity of Australian qualifications?

Currently only universities offer enabling courses which they self accredit. Because they are not currently in the AQF enabling courses cannot be accredited for NSAI’s yet the need is obvious and many such courses offered in the public sector are clearly innovative and important to the enhancement of equity and participation.

There is therefore a clear alignment with public policy objectives and need for enabling courses to be included in the AQF, however because they are applicable to multiple levels set out in the table it seems there may need to be another “dimension” in the table for such courses.

Our members have also indicated the need for a one year higher education qualification that is nested within an Associate Degree and Bachelor Degree structure and have suggested the title of Associate Diploma. There is ongoing demand for undergraduate Diplomas and Advanced Diplomas offered in higher education.

Between Levels 5 and 6 should there be a clarification of

· Bachelor degrees with Honours, and

· Honours Bachelor degrees, and

· the distinction between them and Pass Bachelor degrees.

Again this has proved difficult on the few occasions that NSAIs have applied for government accreditation of Honours programs.

The same distinctions and clarifications might be needed between

· Coursework Masters programs, and

· Masters by Research degree,

and even among the academic expectations among

· Professional Doctorates (such as the EdD, D Min, DBA and LLD),

· Research Doctorates (such as the PhD and ThD), and

· Higher Doctorates (such as the DSc),

since these have different meanings in different countries. For instance, there is a big difference between the Doctor of Medicine degree in Australia and Britain and the Doctor of Medicine in continental Europe and North America. Table 9 of the Proposal mentions only the PhD. Some of the salient issues in the then emerging professional and coursework doctorates were teased out by Trigwell et al[1]in 1997.

Internationally too there are some Masters degrees which are really equivalent to an Australian Honours degree at best; for instance, some of the new Masters degrees in England and Wales (and not just the traditional Oxbridge MA or the older Scottish MSc and its equivalent in New Zealand).

Question 6

What is the best process to use for locating each qualification type in a levels-based structure?

This can only be dealt with at the level of principle since the autonomy of each discipline should be respected. These principles might cover what levels are expected at each level (as with HE Diploma, Associate Degree, Pass Degree) both in terms of the major and in terms of generic skills.

Proposal 2c

AQF qualifications are assigned a measure of the volume of learning based on the notional student learning time involved in achieving the qualification.

Question 7

Would a measurement of the volume of learning add value to AQF qualifications and support improved credit arrangements?

Yes, especially if aligned with international benchmarks. With increasing use of eLearning and flexible delivery, conventional formal contact hours and course durations are losing relevance as a measure of volume. The volume of each qualification would need to be determined by industry need; as present this is captured in the relevant Training Package for VET, and professional accreditation for some HE awards, eg engineering requires a 4 year bachelor degree. International alignment with processes such as Bologna also influence qualification structures.

It is hard to see how this could be done meaningfully and consistently - which does not mean that it should not be attempted. The actual hours, as distinct from the nominal hours, vary not only with the level and complexity of the subject matter, but also with the ability of the students, and – dare we say it – with the skills of the teachers. Table 9 would need more teasing out to fine-tune Honours and the different types of Masters degrees, otherwise it is difficult to work out the meaning of the credit points of the PhD and otherDoctoral awards in relation to the Masters.

Question 8

What is the best process to use to determine the credit point value for each AQF qualification type?

There would seem to be anomalies in Table 9, particularly, but not only, in relation to Diplomas, Advanced Diplomas and Associate Degrees. The Associate Degree still seems to have varying life forms in different institutions despite the work that the AQF Council did previously; that is, it still seems to vary between being a “parachute qualification” at one extreme and two-thirds of a Bachelor Degree at the other extreme.

It may be more meaningful to have credit points for each column of Table 1 so that there is comparability within columns. Whether that can be translated into acceptable comparability between columns is a moot point.

As noted, current credit point measures vary considerably, and we believe there is value in having a single measure – rather like the Euro common currency. This would simplify transparency, and credit transfer between courses. If we take a notional learning load of 30 weeks pa times 40 hpw, then an annual academic load might be 1200 hrs, or 120 credit points on the 10:1 ratio. As noted some professional bachelor degrees are currently 4 years, not 3.

In current practice, it will be difficult and not necessarily useful to attribute a set number of credit points (or a limited range) to each qualification type, especially in VET, as Table 9 endeavours to do. Under current Training Packages, typical durations for the same level VET level of qualification vary considerably.

For example, in the new Aviation AVI08 package, the basic commercial pilot training is the AVI40108 Certificate IV in Aviation (Commercial Pilot Aeroplane Licence). With no RPL, this typically takes 16 months full-time to learn the theory and achieve the practical competencies. For most types of professional aviation employment, students will also need the AVI50408 Diploma of Aviation (Instrument Flight Operations). The teaching of this is often integrated with the Certificate IV, but if taught sequentially, would usually take about 4 months. The level of the award is determined by the descriptors, but the duration and hence volume of learning is determined by the industry requirements. There are many similar cases in other VET qualifications.

We don’t think it useful to artificially restrict the volume of learning for a particular level of qualification; rather more information is conveyed by the level of the award (eg Diploma) and the volume of learning (eg 60 or 120 or whatever points for a particular Diploma qualification). This information can then guide articulation and credit, and allow industry flexibility to devise qualifications suited to its needs.

We look forward to further opportunities for consultation.

Adrian McComb
Executive Officer

[1] K. Trigwell, A.G. Shannon, R. Maurizi, Research-coursework Doctoral Programs in Australian Universities. Canberra: Australian Government Publishing Service, 1997, [ISBN 0-642-12648].

Accessible Version Imprint