Reforming Regulation of Vocational Qualifications
Jeremy Benson, Executive Director of Vocational Qualifications, to the Skills and Employability Summit at the QEII Centre, London.
When you think of qualifications and the vocational education system would the words ‘shadowy’ and ‘unloved’ spring to mind?
They came from the pen of Professor Alison Wolf just last year.
How about ‘rigid’? ‘Complicated’? ‘Confusing’?
The words of Nigel Whitehead, UK Commissioner.
And the word ‘lost’?
My own word; spoken a couple of years ago to awarding organisations, the bodies that design qualifications – I was talking about lost confidence in the system.
Let’s be honest, the picture those words paint is not a very happy one.
It can be dangerous to generalise of course. There are, at the moment, many good qualifications that are trusted by the employers that use them. They need to be recognised, celebrated, and learnt from. But the way the vocational system overall works does not always give people confidence in the qualifications that are on offer.
We want to play our part in changing that. In a few years I hope to hear instead words like ‘flexible’, ‘relevant’ and ‘valid’ coming from industrialists and academics. I hope to be able to talk of confidence as something the system has got, rather than something that still needs to be found.
Right now, I want to explain to you the things we’re doing that we intend will make an important contribution to achieving that ambition – to changing the language and perceptions that surround the vocational education system.
Our interest in the system is as the regulator of qualifications in England and of vocational qualifications in Northern Ireland. With more than 8,000 different qualifications certificated in the past year, our interest spreads across many topics, from accounting to zoo-keeping.
But no matter the topic of a qualification, our focus is on its validity, which is the degree to which a qualification measures what needs to be measured, by implementing an assessment procedure. A valid qualification must assess skills and knowledge sufficiently well, enabling assessment results to be interpreted and used appropriately, and allowing people to be confident that those results can be relied upon.
This hasn’t always been happening. We know from the work of Alison Wolf and others that some students have found that the qualifications they’ve achieved are not the passport into the career they want. We also know that some employers are confused by the myriad of qualifications available in their sector, and don’t know how to choose one over another, or indeed if they should choose any of them at all.
And debate on vocational qualifications is all too often framed in terms of general qualifications: they are seen as an alternative, good or bad, to GCSEs or A levels.
But the test of a vocational qualification should, rather, be to ask: does it recognise the skills and knowledge that will help someone to move into, and progress in, a career? There is a shared responsibility for making that happen: among awarding organisations, Government, employers and their representatives, colleges and others. And of course we have a role too, as the qualifications regulator.
We’ve taken a look at the regulated sector to understand the impact of our rules and regulations, and engaged with those who work in and use the vocational education system - including colleges, training providers and employers, hearing from them the issues they have with the current set-up. It has become increasingly clear that the system is not working. The evidence is that the rules too often get in the way of – rather than support and enable – good qualifications.
So, two weeks today, following consultation over the last year, we will withdraw the rules that govern the Qualifications and Credit Framework, or QCF.
The idea of the QCF, when our predecessor body introduced it back in 2008, was to bring in a building-block approach to learning. The intention was that students could piece together relevant units of learning, using the credits each unit was worth to support their individual progression needs and to enhance mobility.
But this approach did not provide any guarantee of quality, and did not work for all types of qualifications. Nor is there any evidence that it really supported social or labour mobility.
To achieve the QCF’s ambition, the rules placed much focus on consistency of structure, but did not focus enough on validity – or put another way, it didn’t consider whether the qualifications might actually be any good. I think Alison Wolf described this issue well. She said that while the rules enabled a standardised, unitised approach, what an awarding organisation couldn’t do was fit an award to the subject-matter or to the specific demands of a particular occupation.
Indeed, the assumption behind the QCF approach was: design your qualification to meet these rules, and all will be well. But of course, designing and delivering good qualifications involves so much more than meeting some design rules. Even if these rules made life easier for awarding organisations, many of them told us that the rules were in fact stopping them from innovating, or even from taking the approaches to assessment that most suited the topic being taught.
It came as little surprise, then, that when we consulted on removing the QCF rules last year, there was widespread agreement that the rules should go. We are now ready to withdraw the rules at the end of this month. The end of one era for the qualifications system, and the ushering in of another.
But the next era will not see a radical overhaul of all qualifications, as happened when the QCF was introduced. As I said at the beginning, problems with the regulatory rules have not stopped good qualifications being created – so we’re not requiring changes to all qualifications. Nor will we put in place another set of prescriptive rules. Having a detailed set of rules specific to vocational qualifications is not the best way of securing validity.
And of course we’re not removing all our regulations - awarding organisations will still have to comply with our General Conditions, and we’ve updated those to reflect the demise of the QCF. Our Conditions are outcome-focused: they focus on what the awarding organisations and their qualifications should achieve, not how they should achieve that.
Now we’re able to focus on outcomes and on our Conditions, we’ll be conducting a range of regulatory activities, such as audits, to test how far awarding organisations can show they’re meeting our requirements. We’re looking at how far we can report on and encourage good practice, so that awarding organisations do more than just meet the bare minimum requirements.
The new era will not just see a renewed regulatory approach, it will also see a new acronym – sorry! The RQF, or Regulated Qualifications Framework, will be a tool, not a rule or a process, and will help people to understand all of the qualifications we regulate. If you take a look on our website this afternoon, you’ll see a digital postcard available to download, which will give you an introduction to the framework.
We’ve described the RQF as being a bit like a library. There’s a range of books on offer, and as libraries do, we’re stacking the books in an order. Our shelves are arranged to fit books from Entry level 1 up to Level 8. That’s exactly the same levels as now. People broadly understand the current levels, and how they relate to levels in other frameworks, so we’re not going to change those– though we’ve tightened up some of the definitions.
And as you look at our bookcase, the shorter reads are on the left, and the hefty tomes, your War and Peace for example, are to the right. We’re bringing more clarity to how qualification sizes are described; another new acronym I’m afraid – TQT, or Total Qualification Time, although we’re keeping Guided Learning Hours within that, as we know it’s helpful - to those planning curricula and timetables, for example.
In a way, this all makes us something of a librarian. Now, a librarian doesn’t decide what should be in a book, or the number of chapters it should have – though they may take a closer interest in some more than others, as we do.
Rather, a librarian helps people to understand the different books available and to find what they’re looking for. So as well as the bookshelf, we have a catalogue. Now, some people might think that a bookshelf is a rather old-fashioned analogy. Well, I rather like books! But our catalogue, the register of regulated qualifications, is completely on-line, and we’re updating it to make it easier and quicker to search.
And – stretching the analogy a bit perhaps – if we as the librarian find a book that has been misclassified, or doesn’t do what it claims to do, we can take action against the book or its author. Ultimately we can remove it from the library, and that’s what we’ll do in the most serious cases.
I want to finish by reflecting on what this might mean for how qualifications are used in practice.
Obviously we know that these are tough times for publicly-funded provision. Budgets are shrinking for colleges and other training providers. There are uncertainties from the devolution agenda and the area-based reviews. The Government has big ambitions for expansion of the apprenticeship programme – where of course the assessments should be as valid as for any qualification. All this is bound to impact on the qualifications used to support publicly-funded provision – most immediately, as we’ve seen with the SFA’s recent moratorium in England.
But even in this context we make no apology for setting high expectations for the qualifications and awarding organisations we regulate. If a person has a qualification, that should mean something significant, and it should be something worth trusting. If a person has a regulated qualification – even more so.
Awarding organisations that can respond to this challenge, that can show they can produce good, valid, trustworthy qualifications, will be well-placed to meet the challenges of the future.
So now that we’re removing the QCF rules, it’s over to the awarding organisations to see whether they can meet these challenges. It’s for them, now, to work out how they’re going to review and develop their qualifications using the new freedoms we’re giving them and the higher expectations we’re setting.
And what might success look like in the years ahead? To return to the bookcase analogy:
- there might be fewer books on the shelves
- there might be fewer people looking for books too – at least, from the publicly funded sector
- but those people will find it easier to understand what they need, and find what they’re looking for
- and, with the librarian keeping an eye on things, they can be increasingly confident that the books in the library have been written by authors they can trust
- and those authors will be listening to feedback to make sure the books stay up to date
All of this underpinned by regulatory requirements that support and promote good qualifications. Regulation, in other words, that really means something and really achieves something.
Thank you very much.