The Department of Higher Education and Training (DHET) and the SA Qualifications Authority, Saqa, set a tight deadline for public comment by 9 June, as reported on SHEQafrica.com in the first week of May 2011.
Among the public commentators on the QCTO policies is training certification consultant Fiona Cameron-Brown. She said that the QCTO, launched in 2010, set out to re-engineer the training quality assurance system, and streamline occupational learning, “however the draft policies suggest that the system will be more complex and onerous.
Training quality at risk
“Should these proposals be adopted, occupational training quality will be jeopardized, and a costly and burdensome system could result in massive opting out of the system”, writes Cameron-Brown in a newsletter.
The call for comments on the draft trades training policies was not by Notice in the Government Gazette, but on the Saqa website and a state sponsored skills newsletter, a mere week before the comment deadline.
New training terminology
The proposed training quality assurance system policies do not have accompanying explanatory notes. A number of concepts like the NOPF and a set of new terms, are not familiar to training stakeholders.
New curriculum and assessment process
“The proposed curriculum and assessment policy, differs markedly from the current system, and makes constructive comment on this policy virtually impossible.”
The new documents give no indication on how the proposed entities articulate with the institutional framework in the Skills Development Act or proposed amendments, like SAQA, SETAs, NAMB, skills development institutes, sectoral professional boards, and so forth.
Transition from the current quality assurance system, in which the SETAs play a central role, to the re-engineered system, in which SETAs play a delegated role, is not set out.
New training institutions added
“These policies create new levels of institutions. The SDA provides for the QCTO to delegate functions to other organisations, but the proposals do not indicate whether exiting entities would be among the quality partners. This is confusing regarding institutional functions.”
Qualification design and assessment fees
A draft policy delegates Qualification Design and Assessment to DQPs and AQPs, with fee structures. Cameron-Brown comments that “the QCTO and its associated systems are embryonic, and require testing.”
The existing quality assurance system for occupational learning is funded by a skills development levy from employers, not by statutory fees, as the state now proposes.
Many employers are forced to fund and use the current skills development system. “Many would argue that this cost outweighs measurable benefit, and that a fee based service, in a developing system, would be unfair.”
The new fee structure would burden the already over-burdened FET colleges, who are required to be critically important providers of occupational learning.
The SDA, in section 6, provides for the QCTO to be funded, inter alia, through a parliamentary vote, as well as from grants. SETA ETQAs are funded by the Skills Development Levy. “Therefore, the QCTO, which will take over the majority of their skills development functions, should be similarly funded.”
Cameron-Brown argues that “delegation of functions from the QCTO to SETAs suggest a reduction in the SETA ETQAs’ responsibilities, staff, and infrastructure. A single entity taking on the work of about 20 ETQAs would prevent massive duplication and save costs, that could fund the QCTO.”
Training quality partners functions
The list of criteria and responsibilities to be fulfilled by training ‘quality partners’ is substantial and would require significant human and financial resources. These new entities would be required to generate and publish intellectual property (IP) for the public domain, via the NLRD or internet, at high cost, with no direct return.
“These proposals are confusing and scary for many training providers and employers, in terms of cost and system changes”, writes Cameron-Brown. “I was encouraged when QCTO proposals emerged, the system seemed to be maturing and consulting with industry. I request revision of the proposals, for a simpler and less expensive skills development system, to foster quality training.”
• PHOTO; Fiona Cameron-Brown (BA Rhodes, H Dip Ed) is a training development consultant.
• QCTO policies are posted on the SAQA website, along with the relevant documents and presentations.
• See other relevant reports on SHEQafrica.com in the Related Articles window below this post.