08 June 2018

AQF

The PhillipsKPA report on Contextual Research for the Australian Qualifications Framework Review comments
This report describes the process and findings of the contextual research for the Australian Qualifications Framework (AQF). 
The purpose of this research is to provide contextual information to inform the 2018 Review of the AQF. It comprised: • A comparison of the AQF against a selection of national qualifications frameworks from other countries • A consultation process and desk review of relevant documents and databases to research the breadth of the use of the AQF in both educational and non-educational settings in Australia. 
Structure of this Report 
The Executive Summary provides an overview of the main issues that stakeholders are asking to have addressed in the formal review and sets out issues for draft Terms of Reference for the review. 
Chapter 2 and Appendix 4 summarise national qualifications frameworks in Europe, South Africa, Asia, the Middle East, the Pacific including New Zealand, Canada and Mexico (the USA has no national qualifications framework). The AQF is compared on the basis of a number of key parameters with common international practice. 
Chapter 3 and Appendices 1, 2 and 3 discuss the current uses of the AQF in educational and non-educational contexts in Australia and summarises the implications of these uses for any changes to the AQF. 
Chapter 4 summarises the feedback we received from stakeholders on broader general issues relating to their experience with the AQF. These issues include the purpose, scope, structure, and benefits of the AQF. 
Chapter 5 summarises the feedback received from stakeholders relating to detailed aspects of the AQF levels, their descriptors and their relationship with qualifications. These issues are organised according to the levels of the AQF (pre-tertiary and 1 to 10).
The principal findings are -
At the outset it is important to note that virtually all of the substantive comments made in submissions to the 2009 – 2011 AQF review are still at the forefront of respondents’ concerns in 2018. These comments are summarised in Chapter 4.1. The 2013 revised draft of the AQF, while addressing some concerns, does not appear to have dealt with the major issues that continue to create problems in interpretation and implementation of the AQF. Further issues were also identified in the light of developments since 2012. Prominent among these more recent developments is the widespread trend towards micro-credentials, flexible delivery options and mechanisms to assist learners to construct their own programs, sometimes across sectors, to meet individual learning needs. 
The AQF is very widely used across the Australian tertiary sectors and is generally accepted as a useful instrument with both national and international benefits.
The AQF is embedded in a broad range of legislation, policies, regulations and processes at government level, in statistical and data collections, in some industrial agreements, in the processes of quality assurance and accreditation by registration agencies and professional bodies as well as in the policies and processes of educational institutions that provide vocational and higher education.
The AQF is also impacted by and impacts upon related policy areas such as workforce planning, skills development and migration policy and cannot be viewed as a stand-alone educational instrument. Other reviews, concurrent with this one, such as the Training Package Reform consultation (Department of Education and Training), proposed review of the ANZSCO occupations database (ABS), design of a new employment services model for 2020 (Department of Jobs and Small Business), and the visa reform agenda (Department of Home Affairs) will have significant implications for the AQF. 
It is evident from the submissions by both regulators, ASQA and TEQSA, that there are issues related to implementation of the AQF by both regulators and providers that require attention. Among other things, these issues include ambiguity in terminology, inconsistencies in qualifications descriptors, levels criteria and volume of learning. The same issues are raised in one form or another by many other respondents to the consultation process and are outlined in this executive summary. 
In the 1990s and early 2000s, Australia was a global leader in the development of qualifications frameworks. However, other countries, particularly in Europe, have moved beyond the concept of qualifications frameworks principally as a tool to establish transparency and equivalence of qualifications, towards qualifications frameworks as a tool to facilitate an agile workforce suited to rapid technological, industrial and social change. This evolution in emphasis is in its early stages and reflected more at policy level than implementation, nevertheless it is widespread in its stated intent. Refer to Chapter 2, section 2.2.5 for the variety of policy objectives that are stated in recently revised international frameworks. 
Prominent within the changing policy context for qualifications frameworks is a desire to design them to allow and encourage more flexible construction of learning pathways. Flexible and multi-directional pathways rather than simple hierarchical ones (as the AQF is perceived to be) are regarded as better suited to lifelong learning and rapid retraining to meet new technological challenges. Internationally, qualifications frameworks are being designed with a view to encouraging cross-sectoral collaboration and the engagement of employers and businesses in both designing and delivering ‘on-time’ and ‘in place’ learning experiences that can be recognised formally as part of a qualification. While the AQF allows this possibility, the complexity of the regulatory and sectoral contexts within which it sits is perceived by many stakeholders to impede this level of responsiveness. 
Australia differs from many European countries that have higher levels of employer engagement in the accreditation of education and training opportunities, especially at sub-qualification level. There has been a reduction in traditional apprenticeship programs and the struggle for “work placement” is an increasing problem for professional training in universities. The possibility for accreditation of in-house learning or on the job training in employment and non-educational settings is left in the hands of a virtually unregulated system of individual institutional assessments and recognition of prior learning (RPL) arrangements. 
While RPL and workplace learning are encouraged by the AQF there are no mechanisms within the Australian system to assign levels to ‘non-standard’ learning options, or to regulate or quality assure credit towards formal qualifications for in-service or informal learning or micro-credentials in a way that ensures national or international consistency. The need for these sorts of practices is growing in Australia. For example, in some sectors, particularly information technology, students are compiling a number of short courses and skill sets together into a package that meets industry needs. The AQF does not readily facilitate/accommodate this. The potential use of block-chains to access and verify this type of qualification is also the subject of considerable discussion. Some other countries maintain registries of individual learning units offered by reputable but non-regulated providers that have been accredited at specified levels for specified credit.  
A considerable proportion of the framework consists of policies which detail the responsibility of qualification developers, accrediting authorities and issuing organisations. With the establishment of the legislative base underpinning TEQSA and ASQA it would be less confusing for international and lay audiences if this regulatory detail were removed from the Qualifications Framework per se and added to the TEQSA/ASQA conditions for registration of providers and accreditation of courses. Providers point out that the processes for meeting and demonstrating AQF compliance are largely dictated by TEQSA and ASQA at the moment. Very few international qualifications frameworks have supporting policy documents packaged as part of the framework as does the AQF. In some countries, the Agency responsible for maintaining and administering the qualifications framework is also the qualifications and/or quality assurance agency, in others the framework is simply an information and support tool and has no regulatory role. Most take the approach of briefly describing the policy areas in the framework document while referring for details to the website of the responsible agency. A submission to the contextual research by TEQSA highlights a considerable number of issues relating to the legal status of the AQF and its associated policies which should be addressed in the review. 
While the overall value of the AQF is well recognised in Australia difficulties in its design, expression and the conceptualisation of the levels have been identified by all sectors and with enough consistency to warrant their inclusion in the terms of reference for the formal review. The substantive issues related to the levels and descriptors raised by stakeholders are addressed in Chapter 5, which could be used as a reference point for the review. Widespread concern over difficulties in interpreting and implementing levels 5, 6 and 8 in particular is expressed in the responses to the consultation, although levels 1 to 3 and 9 to 10 also present problems and anomalies. 
The AQF relies heavily on notional volumes of learning expressed in years of study which is out of step with modern international practice. Movement towards a system based on credit point values related to notional average hours required to achieve learning outcomes would be in keeping with international practice and would have the added advantage of facilitating a common currency for a national credit transfer system to support pathways and recognition of non-formal learning. The problem with volume of learning is, however, more complex and has created significant difficulties with the implementation of the AQF at most levels.
The AQF in its current form is exceedingly complex and rich in semantic detail. It is not easily understood by the average reader or by international audiences or the wider community who are unfamiliar with the history of its development. In its printed form the AQF is four times longer than the New Zealand Qualifications Framework. Some users report confusion over terminology, ‘technical lingo’ and question the need for or relationship between both levels criteria and qualification descriptors. 
Qualifications Frameworks in many European countries are viewed as a valuable resource for the general public and employers in informing their educational and employment choices. Consequently, explicit emphasis is placed on the governance and promotion of frameworks and on raising awareness of their utility as guides to personal decision making and workforce training and planning. Neither the governance framework nor the physical expression of the current AQF facilitates its use as a communication tool for the wider audience beyond course designers and regulators. 
Consistent with the ongoing evolution of national qualifications frameworks the AQF review should consider the need for a governance framework that will provide the ability to monitor and respond to changing needs and policy objectives and to clarify and simplify its position within the education and qualifications landscape. The consultations for this contextual research revealed that there is considerable lack of clarity both nationally and internationally about the standing and purpose of the AQF within the relatively complex Australian landscape of jurisdictional/federal, general/foundational, school, vocational, higher, postgraduate, professional and continuing education. Most international qualifications frameworks are administered by statutory authorities appointed by governments or by branches of ministries and government education agencies. It is common for these authorities to also have steering or advisory committees consisting of stakeholders. The Frameworks are surrounded by or incorporated within a relatively predictable web of regional frameworks, industry advisory bodies, qualifications agencies, quality assurance agencies and education providers who in some countries are given significant autonomy. 
Reinforcing the need for a responsive governance structure for the AQF is a comment provided by one senior university executive: The AQF functions as a public sector instrument concerned with compliance, standardisation and predictability. ……‘future proofing’ is premised on a notion of the AQF as a kind of fixed point. The tertiary sector environment is anything but fixed, with many of the changes ….. coming from the public sector [policy]. Other significant changes include increased demand for micro and flexible credentialing across qualification level from the private sector. It will be challenging for the AQF to remain a useful contemporary instrument. The continuing dynamic nature of competition, changing public sector expectations and policy create a dynamic tertiary sector environment. Timely and responsive mechanisms will be required to ensure that the AQF does not constrain institutional and sector competitiveness, nationally and internationally.
The report  offers recommendations regarding the review Terms of Reference
The following suggested issues could be considered in developing terms of reference for the review and are grounded in the findings summarised above, specifically the aspects of the current framework that impede its effectiveness, the changing dynamics and demands of both education and employment, and international trends in qualifications frameworks and policy. The principal task for the review is to position the AQF as an instrument that is responsive to emerging needs and able to be readily understood and used by its various audiences, including international ones. 
1. Review the structure and description of the AQF components (levels, qualifications and relevant explanations) including the extent to which: a) the relationships between levels and qualifications are clear, appropriate and unambiguous; b) the levels as currently defined are appropriate and fit for purpose; c) the descriptors are expressed in simple language that supports ready interpretation; and d) the knowledge, skills and capabilities reflect and support the full range of learning outcomes required for adaptation and successful participation in work and life. 
2. Consider the issue of volume of learning including: a) whether the volume of learning should cease to be expressed in the AQF in terms of calendar years and be replaced by a credit point system; b) whether the disparities in volume of learning between qualifications at the same level can be supported by additional information such as prerequisite learning to dispel confusion; and c) whether the volume of learning can be aligned with other measures of learning volume employed in VET sector specifications and requirements. 
3. Review the positioning of vocational education and training (VET) and higher education (HE) qualifications in the AQF and consider: a) whether more explicit differentiation of VET and HE qualifications would be beneficial in general and specifically at levels 5, 6 and 8; b) whether the variety of qualification titles used at the same levels for VET and HE continue to be relevant and meaningful in both the national and international context; c) means by which any implication of a status hierarchy from VET to HE qualifications can be mitigated through changes to the structure or language of the AQF; and d) means by which greater consistency in regulation of compliance with the AQF can be achieved between HE and VET sectors. 
4. Review the desirability and feasibility of developing a system for the quality assurance and incorporation within the AQF of sub-qualification credentials such as skill sets, enabling and foundation courses, and in-service and advanced training provided by industry or professions. 
5. Consider whether the AQF policies (issuance policy, pathways policy, register policy, addition or removal policy, and principles and processes for alignment with international qualifications frameworks and relevant explanations) (a) are appropriate and fit for purpose and (b) should remain within the AQF itself or be rationalised with TEQSA/ASQA registration and accreditation guidelines. 
6. Review ways in which the AQF could more effectively facilitate learning pathways and mobility within and between levels, sectors and qualifications. 
7. Consider what changes may be required to AQF governance arrangements, to the AQF itself or to regulation that references the AQF to ensure consistency of its application and ongoing monitoring and review. 
8. Given the findings from issues 1 to 7, recommend any necessary changes to the AQF and devise an implementation plan for achieving the changes.