66.We are keen to ensure that awarding organisations and responsible bodies understand the proposed transitional arrangements. We would therefore welcome comments and suggestions on the proposed arrangements. We would also be happy to respond to requests for clarification on any of the proposed arrangements. Awarding organisations and responsible bodies can comment on the proposals by emailing transitionals@ofqual.gov.uk or using the comment boxes online. Alternatively, they can send written comments, or a request for clarification, to Regulatory Policy Team, Ofqual, Spring Place, Coventry Business Park, Herald Avenue, Coventry, CV5 6UB.
67.The deadline for comments was noon on 25 January 2010.
The IAM believes that given, for the most part, the transitional arrangements replicate the status quo in relation to the regulation the proposals represent a sensible position for Ofqual to take during any transitional period before any changes are implemented as a result of the wider longer term consultation that is also on-going.
The IAM will respond separately to the Regulating for confidence in standards consultation.
The IAM has one specific concern in relation to the transitional arrangements proposals in relation to paragraph 39 regarding the register that Ofqual intend to develop. Whilst the IAM has no problems with the first two bullets in this paragraph (as this is what is already publically available) the final bullet does raise some concerns.
The IAM feels that the last bullet would appear to suggest that their confidential development plans would have to be shared and this could result in other awarding organisations becoming aware of this information and using this to develop their own versions of these qualifications. The IAM has shared, as required, their qualification development plans with the appropriate SSC/Bs. If the last bullet is only indicating that Ofqual will publish details about which subject/sector areas and forms of qualifications that an awarding organisations can offer than this is reasonable but the IAM would not wish to publically state the precise titles of qualifications that may submit over the next period of time as we would consider this commercially sensitive information.
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ConstructionSkills, based on experience of a range of regulatory body requirements including the former National Council for Vocational Qualifications (NCVQ) and Qualifications and Qualifications and Curriculum Authority (QCA), do not consider the Ofqual proposals meet the principles of good regulation of being proportionate, accountable, consistent, transparent and targeted. ConstructionSkills are concerned that Ofqual’s transitional arrangements are unclear, including the intentions and general principles which Ofqual propose to maintain the status quo and safeguard standards and protect learners. We thank Ofqual for already clarifying that these transitional proposals provide for the National Vocational Qualification (NVQ) Code of Practice to apply to NVQs in the existing National Qualification Framework (NQF), but not to qualifications in the Qualifications and Credit Framework (QCF) that use NVQ in the title. We are disappointed that Ofqual, as the new independent regulator, does not appear to have listened to the construction and built environment sectors’ concerns about maintaining the standard of work-based assessment of competence certified by quality-assured NVQ arrangements. The sectors’ learners, employers, awarding organisations, training and assessment centres, unions, professional institutions, industry certification schemes and clients have, since the initial proposals for the Framework for Achievement and then the QCF, requested transitional evolving arrangements as they understand and value the NVQ Code of Practice and sector’s assessment strategy arrangements which provide UK-wide comparability and consistency with the quality-assurance arrangements for Scottish Vocational Qualifications (SVQs).
ConstructionSkills note that Ofqual primarily directed their proposed transitional arrangements at awarding organisations. We wish to assure Ofqual that ConstructionSkills see the transition and future regulatory arrangements as a key strand of the Construction Qualification Strategy, alongside communicating information to the sector about the ongoing maintenance and improvements to the qualification framework. ConstructionSkills wish to work with Ofqual, the Alliance of Sector Skills Councils, the Federation of Awarding Bodies, the Built Environment Awarding Body Forum (BEABF), ConstructionSkills’ Standards and Qualifications committees (including employers, awarding organisations, providers, unions, professional institutions and industry certification scheme representatives), the Office for Standards in Education, Children’s Services and Skills (Ofsted), the Learning and Skills Council (LSC)/its successor organisation, the Skills Funding Agency (SFA) and the UK Commission for Employment and Skills (UKCES) to ensure that the transition arrangements provide the stability needed to maintain the sector’s confidence in the current and emerging QCF provision; but also to identify, evaluate and agree enhancements to qualification design, delivery, assessment and quality assurance arrangements.
To help the sector and awarding organisations maintain its publicly funded qualification provision, ConstructionSkills has obtained approval from Ofqual and submitted over one thousand NVQ units and associated rules of combinations to the QCF. ConstructionSkills is now working with awarding organisations to ensure these and other sector qualifications are approved by the sector and Ofqual by the end of 2010, in line with the Reform Programme timetable.
We note that Ofqual acknowledged in 2008 that ‘The tests and trials identified that many of the key processes of the QCF are yet to be fully tested and that most of the benefits are anticipated rather than realised’. The ‘2009 Review and Evaluation of QCF Regulation’ (January 2010 – pages 30 and 31) issued in January 2010 identifies concerns about the design, development and proposed delivery of assessment; consistency and reliability across centres and guidance about the role and qualifications of assessors and internal verifiers. Ofqual recognises that evaluation was very much a paper-based review of proposed QCF assessment arrangements which have yet to be implemented (page 48) and the delivery and outcomes from QCF assessment arrangements has yet to be looked at (conclusion 7). The report identifies the possible need for additional regulatory requirements for qualifications with ‘NVQ’ in the title as a key issue which will be under review and may be identified as priority as part of wider reviews of regulatory requirements but not until the beginning of 2011, at the earliest (conclusion 2, pages 42 and 44). We are unclear why Ofqual can justify in the evaluation report not developing additional regulatory requirements because other QCF qualifications may have the same purpose bu t are not branded as NVQ and stability is needed. The 2009 evaluation clearly identifies potential risks which ConstructionSkills are concerned may affect the quality and standards of assessment and confidence in QCF NVQ qualifications achieved. We therefore wonder why Ofqual now consider it appropriate to maintain the status quo for the mandatory NVQ Code of Practice supporting the assessment and regulatory arrangements for NVQs in NQF; yet feel confident to introduce voluntary arrangements for NVQs in QCF without the back up of the mandatory, recognised, Code of Practice.
ConstructionSkills’ experience over the past ten years supporting the sector’s initiative qualifying the UK-wide workforce has identified that regulatory and awarding organisations’ interventions tend to be needed at assessment centre level, where industry demand for certification and access to public funding combine with a lack of commitment to good assessment and quality assurance practices. Ofqual proposals however are targeted on recognising qualifications and awarding organisations. We have helped the sector and its clients maintain confidence in NVQs and comparability with SVQs by working with the BEABF to develop, refine and implement the sector’s assessment strategy focusing on centres’ risk assessments, internal verification and assessment arrangements backed by the mandatory NVQ Code of Practice, including clear external verification arrangements and assessor and verifier qualifications recognised across the UK. The sector recognises, and has continually advised regulators, that these same assessment and quality assurance risks are likely as the status quo in NQF or QCF of the work-based operating environment of NVQs will remain similar. The risks may actually increase in implementing QCF as awarding organisations and centres without NQF NVQ experience try to realise the benefits of a wide range of untested QCF qualifications and units as public funding for NVQs in NQF is phased out.
Despite Ofqual beginning its work in April 2008 to help ensure qualification content and assessment provides value for money the transitional proposals still do not address the bureaucracy relating to 14 -19 qualifications, including Diplomas, overseen by a range of bodies including the Department for Children, Schools and Families (DCSF); the Department for Business, Innovation and Skills (BIS); the Joint Advisory Committee for Qualifications Approval (JACQA) and the Qualifications and Curriculum Development Agency (QCDA). The sector has also ongoing concerns about the quality of the National Curriculum supporting young people so they can achieve the required functional employability skills before leaving school without requiring further public or sector resources to be subsequently spent repeating similar content and assessment.
Considering paragraph 41, ConstructionSkills are currently required to maintain the UKCES Action Plan database and have to obtain details from awarding bodies about their Ofqual submissions and approvals of QCF units and qualifications. We would welcome rationalisation of these various databases and in the short term receiving the information direct from Ofqual about the awarding organisations’ submissions and approvals.
We also have concerns and queries about Ofqual’s proposed future longer-term approach outlined in its parallel consultation on the regulation of qualifications, examinations and assessments – ‘Regulating for confidence in standards’. We plan to attend Ofqual consultation events to help us understand these proposals and we would welcome the opportunity to work with Ofqual to resolve our sector’s concerns about protecting the standard of NVQ in QCF.
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Dear Regulatory Policy Team,
I am writing to inform you that the CIOB fully endorse the response, prepared by ConstructionSkills’, to Ofqual’s Proposed transitional and transitory regulatory arrangements for regulated qualifications and assessment arrangements from 1 April 2010, ‘Ensuring regulatory continuity’.
The CIOB agree with and support with the concerns by ConstructionSkills that Ofqual’s proposed transitional arrangements will not maintain the status quo and safeguard standards and protect people achieving National Vocational Qualifications (NVQs) in the Qualifications and Credit Framework (QCF).
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