The NFQ: a reason to celebrate
Presentation by Padraig Walsh, CEO of QQI to NFQ 20th Anniversary Conference
Radisson Blu Hotel, Golden Lane, 17th November 2023
"The National Framework of Qualifications (‘the NFQ’) has stood Ireland well and has worked its way into the national lexicon, in a way that many of its counterparts elsewhere have not.
For example, Question 27 on the Irish national census form 2022 asked “What is the highest level of education/training (full-time or part-time) which you have completed to date?” and makes a reference to each of the ten levels of the NFQ.
The iconic NFQ fan diagram is apposite, depicting a rainbow that can be traversed rather than a ladder that must be scaled. A lifelong learning path through the Framework can and should involve going across and back down the Framework as well as going up.
In 2015, the pre-existence of the framework and its associated levels allowed for the Framework for Junior Cycle to make explicit reference to the NFQ and its ready accommodation of NFQ Level 1 and Level 2 learning programmes. The National Council for Curriculum and Assessment (NCCA) and QQI are committed to working collaboratively to determine the appropriate inclusion of the various elements of senior cycle reform within the NFQ.
Another strength of the Framework has been its facilitation of the Recognition of Prior Learning (RPL) and particularly the concept of RPL for Award. This time last year, I attended the awards ceremony in Limerick for the first graduates of the Level 6 Hairdressing apprenticeship offered by Limerick and Clare Education and Training Board who received their awards solely through the formal recognition of their prior learning. This followed on from the previous experiences of RPL for award such as that of the TOBAR project between Donegal ETB and the Defence Forces that resulted in awards solely by RPL being made at Levels 3-6.
The NFQ has also made possible the Introduction of Professional Awards into the Framework. Prior to 2012, the National Qualifications Authority of Ireland (NQAI) facilitated the alignment of professional awards such as accountancy, and also included international vendor awards.
This concept of alignment did not carry through (inadvertently) into the 2012 Qualifications and Quality Assurance Act that established QQI. This has been rectified by amending legislation in 2019, allowing for a new concept of Listed Awarding Body – a more robust process than alignment – with the requirement for QQI oversight of the quality assurance of the awarding body and the requirement for the awarding body to have appropriate quality assurance over any associated providers that offer its awards.
This will increase the number of pathways to the NFQ for post-secondary qualifications – as a Designated Awarding Body, as a Delegated Authority Awarding Body, as a Linked provider of a Designated Awarding Body, as a Listed Awarding Body or as a provider of QQI awards. Although the pathways differ, the route to the framework must always follow a robust, periodic quality assurance process.
One of the main benefits of the NFQ and the other instruments introduced in the 1999 Qualifications Act was that it allowed Irish education and training to respond quickly to the COVID-19 pandemic and the sudden pivot from face-to-face teaching and assessment to an online environment.
A key finding of the QQI August 2020 report on “The impact of COVID-19 modifications to teaching, learning and assessment in Irish Further Education and Training and Higher Education” was that:
“The principle of the conservation of essential learning outcomes helped focus minds on what needed to be done rather than what could no longer be done. The time invested by the institutions in the elaboration of intended programme and module learning outcomes over the past 20 years stood them in good stead during this emergency.”
A NATIONAL FRAMEWORK OF QUALIFICATIONS or a NATIONAL QUALIFICATIONS FRAMEWORK?
It is worthwhile situating the NFQ among its counterparts in Europe and elsewhere. In Europe, the general term used is a ‘national qualifications framework,’ that is a framework of national qualifications, in that it generally includes exclusively nationally developed and awarded qualifications. In many cases and in higher education in particular, older qualifications had to be discarded and were replaced by newer qualifications to fit in with the aims of the Bologna Declaration.
After that declaration was signed in 1999, a seismic change for many European countries, was the move away from a so-called, long, first-cycle higher education award, and the development of new qualifications in the space of Bachelor’ and Masters’ degrees. National governments required that these new qualifications be accredited and evaluated at programme level and, industry, business and the professions had to be exhorted to recognise the ‘first cycle’ or bachelor’ degree as being relevant to the labour market, including the public service.
It was not until a number of cycles of bachelor’ degree students had graduated from these new programmes and they had been subjected to a number of external programme accreditations that mainland European governments felt confident enough to ease the requirements for external programme accreditation by moving towards the accreditation of a university’s internal quality assurance system.
Bologna signatory countries like Ireland and the UK that already had in place the three cycle Bachelor, Masters and Doctoral structure were freer to move faster with the development of qualifications frameworks. Ireland took the decision to develop a framework of the qualifications that were already available nationally and assembling them into what became termed a National Framework of Qualifications (‘an NFQ’). This meant that the number of levels in the Irish Framework had to be such that it could accommodate the multiple qualification types at higher education such as the higher certificate, higher diploma, general bachelor’ degree, honours bachelor’ degree, post graduate diploma and Masters’ degree across only two cycles of the Bologna framework of qualifications. This led to the inclusion of six major awards at four levels across two higher education cycles.
IMPACT OF NFQ ON LEARNER BEHAVIOUR TOWARDS HIGHER EDUCATION
Learners have changed the way they view different higher education offerings since the NFQ was introduced. Is this consequential or coincidental?
In 2000, there were approximately 53K applications to the Central Applications Office for National Diploma or National Certificate courses versus approximately 51K for degree courses.
By 2003, those numbers had moved to 48K for diploma/certificates and 55K for degree applications.
In 2004, the first year after the introduction of the Level-based NFQ, that had dropped to 43K for Level 6/7 programmes and 54K for Level 8 applications.
By 2023, the number of applications for Level 6/7 programmes was down to 30K (the lowest ever) and up to 68K for Level 8 degree programmes.
What is interesting is that the sum of the applications for the two CAO lists has hardly changed at all between 2000 and 2021 - being 104K in 2000 and 103K in 2021.
Is this because demand for Level 6 Higher Certificates is going down or because the supply has choked?
It would appear that the technological sector has been vacating the Level 6 space for a long time. In relation to the 2023 CAO offerings, there are now only 56 Level 6 programmes on offer. MTU, for instance, only offers three such programmes and TU Dublin only five. There appears to be only two terminal Level 6 higher education qualifications on offer – those of Pharmacy Technician or Dental Nursing.
The Level 6 certification numbers tell the same story in the public HEIs where the number of Higher Certificate awards has dropped from almost 2,500 in 2016 to 2,000 in 2022.
The Level 7 award has not fared much better. With the establishment of the NFQ, the typical three-year higher education programme moved from a National Diploma to an Ordinary Bachelor’ degree.
The Oxford dictionary definition of ‘ordinary’ is given as being: “of no special quality or interest; commonplace; unexceptional; plain or undistinguished.”
The numbers of Ordinary Degree awards made by public HEIs has dropped from 7,500 to 5,600 between 2016 and 2022 while the number of Honours Bachelor’ degree awards has gone from 31,500 to 34,500 over the same period.
FRAMEWORK AS SOFT INFORMATION TOOL or HARD FILTER
Upon its introduction in 2003, the National Qualifications Authority of Ireland defined the NFQ as ‘the single, nationally and internationally accepted entity, through which all learning achievements may be measured and related to each other in a coherent way’.
While the framework may have begun its life primarily as an information source, it quickly transformed into a filter for government funding, for student grant aid and for employee recruitment.
The ‘previous education and progression’ criterion used by Student Universal Support Ireland (SUSI) states that an applicant for higher education grant funding must “be progressing in (their) education by attending an approved course that leads to a higher level of qualification than any that (they) may already hold and that is at a higher level than any course (they) may have previously attended.”
The Department of Children, Equality , Disability, Integration and Youth rules for eligibility for the Early Childhood Care and Education (ECCE) funding programme for 2023/24 requires that all staff working directly with children in a pre-school service must hold at least a Level 5 major award in childcare on the NFQ, and furthermore that each room must have a ‘lead educator’ holding a minimum of a Level 6 qualification.
The SUSI website grant eligibility information indicates that the Barrister-at-Law degree offered by the King’s Inns and the Professional Practice Course (PPC) of the Law Society of Ireland are eligible for SUSI funding as they are approved courses for post-graduate study at Level 9 in the NFQ. But the courses and the ‘qualifications’ to which they lead are not at Level 9 and are not in the NFQ as neither the Honourable Society of King’s Inns nor the Law Society of Ireland are currently providers of framework awards.
The Kings’ Inns or the Law Society could, however, should they so choose, become Listed Awarding Bodies when the relevant section of the Qualifications and Quality Assurance (Amendment) 2019 Act is commenced. This section will also allow FET awarding bodies like City and Guilds and ITEC, for instance to have their awards included in the NFQ, where they will have to undergo the same level of rigour in relation to quality assurance processes as all other framework awards.
QQI is not immune to this filtering criticism either. Currently, we have a competition for Senior Executive Officer (Executive Officer equivalent in the Civil Service) with ‘a higher education qualification, preferably at NFQ Level 8 or higher’, listed as part of the desirable requirements of applicants. The requirement rises to NFQ Level 9 or equivalent as being an essential requirement for the role of Director (Principal Officer (Higher) equivalent) when we have previously advertised for that position.
FRAMEWORK CHALLENGES
As part of QQI’s preparation for this conference, stakeholders informed QQI about where they perceive there are challenges in the current Framework. They cited the sense of a lack of clarity regards awards at Level 5-7, the continued contested space at Level 6, the potential confusion at Level 9 and confusion regarding the varying award titles and credit volumes of non-major awards, particularly at levels 6-9.
What is the contested space at Level 6?
When the NFQ was introduced in 2003, there were two separate Awards Councils – one for Further Education and Training and the other for Higher Education and Training. The highest level of FET and the lowest level of HE overlapped at Level 6, giving rise to the awarding of the Advanced Certificate at FET Level 6 and the awarding of the Higher Certificate at HE Level 6.
There was also the issue of two difference credit systems, with the Higher Education system being circumscribed by the de facto European standard of ECTS (the origins of which dates back to 1989).
The contestation largely relates to the preferment that appears to be afforded the Higher Certificate over the Advanced Certificate in gaining advanced entry beyond first year of a Level 8 Honours degree programme in higher education.
This has resulted in a significant difference in the volume of QQI major awards at Levels 5 and 6. In 2022, QQI made 15,570 Level 5 major awards but only 6,539 at Level 6 (including 3,181 apprenticeships awards).
In 2021, QQI commissioned Ecctis (the body responsible for the UK ENIC) to undertake an evaluation of the two qualifications. Their report found that both awards were properly levelled at Level 6 with some learning at Levels 5-7, noting that there were a greater number of ‘knowledge’ strands in the Higher Certificate than in the Advanced Certificate.
Ecctis noted that although there is a clear difference between the NFQ award-type descriptors that were designed for the two Level 6 awards, the FET Advanced Certificate and the HE Higher Certificate but that ‘it is unclear whether the same level of differentiation is evident in the outcomes of the (two) qualifications as they are implemented in practice.”
And in reality, there are two main types of advanced certificates – a one-year Level 6 following a one-year Level 5 FE certificate at a PLC college – and a four year, in most cases, programme leading to a Craft Apprenticeship.
Now let us look at the new tertiary degrees introduced earlier this year – these short circuit the main issue of two years’ post Leaving Certificate study only obtaining advanced entry into year 2 of a Level 8 degree programme.
But they introduce an anomaly when it comes to potential ‘step-back’ or ‘exit’ awards.
Take for example, the new 4-year Bachelor of Business (Level 8) tertiary programme offered by Cork ETB, Kerry ETB and MTU. On successful completion of Stage 1 (Year 1), students will receive a QQI Level 5 Business Major Award.
Contrast that with the new, same name, 4-year Bachelor of Business (Level 8) tertiary programme offered by Limerick and Clare ETB and the Technological University of the Shannon (TUS). On successful completion of Stage 1 (Year 1) , students there will receive the TUS Certificate in Business Minor Award, Level 6, 60 ECTS.
Is it now time to look at the concept of a single major award at Level 6?
But there are currently two different credit systems in place – one for FET and one for HE and there are differences in the notional amount of learning time assigned to a credit point in the two systems. There is no universally agreed FET system at European level in contrast to HE, where ECTS has been (almost) universally adopted at the level of the European Higher Education Area (EHEA). Ireland does not have the freedom to operate a single credit system throughout the framework unless it is ECTS-compatible for HE awards.
What about the potential confusion at Level 9?
At this level, there are two major awards – the Post Graduate Diploma and the Master’s degree. Is the gap between the final year of an Honours Bachelor’ degree and a post-graduate diploma less than that between a post-graduate diploma and a Masters’ degree and does that matter?
Has the numerical nature of Framework levels contributed to qualification inflation, where the entry level for the Teaching and Engineering professions are now Level 9 Masters’ degrees? Some architectural programmes are moving away from the ab initio five year Bachelor of Architecture model into a Bachelor of Science in Architecture followed by a master’s in architecture model spread over five years. Is the professional entry point to the medical profession, correctly levelled at a Level 8 Honours Bachelor’ degree?
Credit volumes of non-major awards, particularly at Levels 6-9
The Framework was conceived to contain major, minor and special-purpose awards. It was extremely helpful that the concept of small (low volume) awards were in place from the start – this was always going to be necessary for FET. This allowed awards to be accumulated or stacked – hence the Common Awards System (CAS) component awards being stacked towards a major award.
But smaller awards have also had a place in higher education – consider the special purpose awards developed to enhance the scope of practice of nurses, for instance.
The availability, by initial concept, of smaller non-major awards, allowed for the early introduction of micro-credentials into the NFQ.
But micro-credentials bring their challenges as well as their opportunities. These include the desirability, or otherwise, of all micro-credentials being awards and the challenge of accommodating such credentials in an NFQ without stultifying their development or confusing and potentially misleading learners as to their currency exchange, portability or stackability.
The NFQ grid of eight award type descriptors across ten level indicators was challenging to accommodate for all awards when introduced in 2003. Can we provide a sufficient descriptor narrative as the volume of the award tends toward zero? Just how small does the volume of learning have to be for it to be a qualification and, in particular, for such a qualification to be ascribed a Framework level.
In response to provider demand for the validation of micro-credentials, QQI has currently taken the pragmatic, we believe, approach of setting a lower limit of 5 ECTS and an upper limit of 30 ECTS for our own micro-credential higher education awards.
We have done this in the recognition that we, as an awarding body, operate in both the FET and HE spaces, but that we are legislatively permitted only to validate programmes leading to awards in the NFQ, meaning they must have credit and must therefore be assigned a framework Level.
The 2012 Act puts a responsibility on providers accessing the NFQ that their programmes should lead, where that is possible, to awards in the Framework, that the Framework is a framework of qualifications and associated levels and that, while it is possible to have learning opportunities for credit and not for award, particularly where the volume of both learning and credit is small, it is not possible, we believe, to disentangle the concept of level from that of award. Indeed, there is significant potential for learner confusion if the concept of credit and NFQ level are unbundled from the awarding of a qualification.
It is also worth noting that the founding document of the Framework – the policies and criteria for the establishment of the NFQ stated that the National Qualifications Authority of Ireland (NQAI) “makes no distinction between an award and a qualification in its work. The term ’qualification’ is used as part of the concept of a ’National Framework of Qualifications’ and otherwise the term ’award’ is used.”
QQI AND FRAMEWORK INFORMATION
The sheer number of pathways and discrete sources of information on the pathways for learners can add to the complexity and opacity of the qualifications system rather than aiding its navigation by learners.
QQI is therefore endeavouring to make our information sources as comprehensive as possible.
We have revamped Qualifax – with the new tagline ‘every course explained.’ The new site was launched in September and has a new, vibrant look and uses responsive technology so that learners, as its primary users, can access it on mobile devices.
We have also further developed the Irish Register of Qualifications (IRQ.ie), as the authoritative guide to quality-assured qualifications in the NFQ. This site contains all the awards of the DABs and QQI (therefore including most of FET and private HE) and will in future contain the awards of Listed Awarding bodies, likely containing the main professional awards.
FRAMEWORK DEVELOPMENTS TO DATE
And it is not as if the Framework has not already seen changes since its introduction in 2003.
Awarding bodies and providers defined the original fan diagram: - The State Examinations Commission (SEC), FETAC, HETAC, universities and Institutes of Technologies.
The fan visualisation was amended in 2020 to now reflect sectors such as General Education (in Schools), Further Education and Training and Higher Education. This was driven by the changes, in particular, in the higher education provider landscape over the twenty years of the framework’s life and by changes in the relationship of these providers with the Framework and its associated instruments.
Since the NFQ was established in 2003, all of the Institutes of Technology became awarding bodies with delegated authority initially for undergraduate and subsequently for postgraduate taught awards. They then became designated awarding bodies under the Qualifications and Quality Assurance (Amendment) Act 2019. Subsequently, twelve of the Institutes of Technology merged to form five new Technological universities between 2019 and 2022 The new universities possess independent awarding powers up to doctoral level in the NFQ. Indeed, the structures of the NFQ provided at least part of the context for the relatively smooth transition of full awarding powers to the new universities.
In 2022, the fan narrative was further expanded to include mention of micro-credentials and the Irish Register of Qualifications.
The general education awards now include the Junior Cycle spread over Levels 1-3, whereas its predecessor Junior Certificate was solely at Level 3.
The general award type descriptors were bolstered by the publication in 2015 of professional award-type descriptors in for Levels 5-8 that made possible the development of many of the new post-2016 apprenticeships and also allowed for the straddling of the further/higher divide in the area of Early Learning and Care programmes leading to QQI awards.
One of the other areas of contestation in the original Framework was the placement of all craft apprenticeships at Level 6. With the development of new apprenticeships outside of the craft space since 2016, apprenticeships now span Levels 5-10 in the Framework.
RECENT DEVELOPMENTS AFFECTING THE NFQ
The inaugural QQI review of the 16 Education and Training Boards in 2021-22 culminated in the publication of individual reports and a Sectoral Report. This was a milestone event for QQI and the Education and Training Boards. While the ETBs have their individuality of geographical spread and balance of urban and rural, there was a great deal of commonality in both the commendations and achievements of the ETBs in the 10 years since their establishment but also in the challenges facing them. Many of these challenges and their resolution are central to the ongoing work of QQI in developing and reviewing framework award standards.
THE FUTURE OF THE FRAMEWORK
QQI’s work in the development of Broad standards at Levels 1-4 is almost complete and should greatly facilitate a more flexible and agile approach to the development of new FET qualifications at the initial levels of the Framework. Similarly, future developments at Levels 5-6 for FET awards should help ETBs to address the issues in the inaugural review about more flexible, agile, and responsive programme development to facilitate industry and learners at the upper levels of FET in the NFQ.
The promotion by government and the heightening of awareness of FET and its potential, in particular, to secondary school children can surely be creatively facilitated by the space provided by transition or fourth year. Exposing secondary school learners to FET in Senior Cycle is too late. While Transition Year has historically been characterised by non-formal structures and assessment, there is a fertile space to be exploited for FET including the potential of FET for award, in this area. This could include an introduction to the concept of apprenticeship and training, as well as education.
QQI has also published this month a review of the national access, transfer and progression (ATP) policy that informs how learners and education providers engage with the framework. ATP has been fundamental to enabling learners to engage with the NFQ and to benefit from it. The report presents key findings and spotlights some exemplars of practice across the tertiary education and training sector, with a number of recommendations for QQI to consider.
We believe it is entirely appropriate to celebrate 20 years of the Framework this year but QQI has already begun the work of developing our new Statement of Strategy which will be sent to the Minister for observations next June.
QQI has been given the statutory responsibility to keep and maintain the Framework, to review the policies and criteria on which it is based, to review its operation and to amend it from time to time.
We believe it is timely to confront some of the challenges I have highlighted above – many of which were discussed in our pre-conference workshops yesterday and will be further developed, as part of today’s conference and we look forward to working with many of you in the task of furthering developing the NFQ over the years ahead."
