WHITE PAPERSSUBMISSIONS
WHITE PAPER
Policy on Monitoring
WHITE PAPER
Policy on Quality
Assurance Guidelines
WHITE PAPER
Policy for Determining
Awards Standards
WHITE PAPER
Policy and Criteria for
Making Awards
Consultation closed on
14th November 2014.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
SUBMISSIONS
QQI received submissions for each of the White Papers
from each of the following stakeholders:*
POLICY ON MONITORING
» Aontas
» Further Education Support Service
» Chartered Accountants Ireland
» Dublin City University
» Dublin and Dun Laoghaire ETB
» Federation of Irish Complementary Therapy Associations
» Griffith College Dublin
» The Higher Education Colleges Association
» The Royal College of Surgeons in Ireland
» University College Cork
» IADT Dún Laoghaire
» Longford Women’s Link
» Trinity College Dublin
» University College Dublin
POLICY FOR DETERMINING AWARDS STANDARDS
» Further Education Support Service
» Waterford Institute of Technology
» Dublin City University
» Federation of Irish Complementary Therapy Associations
» Dublin and Dun Laoghaire ETB
» Chartered Accountants Ireland
» Griffith College Dublin
» The Higher Education Colleges Association
» IADT Dún Laoghaire
POLICY ON QUALITY ASSURANCE GUIDELINES
» Aontas
» Chartered Accountants Ireland
» Dublin City University
» The Higher Education Colleges Association
» The Irish Universities Association
» Federation of Irish Complementary Therapy Associations
» Griffith College Dublin
» The Royal College of Surgeons in Ireland
» University College Cork
» IADT Dún Laoghaire
» Longford Women’s Link
» Trinity College Dublin
» University College Dublin
POLICY AND CRITERIA FOR MAKING AWARDS
» Waterford Institute of Technology
» Dublin City University
» Federation of Irish Complementary Therapy Associations
» Griffith College Dublin
» IADT Dún Laoghaire
*The submissions have not been altered, except to divide feedback between the specific consultation documents to which they apply.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
AONTAS
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
WHITE PAPER: POLICY ON MONITORING
Submission by: AONTAS
With regard to this paper, we would highlight the following points for consideration.
Page 6 d) Incidents or risk factors which may affect learners (for example: financial Issues, capacity
issues impending media disclosures etc. that may relate to academic quality) and constitute a cause
for concern and which may trigger direct intervention by QQI.
We agree that providers must ensure quality and continuity of education provision to their learners
in line with their quality assurance procedures. In order to meet this requirement, clear
unambiguous guidelines should be provided so that providers can meet their responsibilities. We
would suggest that QQI will explicitly state the details which constitute a cause for concern and to
outline in detail what is meant by financial and capacity issues that require disclosure to QQI.
Page 9 3.4 QQI will develop detailed procedures and guidelines to guide QQI and providers in their
obligations under this monitoring policy
We welcome detailed guidelines in this regard and for their effective communication with education
providers.
Conclusion
The AONTAS Community Education Network is committed to continued engagement with the QQI
and welcomes the opportunity to shape their future policies. We would welcome clear
communication regarding the QA requirements of QQI and accompanying guidebook documentation
that would enable education providers to engage efficiently in QA and monitoring processes.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Further Education Support Service
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Further Education Support Service
FESS welcome the White Paper: Policy on Monitoring. There are issues to be addressed.
Pages 3 (section 2) and 4 (section 3.1)
There appears to be a contradiction between the definition of Monitoring in the 2012 Act ….( page
3) where it states that QQI will monitor a range of provider activities including “the effectiveness of
providers’ QA procedures” and the subsequent text on page 4 stating that Monitoring is not…. “the
review of the effectiveness of a providers’ QA procedures”. It may be the interpretation of the
terms ‘review’ and ‘monitoring’ that is causing confusion, as this occurs elsewhere in the text also.
The term ‘review’ is used in the White Paper: Policy on QA Guidelines to explain a QQI function -‐ the
review of the effectiveness of a provider’s QA procedures. Perhaps monitoring is expected to have a
more generic connotation?
Page 5 (section 3.2) Types of Monitoring
The proposed titles for the three types of monitoring do not reflect fully the nature of the activities.
Page 8 (section 3.3) Consequences of Monitoring
“The outcomes of all QQI monitoring activities will be published”. It would be beneficial to explicitly
state that the provider feedback/comments to QQI on monitoring will be in included in the final
published documents.
An additional issue is that it is not clear if a provider can appeal the findings of a monitoring exercise
by QQI. Clarification is required here.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Chartered Accountants Ireland
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Chartered Accountants Ireland
We have reviewed the proposed document on Monitoring and wish to confirm that it is clear and
have no suggestions for additions or amendment.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Dublin City University
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Dublin City University
Page 3: -‐ There is no legal definition of ‘monitoring’ in the QQAI Act which might potentially lead to a
potential challenge to QQI’s interpretation of this activity as outlined in the white paper.
-‐ Does the item on ‘re-‐validation’ apply to DABs?
-‐ In reference to: ‘QQI monitoring works towards these strategic goals.’ there is no previous
reference to ‘goals’ on the page.
Page 4: The monitoring principles as outlined are appropriate and welcome.
Page 7: It is hoped and expected that data provided to the HEA on a regular basis from DABs can be
shared with QQI and that duplication of data provision will not be expected. The use of publicly
available information is appropriate.
Page 9: 3.4 The provision of detailed procedures and guidelines to assist DABs in their monitoring
obligations will be very welcome.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Dublin and Dún Laoghaire ETB
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Dublin and Dún Laoghaire ETB
Section 3.3 Consequences of Monitoring
“The outcomes of all QQI monitoring activities will be published”. It would be our contention that
provider response to the monitoring report should also be published.
It is currently unclear as to whether providers can appeal the findings of a monitoring report, and
some clarification would be appreciated in this regard.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
The Federation of Irish Complementary Therapy Associations
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Federation of Irish Complementary Therapy Associations
FICTA (Federation of Irish Complementary Therapy Associations) deems the QQI's overarching and
organisational approach to monitoring the qualifications and QA landscape, and QQI's strategic goals
to be satisfactory.
Overarching principles that will apply to the monitoring of all types of provision and between sectors
are necessary to generate public and learner confidence in QQI's monitoring activities and services,
such as the implementation of the NFQ.
The principles which underpin QQI's approach to monitoring are reasonable.
There seems however, to be a disconnect between the White Papers assertion that monitoring is not
(c ) "A means of policing …. (among other things) poor quality provision", and the following
paragraph which says that the outcome of monitoring may contribute to QQI's assessment of the
quality of provision and, if giving rise to causes for concern, the possible consequences are noted in
item 3.3.
With regard to the possible consequence (g) -‐ it hardly seems fair to learners to withhold
certification at some level (or awarding credits towards certification) as a result of a providers failure
to meet their obligations to them. The development of detailed procedures and guidelines to guide
the QQI and providers in their obligations under this monitoring policy are highly recommended.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Griffith College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Griffith College Dublin
Overall: Not disputing the need for the particular content included, the focus of the policy is
very much on compliance and quality control. This suggests conformance with
prescriptive standards and an orientation that appears reactive rather than active.
Section 3.1: Possible inclusion:
g. Provides an opportunity for informed reflection and enhancement of quality
procedures on behalf of the institution
Section 3.2 Possible inclusion
e.g. Type 4: Monitoring: Evidence of innovative Best Practice
Is there a case for an upside in addition to the downside of concern? Could
monitoring reveal excellent practices / innovative improvements worthy of
comment / blogging / dissemination?
Section 3.3 Consequences
The section currently conveys a largely negative tone outlining all the things that can
go wrong.
Monitoring provided by critical friends / peers / with shared interests in the
development of learners can be an altogether positive and enriching experience as
institutions address limitations, make corrections and advance their commitment to
excellent practices.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
The Higher Education Colleges Association
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Higher Education Colleges Association
HECA was glad to see that its feedback on the QQI Green Paper had been taken into consideration.
HECA welcomes the rather broad brush statements in this White paper which accommodates the
specifics of diverse providers. However, there was a concern that some of the policy statement
were a little too vague and could pose the question as to how required minimum standards might be
understood by a new provider. The statement that “Monitoring is an external QA process that
involves both routine and once-‐off evaluations, analyses, observations and recording of provider
activities” would seem to infer some “effectiveness of providers’ QA procedures”, but the Policy
Statement on Page 4 states that this is not what is involved in “monitoring”.
HECA felt that there was a potential lack of clarity created by some other statements as follows:
On Page 4 it states “Equally, monitoring is not” ….. (c) A means of policing the education and
training landscape for corruption, incompetence or poor quality provision.
This statement was questioned as it was felt that the purpose of monitoring was indeed to do just
that.
On Page 8 under TYPE 3 – MONITORING CAUSES FOR CONCERN:
Reference is made to “Complaints made by third parties or information received in other ways (the
media, or through whistle-‐blowers for example)”. HECA has a concern that there is an implication
that all complaints will automatically be deemed legitimate.
HECA would also welcome some further clarity on the “provision of public information” as stated on
Page 4 (d).
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
The Royal College of Surgeons in Ireland
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Royal College of Surgeons in Ireland
RCSI welcomes this document and is in accord with the measures proposed.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
University College Cork
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: University College Cork
UCC welcomes the explicit statements in the white paper that, "QQI's approach to monitoring
will...vary between sectors and types of provision" and that, "QQI will develop procedures and
guidelines for monitoring activities for each type of provider and for different provider activities." In
particular, UCC believes that a one-‐size-‐fits-‐all approach to monitoring activities would not be
appropriate. However, it cautions against a proliferation of monitoring activities for each type of
provider. Monitoring should be as streamlined as possible and follow, as far as possible, the
institution's own monitoring activities.
More specifically:
The last sentence of the first para on page 2 -‐ we would like clarification of what is meant by this.
Page 4, section 3.1 d) Would it be possible to give an example of a positive or negative consequence
of monitoring?
And f) Might this be better if it were split in two? I.e. F) Provides accountability and g) may give rise
from time to time, for investigation of a cause for concern. Doesn't all monitoring provide for both
accountability and improvement, the former not only when there is a cause for concern?
Page 6: type 2 routine information provision: would it be possible to clarify which providers are
required to provide which kinds of information?
The term 'lifecycle of engagements' is used throughout the document -‐ despite this term having
been used by QQI before, UCC would welcome more clarification on what exactly it means.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
IADT
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: IADT
General comment:
This document seems less crisp than some of the other draft policy documents. It seems in places to
be more of a discussion document (which may be reasonable in a consultation context).
Nevertheless the document’s necessary broadness, given the diversity of sector, makes it
challenging to have a sense of the distinctness of “monitoring” as a thing. Is this policy required in
this format? Or would a different word, other than monitoring (notwithstanding the legal basis), or a
different policy context, better capture the ideas?
Page 4, 3.1 Monitoring
"QQI's approach is underpinned by principles that monitoring …"
Are these principles or a set of understandings?
“Monitoring will be mainly focussed on (but not limited to) programmes leading to QQI awards”
What does this mean exactly? Or what are the implications?
“f. Provides accountability from time to time where there is a cause for concern.”
To whom or for whom?
“Equally, monitoring is not:
a. The review of the effectiveness of providers’ QA procedures”
Is this statement not a direct contradiction of the statement of law made at the outset of the
document?
“A means of policing the education and training landscape for corruption, incompetence or poor
quality provision.”
To an external entity, this sentence may be concerning -‐ e.g. who does 'police' for corruption?
Perhaps its inclusion here is misleading, or misplaced?
“However, the outcomes of monitoring may contribute to QQI’s understanding of the effectiveness
of a provider’s QA procedures and their implementation as well as the quality of their provision.”
What are the implications of such an understanding by QQI? Where would such an understanding be
published or how would it influence practice?
Page 5, Top of page
“QQI will develop procedures and guidelines for monitoring activities for each type of provider and
for b. different provider activities.”
Is there a definitive list of the 'types' of providers?
Page 5, Paragraph 3.2, Type 1
This seemingly contradicts the statement at the outset that 'monitoring' is an external activity. The
initial statement may wish be more nuanced?
Also is it a 'shared' responsibility? Is it not rather a distinct, independent responsibility of each party?
“In this way self-‐monitoring guides providers in demonstrating the effective implementation and
enhancement of their QA procedures. It also helps QQI to provide public information on the quality
of programmes and the awards they lead to.”
When this sentence refers to the 'quality of awards' as distinct from the quality of 'programmes'
what exactly is it contemplating?
Page 6 DABs & DA...
Last sentence of first paragraph is not clear
Page 6
“Annual Institutional Quality Reports and Annual Dialogue Meetings provide information and
engagement on institutional activities to do with quality assurance, including follow-‐up."
Should these be defined/limited mechanisms, or should they be followed by the phrase, “or other
engagement mechanisms”?
Page 6
“d) Incidents or risk factors which may affect learners (for example: financial Issues, capacity issues
impending media disclosures etc. that may relate to academic quality) and constitute a cause for
concern and which may trigger direct intervention by QQI.”
“or be perceived to relate to or impinge upon” ??
Page 7
"Providers’ specific information provision requirements will be explained in the provider’s lifecycle of
engagements.”
What does this mean?
Page 7
"If a provider fails to provide routine information to QQI (or information that may be
considered a cause for concern), this may trigger an intervention by QQI."
Such as – maybe refer to Act or other section of the document?
Page 7 -‐ Provision of Public Information
“Providers are obliged to provide certain public information as well. The outcomes of QQI
monitoring will also be made public. This information may be used by QQI (and possibly in
collaboration with other bodies) to create system level reports and analyses which will lead to
enhancements for the education and training system.”
Given the lack of specificity about the types of interventions and the judgements being made or
understandings being gleaned, what format will these outcomes take?
Page 7
“The availability of good quality data from providers is essential to enable QQI to carry out its
monitoring functions effectively.”
This seems like a principle worth stating at the outset.
Page 7, Sharing and Using Available information
“Monitoring will share and make use of publicly available information coming from engagements
(statutory and non-‐statutory) that providers have with other bodies (agencies, funders, government
departments etc.) as well as with QQI.”
This sentence may benefit from restructuring. It may be worth mentioning Data Protection and FOI
legislation contexts.
Page 8, Type 3 Monitoring Causes for Concern
Should there be a colon or something between the word 'monitoring' and 'causes'?
Page 8
Some of the items on the list of causes for concern may need to be prefaced by the word 'alleged' or
'reported'. A conclusion cannot be reached before an investigation has occurred. Also there needs to
be some indication that an investigation will only take place where there is reasonableness or
sufficient seriousness.
The language being used here is very 'conversational', and not quite appropriate for a policy
document, though it is appreciated that it is only an overview/framework.
Maybe some of these statements should be in the principles section.
Page 8, 3.3 CONSEQUENCES OF MONITORING
“The outcomes of all QQI monitoring activities will be published.”
This is repeated from earlier in the document.
Page 8
“It is expected that monitoring will, in general, result in positive and enhancement oriented actions
by providers and QQI, arising from provider self-‐monitoring.”
Expected or desired?
Page 9, 3.4 GUIDELINES
“QQI will develop detailed procedures and guidelines to guide QQI and providers in their obligations
under this monitoring policy.”
Will this be specific guidelines for each type of provider?
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Longford Women’s Link
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Longford Women's Link
With regard to provider self-‐monitoring (section 3.2), it is important that clear guidelines are issued
in relation to this. QQI need to explicitly define the notion of self-‐monitoring and be aware that
community providers will not have the funds to engage the use of external facilitators and therefore
clear and explicit guidelines will ensure that this exercise is conducted to the satisfaction of both QQI
and the provider.
In terms of section 3.2 (d), we request that QQI must be very clear as to what they regard as a ‘cause
for concern’ so that there is no ambiguity as to the obligations and responsibilities of providers.
We welcome the commitment under section 3.4 to develop detailed procedures and guidelines for
providers.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
Trinity College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Trinity College Dublin
TCD welcomes QQI’s statement that its approach to monitoring will vary between sectors and types
of provision. We also welcome recognition that as a Provider and a Delegated Awarding Body (DABs)
under the 1997 Universities Act, we are responsible for the quality of our own provision, its
implementation, evaluation and ongoing enhancement of QA procedures.
The three types of monitoring outlined in the White Paper are appropriate, and it should be noted
that the university already conforms to the monitoring types described.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON MONITORING
SUBMISSION BY:
University College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: University College Dublin
UCD supports the development of an appropriate, proportionate and adaptable framework to
monitor HE provision in institutions. The policy paper, however, at times, appears to drift into
guideline/procedural aspects e.g. page 6 under Type 2 Monitoring: providers are obliged.....to
provide information to QQI, including: details of changes affecting programmes.....details of
arrangements for the protection of learners etc.
1. Page 3 -‐ UCD would support a variable approach to monitoring between sectors and types of
provision as indicated in the draft policy
2. Page 4 -‐ 3.1 a indicates that monitoring helps to demonstrate the effective implementation
of QA procedures; however, the 'second' 3.1 a(!!) states that monitoring is not 'the review of
the effectiveness of provider's QA procedures' these two statements risk being perceived as
being in conflict -‐ greater clarity would help.
3. Page 4 -‐ 3.1 d -‐ it is unclear how the following statement stands as a 'principle' -‐ QQI's
approach to monitoring is underpinned by the principles that monitoring: ' may have
positive or negative consequences for providers (some of which may be significant). And
again under 3.1 f ; provides accountability from time to time where there is a cause for
concern -‐ is this a 'principle'? Are the words 'from time to time' appropriate?
4. Page 5 -‐ 3.2 -‐While UCD welcomes the intent behind the statement that: monitoring will look
at different providers in different ways depending on their sector and activity -‐ presumably it
is not 'monitoring' itself that will look at providers in different ways -‐ it may be more
accurate to state, for example, that ' QQI will deploy an adaptive approach to the
development of monitoring systems to reflect the diversity of institutions within the various
sectors.......'.or something similar.
5. Pages 5-‐8 -‐ The utility of the distinction between type 1 and 2 monitoring is unclear -‐ Type 1:
Provider self-‐monitoring; Type 2: Routine information provision -‐ there appears to be
overlap between these two types in that eg in both types, routine information is provided;
6. UCD supports the general principles of transparency and accountability, but not without
some qualification, for example: Pages 7 and 8 -‐ Type 3 -‐ monitoring for causes for concern -‐
will this monitoring be published? Page 7 and 8 state: ' The outcomes of QQI monitoring
will be made public -‐ there appears to be no provision to appeal an adverse or inaccurate
monitoring outcome -‐ this may possibly raise the potential for eg legal challenges, which
may compromise the explicit statement: that all monitoring will be made public. There may
also be issues around commercially sensitive or confidential material being published. Some
further discussion around this aspect of the document would be helpful.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
AONTAS
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
WHITE PAPER: POLICY ON QUALITY ASSURANCE GUIDELNES
Submission by: AONTAS
As the QQI Quality Assurance Guidelines are not detailed in this White Paper one cannot respond
comprehensively in this regard. However, the following areas for consideration are being proposed:
QQI QA Guidelines:
Page 5 b) Communicate expectations about the quality of provision, assessment and the teaching
and learning experience in the Irish education and training community
We welcome the QQI committing to communicating their expectations. In order to ensure providers
are clear of their obligations we would request that such communiqué are detailed and clearly
outline the requirements of the education provider.
One such topic is ‘capacity’ which has been noted in a number of QQI policy documents. The
concept of capacity needs to be clearly articulated so that providers are empowered to meet the
requirements of QQI.
Page 5 d) Are a resource for providers’ establishment of their own QA procedures. They help identify
and inspire areas for enhancement, they are not solely a compliance checklist
We would raise concern that detailed guidelines are not seen by QQI as a checklist for providers,
rather they are the minimum standard expected for Quality Assurance. Detailed guidelines facilitate
clear, transparent direction for which the provider can build and shape their own quality assurance
processes. We would have concerns regarding the notion that previous guidelines, e.g. for FETAC QA
were merely a checklist, rather they provided the basis for QA processes to be developed and built
the QA capacity of providers. 2 The need for effective communication between QQI and education
providers features strongly within our membership. Therefore, in this regard, we call for clear,
unambiguous QA guidelines which explicitly state what QQI requires for assessing applications. In
order to support effective engagement with QA processes, education providers require support
information. We would call for appropriate accompanying information documentation, e.g. a QA
guidebook, is necessary in order to ensure a smooth transition from the existing QA processes, and
also to ensure there is good clear communication with providers using QQI services.
In Section 3.3: Key to development is the collaboration and consultation with the education and
training community and stakeholders in the qualifications system.
It is unclear how this process will take place. We could call on QQI to engage with community
education legacy providers who have garnered a wealth of expertise in relation to QA.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
Chartered Accountants Ireland
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Chartered Accountants Ireland
On behalf of Chartered Accountants Ireland I wish to confirm that we have reviewed the above
policy statement and consider it to be clear and comprehensive. We do not have, at this time, any
suggestions for amendment or improvement.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
Dublin City University
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submissions by: Dublin City University
Page 4:
3.1 It is not clear why the following: ‘(including teaching and research)’, in included after ‘the
learning environment’.
The consultation with stakeholders on the development of QA procedures is welcome. It is
anticipated that much of the current QA structures in DCU can be retained and improved where
appropriate. It will be important to advise all stakeholders on the method and frequency of any
proposed reviews of the effectiveness of QA procedures.
3.2 The application of the term in the QQAI Act ‘have regard to’ in relation to QQI’s QA guidelines
might be open to interpretation between providers. It would be helpful if the final policy could
address this.
Page 5:
3.2 It is unclear what is meant by ‘prescribed mechanisms for meeting criteria’. Further explanation
of ‘standards’ and ‘supplementary and supporting documentation’ in this context would also be
welcome.
QQI QA guidelines (a) The word ‘keystone’ could be misinterpreted – ‘underpin’ might be clearer.
(f) It is helpful that differentiation between and among providers is acknowledged here.
Page 6:
A different phrase to ‘voluntary higher education’ is suggested for clarity.
3.3 As well as building on the existing QA guidelines it will be important that the new guidelines link
in with and reflect the new institutional review model being developed.
For bullet point 3, it might be clearer to state ‘Address any gaps in the guidelines that may arise out
of…’
Page 7:
(a)DCU already has well established procedures for programme design, validation, accreditation and
assurance that are favourably commented on by external examiners and reviewers.
3.4.b Suggest this paragraph be re-‐written for clarity. Appears it is addressed mainly at language
schools. 4
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY ON QUALITY ASSURANCE GUIDELINES
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The Higher Education Colleges Association
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Higher Education Colleges Association
HECA welcomes this White Paper clarifying QQI policy on Quality Assurance Guidelines and notes
that many of the matters raised by HECA in response to the Green Paper No 4.10 have been
addressed in the White paper.
3.1: HECA agrees with the position stated in the paper that QA is the responsibility of the provider
with QQI providing an external oversight function.
3.2: HECA welcomes the approach outlined in this section whereby QA guidelines form the keystone
for a variety of QA activity including validation, provider review, the IEM, award recognition etc.
HECA is strongly of the view that this approach leads to efficiency and the development of a
comprehensive cohesive approach to QA within an institution. It also endorses the view in the White
paper that "QA guidelines should relate to ongoing enhancement and inspiration" of the QA
approach and not solely act as a "checklist for compliance".
HECA would welcome further clarity and description of the approach described as guidelines being
issued in ''modular'' format for different sectors or specific themes.
3.3: HECA welcomes the approach whereby the new QQI QA guidelines will be developed by building
on the existing guidelines, largely developed under the previous HETAC system, and in which HECA
providers have invested considerable time and resources.
HECA is in agreement with the approach to the development of the QA guidelines being
"collaborative and evolutionary rather than revolutionary".
3.4: HECA welcomes the provision of guidance where necessary and sees this as a step on the way
towards greater maturity on the part of the institution or sector in question.
3.5: HECA agrees that QA guidelines should be continually redeveloped and updated but in a
considered manner that is efficient and cognisant of the maturity of the institutions concerned.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
The Irish Universities Association
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Irish Universities Association
P2 Introduction and Rationale
This section states that “The principles underpinning QQI policy on QA guidelines are both stated
explicitly and embedded within this policy”. The IUA considers that all principles need to be stated
explicitly, rather than embedded, (ie stated implicitly).
P3. Legal context
The IUA welcomes QQIs intention to issue a range of guidelines for different types of providers.
P4. QA Guidelines
Section 3.2 states that guidelines are not QA procedures or criteria. However, it then refers to
protocols (prescribed mechanisms for meeting criteria), criteria, standards, etc. The universities will
need to determine their own mechanisms to meet whatever guidelines and/or criteria are required,
not follow prescribed mechanisms set by QQI.
Section 3.2 also refers to guidelines which are “adapted and continuously evolved”. See also Section
3.5 which refers to “continual development”. When guidelines exist, these need to be stable so that
HEIs can use them to ensure long-‐term quality enhancement. It is not possible to operate effective
QA in an environment where guidelines are continuously being changed.
P6:
The universities would welcome further explanation of the “modular” format concept proposed
(“Guidelines will be issued in a ‘modular’ format”). It should be noted that The QAA approach is
based on chapters, not modules. Does this imply that different sets of guidelines will be issued at
different times, for different sectors, different themes?
There is also a reference to “voluntary higher education”. It is not clear what this terminology
means.
3.3 Approaches to development
The White Paper states that “QQI QA guidelines will be developed by building on the existing QA
guidelines”. The IUA encourages QQI to take into account the recent “Review of Reviews” in this
context, which indicated the need for a broader discussion about a range of possible new
approaches to QA.
There is also a reference that QQI will “address any gaps that may arise out of the implementation of
the national strategies for further and higher education and training….”. In the opinion of the IUA,
this is an HEA matter, unless QQI tightens this reference to refer explicitly to QA guidelines. It might
be preferable to rephrase this as “ensure that QA requirements arising from the 2012 Act are
considered in any institutional cluster arrangements, mergers or alignments, arising from the
National HE strategy”, or words to that effect.
P7, Section 3.4.b Prescription and Aspiration
“Where the activity or sector being addressed warrants detailed and prescriptive guidance, this may
be provided for within the guidelines. Where the area being addressed by the guideline is, for
example; less mature or poses a greater risk to learners or the education and training system in
general, the guidelines may be less of an aspiration and more of a statement of expectation. This
does not imply compliance oriented guidelines, but that more guidance is seen as necessary.”
In the IUA’s opinion, this entire paragraph is confusing and needs to be rewritten.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
The Federation of Irish Complementary Therapy Associations
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Federation of Irish Complementary Therapy Associations
The Federation of Irish Complementary Therapy Associations (FICTA) welcomes
QQI's approach to the development of QA guidelines which will explain what QA guidelines are and
how they should be used. The stated purpose of "guidelines" and their value to providers as a
resource in developing their own QA procedures is agreeable.
The development of a range of guidelines for different types of providers and appropriate for
different purposes is welcome. The overarching principles which will apply to all QA guidelines
should result in consistency in the quality of provision and standards attained by learners across all
education and training systems and sectors.
The development of guidelines for innovation in provision, which could otherwise result in chaos and
confusion, is noteworthy.
QQI's collaborative and evolutionary approach to the development of guidelines is appropriate and
should result in the empowerment of providers, giving them a sense of 'ownership' which could
generate real commitment to deliver on their own
QA procedures to the benefit of learners and the satisfaction of the QQI.
FICTA looks forward to engaging collaboratively with the QQI in the development of
QA guidelines for the CAM (Complementary and Alternative Therapy/Medicine) sector.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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Griffith College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Griffith College Dublin
Overall: Not disputing the need for the particular content included, the focus of the policy is
very much on compliance and quality control. This suggests conformance with
prescriptive standards and an orientation that appears reactive rather than active.
Section 3.1: Possible inclusion:
The section might include references to expectations and responsibilities for quality
enhancement. This would complement its existing focus on control and assurance.
Section 3.2 Possible inclusion
The section might strengthen the quality enhancement perspective. The welcome
reference to enhancement (in (d)) will serve to bring organisations up to the
standards and practices of others in the country. It would be helpful if institutions
leading best practice could benefit from similar enhancement opportunities
Section 3.3 QQI can also ‘determine’ effective practice by adopting guidelines issued by other
providers.
The choice of the term ‘determine’ appears prescriptive with respect to guidelines.
Possible inclusion: Encourage, support and disseminate innovation and
enhancement with respect to quality standards
The section appears responsive and reactive, and while revolutionary change is not
sought, there might be a case for Ireland’s greater role in contributing to and driving
such changes.
Section 3.4 Possible inclusion
QQI’s QA guidelines will reflect Ireland’s commitment and contribution to
international best practice …
Section 3.5 This section presents a strong compliance orientation along with a reactive stance of
‘keeping up’ with the evolution of education.
A complementary balance might be achieved in the re-‐presentation of the last
sentence along the following lines:
Suggestion: QQI’s role in this sense is to assess and advance the effectiveness of the
guidelines and to facilitate and support their on-‐going development in collaboration and
consultation with educational partners, both nationally and internationally.
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The Royal College of Surgeons in Ireland
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Royal College of Surgeons in Ireland
RCSI welcomes this measured document, in particular the emphasis on collaboration and
consultation in the development of guidelines.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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University College Cork
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: University College Cork
UCC welcomes the indication in the draft policy that a 'range of guidelines for different types of
provider' will be issued, thus avoiding the problems related to one-‐size-‐fits-‐all documents.
Overall, it is difficult to provide too much detail on this policy without having a clearer indication of
what the Guidelines themselves will look like. However, some overarching points:
What will the impact of the Review of Reviews report be on the development of the Guidelines?
Some of the language used is rather opaque.
Specific comments on aspects of the policy:
3.2 states clearly that the guidelines are 'intended to guide providers...' and that they are not QA
procedures or criteria. However, the document then states that they will be borne in mind when
'determining protocols (prescribed mechanisms for meeting criteria)' Without knowing what these
criteria might be, UCC, as a university that is responsible for its own quality assurance, would query
the necessity of 'prescribed mechanisms' believing that it is responsible for determining its own
procedures for QA and QI.
3.2 (page 6) More definition of what is meant by 'modular format' would be useful (notwithstanding
the footnote). Under the second bullet, what is meant by 'voluntary higher education?
3.3 We would suggest making the third bullet more specific by adding the following: 'Address any
gaps IN THE GUIDELINES TO ENSURE THAT QUALITY ASSURANCE REQUIREMENTS ARE COVERED.'
Section 3.4b More clarity on what is meant by Prescription and Aspiration would be useful -‐ the
message in this paragraph is confusing.
3.5 We agree that review and development of such guidelines is necessary but would suggest that
'continual development' is not helpful-‐ if guidelines are constantly being revised, then HEIs have no
solid basis on which to develop their own processes.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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IADT
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: IADT
Re title:
Given the potential confusion around terms, could the word Policy appear on its own line. This is a
Policy (not a Guideline!)
Page 2, Introduction
“The aim of the policy is to provide the rationale and architecture for all QA guidelines issued by
QQI. In summary it should explain:
»» What QA guidelines are and how they should be used”
Perhaps also include by whom they should be used?
Is the word ‘architecture’ the clearest one in the context? Would ‘structure’ be more
straightforward?
»» The overarching principles which will apply to all QA guidelines
»» The rationale for developing a suite of guidelines for different sectors and themes.
The principles underpinning QQI policy on QA guidelines are both stated explicitly and embedded
within this policy.”
It is assumed the principles referred to in bullets two and three are principles for the same thing.
Whilst the distribution of principles throughout the document in an implicit, and from time to time
explicit, way may be a sophisticated presentation, given the time constraints of those reading this
type of document, perhaps a more simple (albeit simplistic too) approach would be to give a section
with overarching principles? The number of persons who engage with QA as a ‘discipline’ in and of
itself, are very few; the more sophisticated approach suggests a more nuanced engagement than
persons generally have time for.
The last bullet/sentence ‘The rationale for…’ seems to have missed the opportunity to simply state
that QQI wishes to develop different guidelines for different sectors.
Page 4, 3.1
“3.1 QUALITY ASSURANCE IN EDUCATION AND TRAINING
QA is a term generally used to describe the processes that seek to ensure that the learning
environment (including teaching and research) reaches an acceptable threshold of quality. QA is also
used to describe the enhancement of education provision and the standards attained by learners.”
In many jurisdictions QA and Q enhancement are not synonymous as this suggests. If it is intended
that the terms be viewed as meaning the same, this should be made explicit as it would not be
generally presumed.
“QQI also has a role in working as an international agency to ensure that European norms and
international effective practice are communicated to the Irish education and training community
and are appropriate to the Irish context.”
This sentence is a bit ambiguous. The clause after the 'and' suggests that QQI should be lobbying
European and other international policy makers to ensure policies proposed are inclusive of the Irish
context. If this is the intent, this is a separate and distinct point, and one worth making.
Page 4, 3.2 QUALITY ASSURANCE GUIDELINES
QA guidelines are intended to guide providers through their responsibilities [1] for the quality of
education and training and the consistency of their awards with the Framework, so they are
developed in collaboration with the education and training sectors. [2]
QA guidelines are not QA procedures or the criteria for assessing the effectiveness of QA
procedures.
The 2012 Act requires providers to “have regard to” QQI’s QA guidelines (Section 28 (2)) when
developing their QA procedures. QQI will similarly have regard to the guidelines when determining
protocols (prescribed mechanisms for meeting criteria1); criteria (things which must be
demonstrated by providers in order to access services2); standards (thresholds for educational
quality which must be met3); and supplementary and supporting documentation to inform
providers4 and to provide further explanation. [3]
1 the phrase ‘guide providers through their responsibilities’ might be better expressed ‘support in
discharging their responsibilities’
2 The meaning of this sentence is not clear. Should the clause starting 'so' be a separate sentence to
make clear the meaning?
3 It would be helpful if QQI produced a statement/policy on the status of “Policy”, Procedure,
Guidelines, etc. as terms used by QQI. How or where are they defined? If this is already done, can the
appropriate reference be inserted? This merits more than insertion in a glossary. This is the language
of expectation and implementation and the intent should be very clear.
Page 5
“QQI QA guidelines: [1]
a) Are a ‘keystone’ [2] for a variety of QQI functions, services and policies including:
~~ Validation of programmes (and re-‐validation) [3]
~~ Review of providers
~~ Certification of learners
~~ Authorising the use of the International Education Mark [4]
~~ Recognition of awards within the National Framework of Qualifications
~~ Recognition of prior learning (RPL)
~~ Access, transfer and progression (ATP)
~~ Delegation of Authority to make awards (DA).
b) Communicate expectations about the quality of provision, assessment and the teaching and
learning experience in the Irish education and training community [5]
c) Bring coherence into [6] and between different parts of the education and training system
d) Are a resource for providers’ establishment of their own QA procedures. They help identify and
inspire areas for enhancement, they are not solely a compliance checklist [7]
e) Will be adapted [8] and continuously evolve to remain fit-‐for-‐purpose [9] for the needs of the
education and training community and the qualifications system
f) Can be expected to have different purposes and different impacts in each sector and theme that
they address. The impact upon a provider of the QA guidelines will depend upon the scope of their
provision and the sector they operate in.”
1 What about including something on governance, whole-‐organisation effectiveness, etc. e.g.
Suggest perspectives on provider governance, strategic planning and resource management for
providing effective education and training programmes and associated learner supports.
2 Not sure that the meaning of ‘keystone’ is clear.
3 Is the word validation necessary -‐ could the more inclusive term of approval be used?
4 In the context of this list, should this item not come last? It is not of the same order as the other
items -‐ does it actually need to be included here since this is only a representative list?
5 Is it the quality of an experience that one wishes to consider or the quality of the environment for
that experience?
6 This phrasing suggests there is no coherence. Would the phrase -‐ bring greater coherence -‐ be
better?
7 Suggest that they must not be a ‘compliance checklist’ at all.
8 Would the word ‘change’ be clearer and more straightforward than ‘adapt’?
9 This assumes that a model of QA which is 'fit for purpose' is being adopted. This is an ‘in principle’
matter and if it is desired it should be in the earlier section, and its meaning proposed.
Page 6, 3.3
“QQI QA guidelines will be developed by building on the existing QA guidelines. QQI can [1] also
determine effective practice by adopting guidelines issued by other bodies.
Key to development is collaboration and consultation with the education and training community
and stakeholders in the qualifications system. QQI will:
»» Reconfigure the existing guidelines to comply with legal requirements
»» Develop guidelines that are in line with European and Irish policy on education and training
»» Address any gaps [2] that may arise out of the implementation of the national strategies for
further and higher education and training. For example: [3]
~~ Clusters and strategic alliances in higher education
~~ Innovations in provision that require different kinds of QA guidelines
~~ Reviews of the existing guidelines by QQI and their implementation
»» Adopt guidelines for its own purposes and for the education and training community as and when
required.
1 Would the word 'may' be better, and should 'other bodies' be defined, e.g. European or other
international bodies?
2 Does this mean any QA gaps?
3 It would be useful to include in this list joint provision and joint awards
Page 6, Footnote
“This concept underpins the architecture of the QAA’s “UK Quality Code for Higher Education” which
is organised into modules called “parts” and “chapters”.”
The phrasing of this footnote is not clear. Is the point that we are doing the same as the UK and that
that is important, or that we are doing the same as other international QA bodies, such as the QAA?
Perhaps the QAA documents should be a natural reference point – if so, this should be stated clearly.
Page 7, 3.4a
“QQI’s QA guidelines will reflect Ireland’s commitment to international best practice, EU directives
and policy commitments.”
In other parts of the document or similar documents the term ‘effective practice’ is used. ‘Effective
practice’ seems a better term.
Page 7, 3.4b
“Where the activity or sector being addressed warrants detailed and prescriptive guidance, …”
“prescriptive guidance” is an oxymoron.
Page 8, 3.5
“QQI will not simply issue guidelines and then consider them completed (notwithstanding the fact
that guidelines, as issued are in full effect until replacement guidelines are issued). Guidelines will be
continually redeveloped and updated in order to keep up with the evolution of the education and
training landscape. The guidelines will change as public policy changes, providers innovate and QQI’s
priorities change.”
Is the first sentence necessary -‐ it sounds awkward?
Page 9, Appendix A
This listing omits the 2013 IHEQN, Guidelines for the Approval, Monitoring and Review of
Collaborative and Transnational Provision
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY ON QUALITY ASSURANCE GUIDELINES
SUBMISSION BY:
Longford Women’s Link
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Longford Women's Link
The White Paper on Quality Assurance Guidelines does not actually outline the guidelines
themselves, therefore comments are limited to a number of areas:
Section 3.2 refers to the fact that ‘QA guidelines are not QA procedures or the criteria for assessing
the effectiveness of QA procedures. The 2012 Act requires providers to ‘have regard’ to QQI’s QA
guidelines’. However, section 3.2 (a) states that QQI QA guidelines are a ‘keystone’ for a variety of
QQI functions including validation of programmes and review of providers therefore we would
welcome clarification on this point. We feel that this ties in very much with section 3.2 (b) which
outlines QQI’s commitment to communication and we therefore request that these communications
are timely and outlines explicitly the obligations and requirements of the provider.
Following on from this point regarding communication, we welcome the proposal that guidelines will
be issued in a modular format however we would ask that all guidelines need to clearly set out what
is expected by QQI and also identify the criteria used by QQI in relation to the assessment of
applications. Section 3.2 (d) states that QQI QA guidelines ‘are a resource for providers’
establishment of their own QA procedures’. While we accept that QQI QA guidelines are ‘not solely a
compliance checklist’ we believe that at the very minimum they must be clear and unambiguous in
order to provide direction for providers as they develop their QA systems.
Section 3.3 outlines approaches to development. The paper states that ‘key to development is the
collaboration and consultation with the education and training community and stakeholders in the
qualifications system’. However the paper does not propose how this will be implemented. We
would urge QQI to ensure that the wealth of experience held by community education providers is
not discounted in relation to QA development. It is essential that there is sufficient confidence in
Community Education providers who take responsibility for developing and delivering their
programmes in order to deliver education and training content at the appropriate level and within
the required frameworks and standards.
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Trinity College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Trinity College Dublin
TCD welcomes the opportunity to comment on the Policy on Quality Assurance Guidelines, as
required by the 2012 Act (s28 .2). Since the implementation of the Policy will be guided by ‘modular’
guidelines, still in development, our response to the White Paper can only be at a high level.
We are pleased to see that the QA Guidelines will be adapted as necessary to remain fit for purpose
and developments. This needs to be balanced, however, with a commitment by QQI to ensure good
document control, and to allow the guidelines to become embedded so that institutions have a
stable reference when preparing for their Institutional Review.
TCD also welcomes QQI commitment to develop the Guidelines in consultation with the sector and
to take account of the QQI Act 2012 and the new ESG in section 3.3. TCD, along with other Irish
Universities, is concerned with a perception of confluence between QQI and HEA with respect to
implementation of national strategies. It is important that strategic targets, which have funding
implications, are not directly linked with the function of QQI.
Universities await the release of the Framework on Doctoral Education and clarity on what the HEA
and QQI envisage for assessment of Research quality.
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University College Dublin
The submissions have not been altered, except to divide feedback
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Submission by: University College Dublin
The scope and intent underpinning this White Paper is too broad. As a consequence, the White
paper lacks utility. The role of QQI as set out in 3.1 does not seem to be aligned appropriately with
the scope of the implied role for QQI elaborated upon in the rest of the White Paper.
1. Page 2 -‐ there is a reference to the White Paper setting out, amongst other things, 'The
overarching principles which will apply to all QA guidelines' -‐ it is unclear to UCD what these
principles are -‐ there is no further reference to 'principles' in the rest of the document.
2. Page 3 -‐ UCD supports the need to issue a range of QA guidelines for different types of
provider (and also for different purposes)
3. Page 4 -‐ 3.1 -‐ the reference to -‐ ....'teaching and research.........reaches an acceptable
threshold....' suggests that there is a prescribed standard against which quality is assessed -‐
this implies an audit/compliance approach to quality which is unhelpful as it diminishes the
enhancement element of the current HE quality review system
4. Page 4 -‐ 3.1 -‐ there is a reference to QQI having a role as an 'international agency' -‐ is this
not a function of a 'national agency' ? ie -‐ to monitor international developments
5. UCD recognizes the difficulty of drafting one overarching policy on quality assurance to
cover the significant volume and diversity of HE providers -‐ the document, however, suffers
as a result, by being disjointed eg it tries to cover too many sectors, policies, functions etc.
The policy, as a consequence, is vague : eg page 5 (f) -‐ QQI/QA guidelines -‐ "Can be expected
to have different purposes and different impacts in each sector and theme that they address.
The impact upon a provider of the QA guidelines will depend upon the scope of
their provision and the sector they operate in'
6. Given point 5 above -‐ it is difficult to assess how the policy elements will be applied across
the different sectors
7. Page 6 -‐ what is meant by 'voluntary higher education'?
8. Page 8 -‐ 3.5 -‐ this section is clunky -‐ why not simply state that 'QA guidelines will be subject
to periodic review'?
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Further Education Support Service
The submissions have not been altered, except to divide feedback
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WHITE PAPER: POLICY FOR DETERMINING AWARD STANDARDS
Submission by: Further Education Support Service
The following are the comments of the Further Education Support Service (FESS) on the QQI White
Paper, Policy for Determining Awards Standards. It may also be useful to reference the ESCO
multilingual classification of European Skills, Competencies, Qualifications and Occupations in this
policy.
2.1.1 Validation and Awards Standards (page 4)
“These de-‐facto awards standards are maintained by providers”.
From this phrase it is unclear if the standards will be maintained via the validated programme OR if
providers will actually maintain the award standards.
The precise definition of the ‘default awards standards’, which are referenced throughout the
document, is unclear.
3.2 Development (page 9)
QQI may adopt external standards, criteria, norms or benchmarks in determining its own award
standards.
The rationale for adopting “external standards” is not clear. Is this to be seen as an alternative to
aligning these existing external standards to the framework? Perhaps there are instances where
adopting external standards would be more appropriate, but these are not clear.
3.1 Changes to the CAS introduced by this policy (pages 14/15/16)
3.1.1 Assessment
The approach to assessment cited in this paper is problematic, i.e.” a learner must have acquired
and where appropriate demonstrated all the expected LOs specified for the award. For the avoidance
of doubt, it is not sufficient that all the LOs have been assessed”.
While existing programmes ensure that learners will be taught content reflecting all LOs, assessment
should not be a tick box exercise for each LO. A broad range of LOs should be incorporated into
assessment tasks/activities -‐ indicated in the validated programme.
SEC awards will be treated differently and in the third level sector a learner does not have to
demonstrate (via assessment) that they have achieved all the LOs. Why is the FE sector being
treated differently?
3.1.2 Capstone component award specifications (page 14)
A capstone component award is uniquely associated with a particular compound award.
Clarification is required. It is not evident how this concept will work. The text in the White Paper
explains that the purpose of the capstone component is to “facilitate the demonstration by the
learner of the compound award’s overarching expected learning outcomes – where this cannot be
assured through achievement of other kinds of component awards”.
The capstone component is going to be unique to a particular compound award, but it is possible
that the identification of the learning outcomes from the compound award which are not achieved
through the component awards will differ from programme to programme, depending on the
components that are offered to a learner
3.1.3 Provider Developed Awards Specifications
This is an area where several issues arise. Is this activity for providers with Delegated Authority
only? The concept may bring the FE sector back to the NCVA Locally Developed Modules, where
many different standards existed for the same field area. This will be a complete reversal of FETAC
CAS policy. This may also have implications for the HELS, and regress back to private links between
FE centres/ETBs and third level colleges depending on the awards being offered to learners by
particular providers.
3.1.3 (page 15)
Bullet point number 4: Belong to the provider concerned and may not be used by other providers
without agreement of that provider and QQI.
This phrase contradicts the “common” awards system as the award will not be “common” but
instead, individual to a provider.
3.1.4 Major, Special Purpose or Supplemental Award Specifications without Prescribed Minor Awards
The format of a major award being determined without prescribing any components is unclear.
3.1.5 Major, Special Purpose or Supplemental Award Specifications with Residual Credit
It is unclear why FET credits are being introduced. A credit system where all credits are similar across
the framework levels would be beneficial.
The issue of residual credit not being a ‘wild card’ to enable the arbitrary use of minors is cited. But
is this not a programme validation issue, where providers state the possible components that will
make up the residue credit value, where appropriate?
3.1.5 (Page 16)
Not all of a certificate’s credit needs to be allocated to component awards.
The paper does not clarify how the outstanding credit will then be allocated.
3.1.6 Alternatives to Transferrable Skills Pools for New Compound Award Specifications
Is it appropriate to no longer include transferrable skills as individual components for the FE sector?
Will the provider use the ‘provider-‐developed’ awards, as referenced in 3.1.5 (page 16) to develop a
component award to include the learning outcomes from the compound award, including the
transferrable skills that are not otherwise dealt with in the component awards that the provider is
offering the learner?
It is important not to devalue the transferrable skills. If our aim, as a sector, is to produce learners
with skills that will take then through multiple career changes, the transferrable skills are key to their
ability to adapt. Referencing the inclusion of “transferrable skills”, without specifying what exactly
they are, to the programme developer will result in confusion and a lack of consistency across
provision.
4.1 The CAS’s Certificate / Component Specification Syntax (page 18)
Certificate and component specifications normally address the following headings….
It would be helpful for those reading and interpreting specifications if all certificate / component
specifications used the same set of headings.
The notion of “Expected Learning Outcomes” may be problematic as the use of the term expected
implies that while these are what is expected, they may, in fact, be quite different. It is important
that some familiarity remains.
4.1 (pages 19-‐22)
Clarification is needed in relation to the calculation of the grade and how that will happen. The
notion of ‘other contributions’ is not clear.
It is stated that new award specifications may require that all component grades contribute to the
grading classification along with other contributions. This is welcome only if the exempt grade is
taken on board and considered in the overall calculation.
4.2 Title section
It appears that the (CAS) award title structure will not be changed, and thus there is unnecessary
detail in this section.
4.4 FET credit associated with a CAS award at a given Framework level assumes (unless otherwise
stated) as a baseline that the learner has already achieved the requirements for the previous
Framework level in the discipline-‐area concerned. (Page 20)
Does this mean that a learner can claim an exemption for a component where the learner has
achieved certification in the same component’s discipline area at the level above that of the
compound award?
4.8 Assessment requirements
It is surprising that, in an award specification, this section can be left blank.
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Waterford Institute of Technology
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Waterford Institute of Technology
3.6
Will each provider receive notification when minor changes are made to awards standards both
within and outside the review cycle?
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY FOR DETERMINING AWARD STANDARDS
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Dublin City University
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Dublin City University
No comments
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY FOR DETERMINING AWARD STANDARDS
SUBMISSION BY:
Federation of Irish Complementary Therapy Associations
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Federation of Irish Complementary Therapy Associations
The policy proposed in this White Paper for the range of approaches used by QQI in the
development and determination of awards standards is broadly acceptable to
FICTA.
Would it not be in the best interests of learners access to transfer or progression, to the public and
to potential employers, that the awards made by DAs (1.1.2.) are consistent with or referenced to
the appropriate level within the Framework?
FICTA welcomes the inclusion of "Occupational Standards" (2.1.2), the purpose of which is to qualify
a person to practice a specific profession where practical skills and competencies are a fundamental
requirement and not to be confused with or aligned to apprenticeship awards.
FICTA agrees that such an award is not of itself an indication of fitness to practice, nor a licence to
practice and expects that the CAM sector in Ireland will be actively involved in developing
occupational standards for its own disciplines.
The White Paper states that "It is important to avoid dead-‐end qualification" (2.5), but in Appendix 1
(3.1.2), refers to a "Capstone" component award. As 'capstone' means topping-‐off or finishing, this
seems to conflict with the statement referred to above. An more detailed explanation on the benefit
of a 'Capstone Award' would be appreciated.
Furthermore, the introduction of such terms as "the stem title" in place of NFQ Type and Class, and
subject "string" is quite irritating and far from helpful.
In service to the quality of the consultation process, the development and publication of terms to be
used consistently by QQI should be prioritised.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY FOR DETERMINING AWARD STANDARDS
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Dublin and Dún Laoghaire ETB
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Dublin and Dún Laoghaire ETB
Section 2.1 Approach to Standards Determination
Reference is made such that "QQI’s FET awards standards tend to be more specific than its HET
awards standards and specific standards have been determined for all of QQI’s named FET
awards." While a rationale is outlined for the specificity of awards at HET in the previous paragraph,
there is no rationale outlined as to the reason why FET awards standards are more specific. Such a
rationale would be welcome.
Section 2.6 Common European Framework of Reference for Languages (CEFRL)
It would lead to greater clarity and transparency if component specifications for QQI awards in the
field of languages (foreign languages and ESOL) were referenced against the CEFRL on awards
specifications.
Appendix 3.1.1 Assessment
Referencing section 3.1.1, to successfully achieve an award/component "a learner must have
acquired and where appropriate demonstrated all the expected LOs specified for the award. For the
avoidance of doubt, it is not sufficient that all the LOs have been assessed".
It is unclear what outcome is intended from the above. If it is intended that each of the LOs are
separately assessed, and that a shortfall in the acquisition of any one LO will result in failing an
award, the problems for devising assessments will be numerous. As the assessment of LOs are only
placed within appropriate assessment instruments during the programme/module writing stage, and
bearing in mind that this is determined by the local programme/module writer, it will be incumbent
on writers to devise instruments that assess proficiency at a granular level. While there may be a
case for the successful acquisition of core LOs (mandatory LOs perhaps?), to require success in all
LOs is both at variance with other assessment systems in HE and post-‐primary State exams, will also
cause great difficulty in design and delivery of assessments, and put pressure on the design of future
standards to keep LOs to a minimum core set of mandatory outcomes.
Appendix 3.1.2 Capstone Component Award Specifications
The Capstone concept (presumably an award project) is a welcome one. However, cognisance must
be given to credit value and progression/transfer implications to higher levels of learning,
particularly where RPL is concerned when transferring from a FET to HET programme through
advanced progression routes.
Appendix 3.1.3 Provider Developed Awards Specifications
The process whereby providers can develop their own standards is welcome. However, two points
stand out as requiring clarification:
• Must always include a capstone component as described in the previous sub section.
-‐ A suggestion to amend this to "May include a capstone component...", to remain
consistent with the previous section, i.e. "A compound award’s certificate requirements may
include a mandatory capstone component award...—where [overarching expected LOs]
cannot be assured through achievement of other kinds of component awards."(3.1.2)
• Must be approved (and periodically reviewed) in the context of a programme validation (and
revalidation) process involving an expert panel who can make national and international
comparisons.
-‐How is this Expert Panel devised? Who selects the panel? If DA for FET providers is to
provide parity of esteem with HET providers, there should be an appropriate and fair policy
around engaging with Expert Panels in line with HET processes.
Table 1 credits make no mention of the potential for Capstone credit.
Section 3.2 Standards Development and Determination Process
It would be our opinion that a five year duration for some, if not all, awards may be too long if they
are to remain ‘fit for purpose’.
Section 4.4 FET CREDIT
In rationalising NFQ, progression and access from FET to HET, some clarity or reflection around the
relationship of FET credits and and HET ECTS credits would be welcome.
Section 4.8 ASSESSMENT REQUIREMENTS
"An award specification may apportion the determination of the overall grade to a combination of
assessment techniques: e.g. Project 20% Examination-‐Theory 80%."
-‐ It would be useful if the combination of assessment techniques were programme specific, i.e. a
more flexible approach to determining appropriate assessment of learners reaching expected LOs.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY FOR DETERMINING AWARD STANDARDS
SUBMISSION BY:
Chartered Accountants Ireland
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Chartered Accountants Ireland
On behalf of Chartered Accountants Ireland I wish to confirm that we have reviewed the above
policy statement and consider it to be clear and comprehensive. We do not have, at this time, any
suggestions for amendment or improvement.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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Griffith College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Griffith College Dublin
Recommendation: That QQI actively considers the inclusion on the NFQ of a Postgraduate
Certificate award at NFQ level 9 with 30 ECTS.
Rationale: Candidates who hold an undergraduate honours degree at NFQ level 8 often wish to
advance their education. Some of this education can be appropriately provided in narrow specialist
areas. The title Certificate does not adequately reflect the post-‐graduate nature of the educational
challenge. Equally the duration and breadth of the programme do not warrant a postgraduate
diploma.
Familiar examples in the UK include the PGCE (Postgraduate Certificate in Education)
Some typographical queries / suggestions:
Section 2.8: Credit
Awards are made on the basis of the achievement of prescribed standards of knowledge,
skill and competence.
Section 2.9 … and providers with DA are required to establish procedures
The assessment, classification and grading of education and training awards are discussed in
QQI’s …
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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The Higher Education Colleges Association
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Higher Education Colleges Association
Having considered this White Paper, HECA’s response is as follows:
Page 4: 2.1: Reference is made to “(repurposed) Framework award-‐type descriptors”. HECA is
unsure what is meant by this and would welcome clarification.
Page 9: 3.2: It is stated that “QQI may manage the development of an award standard itself or
enter into an arrangement with another body”. HECA would appreciate further clarification as to
how such a body would be selected; what criteria would be used whether
statutory/professional/regulatory etc.
Page 10: 3.6: Under the heading “Review” it is stated that “Minor changes may be made by the QQI
executive outside the review cycle where necessary”. Further information would be welcome to
explain what is meant by “minor changes”; how would these be communicated; would providers
have the opportunity to comment or to suggest other changes?
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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POLICY FOR DETERMINING AWARD STANDARDS
SUBMISSION BY:
IADT
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: IADT
Page 2, 1.1.2 Providers with DA
DA should be spelt out.
“These providers make awards in respect of programmes of education and training that they
validate against QQI awards standards.”
It would be important, particularly for an international audience, to insert the word ‘autonomously’
before the word ‘validate’.
Page 2, 1.1.3, Designated Awarding Bodies....
Given that this is a limited group and that this document may have international readership, perhaps
they could be listed in a footnote, to ensure completeness of information?
Page 3, 1.1.4
It would be useful to state that this can include international bodies and professional bodies.
Page 4, 2.1. Approach to Standards Determination
"The least specific award standards are the (repurposed) Framework award-‐type descriptors."
It would be useful to insert a reference to where these can be accessed.
“QQI’s higher education and training (HET) awards standards tend to be less specific than its further
education and training (FET) awards standards.”
Why? Why does level of award require a different specificity? Is there another/different
determinant other than 'level'?
Page 4, 2.1.1 Validation and Awards Standards
"The de facto award standard for a particular named award as issued is the statement of
minimum..."
Perhaps give example of a named award so that this sentence is clearly understood.
Page 4, 2.1.1 Validation & Awards Standards
"While QQI awards standards and corresponding awards specifications are more or less specific, the
intended programme learning outcomes to be acquired, and where appropriate demonstrated,"
What is the purpose of this clause? Is it unnecessarily introducing a concept of assessment here?
Page 4, Page 5
Last paragraph/sentence
Perhaps this paragraph can be broken into two sentences, or in the final document perhaps it can be
on a single page.
Page 6, 2.2
What does this sentence imply about FET validation and awards standards?
How about something like this instead?
Specific awards standards will not routinely be determined for HET awards. The culture of autonomy
within HE, combined with staff participation and leadership in communities of knowledge and
practice, means that HET providers are normally best placed to determine minimum intended
programme learning outcomes.
Page 7, 2.4 APPRENTICESHIP AWARDS STANDARDS
“Where required, QQI will determine awards standards for FET and HET apprenticeship awards. The
approach will be consistent with the principles outlined in this policy and the implementation plan.”
It may be useful to extract those principles into a dedicated section.
Page 9
"QQI may manage the development of an award standard itself or enter into an arrangement with
another body."
Such as...
Page 14, 3 -‐ The CAS
This seems very complex. Is it necessary in its present form?
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY AND CRITERIA FOR MAKING AWARDS
SUBMISSION BY:
Waterford Institute of Technology
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
WHITE PAPER: POLICY AND CRITERIA FOR MAKING AWARDS
Submission by: Waterford Institute of Technology
2.1.1b. Special Purpose: Level N Specific Purpose Certificate
Seeing as the title of the award is “Special Purpose” should the parchment also say “Special Purpose”
rather than “Specific Purpose” for consistency (or vice versa?).
2.1.1 and 2.1.2 (d)
It is not clear where the title of the major award appears on the parchment.
2.1.2
Will Level 9 and Level 10 research awards also have the format: [Named Award Stem] in
[Specialisation]?
2.6
In what way is an award withdrawn? Can a graduate rescind an award?
Appendix 1
We request that Ed. D Doctor of Education be added to the appendix.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
SUBMISSIONS: WHITE PAPERS
POLICY AND CRITERIA FOR MAKING AWARDS
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Dublin City University
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Dublin City University
Page 8:
The following sentence needs amendment: ‘Awards are made on the basis of the achievement of a
prescribed standards knowledge, skill and competence.’
Page 10:
Is it certain that all major awards from DABs are included here? E.g. UCD has a Masters of
Engineering Science.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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The Federation of Irish Complementary Therapy Associations
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: The Federation of Irish Complementary Therapy Associations
QQI's policy and criteria for making awards are generally agreeable to FICTA.
We are curious to know what an "unclassified award" would be?
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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Griffith College Dublin
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: Griffith College Dublin
Section 2.1.2: The distinction made between training awards and licences to practise is welcome.
Section 2.5 The choice of the term ‘dead-‐end qualification’ seems harsh. Not all qualification
paths need to terminate at NFQ level 10. For example training in manual handling
and SAFE Pass may be sufficient for most candidates in a sector with respect to one
aspect of their employment. There may not be a need for follow-‐on cognate
training. These candidates may seek alternative paths on the framework for
progression by following other areas of development.
Section 3.3 The use of the word ‘normally’ suggests that consultation may not always be
provided. Is there not a case for ensuring that such a consultation process exists? In its absence, a
standard developed by QQI or another body (3.2) could be approved by QQI Policies and Standards
Committee without the safeguards of such input.
QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME
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SUBMISSION BY:
IADT
The submissions have not been altered, except to divide feedback
between the specific consultation documents to which they apply.
Submission by: IADT
Page 2, 1.1.3
Should the title of this section be reversed, i.e. “QQI entering into Joint Awarding Agreements with
other Awarding Bodies”
“Under section 51 of the 2012 Act, QQI may, for the purposes of making a joint award to an enrolled
learner in respect of a programme of education and training that it has validated, enter into a joint
awarding arrangement with”
This implies that it is not relevant to providers to whom authority has been delegated. It would be
useful to state this explicitly, even in a footnote.
Page 3, 1.3
The 2012 Act is already quite detailed and this policy need not necessarily repeat what is contained
in the Act.
Suggest deleting ‘already’
Page 4, 2.1.1
“[Named award stem] in [Specialisation]” – Is the word ‘stem’ necessary? What does it contribute?
Page 5
“c. No minor, special purpose or supplemental award classes are currently available at Framework
Level 10.”
Why is this statement here? What is the precise point? It is supplementary information, rather than a
policy statement?
“Award names for the professional award class shall be agreed in writing with QQI on a case-‐by-‐case
basis.”
Does this include institutions with DA? If so, surely it is an unnecessary control?
“Single subject certificates issued by providers are not Framework awards.”
Would there be value in including the fact that they may be recognised as learning leading to a
Framework award.
Page 6, 2.2
“Education and training awards may be made under this policy by QQI (subject to payment of the
applicable fee by the provider concerned) and by providers to which, under section 51(3), authority
to make an award has been delegated.”
Is this an appropriate clause in a policy document on criteria for making awards? Its exclusion from
this document does not remove the requirement.
2.3 MAKING EDUCATION AND TRAINING AWARDS UNDER SECTION 50(3)
QQI provides an award making service that is available to the general public. Details of the service
will be provided separately when available.
Should this not be at the outset of the document, in the section which addresses purpose/scope. It
seems to have misplaced prominence here.
2.4 CONFERRING EDUCATION AND TRAINING AWARDS
“An education and training award signifies a significant achievement and it is fitting that there be a
formal public announcement of all awards made.
A formal public conferring ceremony should normally be arranged for each cohort of higher
education and training graduands. Guidelines on academicals (caps, academic gowns, hoods and
epitogues) and the conduct of conferring ceremonies are available from QQI.”
It would be helpful if the name of the document in which these Guidelines appear was given.
2.5 RECORDS
QQI collects, and requires providers with DA to collect specified data about each named award made
and the learner to whom the award is made. This data must be made available to QQI on request.
Such providers are also required to keep informed of the current QQI specifications with respect to
the collection and maintenance of award records.
What is QQI's role re providing information to providers?
Page 7
“All providers to whom this policy applies shall ensure that they implement [1] procedures for the
withdrawal of an award from a learner (or for the recommendation of withdrawal of an award by
QQI) including learner appeals procedures [2]. The procedures for the recommendation of
withdrawal of an award shall be the responsibility of the provider concerned when the award was
made by QQI unless the provider concerned has ceased being relevant provider under the 2012
Act.[3]”
1 Perhaps “have procedures and implement as appropriate” might be better?
2 It is not clear what the relevance of the last clause is.
3 The meaning of the last sentence is not clear.
Page 8, 2.8
“Accordingly, credit can only be attached to a named award when the learner’s baseline knowledge,
skill and competence are specified.”
What does this mean? It seems to imply something about entry requirements? Is there some
implication of this sentence that is meant to be understood, if so it may be useful to make it explicit?
“Averages are to be taken over learners studying at similar NFQ levels in the same broad field of
learning.”
What does this mean? Who is taking averages of what and for what purpose?
Page 8, 2.9
“The assessment, classification and grading of education and training awards is discussed in QQI’s
published guidelines on assessment.”
It would be useful to insert the name of this document.
Page 8, Footnote
“HET credit has up to now been affiliated to the European Credit Transfer System; QQI is examining
the future feasibility of this affiliation.”
Presumably such an ‘examination’ will be taking place in transparent consultation with the QQI
providers and other HE providers in Ireland and no unilateral decision will be taken on such a matter?
Page 9, 2.12
PROCEDURES FOR AWARD CERTIFICATION BY QQI
“QQI makes awards based on quality assured results received from providers whose programmes
have been validated.
Providers are invoiced for certificates generated according to a published fee schedule.”
Is this appropriate or necessary in a policy document? Is it not superfluous here?