Purpose
1 This paper provides:
i The results of a consultation exercise undertaken by the Quality Assurance Agency for Higher Education (QAA) on the position paper "The national qualifications framework for higher education qualifications in Scotland". The paper was the third in a series of consultations and was issued in July 2000 with a request for comments by 30 September 2000. During this period there were also a number of workshops and meetings with the sector to look in detail at the framework proposals and in particular at the qualification descriptors.
ii The response to the points raised through the consultation and the plans for finalising and publishing the framework
Introduction
2 A total of 34 responses to the consultation paper were received of which 15 were from institutions of higher education in Scotland; one from a UK-wide University; two from departments within institutions (grouped together below as HE); two from higher education representative bodies (RB); one from the SQA; one from the Association of Scottish Colleges; seven from Professional or Statutory Bodies (PSBs); two from UK higher education subject associations (SAs), and four from National Training Organisations (NTOs).
3 The responses were considered by the QAA Advisory Committee for Scotland and, in light of the Committee's deliberations, the QAA has now produced a draft final guidance document that is being issued for comment in November 2000 and will published in final form in January 2001.
Main issues raised
4 Responses to the consultation raised a variety of issues, of which the main ones are set out below. (The full summary of issues raised and the ways in which QAA will respond to these are set out below, from paragraph 6 onwards).
i There was wide support for the framework and for most of the detail put forward in the paper;
ii The main issues remaining to be addressed were:
The timetable for implementation;
The credit requirements of 'integrated Masters programmes' and in particular a strong view from the sector that the minimum number of M level credits be reduced from 150 to 120;
The credit requirement for taught Doctorates and in particular that the minimum number of credits at the doctoral level be reduced from 450 to 420;
The proposal for 'subject' titles of qualifications and in particular that the proposal put forward in the position paper was un-workable and undesirable.
Way forward
5 In light of the outcomes of the consultation and its consideration of these, the Advisory Committee for Scotland agreed:
- that the framework for Scotland:
- a. should reflect the particular features and outcomes of the higher education system in Scotland including the very important place of credit as a key component to the framework and to the wider Scottish Credit and Qualifications Framework;
- b.whilst having clear and strong links and alignments with the framework in England Wales and Northern Ireland, should also demonstrate a coherence and integrity of its own to meet the needs of a higher education sector operating in the context of the Scottish Parliament and its policies and strategies for lifelong learning and wider participation.
- that the structure of the four undergraduate levels and qualifications in Scotland is confirmed as set out in the Position Paper;
- that the credit definition of the integrated Masters be amended so that the minimum number of M Level credits is 120. This should be the minimum requirement across the generality of the academic qualifications framework. Where a particular professional body had requirements beyond this, however, then it was for that professional body to make clear its requirements. In reaching this agreement, the Committee was mindful of the need also to consider any views emerging from England, Wales and Northern & Ireland on this issue;
- that the issue of subject titles of qualifications be address through a general note of guidance along the lines that institutions should have in place clear, consistent and meaningful approach to naming qualifications;
- that the timetable for implementation should be as that proposed for England Wales and Northern Ireland namely that from the start of the 2003 academic year, all entrants to higher education should be joining programmes that were in accordance with the framework;
- that a draft final guidance document on the Scottish Framework should be drafted to take into account the main points noted above and also the other issues set out in paragraphs 6 onwards below;
- that the draft final document would be issued for comment by the sector in time for the final document to be confirmed by the Board meeting in January 2001 for subsequent publication;
- that the document should include the draft qualification descriptors. The descriptors for postgraduate qualifications should be the same as those used in the framework for England Wales and Northern Ireland and the descriptors for the Honours degree should be in alignment.
Summary of issues raised and the QAA response
6 In paragraph 7 through 36 below, the points in bold indicate the decision of the QAA Advisory Committee for Scotland following consideration of the issues raised in response to the consultation.
General
7 Most respondents welcomed or made no comment on the introduction of the
framework in general. In reference to the Scottish Credit and Qualifications
Framework (referred to in the Position Paper but not the subject of consultation)
a few respondents (1 HE, 1 RB, 2 PSB, 1NTO) commented on the completeness of
the Scottish framework and praised the inclusion of vocational and academic
qualifications.
8 A few respondents (2 HE, 1 PSB) expressed a concern about a lack of clarity about how the framework related to benchmark information and programme specifications and stated how the on-going development and application of the framework should be informed in the context of these. It was felt by one organisation that it was important that the framework should not become fixed but should be seen as "evolutionary" and perhaps be open for modification in the near future.
i The final publication or other documents will make clear the links between these different structures and their relevance in Academic Review.
9 There were a few comments (4 HE, 1 RB) on the lack of inclusion of Medical, Veterinary and Dental degrees. Those who commented suggested that the degrees be included after consultation with the institutions that offered them and the relevant PSB. This was also extended by one institution to include Intercalated Honours degrees.
i Although these are important areas of provision, they presented a particular issue which should not delay the general finalisation of the Framework. In the meantime discussions will take place with the relevant bodies as indicated above.
10 One institution expressed a concern that the transfer of credit between programmes and institutions was not mandatory and that this would weaken the framework.
i As this was a minority view, no action is to be taken.
Relationship between EWNI and Scottish Framework
11 Two respondents supported the introduction of a common framework across the UK but most respondents were in clear support of a separate Scottish framework. One institution stated in reference to the Bologna declaration, that there was no need for greater similarity between these two systems (Scotland and EWNI) than between any other two of the 29 European systems of higher education covered by the Declaration.
12 There were requests, particularly from PSBs, for clarification of the exact relationship between the two frameworks particularly in relation to the equivalence of the postgraduate degrees and the alignment of the Honours Degrees. There was also a concern, however, that the proposal to introduce four undergraduate levels in the EWNI framework would imply, incorrectly, that there is an exact equivalence of levels across the two frameworks.
i Clarification of the identical relationship at postgraduate levels and equivalence of relationship at the honours degree will be provided.
Clarification of the relationship between the two frameworks below postgraduate levels will depend in part on decisions about the number of levels in EWNI, but also on the differences between the credit definitions of Scottish qualifications and those in the rest of the.
Principles
13 There was broad support for the principles underpinning the frameworks and, in particular, with the statement that the "framework is not intended to be, and should not be used as, a straightjacket" (10 HE, 1 RB).
i The final document will stress the principle of flexibility whilst also preserving consistency in the basic features and aspects of the Framework including in the minimum credit requirements. It will also stress, however, that mindless attempts to apply a 'credit ruler' should be avoided.
14 Several respondents (3HE, 1SA) were concerned that the position surrounding the award of a qualification at a lower level following failure at a higher level was not clear enough in the document: as long as the outcomes for the lower qualification were met then that qualification at the lower level could be awarded.
i This point will be clarified in the final publication
Credit definitions
15 Considerable concern had been expressed about the requirement of a minimum of 150 credits at SHE5 for integrated Masters degrees (10HE, 2 PSB 1SA). It was felt by all that commented on this that this was unrealistic and could not be supported by institutions who in all cases offered integrated Masters courses in the standard 30-week year session.
16 One institution pointed out that the requirement for a minimum of 150 credits may be inoperable given the need for varying curricula that may have to strike a balance between breadth and depth of study and/or requirements of PSBs. One PSB thought that the credit requirement might inhibit the development of provision "in emerging technologies and new fields of application." Respondents argued that the minimum credit requirement for the Masters degree be reduced to 120 or, in one case, 90 credits.
i The minimum number of level SHE 5 credits will be reduced to 120 as set out in paragraph 5. iii above
17 Several respondents argued that the minimum credit requirement of 450 at SHE level 6 for taught doctorates should be reduced to 420 (3 HE 2 RB).
iThe minimum number of SHE Level 6 credits should be 420
18 One institution felt that in the case of non-Honours degrees that had a clear subject or professional focus the framework should not state that the minimum requirement of 60 credits at level 3 would probably be exceeded. This was perceived to be the responsibility of the institution and/or the professional body and not an Agency concern. Another institution felt that 60 credits at level 3 was not adequate to meet the requirement under the level descriptor of the concept of "critical understanding"
19 Concern was expressed by a PSB that the minimum requirement for study at levels 3 and 4 for the Scottish Honours degree had been set at 180, when most Scottish institutions have a requirement for 240 credits at this level and this reduction may result in the diminution in the standard of the Honours qualification. Clarification is required as to why credit requirement has been set at this level.
i This point will be further clarified in the final documentation
20 Some institutions (4HE) felt that the credit definitions were too rigid and were not flexible enough to allow differences in standard module sizes. For example, if the institution standard credit rating for a module would not divide easily into 120 credits or the minimum credit requirement for the exit award there might be a problem meeting those credit requirements. This might mean that students would have to obtain substantially more than the minimum credit requirement in order to obtain an award.
21 One institution suggested that it was the number of credits at the final levels of the award that was more important than the total number of credits.
i This was not a widely held view. The point made at paragraph 12 above will be reinforced in the final document.
Nomenclature
22 With regard to the nomenclature of awards that are postgraduate in time but not in outcomes, there was a guarded welcome by most to these awards being named 'graduate certificate' or 'graduate diploma' (8HE, 1 PSB), although there were several comments about the titles being unattractive or not sufficient to distinguish the exact nature of these awards from other postgraduate awards (3HE).
23 Several respondents (2HEI, 1 RB), and also the COSHEP Teaching Quality Forum suggested that in order to avoid unnecessary complication, the number of awards should be restricted to two, a graduate certificate awarded for qualifications with a credit rating of over 60 and graduate diploma reserved for qualifications of 120 credits or above.
24 One institution suggested that it would be simpler to reserve distinctions such as these for programme specifications that would indicate the entry level of the award and the level of the final learning outcomes obtained. Indeed another respondent suggested that concepts such as "postgraduate in time and not level" were not required in a framework where it was the level of outcome that was the defining principle of determining the nature of a qualification.
- The Diploma title will be used for all qualifications of 120 credits or more.
- While proliferation of titles is undesirable, in all cases institutions should make clear in programme specifications the level of the particular qualification.
- The Committee agreed that the title of MBA was perhaps a special case and had a well know and international currency. In respect of clarifying its position and also to clarify its nature, the Committee recommended that QAA should develop a specific subject benchmark statement for the MBA.
25 The proposals to address the use of subject in qualification titles, specifically at the Honours level, were not generally welcomed (4HEI, 1 RB). Two institutions suggested that if the proposal were amended to stipulate that it was the amount of study in the final two Honours years that determined the subject focus of the degree, then the proposals may be workable and acceptable. In other cases, however, and in addition to concerns that the proposal was too prescriptive, it was felt that due to the traditional focus in Scottish Higher Education on breadth in the first two years of study it might be impossible for a student to study a subject to the amount suggested by the percentage requirements stipulated in paragraph 51 of the Position Paper.
26 It was also thought that the nomenclature suggested might become extremely cumbersome when addressing modular degrees and that the precise nuances of definitions might be confusing to the general public. For example, the difference in wording between Subject D with Subject E (a single subject with a minor) and Subject D and Subject E (joint subjects) was not great, but did reflect a substantial difference in the subject focus of the degree.
i The Committee agreed that although it was important that subject titles are an accurate reflection of the coverage of the programme, the proposals were unworkable and should be abandoned in preference to a general guideline on the consistent use of meaningful titles which would be discussed with review teams.
27 Several institutions were pleased that the undergraduate MA would continue to be used, although, one institution expressed a concern about its continued use.
28 Several respondents (2 HEI, 1 RB) had said that the nomenclature suggested for Honorary degrees was not attractive to institutions.
29 Some respondents had expressed concerns about the definition of the PhD where this stated that 'artifacts' etc should be accompanied by a written commentary. Response had argued a) that, for example in the case of art and design or music composition, it was entirely appropriate and indeed accepted practice, for works of design/composition to be submitted and assessed in their own right and that a written commentary was neither required nor added anything to the submission, and b) that the term 'artifact' was an unfortunate term to use for significant pieces of compositions/design etc.
i The final publication should take into account both the above points.
Qualification descriptors
30 There was broad support for the concept of qualification descriptors with most respondents indicating that they were pleased to note that it was the qualification descriptors rather than the level descriptors that institutions would have to relate to in terms of Academic Review.
31 There was broad support (6HEI, 1RB, 1 PSB, 1SA) for introducing identical wording across the UK for qualification descriptors for postgraduate degrees.
32 Some respondents thought the descriptors to be clear and accurate and to be well balanced and others felt that the language used should be "tightened up". One respondent thought that the generic descriptors of the characteristic outcomes were not clear enough to distinguish between the Scottish non-Honours degree and the Honours degree. It was welcomed by several respondents that the descriptors were "expressed in terms of modal rather than threshold achievements".
33 One institution preferred the EWNI qualification descriptors to the Scottish descriptors and another felt that the text under the General section should be retained but that the text under the headings that start with 'Characteristic outcomes' and 'Typically holders' should adopt the format used in the EWNI descriptors. One PSB believed that the Scottish framework "tended toward over specification, but has a better balance between the requirements for knowledge, understanding and skills than the EWNI paper."
- A workshop has been held with HEIs in Scotland to consider the descriptors in detail and to inform the next draft of the descriptors that will be issued with the draft guidance document.
- These descriptors will adopt some aspects of the Scottish format and some aspects of the EWNI format. It was agreed that this process should be continued to produce a common set of postgraduate qualifications descriptors across the UK.
Level descriptors
34 The Group noted that several institutions (5HEIs) preferred the format used for the level descriptors in the EWNI framework, citing that they were more concise and simpler. One respondent noted that more work was required on the descriptors to produce more clarity and "less jargon". Two respondents (1 HEI, 1PSB) queried the use of level descriptors and thought that the public would not find them particularly informative and institutions would find them too prescriptive.
35 However, there were several comments from both institutions and PSBs (2 HEI, 2 PSB) that the level descriptors either did or should allow for a wide diversity of qualification types to be reflected in their composition and that also the descriptors had been more successful than the EWNI version at "differentiating credit level statements from qualification positioning statements." One institution urged the Agency to undergo further work to encourage more consistency between the level descriptors in the two frameworks.
(Note, the Position Paper included the first draft of the Level Descriptors. They were included for the sake of completeness rather than for comment and there has since been a separate consultation on a second draft of the descriptors).
i The level descriptors, which are for the SCQF as a whole, will not be included in the final QAA publication on the qualifications of higher education institutions but will be addressed separately as part of the work on the SCQF as a whole.
Timetable for Implementation
36 The Group noted that many institutions felt that the six-year timescale for embedding the framework was not long enough to give them time to implement changes to five-year integrated Masters degrees and there were requests to be given more time. In addition, clarification was sought from one institution regarding the timetable for changes to one year and two year courses.
i The timetable for implementation will be as in the rest of the UK as set out in paragraph 5.v above.
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