The Association of Private Providers of Education Training and Development (APPETD) said that the registration with the Department of Education was a contentious issue for them as it was difficult and did not acknowledge registration done by the Sector Education and Training Authority (SETA) as the designated Education and Training Quality Assurers (ETQAs). The DoE only recognised registration by Umalusi and by the Council on Higher Education. This was problematic as Umalusi and CHE had certain requirements that were not necessary for private providers such as media centres and libraries which were criteria designed for universities and colleges. It was because of these issues that the APPETD was recommending that the registration of training providers offering occupational training be done by the Department of Labour. This would prevent duplication in terms of accreditation and registration and ensure that the registration requirements for occupational training were suitable for training providers.
The South African Qualifications Authority detailed several concerns and recommendations but noted that some proposals in their earlier submission to the Department made on the 28 March 2008 had been effected. In addition to the written submission, they said the QCTO and the 3 QCs were very important in the NQF. SAQA was particularly concerned about the establishment of the QCs.
Members asked if there were any synergies and/or contradictions in the listed qualifications. SAQA replied that the names were very important in terms of comparisons because people not part of the debates leading to the conclusions about the names may fail to understand the right meanings. This was an ongoing debate. The most essential matter was the quality SAQA offered, although the naming was also important. The NQF existed to ensure that there were no dead ends in formal qualifications.
Association of Private Providers of Education Training and Development submission
Ms Mariétta van Rooyen: Delegate and Past Chairperson of the Association of Private Providers of Education Training and Development (APPETD) presented a submission on the Skills Development Amendment Bill in the interest of the association’s members.
The registration with the Department of Education (DoE) was a contentious issue as it was difficult and did not acknowledge registration done by the Sector Education and Training Authorities (SETAs) as the designated Education and Training Quality Assurers (ETQAs). The DoE only recognised registration by Umalusi and by the Council on Higher Education (CHE). This was a problem as Umalusi and CHE had certain requirements that private providers did not need to have. Such requirements include having media centres at the institutions, libraries and so forth, which were criteria designed for universities and colleges. Some private providers had failed to get accreditation because they did not have these facilities which were not necessary as the providers focus on providing practical experience which did not necessitate research. Furthermore the DoE would only acknowledge and register companies registered as Pty and not Co-ops and Close Corporations (CC).
Ms van Rooyen indicated that it was due to the above issues that the APPETD was recommending that the registration of training providers offering occupational training be done by the Department of Labour. This would prevent duplication of accreditation and registration and ensure that the registration regulations for occupational training were suitable for training providers.
At present registration of providers is required at the Department of Education. The registration of training providers at the Department of Education has been one of the most contentious problems in the system as the DOE does not recognise accreditation other than that with the CHE and Umalusi. This meant that the accreditation with SETAs and professional bodies had to be duplicated. It also meant that skills development providers were required to comply with criteria designed for universities and colleges.
APPETD recommended that the registration of training providers offering occupational qualifications be done by the Department of Labour. This will prevent duplication in terms of accreditation and registration and ensure that the registration regulations for occupational training can be fit suitable for training providers.
The wording of the amendment of section 17 should thus read “a training provider accredited by the Quality Council for Trade and Occupations (QTCO), and then registered by the Department of Labour….”
APPETD also proposed the amendment of section 23 of Act 97 of 1998. The problem was that there was a duplication of registration for skills development/training providers and it created an unnecessary burden on providers. In addition, the establishment of skills development providers was too broad and open to all kinds of interpretation.
They said that skills development providers need to be recorded on the information systems of Employment services. The institutes of excellence could be registered as such by the employment agencies as prescribed.
They also suggested that the QCTO be responsible on all levels of qualifications of the National Qualifications Framework (NQF) for occupational standards and qualifications and their quality assurance for learning in and for the workplace.
These proposed amendments would mean that problems between the Departments of Education and Labour about the accreditation and registration of training providers would then be at an end.
Mr L Labuschange (DA) asked whether the APPETD was requesting that provision be made for on the job-training to be recognised right up to the highest National Qualification Framework (NQF) levels. He commented that an issue that needed to be considered in making such a provision was the problem of the fly-by-night training providers. He asked how this issue fitted in with the recommended provisions and/or adjustments.
Ms van Rooyen replied that the phrase ‘skills development and learners’ also included the Sector Education and Training Authorities (SETAs), Training Providers and Employers. This needed to be considered in the provisions. She added that when they were people trained as individuals then the fly-by-night situation may occur, although this was a criminal act. However the registration through the Department of Labour (DoL) resolved the issue.
Mr B Mkongi (ANC) commented that the Joint Policy Statement requirement for the establishment of QCTO addressed the issues in the APPETD submission. He asked if the proposal that there be only one registration compromised quality of the training and so forth.
Ms van Rooyen replied that the experience of the Private Training Providers was that the peer review by the educational institutions did not take into account that training providers were not academic institutions and thus did not need to conduct research or have libraries and media centres. She added that Training Providers needed separate reviews by similar institutions.
Mr Mkongi commented that the suggestions and proposals questioned the role and functions of the institutions established for registration and accreditation. He suggested that the South African Qualification Authority (SAQA) play a facilitation role in the discussions and suggestions.
Mr S Isaacs, SAQA: Executive Officer, commented that Ms van Rooyen had indicated very valid and crucial issues. It was correct that a Training Provider need to be accredited by the ETQAs, although the DoE may require Umalusi and CHE for accreditation. He agreed with APPETD that Training Providers after registering with the QCTO were reluctant to register with Umalusi and CHE because of the reason indicated by APPETD.
Ms van Rooyen commented that SAQA’s role was really important. She commented that individuals who had gained experience in the workplace should not have to go to universities to get a qualification.
A member commented that the Standard Generating Bodies (SGBs) were also important in the discussion.
Mr Isaacs replied that the SGB only looked at the standards of the qualifications. The ETQAs, CHE and Umalusi were responsible for registration and accreditation.
Mr Mkongi asked if it was necessary to have the SGBs
Mr Isaacs replied that there were two processes involved in accreditation. He added that the SGBs were going to be amended to become committees of excellence. The DoL controlled a wide range of areas although the SGBs still have some power. These SGBs have however been made consultative bodies. He further indicated that on oversight, SAQA had an evaluative and monitoring role. With regards to quality assurance, section 17 of the joint bill would indicate that SAQA would monitor the Quality Councils (QCs). The evaluative role of SAQA necessitated more powers
Mr Mkongi commented that he agreed with the issues raised. He asked the APPETD whether global skills development trends necessitated a change of the name Trainers to Skills developers.
Ms van Rooyen replied that as the Chairperson of the Human Resources Development Council, the issue had been raised. The National Qualifications Framework (NQF) Bill addressed whether Human Resources Development (HRD) was semantic to Occupational Training and so forth. Nonetheless Global HRD Practitioners still referred to themselves as Trainers.
Mr Isaacs commented that if the NQF Bill needed to be amended to address the parity of esteem within the titles. He added that the important thing was that the NQF and the three QCs needed to have parity of esteem with all qualifications
Mr Sam Morotoba, Skills Development Senior Executive Manager: DOL, commented that the issues of registration indicated in the proposals were important. The main rationale of these bodies was to ensure quality learning, specifically the QCTO and Umalusi. Umalusi was responsible for Higher Education only. The work-place training was certainly the issue. The SETAs were introduced and were responsible for registration and accreditation. He added that there were providers that continued to operate without being under any legislation. It however made no sense to include these providers under section 17. This might not be the correct place for the specific amendment. It made better sense to include these under section 30B. The second proposal went back to the debate on the development of the Act. Skills development addressed the knowledge of skills acquisition and application. He agreed that there might be semantics involved, although South Africa was moving along global trends in parity of esteem and attitudes over qualifications.
The Chairperson commented that the following week the Committee would attend the Portfolio Committee on Education meeting, to gain clarity on the issues raised.
South African Qualifications Authority submission
Mr Isaacs indicated that SAQA had sent a detailed submission to the DoL and the proposals were subsequently included in the amendment bill. The written submission was provided to the Committee. He indicated that the QCTO and the 3 QCs were very important in the NQF. SAQA was particularly concerned about the establishment of the QCs.
Mr Mkongi commented that he had noticed similarities in various terms in the submissions made by SAQA. He asked whether there were any synergies and or contradictions in the listed qualifications.
Mr Isaacs replied that the names were very important in terms of comparisons because people not part of the debates leading to the conclusions on the names, might fail to understand the right meaning. This was an ongoing debate. The most essential matter was the quality SAQA offered although naming was also important. Professional designations allowed one to be able to practice. The NQF existed to ensure that there were no dead ends in these qualifications.
Mr Mkongi commented that he was raising this issue because some job advertisements did not indicate the NQF level or qualification. He asked how the unemployed and the workers seeking employment were protected.
Mr Isaacs replied that in employment there was a need to have navigational tools addressing Career Guidance and Counselling which would address this issue. He added that according to Human Resources Practices, the advertisement and job requirements should state the required qualification and the equivalent of those qualifications. SAQA regularly monitored newspapers and had found that most advertisements did indicate the NQF level of a qualification. Currently the NQF had 8 levels which were going to be increased to 10 levels. Level 6 would include certificates and diplomas. It was also very important that all these were consistent with each other.
The Chairperson asked whether this was a comment or submission.
Mr Isaacs replied that these were submissions that would be made to the Portfolio Committee on Education on section 26(3)
The meeting was adjourned.
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