Recognising qualifications introduced before 2012

The question of how to deal with qualifications awarded before 2012 and which are not related to a national qualifications system / framework referenced to the EQF has two elements to it:

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A time dimension – i.e. how to deal with qualifications that were awarded before the national qualifications framework/ system was referenced to the EQF (the expected time by which countries are supposed to have referenced their framework or systems to the EQF being 2012)?

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A question concerning the scope of the qualifications systems / frameworks – i.e. how to deal with qualifications that are not part of the qualifications framework or system? 9.6.1 How to deal with qualifications that were awarded before the NQF or NQS was referenced to

the EQF?

The competent authority perspective on the issue varied. The most commonly expressed view was that the existing system would have to be retained in parallel to one based on learning outcomes. This was felt to be workable for some on the basis that there was a strong equivalence between the five and eight level systems. Competent authorities were fairly relaxed with the notion of dealing with older qualifications, given that it is something that routinely happens anyway. Some suggestions were provided that indicate the recognition process becoming less straightforward for applicants with pre-2012 qualifications. For example, one competent authority for accountants suggested:

“We would apply the same processes that we use for non-EU countries, namely to ask the university to define their qualifications in terms of learning outcomes, and then we compare these against our criteria.”

This suggests that if EQF levels were to replace Article 11, different practices may be deployed in different countries, which could be problematic. A more systematic approach would be necessary. However, given that the NQF/EQF implementation is still in relatively early stages, the question of older qualifications has not yet been tackled in the vast majority of countries or at European level. It is possible, though, to set out a hypothetical analysis of the options.

In case the decision is made to use the EQF levels for qualification recognition under the Directive, the following two options exist to deal with „older qualifications‟:

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1) The referencing to the EQF level applies retrospectively (i.e. there may be an existing referencing to a national framework that, assuming no subsequent change to the qualification, can be used to place an older qualification on a level in the EQF).

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2) The older qualification is placed on a NQF/NQS level which is related to the EQF (i.e. there is an explicit process to incorporate older qualifications, perhaps on a case-by-case basis, as part of the work to develop an NQF).

9.6.1.1 Applying the EQF referencing retrospectively

The referencing report is simply a snapshot of the national qualifications levels and the EQF at a specific time165. The qualifications systems evolve, new types of qualifications are introduced and new requirements are defined for existing qualifications. This may have an impact on the referencing of the NQF/NQS to the EQF. In other words, what

influences/affects the relationship between the NQF/NQFs and the EQF are changes and reforms of the qualifications systems.

When the EQF referencing of an NQF/NQS is defined, it concerns the qualifications system as it is at a given point in time. It can be used retrospectively until the time when the latest qualification reform affecting a given qualification has been introduced.

Example A:

A country refers its qualification framework to the EQF in 2012. According to this referencing, the qualification A is placed on a level in the NQF which corresponds to the level 5 of the EQF. The requirements for the qualification A have been reformed in 2004 when new qualifications standards started being used, defining the qualification in terms of learning outcomes. Since then the qualification has not undergone changes that could affect its positioning in terms of level of learning outcomes. Consequently, one could consider that the qualification is at a level equivalent to the level 5 of the EQF as from 2004 but not before that.

165

p. 39 http://ec.europa.eu/education/lifelong-learning-policy/doc/eqf/note3_en.pdf . See also page 30 of http://ec.europa.eu/education/lifelong-learning-policy/doc/eqf/note3_en.pdf

Example B:

In another country, the development of the qualifications framework is part of a large-scale qualifications reform. As part of this reform, all qualifications are redefined according to new (or at least partly new) principles. This includes defining the learning outcomes for each qualification. This new qualifications framework (and the new qualification) is implemented as from 2012 when the framework is also referenced to the EQF. Given that the

qualifications system has undergone major changes before the NQF implementation and EQF referencing, the results of the EQF referencing cannot be applied retrospectively. These two examples are possibly two extremes – the reality of most countries is probably somewhere in the middle – qualifications frameworks and the use of learning outcomes bring in some change166, but it is possible that this change does not radically affect the level of qualifications.

According to Cedefop167, most qualifications frameworks currently in development in EU countries do not have a reforming character but their goal is to ‘communicate’ (i.e. describe) qualifications systems in a new and more transparent manner. Consequently, it can be assumed that in most cases the NQF implementation will not radically reform the qualifications system and qualifications requirements (it will not bring in new qualifications or radically reform the existing qualifications). At the same time, it appears that countries are increasingly making use of learning outcomes to define qualifications. EQF requires NQFs and NQS to be based on learning outcomes and subsequently also qualifications are expected to be defined in terms of learning outcomes.

It can be argued that when a qualification becomes defined in terms of learning outcomes and is then referred to the qualifications framework, it is a new qualification that is different from the qualification before the introduction of learning outcomes. On the other hand, it can also be argued that the fact that a qualification becomes explicitly defined in terms of learning outcomes does not make it radically different from the previous qualification where the learning outcomes achieved by learners were not explicitly defined (but learners still gained knowledge, skills and competence).

9.6.1.2 Placing of older qualifications in the NQF

National authorities could be supported or encouraged to ensure that older qualifications are referenced to the NQF. Most countries are currently busy dealing with defining qualifications frameworks based on existing qualifications and the issue of older qualifications is not being discussed. This is therefore a substantive current gap in NQF development work. However, there are examples suggesting that the issue is being addressed by some countries with more established qualifications frameworks. For example, the French NQF contains old qualifications that are no longer being awarded. In Ireland the National Qualifications Authority has already undertaken work to place some former qualifications within the NQF. Its Policies and Criteria for the Establishment of the National Qualifications Framework168 sets out a proposed approach:

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The key criteria for placement of former awards are learning outcomes. Relevant evidence can be used for determining evidence of standards and learning outcomes (e.g. programme descriptions and curricula, historic equivalences with other

qualifications, transfer and progression opportunities associated with the award).

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It is noted that placement of a former qualification on the framework does not imply that

all outcomes associated with newer, framework-based qualifications at the same level have been achieved because the purpose of the qualifications may be different: „Awards

166

This can even be very important change for certain aspects of education and training such as: assessment processes, use of learning outcomes for teaching or the possibility to validate and recognise non-formal and informal learning

167

Cedefop (2010) http://www.cedefop.europa.eu/EN/Files/6108_en.pdf

168

National Qualifications Authority of Ireland (2003), Policies and Criteria for the Establishment of the National Qualifications Framework

will be placed at levels in the Framework on an overall „best fit‟ basis, with no judgment made or implied about the attainment of any specific learning outcome by individual holders of the award‟.

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Sets of awards may be placed at the same level if there is evidence that they share standards. If not, „then more detailed work will be required to place subsets of individual awards at appropriate levels in the Framework‟.

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It is also set out that a former award may be placed at multiple levels in the framework depending on specific grades or measures of attainment.

The „best fit‟ approach appears logical and would provide the most straightforward way of NQFs adding value in the context of professional recognition for older qualifications. Although there has been little development activity in this area so far, there is a strong rationale for suggesting that those older qualifications that are most likely to be used for the purposes of professional recognition are those that national authorities will focus attention on mapping to NQFs.

9.6.2 How to deal with qualifications that are not in the NQF/NQS that was referred to the EQF? Countries are developing their NQFs and NQS progressively and most begin this process by including only those qualifications that are awarded by the formal education and training sector (i.e. qualifications that are achieved after initial education and training)169. However, regulated professions can sometimes be linked to qualifications that are not part of this „formal education and training system‟. In some cases, the regulated profession is conditioned by a qualification awarded by a recognised professional organisation – for example chartered engineers.

The regulation for chartered engineers is typically related to the fact that a professional organisation gives them a certificate that entitles them to perform certain rights. This certificate is not a qualification from a formal education system. The professional

organisation often requires that the candidate holds a certain education qualification (there can be more than one type or level of qualification – for example, as in the Czech Republic) and that he has some professional experience. There may also be an examination in front of a jury. Independent of the education qualification, all those who hold this professional certificate have equal rights to practice the profession.

It is not clear whether countries will include such certificates in their qualifications framework. In some countries with well-established NQFs, not all qualifications of the above type are included in the NQF, for example:

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In France, the qualification to work as auditor (commissaire aux comptes) can be achieved through two pathways which both require substantial professional experience170 . One is linked to an initial education qualification complemented by professional experience. The initial education qualification is in the NQF but the certificate of auditor as such is not.

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In France, it would theoretically be possible to include this qualification in the NQF, although the way the certification is defined would have to comply with some criteria. The authority governing the certification would have to request that and it is highly likely that they have an interest in doing so (there is no added value for them).

This issue is likely to be determined on cases-by-case basis, depending on whether the professional organisation is interested in having its certificate in the NQF. For these qualifications, it would not be possible to use the reference to EQF levels because they are outside the NQFs/NQS.

169

See Cedefop 2010 and 2009 on NQFs http://www.cedefop.europa.eu/EN/Files/6108_en.pdf

170

http://www.metiers.justice.gouv.fr/presentation-des-metiers-10070/les-autres-metiers-de-la-justice- 10074/commissaire-aux-comptes-16329.html

In document Revised Final Report - Study evaluating the Professional Qualifications Directive against recent educational reforms in EU Member States (Page 152-156)