Council on Higher Education Comment and Advice to the Minister of Education on the NQF Consultative Document: An Interdependent National Qualifications Framework System



The Higher Education Act (No. 101 of 1997) sets out the roles and responsibilities of the Council on Higher Education (CHE) and its permanent committee, the Higher Education Quality Committee (HEQC), with regard to policy and quality assurance related matters in the Higher Education sector. Stated simply, in terms of their respective mandates, the CHE advises the Minister of Education on all matters relating to higher education and the HEQC is responsible for the quality assurance activities of all public and private providers operating in the Higher Education and Training band of the National Qualification Framework (NQF). Bearing this in mind, the CHE and the HEQC have decided to provide a joint response to the Consultative Document: An Interdependent National Qualifications Framework System.



The Consultative Document (CD) is the work of an Interdepartmental Task Team established by the Department of Education (DoE) and Department of Labour (DoL) in response to the Report of the Study Team on the Implementation of the National Qualifications Framework (RST). The CD, however, is not just a response to the previous report



"(it) embodies a new perspective on the NQF and proposes significant changes in the structures responsible for its implementation" (CD, p. 3).



The Interdepartmental Task Team goes beyond the proposals of the Study Team through two major interlinked changes. These are:



  1. Firstly, the conception of the interface between learning and work. The 'integrated approach' to education and training that has been a key objective of South Africa's NQF and has strongly shaped its implementation over the last seven years is replaced by an 'interdependent approach' that rests on conceptual and organisational distinctions between three 'learning pathways' .

  2. Secondly, the co-operative governance structures of the NQF. The CD proposes the creation of three qualification and quality assurance councils (QCs) and making the Interdepartmental Task Team a permanent structure carrying significant advice, policy and planning functions.




Recognising the importance of submitting a comprehensive and constructive response to the CD, the CHE and the HEQC commissioned consultants to prepare reports that were presented to a joint workshop on Friday 3 October and to a meeting of the Board of the CHE on Monday 13 October.1 These inputs, workshop and meeting provided the substance for this response.



While the CHE and HEQC welcome the release of the Consultative Document and support a number of its recommendations (see sections 2 and 7), we fundamentally disagree, with its reconceptualisation of the integration of education and training based on conceptual and organisational distinctions between three 'learning pathways'. We believe that the concept of 'interdependence' marks a dangerous retreat from the principle of the 'integration' of education and training. This will undermine access with quality to higher education and training especially for learners in the workplace.



Furthermore, we reject key recommendations on the grounds that these will compromise the development of an equitable, high quality national education and training system in South Africa, and undermine progress already made towards the implementation of the NQF. In these areas of disagreement, alternative proposals are provided.



The CHE and HEQC believe that the Interdepartmental Task Team have provided an accurate description of the problems that have bedeviled implementation of the NQF. However, the proposed solutions to these problems will exacerbate rather remedy the problems and will have a severe negative impact on South Africa's higher education and training system. While we accept that our interpretation of the Consultative Document may not align with the intentions of the Interdepartmental Task Team, we believe the validity of our interpretation is supported by our detailed analysis of the CD in the following sections. Any policy document is open to multiple interpretations and unintended consequences and it is a major failing of the CD that there are significant areas of ambiguity and lack of detail that open the door to conflicting interpretations.



The CHE and HEQC believe that the nature and measure of the CD's response to the problems of NQF implementation are inappropriate. The CD acknowledges that the NQF concept and objectives "continue to command widespread support" (CD p. 1). And yet, the CD proposes radical surgery to the concept of the NQF without providing a clear explanation of why this is necessary. It makes far more sense to build on the existing concept and objectives, given that they command 'widespread support'. By proposing fundamental changes, the CD undermines what has been achieved and will throw the whole education and training system into a state of confusion and uncertainty.



Broadly, this response will show that the CD is flawed politically, epistemologically, pedagogically and strategically.



  • Politically, the unhinging of education and training will result in the 'dumbing-down' of workplace learning and prevent access, mobility and progression for workers wishing to achieve worthwhile higher education and training qualifications.

  • Epistemologically and pedagogically, the CD tries to combine two incompatible principles: a principle of equivalence whereby qualifications and the learning they represent are similar across different sites and modes of learning; and, a principle of difference whereby important differences between modes and sites of learning are recognised. The CD assumes, but does not explain how, these tensions will be resolved.

  • Strategically, the CD proposes fundamental changes in the way the NQF is governed with new roles and responsibilities for SAQA and the Interdepartmental Task Team. These strategic proposals are not explained clearly and are likely to lead to confusion over the roles and responsibilities of different statutory bodies and hinder effective implementation of the NQF.




The CHE and HEQC also note with regret that the Consultative Document does not provide a synthesis or analysis of the responses to the Report of the Study Team, which we assume was the point of departure for the production of the Consultative Document. While acknowledging the importance of the DoE and the DoL achieving a "common understanding of how best to advance the objectives of the NQF" (CD p. 3), this objective should not be prioritised in a manner that undermines key objectives of the NQF and progress that has been made towards implementing these objectives. We believe that the incremental approach to change adopted in the Report of the Study Team, building on strengths within the present system while addressing weaknesses, provides a better approach to change. The radical recommendations proposed by the CD, if implemented, will have severe negative consequences for the education and training system and will hinder the implementation of the NQF and the effective achievement of the objectives of the government's Human Resource Development Strategy.






  1. See the 'Research Report' (reference: CHE Discussion Forum: Options for the NQF in South Africa) commissioned by the CHE from Young, M. (2003)