Graduate and Vocational Graduate Certificates and Diplomas in the AQF

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1 Graduate and Vocational Graduate Certificates and Diplomas in the AQF July 2012

2 This work is copyright-free to universities and other relevant bodies provided that attribution of authorship is made to Universities Australia. Apart from such use, all rights in copyright are reserved. Further inquiries should be made to the Chief Executive: GPO Box 1142 CANBERRA ACT 2601 Ph: Fax: contact@universitiesaustralia.edu.au Web: ABN:

3 Contents Introduction... 2 A Problem to be Solved?... 2 Structural Issues... 2 Levels and Equivalency... 2 A Baseline Qualification at Level 7: The Bachelor... 3 A Short Note on Pathways... 3 Specific Issues... 4 Removal of the Graduate Certificate... 4 The Uses of Graduate Certificates... 4 The Robustness of the Graduate Certificate as a Qualification... 5 Longer Volume of Learning and Market Need... 5 Terminology... 6 The Level of the Graduate Certificate... 6 Removal of the Vocational Graduate Certificates and Diplomas... 6 Retention of a Level 8 Graduate Diploma Qualification... 7 Implementation Timeline... 7 General Comments on the AQFC Decision Making Process... 7 Appendix... 8 Specific Example of Graduate Certificates in Action: Queensland University of Technology School of Nursing... 8 Graduate and Vocational Graduate Certificates and Diplomas in the AQF 1

4 Introduction Universities Australia (UA) welcomes the opportunity to comment on the Australian Qualifications Framework Council s consultation paper on Graduate and Vocational Graduate Certificates and Diplomas. UA appreciates the complexities involved in seeking to reform the existing structure at levels 7 and 8 of the AQF and also acknowledges that the responses to the initial consultation on these matters were inconclusive. While we acknowledge that the option proposed by the AQFC cannot represent a consensus view, we are extremely disappointed at the absence of any further consultation on its development, and its presentation as a fait accompli, with feedback being sought exclusively in relation to matters of implementation and unforeseen consequences, not substance. UA supports the proposal to remove the Vocational Graduate Certificate and the Vocational Graduate Diploma qualifications, but we do not believe that the case has been made to remove the Graduate Certificate, nor that a sufficient attempt has been made to understand the place of the Graduate Certificate within the existing AQF and its significant value to the wider community. We therefore do not support the proposal to remove the Graduate Certificate. There are both general and specific reasons for taking this position, which are expanded upon in the remainder of the paper. A Problem to be Solved? The paper fails to clearly articulate the nature of the problem that the proposal is seeking to resolve. The November 2011 consultation paper on this matter suggested that the core issue was a need to better define the Graduate Certificate and Graduate Diploma qualification types. The views expressed [in earlier discussions] included differentiating between qualifications used for broadening and extension or deepening in a discipline/field of study and distinguishing between qualifications that are graduate or postgraduate in purpose. The current paper suggests (page 4) that the key issue is that there is a hiatus in VET pathways at level 7. UA considers that the proposals do not resolve either of the suggested problems. More importantly, if implemented, the proposals would seriously constrain the nation s ability to meet its workforce and professional needs in a fast-changing and highly competitive domestic and global environment. Tertiary institutions would be unable to meet market demands unless they were to do so by offering courses outside of the AQF. This latter option would have the unfortunate consequence of weakening the credibility and influence of the AQF. Structural Issues UA does not believe that the AQFC s proposals accurately reflect the purpose and use of the AQF or adequately take account of some key structural points. These points are outlined below. Levels and Equivalency UA considers that the 2011 AQF is starting to reveal inherent flaws that were not apparent when the Framework was introduced. Chief amongst these is the core assumption as stated through the level criteria that qualifications at the same level provide equivalent skill sets, regardless of the differences between volume of learning; content; mode of instruction; and, crucially, purpose. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 2

5 The flow-on effect of this assumption is that it is the level of a qualification, and not the specific qualification type, that is considered by the AQF to be the important factor in considering pathways between qualifications. This is a false assumption. While it is reasonable to include, within a single level, qualifications with different volumes of learning, it should not be assumed that graduates of the two programs are equally prepared to move to the next higher educational level. While the consultation paper acknowledges that qualifications are different and may be part of different pathways, it does not appear to allow the legitimate and often desirable possibility that some pathways would end at points before level 10. The implication is that the AQFC considers that the only way is up, but this does not reflect academic realities, where pathways can occasionally require sideways or even backward steps before upward movement can be continued. This approach, while providing certainty, does not provide the necessary flexibility to accommodate a wide range of needs and demands. A Baseline Qualification at Level 7: The Bachelor While flexibility in the architecture is essential, such flexibility does not, and should not, preclude the existence of key qualifications that act as the central pillars of the Framework. The level 10 doctorates, for instance, provide a clear capstone to the structure. The most important pillar is a qualification that serves as the gateway to Masters and Doctoral study. UA s position is that this should be the Bachelor degree. The consultation paper suggests, however, that this baseline qualification will be moved from the level 7 Bachelor to the level 6 Advanced Diploma (see especially the tables on pages 6-7). This would seem to be a serious backward step that would undermine the value and international competitiveness of Australia s Masters and Doctoral qualifications. Furthermore, it would be possible to avoid the Bachelor qualification altogether. The Bachelor degree provides a depth and breadth of learning, as well as the essential skills including basic research skills required for study at levels 8-10 and that predict success at these levels. Moving the baseline to level 6 whether through and Advanced Diploma or Associate Degree will reduce the volume of learning in the pathway and risk weakening the achievement of students at the more advanced levels. The proposal to enable quicker, easier access to a Master s degree without a Bachelor qualification appears to be at odds with AQFC s recent decision to strengthen the robustness of the Master s degree by increasing the duration of study. Furthermore, we note that the Bachelor qualification is central to the European Bologna system (among others) and an allowance for Australian students to avoid that qualification may render the AQF suspect internationally, with unknown consequences for student mobility and the international student market (particularly at postgraduate level). Such an outcome would run counter to the AQF s objective of aligning the AQF with international practice. This is not a matter that is of exclusive interest to universities. Bachelor programs are becoming an increasingly common offering of VET institutions and private providers. A Short Note on Pathways The AQFC paper notes that there is a hiatus in the VET pathways between levels 6 and 8. UA does not consider this to be sufficient reason to justify the proposal particularly given that pathways for VET students through level 7 are already in place, as acknowledged in the AQF s pathways policy. Advanced Diplomas can gain significant credit into Bachelor degrees and it is arguable at best whether this needs to be augmented by an alternative qualification type. In any event, the concept of there being a hiatus in the VET pathway should be considered of little import in light of the AQFC s own contention that the AQF should be seen as a seamless framework that encompasses all parts of the tertiary education Graduate and Vocational Graduate Certificates and Diplomas in the AQF 3

6 sector. The paper goes some way to recognising this through its proposal to remove Vocational Graduate Certificates and Vocational Graduate Diplomas from the AQF. Specific Issues Removal of the Graduate Certificate The AQFC paper proposes removing the existing level 8 Graduate Certificate of 6-12 months volume of learning and effectively replacing it with a level 7 Graduate Diploma of months volume. UA opposes this proposal and does not believe that the case for change has been made. The Uses of Graduate Certificates The Graduate Certificate is a valuable and well understood qualification for up-skilling the workforce. It is well used by students, with approximately 15,700 completions in This suggests that there is a strong demand for qualifications of this type. Traditionally the Graduate Certificate has often been used as a very specifically focused form of professional development to provide specialist knowledge and skills recognised by industry, government and the tertiary sector itself. It plays an important role in delivering life-long learning and ongoing professional development. These Graduate Certificates build on existing skills developed through Bachelor study or Bachelor-equivalent professional experience. To give an example of this style of Graduate Certificate, The University of Queensland is offering Graduate Certificates of Gastroenterology, after being encouraged by the Department of Health and Ageing to prepare nurses for the national bowel screening initiative. Another example is the various Graduate Certificates in Tertiary Education, available to an increasing number of new academics seeking to embark on their teaching careers. A long list of similar examples could be compiled. A very small sample to demonstrate the range is provided below: pathway qualification for qualified teachers to move into TESOL teaching providing commercialisation skills to PhD candidates to obtain industry-specific management skills to provide Indigenous students with cultural resource management skills to provide engineers and scientists a primer in occupational hygiene. Many such cases are formally accredited by relevant professional associations and employer bodies, including government departments. In none of these cases would a longer course of study be necessary or efficient. Short-courses such as Graduate Certificates provide the much needed flexibility to rapidly respond to specific needs without the long pipeline effects of standard Bachelor or Masters programs, and accord with the AQF objective to support contemporary and relevant qualification outcomes and individuals lifelong learning. Graduate Certificates also allow for interdisciplinary transition to provide pathways for students wishing to move into new fields of study either for professional or further learning purposes. In these cases it is inappropriate to insist that students undertake a second Bachelor program of study, but they do require recognition of their extension, or bridging study. Graduate Certificates allow students to move sideways. The Appendix to this response provides a case-study overview of the Graduate Certificate in Nursing offered by the Queensland University of Technology. It illustrates the utility of and need for the retention of the Graduate Certificate, as well as the consequences that would follow the implementation of the proposed changes. This case study is typical of a very large number of similar courses being run at every Australian university. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 4

7 The Robustness of the Graduate Certificate as a Qualification The AQFC paper asserts that the existing Graduate Certificate is not sufficiently robust as a standalone qualification. However the paper does not explain what is meant or upon what basis this conclusion is reached. The existing AQF specifications for Graduate Certificates make it clear that the skills and knowledge gained through their study is deep, though it may be specialised and of short duration (e.g. specialised technical and creative skills in a field of highly skilled and/or professional practice ). The volume of learning alone cannot determine the quality of the outcomes gained through a qualification, and the existing specifications allow for this. It must be noted that, although Graduate Certificates are short, this is because the subject material to be learned is itself typically small in volume, covering narrow fields of study and a few particular units. Graduate Certificates (and Graduate Diplomas) are not undertaken as isolated islands of study, but instead can only be undertaken following other, longer studies of level 7 or above. They should not be considered as entirely separate packages of work that must stand or fall on their own merits, but should be seen only in conjunction with their pathway studies already completed. It may be useful to compare Graduate Certificates with their level 4 counterpart, the Certificate IV. The Certificate IV has a stated volume of learning of typically years. There may be variations between short duration specialist qualifications that build on knowledge and skills already acquired and longer duration qualifications that are designed as entry-level requirements for work (emphasis added). If the AQF allows elsewhere for a short course that builds on study already undertaken, the principle must surely be transferable to other levels within the AQF. Although it sets the specifications for qualifications, the AQFC is not the appropriate body to judge whether institutions are effectively delivering the qualifications to the set standard. This is properly the role of the Tertiary Education Quality and Standards Agency (TEQSA), and the AQFC should allow TEQSA processes to determine whether institutions are delivering Graduate Certificates that meet the standard demanded by the specifications. Should TEQSA determine that this is not the case, then the AQFC will have some evidence to support the argument that is missing from the current paper s assertion. Longer Volume of Learning and Market Need Doubling the volume of learning of the Graduate Certificate s proposed replacement qualification would have the very serious consequence of creating barriers to participation. The additional time commitment required would increase the cost of participation, and would disproportionately affect people undertaking study alongside employment and those who are mature age or from disadvantaged backgrounds who often undertake higher degree study on a part-time basis (Flinders University, for instance, currently has 162 students enrolled in Graduate Certificate courses, of whom 81 per cent are women, 99 per cent part-time, and 80 per cent of whom are aged over 30). Insisting on longer awards will have adverse effects on students by forcing them to pay for two years of study, with expected consequences on enrolments that will run counter to the Government s current push for increased participation. Shorter duration programs help to reduce barriers to participation and assist participants and employers to manage the risk of participation in further study, particularly for students that have not studied for some time. A significant number of students undertaking Graduate Certificate courses have their studies funded by their employers. It is possible that some employers would be less willing to support these courses if they were twice the duration, both in terms of cost increases and in the time spent away from the workplace. Employers fund their employees because Graduate Certificates are frequently vocational Graduate and Vocational Graduate Certificates and Diplomas in the AQF 5

8 with content tailored to the needs of a profession or industry and because they deliver a good rate of return on the investment made. It would be inappropriate to remove programs that Australian employers support financially and that they find relevant to update the skills of their employees. An unintended consequence of the proposed change would be a likely increase in the number of institutions that will offer non-aqf standard short courses to meet the existing demand. UA strongly opposes the increase in volume of learning in the Graduate Certificate or its proposed replacement, the level 7 Graduate Diploma. Terminology The use of the terms Graduate Diploma and Advanced Graduate Diploma is argued in the paper as providing a useful symmetry to the level 5 and 6 Diploma/Advanced Diploma. It is our contention that the plethora of various Diplomas will lead to confusion for students and employers. Additionally, the transferral of an existing title to a different qualification entirely, as is the case with Graduate Diploma, will cause difficulties for those who already have the old style qualification, particularly as the drop in level may lead to a de-facto devaluing of their qualifications. While this could be rectified through a re-classification system, it is likely to be expensive and cumbersome. The term Graduate in the public mind has the same connotation as Postgraduate. That is, the holder will already have completed a Bachelor degree. We would not support terminology that would grant this common recognition to any individual who has not in fact completed a Bachelor degree as it would have the unwanted consequence of increasing the value of the qualification. With these caveats in mind, the question of terminology remains open. UA recommends that the AQFC explicitly market test both the proposed terminology as well as the rejected terminologies listed on page 5 of the paper, should it proceed with the implementation of the proposals put forward in the consultation paper. The Level of the Graduate Certificate The Graduate Certificate is currently located at level 8 of the AQF. It can be argued that a broadening, or extension, Graduate Certificate, that contains undergraduate material, should be located in level 7, but this is not appropriate for those Graduate Certificates that build on existing skills and knowledge in an area. Several members have suggested to UA that Graduate Certificates, or two variations using different names, should be located in both levels 7 and 8 and be differentiated by purpose and level of learning. UA recommends that this idea be examined by the AQFC and the sector, subject to considerations on volume of learning, outcomes and terminology. Removal of the Vocational Graduate Certificates and Diplomas Universities Australia members overwhelmingly support this proposed change to the AQF. Under the existing AQF model the divide between Vocational and non-vocational Graduate Certificates and Graduate Diplomas is one of terminology only. Given that the specifications for the respective qualifications are identical, there is no need to distinguish between them. This artificial distinction only serves to add unnecessary complexity and confusion. The Vocational qualifications at this level are already obsolescent. NCVER figures for 2010 indicate that there are approximately 4000 students enrolled in these qualifications compared with nearly 35,000 undertaking the higher education equivalents. There are suggestions that students perceive the higher education versions to be of higher quality. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 6

9 The removal of Vocational Graduate Certificates and Vocational Graduate Diplomas would be consistent with moves in the VET sector to reduce the number of qualifications that are undertaken by only a small number of students. Retention of a Level 8 Graduate Diploma Qualification Subject to the caveats outlined above regarding terminology, Universities Australia supports the retention of a level 8 qualification equivalent to the existing Graduate Diploma. Such a qualification fills an important role within current university practice and pathways planning in enabling Bachelor s degree graduates to move sideways into a new discipline area, while building on their prior learning experiences. Implementation Timeline UA insists that any changes made to the existing Graduate Certificate and Graduate Diploma structure must be implemented in accordance with the timeline already established under the 2011 AQF process. That is, institutions will have until 2015 to implement any changes. The drafting on page 7 of the paper could be interpreted as suggesting full implementation by 1 January UA understand that this is not the intention and suggest that this be clarified should any changes be pursued. General Comments on the AQFC Decision Making Process Restrictions on pathways implied by the proposed changes are inconsistent with the purpose of the AQF as stated in the 2011 version of the Framework, that is, that the AQF is to accommodate a diversity of purposes, support for the development and maintenance of pathways, and support and enhancement of student mobility. The current paper appears to run counter to these principles. We also note the restricted nature of the input sought in this consultation. This is of particular concern given that the proposal put has been developed on the basis of very limited (if any) consultation with the university sector. This is not consistent with the AQF s own policy on Qualification Type Addition and Removal, which demands a comprehensive consultation with, and support from, relevant industry, professional, provider and government stakeholders. We note in particular clause on the need for robust evidence in favour of, and sectoral support for, the removal of a qualification. UA is not aware of any process of consultation with relevant industry, but if this has occurred, we would appreciate advice from the AQFC as to the industry view. Statements such as the AQFC intends making the following changes (page 4) do raise strong concerns that the AQFC is not abiding by its own consultation policies and is making decisions which are not as well informed as they might be. Concerns amongst universities about the consultation and decision making process of the AQFC will be the subject of a separate communication between UA and the AQFC. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 7

10 Appendix Specific Example of Graduate Certificates in Action: Queensland University of Technology School of Nursing QUT s School of Nursing has provided UA with the following detailed example of how it uses the Graduate Certificate, and its comments on what the proposed changes will mean for it. We have attached it below for the information of the AQFC. 1. Two thirds (257 of 347) of our current postgraduate enrolments are in NS32, our 4 unit Graduate Certificate in Nursing. All of these enrolments are domestic students who are Commonwealth supported. The 4 unit Graduate Certificate is a workplace-based program that deepens nurses knowledge and skills in relation to a speciality area of the same discipline. Most specialty nursing areas in Australia are entered via a Graduate Certificate, which is why they are Commonwealth supported. 2. The Graduate Certificate provides a very useful way for the School to work with industry to recognise specialty nursing practice and develop our relationship with the profession through our course advisory committees. It is highly relevant to the clinical nature of the discipline of nursing and tends to attract nurses who wish to practise at an advanced clinical level. Nurses working clinically comprise the majority of nurses in Australia and are a potentially large pool from which to draw enrolments. The Graduate Diploma course NS64 and the Masters course NS85 tend to attract the relatively few nurses interested in research, education or management careers. 3. Another reason that NS32 is so popular is that it enables students to specialise in a discrete area of practice. As a result, employers tend to class it as an entry to specialised practice degree. It is therefore linked to a qualification allowance in Queensland public hospitals, which results in a pay rise for those nurses who have gained a minimum of a university-conferred graduate certificate pertinent to their area of specialty practice. We should be cognisant that under the new structure proposed by the AQF, the present 4 unit graduate certificate at Level 7, the same as a Bachelor degree, might not be considered entry to specialised practice and might therefore not attract a qualification allowance. 4. Our graduate certificates are often linked to transition education programs developed by industry, whereby students receive advanced standing into our graduate certificate for successful completion of industry-developed modules. This is a significant incentive for nurses to come and study with us. 5. Finally, our elite Nurse Practitioner Masters specifies advanced practice as an entry criterion. Our Graduate Certificate is a pathway into this course. While clearly we might need to work towards the proposed changes to the AQF, several factors need to be accounted for in our planning for this: 1. Given the nature of advanced clinical nursing work, very few domestic nursing students progress from the Graduate Certificate to the Graduate Diploma (NS64) or Masters of Nursing (NS85). NS64 and NS85 are not Commonwealth supported and require two or three times the volume of learning for the student to obtain their qualification allowance. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 8

11 That is, beyond the 4 units entailed in the Graduate Certificate, postgraduate study is more expensive and does not necessarily result in any financial benefit for many nurses. Unless the proposed Level 8 Graduate Diploma, which similarly requires a greater volume and level of learning, can be Commonwealth supported, significantly fewer nurses will enrol in that program. We will need to find creative solutions to the significant disincentive of more time and more money that will be required of our students to gain a qualification that we cannot guarantee will lead to salary recognition. 2. The demotion of the Graduate Certificate to a level 7 Graduate Diploma would disadvantage students in other ways and we need to factor this in. For those students who enrol in the proposed level 7 Graduate Diploma or level 8 Advanced Graduate Diploma, but who struggle with the level of study, there would be no honourable exit point for those who manage to complete less than the minimum of 1 year full time required of both courses, and possibly no salary increment despite successful completion of some units. We would need to find a satisfactory exit strategy, or perhaps link up more closely with our shorter CPD programs. 3. Our international enrolments, which traditionally comprise one third of our enrolments in the Graduate Diploma and Masters courses, have declined 25 per cent since the start of the global economic downturn, and we expect this decline to continue. Along with the attrition we would expect with the proposed AQF revision to the Graduate Certificate, the viability of our entire postgraduate program is no longer assured. 4. Under the new arrangements, the transition programs we currently recognise for advanced standing are likely to be classed as (vocational) graduate certificates at level 7. We will need to think seriously about how to work further with industry to ensure how recognition of their courses is maintained. Graduate and Vocational Graduate Certificates and Diplomas in the AQF 9

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