SUBMISSIONS WHITE PAPER QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME

Transcription

1 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS WHITE PAPER Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8 and 9

2 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS [Page 2] SUBMISSIONS QQI received submissions by from the stakeholders listed below.*»» Certified Public Accountants Ireland»» Chartered Accountants Ireland»» Engineers Ireland»» Higher Education Colleges Association»» Institutes of Technology Ireland»» Medical Council»» The Royal Institute of the Architects of Ireland»» Society of Chartered Surveyors Ireland *Please note the responses on the following pages appear as received and have not been proofed/edited by QQI.

3 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Certified Public Accountants Ireland Please note this response appears as received and has not been proofed/edited by QQI.

4 CPA IRELAND Submission Regarding Qualifications and Quality Ireland s (QQI) White Paper: Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8 and 9. Version January 2014 CPA Ireland is pleased to make a submission as part of QQI s consultation process on the White Paper, Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8 and 9, published in December CPA Ireland is one of the main Irish accountancy bodies, with 5,000 members and students. The CPA designation is the most commonly used designation worldwide for professional accountants and the Institute s qualification enjoys wide international recognition. The Institute s membership operates in public practice, industry, financial services and the public sector in over 40 countries around the world. The Institute is active in the profession at national and international level, participating in the Consultative Committee of Accountancy Bodies Ireland CCAB (I) and together with other leading accountancy bodies, the Institute was a founding member of the International Federation of Accountants (IFAC) the worldwide body. The Institute is also a member of the Federation des Experts Comptables Europeens (FEE), the representative body for the main accountancy bodies in 32 countries. The Institute fulfils its statutory role as a recognised body by overseeing the professional activities of its members in practice, and ensuring that education and training standards are maintained. As the first accountancy body to introduce a mandatory regime of Continuing Professional Education, the Institute ensures that all its members remain at the leading edge throughout their careers. The Institute provides a quality service to its members and students, which has been recognised through the award and maintenance of ISO 9001:2008. For further information visit The comments and suggestions on the following pages are related to the specific sections of the White Paper. CPA Ireland submission in response to QQI s consultation on the White Paper, Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8 and 9, published in December 2013.

5 Section 1 INTRODUCTION Section 1.2 LEGAL BASIS This section of the consultation paper states Alignment is a necessary alternative tool for recognising awards within the Framework. CPA Ireland notes: 1. The Qualifications and Quality Assurance (Education and Training) Act 2012 (the 2012 Act) makes numerous references to recognised within the framework and validation, there is no reference at all to alignment, and 2. There is no reference, either, to alignment in the Role of QQI or the Functions of Authority as listed (a) to (p) on the QQI website (18 January 2014, web address: COMMENCEMENT OF THIS POLICY This section advises that All professional awards aligned under previous policies must be submitted for re- alignment as soon as practicable. Alignment of professional awards will not be otherwise renewed. Suggestion: Replace submitted for re- alignment.. with submitted for renewal of alignment or re- alignment The following clarifications are sought: 1. By whom, and how, will as soon as practicable be determined? 2. Will there be a time limit imposed by QQI? The sentence as written could be interpreted as being somewhat open ended. As previously advised by HETAC and QQI, this section should state that full submissions under this policy are required for the renewal of alignment, or re- alignment, of any awards aligned under previous policies. Section 2 POLICIES AND CRITERIA 2.1 APPROACH This section advises that Additionally alignment involves (where applicable) the recognition of the quantity of ECTS credit to be associated with the professional award. Clarification is sought on the criteria for determining where it may, or may not, be applicable to recognise the quantity of ECTS. The provision of examples might assist in this regard.

6 2.3 PROGRAMME VALIDATION AS AN ALTERNATIVE TO PROFESSIONAL AWARD ALIGNMENT FOR GAINING RECOGNITION WITHIN THE FRAMEWORK Suggestions: 1. Points 1 to 6 could be relocated to an appendix to this document. 2. If suggestion 1 immediately above is accepted add These differences are discussed in Appendix?? to this document. after the sentence Alignment and programme validation (by QQI) have much in common but there are significant differences between them: 2.4 DURATION OF PROFESSIONAL AWARD ALIGNMENT There is a reference to a specified period in this section. Clarification is sought as to who specifies this period and on what basis. This section also may cause difficulties for professional bodies and their members of long- standing. It may not be practicable or possible to provide the evidence required. A grandfathering process should be considered especially for professional bodies that have mandatory CPE/CPD requirements that are audited. 2.5 PROFESSIONAL AWARD ALIGNMENT AND CHANGE Suggestion: Add Examples include: after the sentence ending while often self- evident may be a matter for expert judgement. Clarification is sought on who should procure the expert advice, and whether there will be an appeals process (and details of same) in the event of a difference of opinion THE EXTERNAL ASSESSMENT PROCESS This section of the White Paper appears to CPA Ireland to be scaled back significantly from the corresponding section in the 2011 Professional Award Alignment Policy and Criteria published by HETAC and the NQAI. CPA Ireland accepts that it should bear its own costs with respect to external assessment. However, it is unclear to CPA Ireland if the reference that the applicant is competent, resourced and sufficiently trustworthy and reliable to manage such a process is intended to mean that an applicant must also bear the costs of the assessment panel. CPA Ireland is of the view that the costs associated with the external assessors should be covered by QQI out of funds generated from applications for alignment. This section of the White Paper also refers to a signed memorandum of agreement between QQI and the applicant concerned. CPA Ireland is of the view that an indication of the proposed content of the memorandum of agreement would be useful. Its absence limits the scope for comment and suggestions in relation to this aspect of the consultation on the White Paper. CPA Ireland suggests that the memorandum should include matters such as: panel composition, dates, deadlines, confidentiality, report format, appeals, avoidance of potential conflicts of interest, input from

7 assessors from outside this jurisdiction, and the role of QQI in both the formation and work of the panel. Clarification is sought on the basis for QQI setting aside an external assessment report, and the exceptional circumstances that may give rise to QQI managing a new process SEVEN OUTLINE CRITERIA FOR PROFESSIONAL AWARD ALIGNMENT Suggestion: Replace SEVEN with EIGHT Clarification is sought with respect to the third of the eight criteria as to where it may, and may not, be relevant to provide volume information RENEWAL OF ALIGNMENT AND RE- ALIGNMENT Suggestion: Add as referred to in 2.17 after The process will be conducted by QQI as a de novo alignment and the same appeals process 2.15 CONDITIONS OF ALIGNMENT Clarification is sought with respect to: 1. The statistical information QQI will require for each associated programme of education and training leading to an award. There may be data protection issues as the programme providers may be independent of an applicant professional body. 2. The meaning of the requirement described in the following sentence: Implement any special conditions of alignment attached to the relevant award- type descriptors. Perhaps, if appropriate, this could be replaced by Implement any special conditions of alignment arising from the external assessment review process? If not, then additional clarification is required.

8 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Chartered Accountants Ireland Please note this response appears as received and has not been proofed/edited by QQI.

9 CHARTERED ACCOUNTANTS IRELAND I have reviewed the content of the draft consultation recently issued. I am happy with the content of this document and would commend you on its clarity. I have two minor points on which clarification is sought however: In paragraph it states that the professional body must have the capacity to maintain a secure and professional awards archive. The meaning of this is not clear. Is this a database of members who have qualified with the professional body? Most professional bodies will have a list of members who are members and the related exam records. It should be noted that membership may lapse for various reasons. The meaning of the word archive is not clear in this context; In paragraph 2.1 it states the external assessment will always scrutinise the associated summative assessment procedures. Some clarification of the exact expectation and scope of the word procedures in this context would be helpful. Otherwise I have no comments. This response is done on behalf of this Institute. Kind regards Ronan Ronan O Loughlin Director of Education and Training Chartered Accountants Ireland Chartered Accountants House Pearse Street Dublin 2

10 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Engineers Ireland Please note this response appears as received and has not been proofed/edited by QQI.

11 ENGINEERS IRELAND Response To Consultation paper By Quality Qualifications Ireland On the Policy and Criteria Aligning Professional Awards with the National Framework of Qualifications at Levels, 7 8 and 9. Damien Owens, Registrar Engineers Ireland 24th January 2014 Introduction Engineers Ireland is the voice of the engineering profession in Ireland and has over 20,000 members. We have been representing the engineering profession since 1835, making us one of the oldest and largest professional bodies in Ireland. Our members come from every discipline of engineering, and range from engineering students to fellows of the profession. Engineers Ireland awards professional titles to our members according to their qualification, including: Chartered Engineer (CEng MIEI) Associate Engineer (AEng MIEI) Engineering Technician (Eng Tech MIEI) The majority of applicants that are awarded professional titles by Engineers Ireland already hold accredited NFQ qualifications and therefore the alignment of the professional title to the NFQ is moot. However, a small proportion of applicants that are awarded professional titles may hold unaccredited or insufficient educational qualifications (less than 5% of applicants). Engineers Ireland s Regulations also provide for the consideration of applications from individuals who have acquired the competencies for professional titles in informal ways, such as experiential learning. In such cases it is important to note that though evidence of exposure of the candidate to academic learning outcomes is sought and assessed, the primary outcome of the process is to determine if the applicant is a competent practitioner in the real world i.e. the professional title is a reflection of the holder s competence to undertake professional practice and includes a determination of ability beyond purely academic issues. Engineers Ireland is the registered Competent Authority in Ireland for the engineering profession under EU Directive 2005/36. The fundamental aims of Engineers Ireland are: To promote knowledge of engineering and of engineering science,

12 To establish and maintain standards of engineering education and training, To promote and provide opportunities for continuing professional development for engineers and engineering technicians, To maintain standards of professional ethics and conduct, To ensure that the Registered Professional Titles of Engineers Ireland are awarded only to appropriately qualified engineers and technicians. Engineers Ireland welcomes this opportunity to provide feedback to QQI on this important consultation. Our comments are presented below and are in the same order as the consultation documents. General comment Engineers Ireland considers that the consultation document broadly reflects the current needs of professional organisations. Each organisation will have different requirements and it would be difficult to develop a construct that would address every possible scenario. One of the challenges of the proposed alignment process will be to determine the blend of adherence to pure academic learning outcomes combined with experiential elements which will constitute the final alignment criteria. We must be mindful that we are not introducing alignments or awards which are adding to duplication or confusion. 2.1 Approach The proposed approach involves (where applicable) the recognition of the quantity of ECTS. The accreditation of engineering programmes is outcome based and the use of ECTS framework is of limited value. Similarly, assigning ECTS for the experiential (i.e. non taught) elements of the professional award may lead to anomalous outcomes. Competence measurement does not lend itself to being assessed in terms of time of effort but on demonstration that the competence has been achieved. 2.5 Professional Alignment and Change This section refers to continual internal monitoring. Is it intended that there would be periodic reviews e.g. annually? Would there be a cost for these reviews, who would carry the cost, and who would undertake them? 2.6 Key stages in the Professional Award Alignment Process Who pays the external assessors and what is the fee? Professions with multiple recognition bodies Irish professional bodies by virtue of existing agreements may mutually recognise overseas professional qualifications as equivalent to the Irish professional qualification. Will this overseas person also receive NFQ qualification equivalence?

13 If the profession is recognised with an overseas professional body will this clause still apply? If it does not then are there implications under the EU Directive 2005/36 on professional recognition? The External Assessment Process If the applicant manages the external process then it is de facto a conflict of interest? Either QQI manages the process or not if the applicant does so then QQI itself can be compromised. How will the alignment process be continuously reviewed? e.g. an annual audit of the professional body? An annual declaration by the professional body?

14 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Higher Education Colleges Association Please note this response appears as received and has not been proofed/edited by QQI.

15 HIGHER EDUCATION COLLEGES ASSOCIATION (HECA) RESPONSE TO QQI WHITE PAPER ON POLICY and CRITERIA FOR ALIGNING PROFESSIONAL AWARDS with the NATIONAL FRAMEWORK of QUALIFICATIONS at LEVELS 7, 8 and 9 HECA welcomes clarification on the process of alignment as detailed in the White Paper. However, HECA believes that, in order to ensure the integrity of the National Framework of Qualifications, (NFQ), and the associated processes, it is essential that all providers seeking alignment with the NFQ are treated consistently with those providers subject to the Policy and Procedures for Validation. HECA would have a concern that Protection for Enrolled Learners in relation to students of Professional Bodies is not covered by the 2012 Act. Alignment must not be viewed as a mechanism by which some organisations can avoid compliance with their Protection for Enrolled Learners obligations, and associated stringent criteria, with which other QQI providers must comply.

16 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Institutes of Technology Ireland Please note this response appears as received and has not been proofed/edited by QQI.

17 Submission of Jim Murray on behalf of Institutes of Technology Ireland QQI White Paper: Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8 and 9 General Observations IOTI welcomes the publication of this document, as it supports the broad principle that all learning should be recognised through the National Framework of Qualifications, no matter, how, when and where it is achieved. In broad terms, IOTI also supports the thrust of the document, which seeks to ensure that the alignment process for professional awards at higher education levels in the NFQ is underpinned by quality assurance processes, that are sufficient to inspire confidence that the aligned awards are correctly levelled and thus broadly comparable to other awards at the same levels. IOTI notes that the general approach in the White Paper is to seek to utilise the quality assurance processes used in higher education as a basis for the aligment, whether this is through the use of the self- assessment/external assessment model from the Standards and Guidelines for Quality Assurance in the EHEA; or through the option to use QQI s validation services. IOTI accepts that this is a policy matter on which QQI, as the custodian of the NFQ, must decide. However, there are some issues associated with this approach which QQI may wish to reflect on further. In the first instance, the approach sends out a message that all learning associated with the upper levels of the NFQ has to be framed, described and quality assured in a conventional/standardised higher education format. This seems to be a departure from the more flexible, learner- centred and sector- neutral approach that characterised the NFQ when it was launched in If it is such a departure, that may need to be articulated more clearly in other QQI documentation, and become an essential principle for other policies and processes associated with the NFQ. A second and related point concerns the legalistic manner and language in which the policy is set out, which is somewhat at odds with the enhancement aspects of quality assurance that underpin the Standards and Guidelines for QA in the EHEA, and the IHEQN principles, cited in the White Paper. IOTI notes that there is a very pronounced emphasis on scrutiny, prescriptive processes, conditions for alignment and the regulatory dimension of QQI s role, that do not sit easily with the mission, vision and values adopted by QQI in its recent strategy statement for Although this specific policy is not directly relevant to the IoTs, IOTI would have some concerns that this approach might percolate into the broader quality assurance policies of QQI in higher education, particularly given that QQI has situated this particular policy so firmly in the higher education quality assurance arena. IOTI appreciates that there is a fine line to be trodden between QQI s regulatory and quality assurance and enhancement functions, but in this particular White Paper the balance seems to lie clearly in the direction of the former. Particular Points It is not clear to IOTI why, given the deliberate linking of this alignment policy to higher education stuctures, the scope of the policy and criteria does not include Level 6, especially

18 as there are a number of professional awards in existence that the IoTs believe would broadly align to this level. Addressing Level 6 in this policy would also have some value in terms of establishing practice/precedent for the alignment of professional awards internationally, particularly in relation to the contested areas of EQF Level 5 and the QF- EHEA short cycle. It is unclear in Section 1.2 what the phrase 'particular class of awards' refers to. Here and elsewhere in the document it would be helpful to the reader to provide illustrative examples. In section 1.4, some indication of the deadline for re- alignment should be specified; as soon as is practicable seems unusually vague in the context of the various prescriptions set out elsewhere in the document. In section 2.2, a better term than 'normal' might be used to characterise the ex post process. It suggests that the candidate award process is abnormal, even though it is described as a (presumably valid) type of recognition within the Framework. In the same section 2.2, it is not clear what would happen in the case of non- activation of the process. One would assume that the candidate status of an award would fall into abeyance if, following endorsement by QQI, a programme associated with that award did not commence within 12 months of that endorsement. Does this need to be formally stated in the policy? Section 2.3, point 4, in relation to dual/joint awards, raises some interesting technical/legal questions. The statement implies that this particular form of joint awarding arrangement will come into play in situations where QQI has validated a programme leading to a well- established professional award. It appears that in such an arrangement the real or legal awarding body in NFQ terms is QQI, but because the branding of the professional award is significant in the market place, dual awards will be issued and constituted as joint awards. This seems to set out a new definition and process for joint awards that stands outside or even contravenes existing/emerging policy on joint awarding, where there are a range of quality assurance expectations associated with the process, including that all of the parties put in place risk analysis processes and sign up to formal agreements/protocols pertaining to such matters as executing the awarding body functions, operations and management concerned with joint awarding. 1 Would the professional body be expected to fulfil such requirements? It is in areas like this that the decision to hitch the alignment of professional awards to the quality assurance arrangements in place for higher education could cause certain difficulties, particularly in terms of redefining existing understandings of concepts such as joint awarding. The question naurally arises that where and when such redefinition takes place in the context of alignment policy, will it have a bearing or influence on the concept in its original context, i.e., higher education joint awarding QA, DA of joint awarding etc. In point 5 of section 2.3, it might be advisable to specify that categories of other bodies known to be involved in providing programmes associated with professional awards, so that all possible parties to such arrangements are aware of any responsibilities they have therein. In point 6 of section 2.3, it might be advisable to specify in what exceptional circumstances the policy could be waived. In 2.6, it is stated that the monitoring can be seen as long- term follow- up and that the principal mode of monitoring will be the five- yearly review. Is this a principle that will be 1 As per the recent White Paper relating to the delegation of authority to the IoTs to make higher education awards (including joint awards), p. 8.

19 implemented in other quality assurance contexts? For example, how does it fit in in terms of the annual dialogue process, presumably a form of monitoring, that the DABs and the recognised institutions with DA will engage in with QQI? Also relevant to this issues is the statement in 2.9 that post alignment follow- up by QQI will allow for monitoring of professional awarding bodies in a manner that is similar (but not identical) to the way it monitors comparable providers of HE. All of this needs greater clarification, for from the way it is currently cast it seems to be a matter that is simply at the discretion of QQI, without any obvious underpinning logic. Under the conditions of alignment in Section 2.15, the possibility of extension is allowed for. It might be better to set out the process for extension of alignment, and how it is linked to the monitoring and review processes, earlier in the document.

20 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Medical Council Please note this response appears as received and has not been proofed/edited by QQI.

21 Comments made on behalf of the Medical Council on the QQI White Paper on Policy and Criteria for Aligning Professional Awards with the National Framework of Qualifications at Levels 7, 8, and 9 We welcome the opportunity to comment on the White Paper. The Medical Practitioners Act 2007 gives Council wide- ranging powers and responsibilities to regulate all stages of medical education and training in Ireland. Council sets and monitors standards in undergraduate, intern and postgraduate education and training. It accredits programmes and the bodies that deliver them. In terms of the levels of qualification set out in the QQI White Paper, the Council has a formal interest only in Bachelor level qualifications, as neither Masters Degrees nor Doctorates impact upon a doctor s registration status. As a regulatory, quality assurance and enhancement body we were very interested to read the QQI s plans as set out in the White Paper. The Policies and Criteria in Part 2 appear to be appropriate. In a number of areas, including: Candidate status being converted to aligned status only after the first batch of awards has been given The limiting of alignment to a period of not more than five years Monitoring as a long- term follow- up The requirement for re- alignment in the event of extensive change the use of externals to maximize objectivity they are analogous to Council s processes. The Seven Outline Criteria for Alignment (2.7.1) also seem relevant. The Conditions of Alignment (2.15) are suitably robust. Natural justice in the form of an appeal against a refusal or withdrawal of alignment (2.17) is appropriate. In general terms, the Council has found that the process of preparing for an accreditation is valuable for providers, with external validation providing additional motivation. The explicitness of the document should tend to promote consistency while at the same time avoiding rigidity. A M Keane 21 st January 2014

22 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: The Royal Institute of the Architects of Ireland Please note this response appears as received and has not been proofed/edited by QQI.

23 THE ROYAL INSITUTE OF THE ARCHITECTS OF IRELAND White paper Policy and Criteria for Aligning professional Awards with the National Framework of Qualifications at Levels 7,8 and 9 Author: Margaret Hynds O Flanagan Role: Admissions Director Organisation: Royal Institute of the Architects of Ireland Function: Statutory Registration Body and Competent Authority for Architects in Ireland (Building Control Act 2007); Professional Body for Architects and Architectural Technologists Date: General Comments: The RIAI welcomes the consultation and the establishment of a clear policy for the alignment of professional awards with the NFQ. The importance of formal confirmation of the standard achieved by those passing professional examinations which are either awarded by, or accredited by, professional bodies has increased greatly as the NFQ has become the accepted benchmark and descriptor of the standard of knowledge, skill and competence a person has been assessed at. Specific comments (these are related to the section numbers provided in the White Paper): 2.1: Will detailed guidance be provided on the meaning of the term is adequately quality assured prior to the opening of the system for applications and will there be discussion/consultation on this issue? Professional awards in many cases are postgraduate awards where individuals who may already be in possession of a Level 8 or 9 award are required to undertake practical professional experience prior to undertaking assessments based on their leaning during the period of postgraduate experience (these can take the form of formal examinations and portfolio/self assessment based recognition of prior learning style exercises (e.g. sections 14(2)(a)II, 14(2)(f), 14(2)(i), 21 and 22 of the Building Control Act 2007)). In general, professional programmes have some educational delivery, but the objective is the practical experience component. The nature and application of quality assurance measurements is therefore of some concern given that the nature of the programmes themselves is quite different

24 from more formal instruction style awards. The provisions at are noted but greater clarity would be welcome. Directive 2013/55/EU, the modernised Professional Qualifications Directive addresses the matter of practical training to some extent, quite specifically in the case of architects at least, and it may prove necessary for some professions to ensure that it is possible to meet the requirements emerging as a result of the new Directive while also addressing the requirements for alignment as set out in the White Paper. Where programmes of study and assessment are provided by Awarding Bodies which are accredited by a professional body for the purpose of gaining access to a professional award, will these have to be separately assessed (per final paragraph of 2.1) or will the quality assurance processes of the Awarding Body in addition to the accreditation by the professional body be considered sufficient? How does this align with 2.3 point 3 where monitoring of provider programmes is expected of the professional body? 2.2: The approach of ex post alignment of professional awards is a welcome recognition of the need to ensure that programmes/assessments reach the promised outcomes. However, this is at odds with the ex ante alignment of awards made by Awarding Bodies and academic institutions. It is also at odds with the ex ante approach required for formal recognition of awards for inclusion in the automatic recognition system of the Professional Qualifications Directive. Inclusion in the process for automatic recognition (Chapter III Title III of the 2005 and 2013 Directives) requires full recognition at national level. In the case of architects this means prescription by the relevant Minister. So the candidate status offered for NFQ alignment, while welcome, would not contribute to a qualification being notified for inclusion in the automatic recognition system. While NFQ alignment is not required for these processes at this time, the apparent disjoint in approach seems likely to cause difficulty in the future : Will specific guidance, and sign off, on the composition of the external group be provided? It would be extremely unfortunate if a process were to be completed only to find that a problem had been identified with the composition of the expert group which could have been identified and

25 addressed at an earlier stage. This could have a serious negative impact on the learners in addition to problems arising with regard to cost and the investment of time and expertise. Will criteria and guidelines be established in advance for when an external assessment report may be set aside? Presumably these would form part of the initial memorandum of agreement, but will there also be general criteria and guidelines made generally available so they can be considered in advance of initiating a process? 2.7.1: Although already addressed, it is important to restate the absolute importance of ensuring that quality assurance processes recognise the fact that many professional awards are practice based and may rely on demonstrated learning outcomes in the absence of any programme of learning provided in advance (e.g. sections 14(2)(a)II, 14(2)(f), 14(2)(i), 21 and 22 of the Building Control Act 2007). 2.14: Noting that alignment may be refused, will the criteria for recognition approval be set out in adequate detail in advance (i.e. a detailed consideration and explanation of 2.7.1) so that the requirements are clearly evident? 2.17: It is not clear on what basis an appeal might be made or how such an appeal would be heard. It is important that this be clarified as soon as possible. Margaret Hynds O Flanagan Admissions Director RIAI 8 Merrion Square, Dublin 2

26 QQI COMPREHENSIVE POLICY DEVELOPMENT PROGRAMME SUBMISSIONS: WHITE PAPERS SUBMISSION BY: Society of Chartered Surveyors Ireland Please note this response appears as received and has not been proofed/edited by QQI.

27 Society of Chartered Surveyors Ireland Response to White Paper on Aligning Professional Awards With the National Framework of Qualifications at Levels 7, 8 and Approach alignment involves (where applicable) the recognition of the quantity of ECTS credits to be associated with the professional award. Clarification is sought on the meaning/implication of where applicable. 2.4 Duration of Professional Award Clarification is sought with regard to the specified interval for retrospective alignment. In the case of a professional body, which has been making awards over an extended number of years, does alignment only apply to award holders following the date of formal alignment? 2.5 Professional Award Alignment and Change Clarification on the issue of professional alignment and change: An extensive change to a professional award s standards (i.e. changes that QQI believe to make a substantial difference to the standard) will result in the automatic withdrawal of alignment. Can QQI clarify/cite examples of substantial change? The External Assessment Process The professional body is responsible for any financial costs incurred by the external panel. QQI may set aside an external assessment report if unsatisfied with the report or if it lacks confidence in any aspect of the external assessment process (this may require that the professional body instigates a completely new external assessment or in exceptional circumstances, QQI may manage the new process itself). Will QQI approve and brief the expert panel before the external assessment process? What are the general criteria for QQI s rejection of the report of an external panel? [Seven] Outline Criteria for Professional Award Alignment General quality assurance, governance, operations and management

28 In respect of general quality assurance, governance, operations and management, QQI guidelines will be in line with the Standards and Guidelines for Quality Assurance in the European Higher Education Area (2005). This document has a very academic emphasis in respect of QA and the resources required by a provider in order to satisfy the stated standards including individual learning resources and supports, effectiveness (and monitoring) of teaching staff, grading systems, progression rates. Unlike universities and institutes of technology, the primary function of a professional body is to enhance, advance and enforce professional standards not the provision of education. It is recommended that QA standards and guidelines should more closely reflect the remit and resources of professional bodies Complaints and Appeals against Refusal or Withdrawal of Alignment by QQI The White Paper makes reference to QQI s complaints procedures and appeals procedures. Will QQI distribute these to professional bodies?