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The Explanatory
Memorandum prepared by the Welsh Government describes the
Bill’s main purposes in the following terms:
The Bill provides
for the establishment of Qualifications Wales as the independent
regulatory body responsible for the recognition of awarding bodies
and the review and approval of non-degree qualifications in Wales.
Qualifications Wales will also, along with the Welsh Ministers, be
responsible for preparing a list of priority qualifications,
designated as such by reason of the significance of the
qualification, having regard to the needs of learners and employers
in Wales. The intention is, through the establishment of
Qualifications Wales, to strengthen the oversight of qualifications
and of the qualification system in Wales.
The Bill is
intended to address the four main limitations of the current
system. These are outlined in the Explanatory Memorandum
as:
•
there is no single organisation that is dedicated to ensuring the
effectiveness of qualifications and the qualification
system;
•
there are no powers to prioritise qualifications and to thereby
focus regulatory activity where it is most needed – with the
result that there are large numbers of regulated qualifications but
limited resources to ensure effectiveness;
•
there are no powers to select a single provider of a given
qualification to ensure that learners across Wales take the same
qualification; and
•
the capacity to drive forward the strategic development of
qualifications within the current arrangements is too limited -
creating a risk that Wales’ qualifications will not be held
in as high esteem, nationally and internationally, as those in
other nations.
The Bill provides
Qualifications Wales with the following principal aims, and it must
act compatibly with these when exercising its functions:
a) Ensuring that
qualifications, and the Welsh qualification system, are effective
for meeting the reasonable needs of learners in Wales;
and
b) Promoting
public confidence in qualifications and in the Welsh qualification
system.
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Question
1 - Is there a need
for a Bill for the purposes outlined above?
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Yes. The
Catholic Education Service welcomes the establishment of
Qualifications Wales designed to develop world-class qualifications
for Wales for the good of learners in Wales and for the greater
good of Welsh society and culture.
We also welcome
the strategic vision and plans to ensure that the qualifications,
including Welsh-medium qualifications, are respected by employers
and universities and that will enable learners to progress along
their chosen pathways.
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If you believe there is a need for the Bill,
what are the main issues that need to be resolved?
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Public confidence in Qualifications Wales and
the portability of qualifications. We welcome the clear
statements already made concerning these aspects.
The Catholic Education Service has some concern
with the long term plan to develop Qualifications Wales towards an
awarding of qualifications function alongside its currently
proposed approval and quality assurance function. We welcome
the planned continuing dialogue on this aspect of the strategic
development of a national qualification system for Wales.
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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2 – This is a problem that
needs to be addressed.
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√
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3 – This is a minor
problem
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4 – Not a problem.
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Question 2
- Do you think the
Bill, as drafted, delivers the stated objectives as set out in the
Explanatory Memorandum?
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Yes.
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If not, how do you think the Bill should be
amended to take account of this?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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§
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3 – This is a minor
problem
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4 – Not a problem.
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Question 3
- Are the sections
of the Bill as drafted appropriate to bring about the purposes
described above?
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Yes. In
particular, the Catholic Education Service welcomes the emphasis on
the independence of Qualifications Wales from the Welsh Government
in order to ensure freedom from short-term political
pressures.
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If not, what
changes do you believe need to be made to the Bill?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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3 – This is a minor
problem
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4 – Not a problem.
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Question 4
- Has the Welsh
Government correctly identified the four main limitations of the
current arrangement, and will the two principal aims the Bill sets
for Qualifications Wales, as well as the eight matters which it
must have regard when exercising its functions, effectively address
these limitations?
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Yes
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If you believe there are problems in this area,
how do you think they could be resolved?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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§
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3 – This is a minor
problem
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4 – Not a problem.
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Question 5
- What are your
views on the proposals for determining ‘priority
qualifications’ and, within these, ‘restricted priority
qualifications’?
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The Catholic
Education Service welcomes the concept of ‘priority
qualifications’ to ensure inclusivity, Welsh-medium and
English-medium comparability standardisation and qualifications
tailored to meet the needs of learners in Wales and of Welsh
society as a whole.
However, there is
a concern regarding the status and nature of Religious Studies.
We welcome the Welsh Government’s decision to allow for
the option of a range of subjects to be included in the new Capped
Points Score indicator of standards at 16, which protects the
status of Religious Studies as a contributory subject to those
standards. In terms of the development of Religious Studies
for all educational phases, within the oversight of Qualifications
Wales, the Catholic Church would welcome reassurance that due
cognisance will be made of the Catholic school’s obligation
to ensure its Religious Studies programme meets the Canonical and
Trust Deed requirements of the Church.
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If you think there are problems in this area,
how do you think they could be resolved?
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We recognise that the current
‘priority qualifications’ are those of the
‘core’ curriculum for the Welsh Government. If
the system evolves to the point where Welsh schools deliver a
solely Welsh qualifications programme, and Religious Studies at all
levels lies within that programme, the Catholic Church would
welcome the continuation of the very helpful partnership that
already exists between the WJEC (and its future successor) and
Diocesan Authorities, to ensure the needs of both the country of
Wales and the Catholic Church are met.
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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√
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3 – This is a minor
problem
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4 – Not a problem.
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Question 6
- What are your
views on the commissioning type process Qualifications Wales would
undertake under the Bill, in respect of restricted priority
qualifications?
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The clarity
regarding the open, fair and transparent commissioning of a single
suite of qualifications is welcome.
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If you believe there are problems in this area,
how do you think they could be resolved?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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§
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3 – This is a minor
problem
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4 – Not a problem.
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Question 7
- How will the Bill
change what organisations do currently and what impact will such
changes have, if any?
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If you believe there are problems in this area,
how do you think they could be resolved?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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§
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3 – This is a minor
problem
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4 – Not a problem.
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Question 8
- What are the
potential barriers to implementing the provisions of the Bill (if
any) and does the Bill take account of them?
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If you believe there are problems in this area,
how do you think they could be resolved?
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How significant is this issue? (Please select
one option)
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1 – This is a key, urgent
problem.
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§
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2 – This is a problem that
needs to be addressed.
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§
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3 – This is a minor
problem
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4 – Not a problem.
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Question 9
- Do you have any
views on the way in which the Bill falls within the legislative
competence of the National Assembly for Wales?
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Question
10 - What are your
views on powers in the Bill for Welsh Ministers to make subordinate
legislation (i.e. statutory instruments, including regulations,
orders and directions)?
In answering this
question, you may wish to consider Section 5 of the Explanatory
Memorandum, which contains a table summarising the powers delegated
to Welsh Ministers in the Bill to make orders and regulations,
etc.
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The Catholic Education Service recognises and
welcomes the power Welsh Ministers have in determining the required
contents of a qualification if it ensures the best outcomes for
learners and for Welsh society, providing the independence of the
commissioning and awarding bodies is maintained.
However, we have a particular concern regarding
Religious Studies. Religious Studies, which we believe should
remain a required subject for all learners in Wales, 4-16, provides
the skills, knowledge and understanding of values, beliefs and ways
of life that play a crucial part in exploring fundamental questions
of human existence, widening horizons and removing barriers of
ignorance. Such a requirement, which is also the strategic
vision of Catholic Religious Studies, also allows Catholic schools
to fulfil their canonical requirement to develop learners’
knowledge and understanding of the Catholic response to such
areas.
We would welcome an assurance that if Welsh
Ministers used their powers to specify requirements in Religious
Studies, the dialogue between the Welsh Government, and Catholic
Church officers, would continue in order to ensure that the needs
of both parties were met.
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Question
11 - What are your
views on the financial implications of the Bill?
In answering this
question you may wish to consider Part 2 of the Explanatory
Memorandum (the Regulatory Impact Assessment), which estimates the
costs and benefits of implementation of the Bill.
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Question
12 - Are there any
other comments you wish to make about specific sections of the
Bill?
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