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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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As an Awarding
Organisation specialising in the Care sectors, CACHE is well-placed
to answer some but not all of the consultation
questions.
We do not agree
with the need for a Bill as we have significant concerns about the
likely impact on learners. We also note that Ofqual, Sector
Skills Councils and the Care Quality Commission already carry out
some of the required functions in our view effectively, and there
are many uncertainties for our own business. We therefore do not
agree with the need for this Bill.
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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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n/a
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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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§
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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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n/a
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If not, how do you think the Bill should be
amended to take account of this?
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n/a
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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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n/a
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If not, what
changes do you believe need to be made to the Bill?
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n/a
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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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§
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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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n/a
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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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n/a
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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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§
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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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We note that
section 13 (5) in the Bill says ‘Qualifications Wales must
publish a determination under this section’ and await further
detail with interest. In the Care, Health and Education sectors,
our areas of expertise, priority qualifications should include
those that are a licence to practise, enable progression to
university and some at Levels 1 and 2 that enable entry into
employment.
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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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n/a
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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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§
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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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Generally, we
would expect any commissioning processes to be clear and
fair.
At this stage and
subject to key details (such as length of tender), CACHE would be
interested in engaging in any commissioning process, for our
particular areas of expertise in Wales:
·
Childcare
·
Playwork
·
Supporting
Teaching and Learning in Schools.
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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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n/a
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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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§
yes
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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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The proposed
changes will have a significant impact upon our organisation.
For example, we anticipate:
−
new
qualifications developments for Wales and for the need for
transferability across borders;
−
increased
administrative burdens including use of a new Regulatory IT System
in addition to existing Ofqual version, and;
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we are
a specialist and expert organisation working in a rapidly changing
environment with consequential operational investment demands.
The current Welsh market is small when considering the
sustainability of such unique qualifications.
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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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CACHE could offer expert qualifications design
consultancy in relevant subject areas.
CACHE could offer qualifications content,
support materials, quality assurance and assessments in Wales
providing the tender period was sympathetic to us sustaining our
not-for-profit business. A five-year contract period would be
a more viable timespan than, say, three-years.
We warmly welcome continued discussions with
policy-makers in Wales to understand precise needs and put forward
further solutions.
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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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Yes
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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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Qualifications
Wales would require learners to take different qualifications in
Wales to those taken and recognised in England. Non-transferability
of qualifications across the Border is already a major issue for
learners (on both sides of the Border); the proposed changes have
the potential to increase this issue.
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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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We would like to discuss this with policy makers
since the resolution depends so much on precise identification of
the ‘problem’. One example of many possible
efficient solutions is for CACHE to develop and offer enhanced
qualifications that are wholly rigorous, relevant and appropriate
for sectors and learners in Wales but with core units already
developed and used in England and internationally, thus allowing
transferability across nations.
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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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Yes
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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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