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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.
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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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Simplifying the
qualification system in Wales would appear to be important –
there are currently too many students doing courses that
don’t necessarily result in employment or progression on to
other courses – need to ensure all qualifications are fit for
purpose and enjoy public/employer confidence; there is also simply
too wide a variety of qualifications, as pointed out by Alison Wolf
in her review – a slimmed down version of the current offer
is important to ensure quality and relevance.
The prioritisation of certain qualifications over
others seems to be essential in order to ensure the education
system is meeting the needs of the Welsh Government, the Welsh
economy, private employers and, of course, students themselves; the
potential downside of this, however, is that there may be financial
and wider staffing implications within schools/colleges, as the
curriculum is adapted – this may mean that there are skills
shortages in certain areas, and over-supply in others, leading to a
potential need to re-train appropriately qualified staff (which has
a financial implication) or even to train more staff in those
priority areas.
Government may need to be mindful of the need to make
adequate provision in its budgets for a number of years to ensure
there are no unintended consequences in delivering on the main
purposes of 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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√
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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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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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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 3
- Are the sections
of the Bill as drafted appropriate to bring about the purposes
described above?
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Yes.
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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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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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The
establishment of an independent Qualifications Wales
organisation has apparent advantages, primarily helping to
guarantee consistency across all centres in Wales, allowing
stakeholders to make direct and accurate comparisons between
regions, schools/colleges and candidates, and remove the element of
competition between Exam Boards, which can lead to certain subjects
or awarding bodies being chosen because they are perceived to be
‘easier’. However, there is also some concern over
this, in that the creation of, in effect, a monopoly could lead to
a lack of the rigour and accountability that a free market system
can help to create; it also means that it is absolutely incumbent
on the awarding organisation to ‘get it right’, if
there is no alternative for centres.
Similarly,
it is essential that we develop a suite of qualifications in Wales
that have the confidence of Higher Education institutions and
employers outside the country (in England and elsewhere) –
rigour and value are of the utmost importance in the portability of
qualifications across the UK borders and in the wider geographical
context of Europe.
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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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Simplifying
the
qualification system in Wales would seems to be important because
it is perceived, under current arrangements, too many learners
undertake learning that doesn’t necessarily result in a
qualifications that lead to progression either to the next level of
learning or employment. There is a need to ensure all
qualifications are fit for purpose and enjoy public/employer/other
stakeholder confidence.
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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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The principle of
simplifying the qualifications system in Wales seems to be
understood but any new system must be robust and capable of
comparison with qualifications in place across the United Kingdom,
and elsewhere, so that Welsh learners are able to compete on an
even playing field with those seeking work or further and higher
education places outside of 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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§
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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 process in place to prioritise and
commission those qualifications must instil public
confidence. Therefore, ‘commissioning
boards/panels’ should be made up of independent members to
include a range of stakeholders who have particular affiliation
with the sectors where those qualifications sit.
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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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Creating Boards/Panels that are sector specific
in nature e.g. independent engineering employers are part of the
panel commissioning engineering quals etc etc.
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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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In terms of the
organisation, the impact will be minimal in terms of delivering
learning programmes, however, if there is a need to re-train or
employ new staff to deliver prioritised qualifications then this
will have financial impact on the organisation.
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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 believe that Welsh Government need to be
mindful of this and make financial provision to cover any
unintended consequences during the implementation of 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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√
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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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Meeting the
principal aims of the Bill itself by ensuring public confidence in
the Welsh qualification system and ensuring qualifications within
the Welsh system are effective in meeting the needs of all
stakeholders.
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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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By undertaking a comprehensive risk assessment
of all the issues identified in the consultation responses with key
stakeholder groups.
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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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No.
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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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There needs to be an amount of confidence and
trust in the powers entrusted to Welsh Ministers and we believe
that the powers delegated to Ministers in section 5 of the
memorandum are appropriate.
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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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In terms of the tables in Part 2 and the
commentary below various options, we feel that although most costs
are in part met within budgets already in situ for Welsh
Government. However, the unintended consequences of the
prioritised qualifications outlined above in terms of the impact of
those on individual education providers/establishments needs to be
factored into Welsh Government thinking.
There is currently a deficit of highly qualified
entrants into the educational teaching profession so there needs to
be some thinking around how the very best talent is channelled into
the profession. Teachers spend a significant amount of time
shaping the young entrepreneurs of the future and good teachers can
have fundamental effect on a young person’s (or older
learner) future direction of travel.
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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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Merely to emphasise that the need to ensure that
the principal aims of the Bill are met to assure all
stakeholders that the qualifications in Wales are effective,
meaningful and promote public confidence across wider geographic
regions of the UK, Europe and the world.
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