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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We
are supportive of plans to establish an independent regulatory body
for Wales. The Bill and supporting Explanatory Memorandum
generally seem to address the arrangements needed to establish
a single
organisation that is dedicated to ensuring the effectiveness of
qualifications and the overall qualification system in Wales.
However, there are a number of aspects of the Bill that give
rise to concerns for CMI and which could have the potential to
impact on the qualification market in a disadvantageous way.
These risks generally relate to:
1.
The
potential for a reduction in the choice of vocational
qualifications (VQs) available to learners in Wales due to some AOs
having no choice other than to withdraw from the Welsh market.
This withdrawal may be a result of AOs not having
qualifications listed on the priority or restricted priority list,
the financial viability of supporting the development, marketing
and awarding of a separate Welsh version of a qualification, the
reluctance or inability to bear the burden of charges for
regulatory activity or the inability/unwillingness to bear the
increased regulatory burden generated by further divergence between
regulatory systems in England and Wales.
2.
The
potential impact on niche sectors who may find that either the
qualifications they require are not on the priority list for Wales
or find that there are no AOs that are willing or able to award
them in Wales.
3.
A
reduction in the mobility of learners in Wales and a resulting
disadvantage for Wales-based learners who may find their
progression routes into FE, HE and employment outside of Wales are
restricted through only having access to Welsh versions of
qualifications.
4.
The
impact on centres (employers, colleges and independent training
providers) who may find their choice of AOs is restricted in the
future and that they need to seek centre approval with a range of
AOs due to restrictions on the awarding of some priority
qualifications. There is also a potential impact on centres
that operate near the border in that they may attract learners from
both sides of the border and may therefore need to offer two
versions of a qualification ( the Welsh version and the English
version) within their centre.
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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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CMI
would urge Qualifications Wales and the Welsh Government to make
sure that any requirements
for Welsh versions of qualifications are at a sufficiently high
level that awarding bodies are able to contextualise qualifications
and/or use core and options approaches to meet those
requirements. This approach
should help to ensure that the Welsh market does not become too
specific and will help to ensure that awarding bodies will be able
to continue to offer valuable qualifications to learners and
employers in 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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§
x
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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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§
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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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CMI agrees that
the Bill delivers some of the stated objectives but is concerned
that the following objectives may not be delivered in
full:
1.
Although we
understand the ambition to establish qualifications that are
delivered in Wales as nationally and internationally recognised
passports to future learning and employment it is not clear how
this will be achieved. We have concerns that, at least in the
short term, before Welsh versions of qualifications are fully
understood, there is the potential to hamper learners’
mobility beyond Wales by offering them access to Welsh versions of
qualifications only. This may be particularly pertinent if
the qualifications are in any way labelled or titled as the
‘Welsh version’ as this labelling it unlikely to be
understood beyond the Welsh market.
2.
We
believe that the public confidence objective is a complex one to
achieve and although we can understand how the changes outlined in
the Bill and Explanatory Memorandum may in theory contribute to
increased public confidence we do not believe there is any
guarantee that this will be the case. One high profile media
case is still likely to have the potential to damage public
confidence in the qualifications system.
3.
The
overall qualifications system may not meet the reasonable needs of
learners if the changes result in the withdrawal of a significant
number of AOs (and hence qualifications) from the Welsh market.
This could result in gaps in provision which could result in
some learners not having their reasonable needs catered
for.
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If not, how do you think the Bill should be
amended to take account of this?
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CMI would like
to see the Bill amended to clarify that the term ‘Welsh
version’ should be an administrative label only which is used
to refer to those qualifications that are accredited by
Qualifications Wales for use in 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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§
x
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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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§
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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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No further
information to add.
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If not, what
changes do you believe need to be made to the Bill?
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No further
information to add.
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How significant is this issue? (Please select
one option)
|
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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§
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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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In relation to
the 4 main limitations of the current arrangements in Wales CMI
believe that:
1.
The
Welsh Government has correctly identified that there is no single
organisation that is dedicated to ensuring the effectiveness of
qualifications and the qualification system and the Bill does
provide for establishing Qualifications Wales for this purpose. CMI
support the establishment of a regulatory body for
Wales.
2.
In
terms of the prioritisation of qualifications and focus for
regulatory activity we believe that there are alternative
approaches that could be adopted to address this issue other than
by establishing a priority list. We are concerned that a
priority list has the potential to quickly become out of step with
the needs of employers and the wider economy, even if there is a
commitment to updating it on a regular basis. The current
system has the benefit of giving the market itself a greater amount
of control over the qualifications that are developed in response
to its needs as long as AOs are agile and responsive to these
needs. If this market-led approach results in a high number
of qualifications these could be regulated on the basis of the risk
they present, taking into account, for example, the numbers of
learners registered and the consequential value of achieving the
qualification (e.g. is it a licence to practice, an entry
requirement for HE etc).
3.
We
believe that having a single provider of a given qualification to
ensure that learners across Wales take the same qualification has
the potential to impact on the market in a range of disadvantageous
ways (see response to Question 5 below). Qualifications can be
comparable without being completely the same and we feel that
Qualifications Wales could invest in research to support the
effective comparability of qualifications rather than take the step
of limiting the availability in Wales to one qualification through
one AO.
4.
The
matter of the esteem in which qualifications are held on a national
and international basis is likely to be difficult to guarantee
irrespective of the approach adopted within Wales.
In relation to
the two principal aims specified we are concerned that there is the
potential for the reasonable needs of some learners not to be met
in the future if there is withdrawal of AOs and their
qualifications from the market. We believe there is a risk
that this will open up some gaps in provision that could leave some
learners without access to the qualifications they require for
their future careers. In addition, as we have stated above,
public confidence in qualifications and in the Welsh qualification
system is probably not an issue that can be engineered with any
certainty and any future errors in the system are probably just as
likely to dent public confidence in the system.
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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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CMI would
recommend that consideration is given to:
1.
Different ways
that can be used to target the regulatory resources that are
available to ensure they are effectively allocated.
Exploration of risk based approaches to regulation may
present an alternative to a priority list approach.
The conduct of
research into effective methods of ensuring the comparability of
qualifications instead of narrowing the offer in Wales to one
qualification via one AO.
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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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CMI
understands and supports the need to provide a qualifications offer
in Wales that meets the specific needs of Welsh learners and
employers. However, in determining the contents of the
priority list of qualifications for Wales we believe there are a
number of important points that should be considered:
■
Extensive,
accurate and up to date labour market information (LMI) and
forecasts will need to be available to ensure the list reflects the
needs of a wide range of stakeholders, both in terms of their
current needs and their forecasted future needs.
■
Accurate
forecasting of needs will be particularly important where industry
sectors are evolving and their needs are changing at a rapid
pace.
■
LMI
will need to take into account the needs of markets beyond the
Welsh border, particularly in England and Europe, to ensure that a
wide range of progression opportunities are available to learners
in the future.
■
The
list will also need to be updated regularly to ensure it continues
to reflect the needs of any new and emerging sectors and does not
tie the qualifications offer to out-dated needs or drive learners
down the route of taking qualifications for which there is no
employer demand by the time they have qualified.
■
The
priority list will need to reflect the full range of qualifications
that learners and employers in Wales require for future success and
not just the academic qualifications that may form part of this
requirement. Vocational qualifications (VQs) have an
important role to play in the ensuring the future success of the
economy within Wales and the importance of continuing to have
access to a wide range of VQs should be reflected on the priority
list.
In
moving forward with the priority list there will be a need to pay
special regard to two areas which may not be reflected on the
overall priority list but are important areas that the
overall qualification system needs to cater for, in
particular:
1.
How
qualification provision for niche sectors within Wales will be
supported. A sector may be niche and offer employment
opportunities to a relatively small number of people within Wales
(and beyond) but this does not mean it should be ignored by the
qualifications system. It may have particular cultural or
regional relevance which it will be important to support in the
future.
2.
How
qualifications that have been developed to cater to the specific
needs of particular types of learners will be supported in the
future. Similarly, there will be learners with particular
requirements which may mean they need access to specific
qualifications that have been developed to take these requirements
into account and it will be important that the system does not
neglect these learners.
CMI
feels that a ‘restricted priority’ status on some
qualifications, where the awarding of these is limited to perhaps
only one AO, is not a desirable way forward and has the potential
to negatively impact on the qualifications market in Wales in a
range of undesirable ways.
Currently
a range of AOs operate within the market in Wales to develop and
award a variety of VQs to meet the needs of Welsh employers and
learners. Awarding bodies work closely with providers to
identify their needs and provide qualifications that reflect these
stated needs. We believe that this approach provides a
healthy qualifications market which gives choice to learners and
providers, drives innovation through competition and ensures that
qualifications continue to evolve and reflect current employer and
learner needs. By restricting the provision of priority
qualifications to one AO there are a number of risks that could
disadvantage the market in Wales, including:
■
The
removal of choice from the centre -
centres may find that if they wish to continue to offer a
particular qualification they are required to work with the
specific AO that Qualification Wales has restricted an award to,
regardless of whether the service levels, systems and processes of
the AO work effectively for the centre.
■
Multiple
approvals and added complexity for centres (employers, colleges and
training providers) -
at present, a centre can choose to work with one AO for all
qualifications or a number of AOs for specific qualifications
across their overall offer. The centre chooses the arrangement that
works best for them. If a qualification is only available
through one AO then the centre will have no choice other than to
work with that AO. If the centre offers a range of
qualifications that are categorised as ‘restricted
priority’ they could find that they need to seek centre
approval with multiple AOs to ensure they can access the full range
of qualifications that they wish to offer to their learners.
This may have cost and resource implications for centres who
may find they face additional costs (centre approval etc) and
complexity (dealing with different AO administrative systems and
procedures).
■
Learner
Access in Wales–
if a learner wishes to access a qualification that is awarded by a
particular AO and this is not the AO that has been selected to
award the ‘restricted priority’ qualification in Wales
then the learner will not be able to access the qualification they
want without moving or studying outside of Wales. Learner
preference may be driven by employer preference, especially where
there is strong brand awareness within a specific sector e.g. CACHE
in the care sector, EAL in engineering, BII in the licensed trade
etc. Where employers operate on a national basis they may
wish their employees in all regions to achieve a qualification via
the same awarding body and they may not understand why this is not
possible in Wales.
■
Impact
on future choice–
the market in Wales is likely to be relatively small for AOs in
most sectors. For some AOs it is currently possible to serve
the market because the qualifications, systems and process are
already established and in place and closely linked with the Ofqual
systems and processes. However, if an AO is not selected to
award a ‘restricted priority’ qualification and has to
withdraw from the market for that qualification in Wales, for
however many years that the restriction is applicable, then it is
questionable as to whether the costs of re-entering that market at
a future date will be feasible. It is also possible that if
an AO is not selected to award a restricted priority qualification
in a particular qualification area that this could impact on their
ability to continue to offer across the rest of their portfolio in
Wales. It is possible that the majority of an AO’s
revenue is achieved on a small number of qualifications and the
revenue earned from these qualifications is, in some cases, used to
subsidise the qualifications offer in other smaller volume or niche
markets. If the revenue generating qualifications are in the
restricted priority category and an AO is not selected to award
these qualifications, it may undermine their whole business model
in Wales and lead to a total withdrawal from the Welsh market.
Qualifications Wales could find that whichever AO is initially
selected to award a restricted priority qualification may be the
only AO that elects to apply to do so in future years. This
could leave Qualifications Wales in a position of not having any
choice in future years, regardless of how satisfied they are with
the performance of the incumbent AO. This is a potentially
high risk position to be in if, for example, the incumbent AO does
anything that damages the public perception of the quality of their
qualification in the market. Longer term, Qualifications Wales may
choose to award the qualification themselves, but it is likely to
take some time to establish this awarding function.
■
Impact
on future innovation- should
the situation outlined above arise, Qualifications Wales could find
that the incentive to innovate in relation to a restricted priority
qualification is diminished as the competitive driver to do so has
been removed.
■
Portability
of qualifications -
there is also a need to consider the portability of the
qualifications that are available to learners within Wales and
whether Welsh versions will be able to support the movement of
learners across the border into England and further afield into
Europe and the international labour market.
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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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If the Welsh
Government/Qualifications Wales has concerns that the awarding of a
qualification by more than one AO has an impact on standards then
CMI believes it is fair to require AOs to work to a common standard
and provide evidence to Qualifications
Wales of how this standard is maintained. The action
taken to maintain the standard could be explained to the wider
stakeholders to help to address any negative perceptions associates
with a choice of qualifications being made available in the same
subject area within the market in Wales.
Under the
research remit of Qualifications
Wales, further research could be conducted into how best to
evidence the validity of vocational qualifications so that there is
guidance available to AOs about how they can support Qualifications Wales in being able to assure
the public of the quality of each of the qualifications that is
available in the market. Similarly, further research in relation to
the comparability of different qualifications would be valuable in
supporting AOs to evidence how their qualifications compare to
other similar qualifications in the market.
CMI believe
that Qualifications Wales should
focus on taking steps to improve the public perception of the
current competitive market before it takes steps to restrict the
awarding opportunities for priority qualifications.
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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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§
X
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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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§
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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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CMI’s
concerns about restricted priority qualifications are outlined
above. In addition to these concerns the only other point
that we would like to make is for the need for any commissioning
process to be transparent and make provision for clear feedback to
those who have participated in the commissioning process but not
been successful.
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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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No further
information to add.
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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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§
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4 – Not a problem.
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§
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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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CMI
believes that some of the proposed changes to the how the
qualifications system operates in Wales could have the following
impacts:
■
If
AOs are required to develop Welsh versions of qualifications for
the market they may not be able to benefit from the economies of
scale that are currently achievable when developing qualifications
for the market in England and Wales. This may well result in
some (and perhaps many) AOs withdrawing from the Welsh market as it
will not be financially viable to operate there, given the size of
the market and the costs associated with qualification development
and quality assurance. This could in turn result in less
choice for learners and employers in Wales, less competition and
potentially, less innovation in the market.
■
If
AOs are required to pay fees to be regulated this too is likely to
impact on how many are willing/able to remain in the market.
Where margins on qualifications awarded in Wales are small,
any fee payable to Qualifications Wales for regulation may make the
Welsh market unviable on a financial basis for some AOs.
Similarly, if fee capping is to be carried out this limits
AOs ability to run their businesses in a way that meets their
objectives and targets and is likely to be seen as unacceptable in
some cases.
■
We
understand the need to provide qualifications in Wales that meet
the specific needs of Welsh learners and employers. However,
we do have a concern that qualifications that become too
Wales-specific could impact on the mobility of learners who wish to
enter FE, HE or employment elsewhere in the UK, or beyond. We
believe that there is a need to recognise that the border between
Wales and England is permeable and that policies and systems
adopted in Wales should not hinder two- way movement between Wales
and other countries in the UK and Europe. It will be essential to
find the right balance between qualification content that meets the
specific needs of stakeholders in Wales whilst also safeguarding
the mobility of learners. CMI does not intend this statement
to signal that we wish the Welsh Government to simply adopt the
qualifications that are available in England as there are many
aspects of recent vocational education and training policy in
England that we do not support. However, we do feel it is
only right to signal the risks to learners of a system that may
focus their future progression and employment within Wales to an
extent that may limit their opportunities.
The
future relationship between Qualifications Wales and other
regulators, particularly Ofqual, has the potential to impact on
AOs. As the regulatory strategies of Qualifications Wales and
Ofqual diverge the burden on AOs is likely to increase as they
will, in effect, need to operate in compliance with two regulatory
systems instead of one. For some AOs the impact this will
have on resource requirements may be significant enough to lead to
a withdrawal from the Welsh market.
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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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No further
information to add.
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How significant is this issue? (Please select
one option)
|
|
1 – This is a key, urgent
problem.
|
§
|
|
2 – This is a problem that
needs to be addressed.
|
§
x
|
|
§
3 – This is a minor
problem
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§
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4 – Not a problem.
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§
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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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CMI does not
feel that the Bill has taken into account the impact that some of
the proposed changes could have on AOs and the qualifications
market in Wales, particularly in the short term. Qualifications Wales will not initially be
established as an awarding body and additional legislation will be
required to facilitate this in the future. This is likely to
take time. In the meantime, if the proposed changes result in mass
withdrawal of AOs from the Welsh market this will impact on the
availability of qualifications and is likely to result in gaps in
provision which will disadvantage learners and other stakeholders.
We feel that further consideration needs to be given to the
feasibility of AOs being able to operate in the Welsh market if
there is a need for a separate Welsh version of a qualification,
regulatory systems and processes that are increasingly diverging
from those in England, a priority list of qualifications, a
restricted priority list of qualifications, fees for regulation,
fee capping for AOs and the real potential for the market to
disappear altogether in the medium term if Qualifications Wales
decides to proceed with its own plans to become and awarding body.
A combination of these factors could make the Welsh market
unviable for a number of AOs.
CMI
believe that regulation is key however it is important to achieve a
balanced approach has too much regulation could mean employer
disengagement which could undermine vocational qualifications and
all the good elements they bring to national
recognition.
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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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CMI is
committed to supporting awarding activity in Wales and we would
welcome an operating environment within Wales that made it feasible
for AOs to continue to operate in that market. We believe
that the range and quality of qualifications that are offered have
the potential to support learners in Wales in making progress into
meaningful further learning and employment. We would
therefore welcome ongoing dialogue between Qualifications Wales and CMI to try to identify
solutions to some of the issues that the current Bill presents so
that AOs can continue to operate effectively in Wales and add value
to the qualifications market for learners in Wales. We are
confident that the effective relationships we have already built
with the Welsh Government and Qualifications Wales will continue
and ensure ongoing collaboration and dialogue.
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|
How significant is this issue? (Please select
one option)
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|
1 – This is a key, urgent
problem.
|
§
|
|
2 – This is a problem that
needs to be addressed.
|
§
|
|
§
3 – This is a minor
problem
|
§
x
|
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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 further
information to add.
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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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No further
information to add.
|
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.
|
No further
information to add.
|
Question
12 - Are there any
other comments you wish to make about specific sections of the
Bill?
|
CMI
would like to make the following additional comments:
1.
As
Qualifications Wales takes shape and assumes its role as an
independent regulator for Wales, we would value the opportunity to
continue to work closely with representatives of Qualifications
Wales to discuss how any planned activities and requirements may
impact on awarding bodies and to support Qualification Wales in any
activities that help AOs to understand what is required of them.
We would also like to support Qualifications Wales to
continue to promote the benefits VQs in the future and in publicly
recognising the benefits of VQs.
2.
The
remit of Qualifications Wales in relation to apprenticeships in the
future is not clear from the Bill or the Explanatory Memorandum.
Apprenticeships are an important progression route for young
people which offer valuable learning, work opportunities and
qualifications as the basis for future careers.
Apprenticeships in England are undergoing significant change
as a result of the implementation of the Richard Review
recommendation. These changes have impacted on the future
role that the regulator in England will have in relation to
apprenticeships. It is not yet clear whether apprenticeships
in Wales will continue to operate in line with the current
operational model or if they too will undergo review and subsequent
change. We believe that the inclusion of qualifications in
apprenticeships is a feature that should be maintained as it
ensures that the apprentice has the opportunity to achieve
regulated, quality assured and portable recognition of achievement
to the required standard which can be used to evidence to employers
and other stakeholders that they have reached the required
standard. We would welcome the retention of qualifications with
Welsh apprenticeships in the future.
3.
CMI
would wish to see continued attempts at collaborative working
between the 4 country regulators, particularly between
Qualifications Wales and Ofqual. We recognise that this
requires the other regulators to commit to such an approach and
that there may well be challenges in achieving this which are
outside of Qualifications Wales’ control. However, we
are conscious that our members work across the 4 countries and the
demands of different regulators can present a significant challenge
for AOs. We would hope that where two or more UK regulators
have the same requirements of AOs this could be handled in a
streamlined way such as the approach to annual statements for
compliance with the General Conditions of Recognition.
4.
There
is some concern that the requirement for Welsh version of
qualifications will require slightly different versions of what is
basically the same qualification (i.e. one version for Wales,
another for England etc.). This could be confusing for
learners, employers and other stakeholders, especially those
outside of Wales or those near the border who may be presented with
different versions of what appear otherwise to be the same
qualification.
The
Bill makes provision for Qualifications Wales to charge for some of
its activity. CMI does not
feel it is appropriate for the regulatory function (a requirement
to operate in Wales) should be chargeable to AOs and is concerned
at the impact this could have, especially CMI who operate on a not
for profit or charity basis. We would welcome an early
dialogue on any proposals to charge AOs to operate in the Welsh
market. Similarly, any plans to fee cap what an AO would be
able to charge in the market would be an issue that we would
welcome early dialogue on.
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