RPL should never be a complex process. There are a number of steps (we propose thirteen to fourteen steps) that can be followed in any field of learning and on any level. You should read my book entitled “The Concepts and Procedures Governing the Recognition of Prior Learning” if you wish to offer RPL in occupational and vocational learning or “A Holistic Approach to the Recognition of Prior Learning” if you are involved in RPL on higher education (academic) level.

Different people have such vastly different prior exposure to any field of learning that it is not realistic to mark an RPL portfolio according to a checklist based on a curriculum or other standard. That is why a holistic approach should be followed, meaning, amongst other things, that you should determine if the candidate achieved the purpose of the qualification or part qualification for which recognition is sought. It is a subjective form of assessment and the assessor must be an expert in the field of learning. Keep in mind, however, that RPL is not credit for life experiences if it is not relevant to the qualification or part qualification.

Even when a holistic approach to RPL is followed, you will find that candidates seldom achieve all the requirements for a qualification or part qualification. This can, and should be corrected by means of top-up learning. Top-up learning, in turn, requires that the RPL assessor do a gap analysis while assessing the portfolio of evidence. Top-up learning should be planned to close the gap.

Private learning providers can make a substantial contribution to RPL assessment by TVET colleges and HE universities and colleges by, for example, training lecturers in RPL, providing universities and colleges with RPL assessors and facilitators, doing the administration of RPL projects, and many more. However, TVET and HE institutions must make sure that the private providers are expert in RPL in the field of learning in which assistance is needed before they close agreements with them.

RPL candidates, their parents, sponsors and employers mostly pay for RPL. However, if RPL is regarded as equal in status to formal learning as is suggested in legislation (The NQF Act No 67 of 2008, the Skills Development Act No 97 of 1998 and the Skills Development Amendment Act No 37 of 2008) and the Articulation Draft Policy, then surely funds should be made available from the National Skills Fund for RPL.

RPL should be cheaper than formal learning. However, it is not always the case because RPL often requires lots of preparation, the availability of expensive equipment and is mostly offered to an individual. Even if offered to a group, individuals will still submit different portfolios of evidence which requires special preparation, different marking methods and different top-up learning content.

RPL can make a substantial contribution to transformation and redress, especially because it provides people who were denied access to formal learning or, for whatever other reason, did not receive formal recognition for knowledge and skills, an opportunity to enter lifelong learning.

We are often asked by potential learners if they cannot do RPL rather than formal learning because it is cheaper and faster. Judging from their comments at conferences on RPL one gets the impression that organised labour is often under the impression that people can be issued with certificates and degrees without learning. RPL is not a quick and easy route for an individual to get something for nothing. Also, RPL is not an alternative to formal learning. RPL cannot replace formal learning and an individual can only obtain credits or a certificate if they did gain relevant knowledge and skills previously.

In closing, it is not the individual only who benefits from RPL. Learning institutions, communities, the economy and the country at large can benefit from it. It is, therefore, important for the government, the industry, learning institutions and quality assurance bodies to support and promote RPL.

RPL is an important element of an articulated NQF because of its strong impact on the credit accumulation and transfer (CAT) system. This is supported by paragraph 36 of the Draft Articulation Policy which reads as follows: “Both recognition of prior learning (RPL) and credit accumulation and transfer (CAT) are enabling mechanisms for articulation and must be primary focus areas when designing the articulation apparatus and mechanisms.”

RPL is often used to allow people access to further studies even if they are not issued certificates. This is a simple way in which to allow people who could not study further because of “dead end” qualifications an opportunity to re-enter lifelong learning.

An efficient post-school education and training system requires a high level of articulation within and between the sub-frameworks, learning programmes and institutions. RPL, if recognised by all three Quality Councils (QCs), can play an important role in bridging the gap between occupational learning (OL); technical, vocational education and training (TVET) and higher education (HE).

It should be possible to accumulate credits on any of the three NQF levels and transfer such learning from one level to the next higher level. In support of this argument, paragraph 6 of the Draft Articulation Policy reads as follows: “This articulation Policy will facilitate movement of learners between and within the three sub-frameworks of the NQF, and between institutions and also within institutions in order to enable access, progression and mobility.”

RPL can play a crucial role in promoting democracy, social justice and participation in the economy. Credits, certificates or just recognition of prior learning in any other form can and should lead to the redress of historical injustices, promotion in jobs, filling of vacant positions and access to further learning.

Paragraph 12 of the Draft Articulation Policy confirms the legitimacy of RPL as a method by means of which credits can be accumulated. ”SAQA is also mandated by the NQF Act, to develop policy and criteria, after consultation with the QCs for RPL, assessment, and credit accumulation and transfer (CAT) (NQF Act, Section 13 (1) (h) (iii). The QCs are mandated to develop and implement policy and criteria for assessment, RPL and CAT, taking into account the policy and criteria contemplated in the NQF Act.”

RPL will be a fully recognised way in which to accumulate and transfer credits and qualifications if all institutions established, accredited and/or registered in terms of the Higher Education and Training Act, The Continuing Education and Training Act and the Skills Development Act  recognise each other’s certificates to the extent that learners can continue their studies effortlessly from one level to the next higher level at public and private higher education institutions, technical and vocational education and training (TVET) Colleges, community education and training (CET) colleges, private colleges and workplace training centres and skills development centres. A measure of bridging training might sometimes be necessary. However, bridging training should not be so elaborate that it actually turns prior learning into formal learning.

There is one stakeholder that needs to rethink their attitude towards RPL in general and private learning providers in particular. They are organised labour and they are currently an obstacle in the way of people obtaining formal recognition for their prior learning. I’ve been at three conferences where representatives of trade unions clearly demonstrated a misunderstanding of the purpose and nature of RPL. They are under the impression, or perhaps pretend to be under the impression, that RPL is a way in which to obtain qualifications without learning. RPL is evidence of PRIOR learning – learning did take place, only in the past. Members of trade unions openly show their aversion against private learning providers. They don’t understand that the leaders in RPL are currently private learning institutions and that many public learning institutions actually still, overtly or covertly, resist RPL.

Equivalence should play a key role in the recognition of prior learning. Qualifications offered by different learning institutions are almost never exactly the same. RPL should provide for this, for example by giving credits for certain exit level outcomes while others still need to be achieved through bridging training before a full qualification can be recognised. Even just similarity between qualifications should be taken into consideration, for example by granting the students credits for an exit level outcome that is not offered by the learning institution considering RPL (principle 17). This is yet another reason why learning programmes smaller than national qualifications should also be recognised and credited.

To achieve principle 17, principle 18 (There must be a core curriculum for each subject in learning programmes) also needs to be accepted. Credits for the core curriculum must be achieved either through RPL or bridging training while other curriculums for subjects (the old elective unit standards come to mind) may be different from the qualification of the learning institution considering RPL.

In closing, the following are necessary for RPL to contribute to the articulation of the integrated NQF:

• All three QCs and their constituent learning institutions should agree on the nature and purpose of RPL and accept the process as a way in which to facilitate lifelong learning across HE, TVET and OL.
• A holistic approach to RPL should be followed. This means that RPL should describe the principles and values of human development and lifelong learning. As such it should consciously support the social purposes of RPL in relation to access, equity and redress, and strive to implement assessments in a manner that promotes dignity, confidence and educational opportunities for all candidates without eroding learning standards.
• Organised labour needs to review their agenda with RPL and discuss their attitude towards private leaning providers with them in order to facilitate mutual trust. SAQA or APPETD can arrange and act as facilitator for such discussions.

One can probably site many obstacles in the way of an articulated NQF and not everybody will agree about which obstacles are the most important. Obviously the very fact that we have three sub-frameworks is already a problem although it can also be seen as a solution. After all, there are differences between the three sub-frameworks that call for different approaches to especially quality assurance.

An important difference between the sub-frameworks is the difference in curriculum format, brought about by the differences in levels, learning emphasis and target groups. However, we need to overcome these differences if we are to achieve an integrated system that is articulated to the education and training needs of the country. This brings me to a number of obstacles that we should address if the Articulation Policy is to make a constructive contribution to the quality of education and training in South Africa.

1. The Draft Articulation Policy sites the conceptual and organizational incongruities in the post-school education and training system as an important barrier to articulation. The main reason for it being a barrier is the difference between standards, as expressed in curriculums, between Higher Education (HE) and Occupational Learning (OL). HE curriculums and Technical and Vocational Education and Training (TVET) curriculums are sufficiently similar to achieve articulation. The question, therefore, is how the OL curriculum format can be adapted so that it will also fit in with the HE and TVET curriculum formats without damaging the unique content needs of the OL system. The following are suggested:
2. Ensure that the level descriptors for HE, TVET and OL are the same and that the three QCs accept them as such. There is, as far as I know, only one recognised set of level descriptors. However, when looking at the curriculums registered on the NQF there is a clear difference in interpretation between HE, TVET and OL. Articulation should start here, which will facilitate the determination of equivalence between HE, TVET and OL qualifications.
3. The knowledge modules (KM), practical skills modules (PM) and work experience modules (WM) in OL curriculums must be logically grouped together so that they will be comparable to HE and TVET modules or units of learning. This means that each set of KM, PM and WM should together form an exit level outcome that can be compared to HE and TVET exit level outcomes in order to determine equivalence. There is no doubt in my mind that that was the original intention but somewhere those responsible for writing curriculums started writing KMs, PMs and WMs separately and independently.
4. A second deficiency of writing KMs, PMs and WM separately, as if they constitute separate and individual learning interventions with different learning content, is that it would be necessary to develop separate learning materials for each KM, PM and WM for what should be one exit level outcome. This was not the original intention. Some Qualification Development Facilitators (QDFs) might still approach it correctly.
5. A particular knowledge module should provide the learner with knowledge that she or he will need to achieve foundational competence in a particular skill, expressed as an exit level outcome. The practical module following on the knowledge module should describe the foundational competence and serve as the foundation for the learner to achieve reflexive competence, which is expressed in and achieved through the work experience module. This is not the case if KMs, PMs and WMs are not logically grouped together to achieve a specified exit level outcome.
6. Moving away from the above, articulation will not be achieved if work experience is regarded as a requirement for certification in OL. Reflexive competence can seldom, if ever, be achieved during formal education and training. HE understands this, which is why it is not a requirement in HE curriculums. TVET sometimes have such requirements although it is seldom captured in a curriculum. Therefore, gaining workplace experience should not be a prerequisite for certification in OL.
7. Workplace experience and the resulting reflexive competence should be the responsibility of each employer, i.e. the industry. Employers or individual learners who completed qualifications without the burden of workplace experience can be tested by a separate assessment body, for example professional bodies or trade test centres, to qualify for a “level” or “status” certificate, after a period in which they gained work experience. These workers can, in addition to qualifications, achieve proficiency certification, for example: associate – expert – developer – master, or: technician – associate – practitioner – chartered practitioner – master practitioner, etc.
8. Removing the workplace experience component from the OL curriculum will dramatically reduce the burden on learning institutions, who seldom have the capacity to offer such training and the industry, who should focus on manufacturing or other income generating activities rather than training. It will, furthermore, provide substantially more open access to learning opportunities to the unemployed who otherwise will often not be able to complete their studies because they cannot gain workplace experience.
9. In terms of format, removing the workplace experience module from the OL curriculum will eliminate most of the unacceptable duplication that is currently typical of all occupational curriculums.
10. In terms of determining equivalence, removing the workplace experience module from the OL curriculum will enable SAQA and the QCs to more realistically compare HE, TVET and OL qualifications, thereby facilitating transferability of qualifications and credits from one learning sector to the next, including qualifications achieved abroad.
11. The CHE and Umalusi should also be more accommodating and less rigid about recognising occupational qualifications.
12. All role players, including the three QCs, SAQA and DHET should accept the merits of learning programmes smaller than full qualifications. Even single unit standards, or modules if you can’t accept unit standards, should enjoy recognition and respect. This implies that credits for less than a national qualification should be read into the NLRD, as was done for the last fifteen years. This will promote lifelong learning and the CAT system. Many of the objectives of the National Development Plan (NDP) and most of the objectives of the National Skills Development Strategy (NSDS) can be achieved by means of less than full qualifications. For example, mentoring and coaching in a multitude of contexts can be achieved by offering short courses focusing on just mentoring or coaching or a combination of the two. Credits should be granted for such courses and they should count towards full qualifications of which such learning programmes are learning outcomes.
13. I firmly believe that we are wasting time and a shocking amount of money by trying to find an alternative for the unit standards approach. The approach is a most flexible and logical process, ARTICULATED to the education and training needs of South Africa. After all, the Draft Articulation policy specifies that there should be no silos, no dead ends in education and training. Principle 19 of the Draft Policy reads “The curriculum must be modularised to enable and enhance the opportunities for people who work and learn to do so seamlessly and exit a module/short course with credits.” What is necessary is that the unit standards should be reviewed. The environment changes and with it the knowledge and skills needs in many fields of learning.
14. A greater measure of quality assurance in exams (summative assessments) is needed. This applies to all three sub-frameworks of the NQF, and, therefore also to all three QCs. Like universities and TVET Colleges, OL institutions should also prepare and conduct their own formative as well as summative assessments.
15. The Assessment Quality Partners (AQP) concept creates distrust between learning institutions and the QCTO. It would, therefore, be extremely difficult to implement successfully. To begin with, it is a requirement for OL only, which will create suspicion amongst HE and TVET colleges and QCs about the quality of learning and authenticity of assessment results, thereby becoming a barrier to lifelong learning and CAT. Secondly, with the curriculums not structured in uniform modules or exit level outcomes, AQPs will find it difficult to prepare exam papers and assignments that are aligned to the standards. This might well lead to legal action by learners and learning providers against AQPs. The problem is compounded because there is no policy on who may develop learning materials, which will lead to different learning institutions offering different content for the same curriculum. AQPs should rather be quality assurance bodies, like the old ETQAs, with the difference that they should have much better quality capacity and an Apex QA Body monitoring their standards and conduct. SAQA can become the Apex QA Body, thereby not creating new financial burdens for the state, or at least not much. One of the functions of SAQA as the Apex QA Body should be to act as an ombudsman between learning institutions and QCs.
16. The CHE/HEQC should accept their responsibility for quality assurance of HE institutions and not pass the buck by requiring HE institutions to quality assure one another. This applies to compliance as well as performance quality assurance. The current situation is unacceptable for obvious reasons of competition and lack of trust. Umalusi does this as does the QCTO, even though they do not have sufficient capacity. Many countries with well-developed education and training systems, such as Sweden, Denmark, Austria, the Netherland and the UK make use of neutral and approved private quality assurance bodies to do quality assurance. Why can’t we do the same?

To summarise, the following are necessary to ensure an effective Articulation Policy:

• Reduce the differences in curriculum formats for HE, TVET and OL.
• QCs should have mutual respect for one another and cooperate.
• Accept and recognise learning programmes smaller than full qualifications.
• Compliance and performance quality assurance should be conducted by independent private quality assurance bodies that have no vested interests in any learning institutions. QCs can do quality assurance if they are sufficiently capacitated with experts in quality assurance.
• An Apex QA Body should ensure that there are no obstacles against articulation between the different role players.

“A well-articulated system is one in which there are linkages between its different parts; there should be no silos, no dead ends. If a student completes a course at one institution and has gained certain knowledge, this must be recognized by other institutions if the knowledge gained is sufficient to allow epistemological access to programme(s) that they want to enter.” (Minister of Higher Education and Training, Dr BE Nzimande, 15 February 2013).

This is a good introduction to the Draft Policy, providing a clear explanation of what the focus of the policy should be. “Epistemological” is somewhat out of place, but I guess it makes the statement sound more academic. I will comment only on paragraphs and principles where I feel that there might be room for improvement. It is not much, seeing that the Draft Policy is well researched and rather elaborate. Extracts from the Draft Policy are given in quotation marks.

“6. This articulation Policy will facilitate movement of learners between and within the three sub-frameworks of the NQF, and between institutions and also within institutions in order to enable access, progression and mobility.”

Comment: Paragraph 7 lists important reasons why the current ETD system does not promote or support an integrated NQF. To this can be added:

• Inability or unwillingness of QCs to cooperate and recognise curriculums and qualifications on different levels and fields in the NQF.
• Critical differences in the curriculum formats of especially HE and Occupational Learning (OL), making it impossible to achieve a smooth flow in learning from one to the other and to determine equivalence between HE and OL qualifications.
• Rigid value systems in QCs which lead to them being rather reluctant to discuss, listen to or accept the suggestions of other QCs.

“22. The scope of this policy extends to regional qualifications frameworks and bilateral agreements between countries to recognize each other’s qualifications.”

Comment: South Africa is probably the only country in the world using the OT curriculum format, making the determination of equivalence and cross-region/cross-country recognition almost impossible. The OT curriculum does not meet the generally accepted requirements for a curriculum, includes information that does not belong in a curriculum because it does not relate to a standard of learning and contains substantial duplication of the same information.

“Principle 8: Address exclusionary practices: Arrangements for articulation must not unfairly advantage or disadvantage either the students entering courses and programmes of study with credit transfer or those students who enter directly without credits for prior learning. The education and training system must be accessible to individuals who are out of work so that they can have the best possible opportunity to get into work or so that they can engage in productive labour in self­ employment opportunities.”

Comment: The current OL curriculum format makes it almost impossible for unemployed people to achieve an occupational qualification. There are other ways in which to gain practical experience and unemployed learners should not be handicapped with requirements (such as summative assessments in the workplace) before they can achieve qualifications. South Africa is not a developed country with low unemployment rates and we cannot adopt systems in use by such countries.

“Principle 13: Simplicity: The system must be a simple one with simple rules so that the educational and skills pathways are easily understood and accepted. Programmes must articulate and not institutions.”

Comment: Specifying that institutions must not articulate can convey the wrong message or, perhaps even create confusion about what is meant by articulation. Institutions must articulate because they develop learning materials and learning event plans and offer learning. Perhaps the statement “Programmes must articulate and not institutions” should be rephrased. Perhaps all the principles dealing with articulation should be supported with a clear elucidation of what is meant by articulation in the context of the document. Articulation means fitting the promotion of quality learning into a relevant context that applies on all levels and in all fields of learning. It is my impression that the concept is not used the same across the document, i.e. inconsistently.

“Principle 19: The curriculum must be modularized to enable and enhance the opportunities for people who work and learn to do so seamlessly and exit a module/short course with credits. This arrangement will also simplify the time­tabling process in TVET and CET colleges to accommodate two or even three sessions per day.”

Comment: This is an important principle because it promotes lifelong and efficient learning.

“38. Articulation affects learners not qualifications.”

Comment: A statement like this should be clarified. I, for one, do not agree with the statement. In fact, the same paragraph continues by discussing standards, not learners. Already at this stage in the document it was stated that articulation affects programmes and learners but not institutions or qualifications. I believe there are too many contradictory and questionable statements without elucidation.

“43. (i) Work with other government departments to remove outdated policies and legislation which hampers articulation.”

Comment: Excellent.

“54. The entry points for NQF level 2 must be clarified between SAQA and the QCs, and the sub-frameworks amended to ensure articulation routes can be implemented. It is proposed that the entry point for NQF level 2 pathways must be either Grade nine (9) or the General Education and Training Certificate (GETCA). The GETCA especially must ensure articulation pathways into TVET programmes offered at CETs and into the skills development programmes offered through the SETA skills development system.”

Comment: I am using this paragraph to illustrate a point that applies to quite a number of determinations. This paragraph related to NQF level 2 learning only. What would be the case with all the other levels of the NQF? In a Draft Policy that applies to the entire spectrum one should not refer to a single occurrence or level without indicating how or where it fits into the whole. Paragraph 57, for example, contains excellent suggestions. However, it relates to OL and TVET only, leaving HE hanging in the air.

Recommendations.

1. The guidelines and principles of articulation should at least encourage, if not insist on a curriculum format that lends itself to determining equivalence and supporting a CAT system.
2. All role players should accept the guidelines and principles set by DHET to achieve an integrated NQF.
3. All three QCs should accept and support SAQA as the coordinator of articulation between the three sub-frameworks of the NQF.
4. The Minister should provide SAQA with a measure of authority to ensure compliance with the guidelines and principles of articulation. Without teeth SAQA will achieve nothings and the QCs will continue operating in isolation.