Mentornet fully agree with the draft National Policy and Criteria for the Implementation of RPL (referred to as “the National RPL Policy” in this feedback document). However, the RPL Policies of QA Bodies differ in some rather critical elements from the National RPL Policy. The following should be considered and, perhaps, discussed with them:

1. Paragraph 7 of the National RPL Policy provides for RPL as a way in which to obtain credits, qualifications and part-qualifications. Quality assurance bodies that set artificial limits and preconditions for RPL can easily destroy the socio-economic and redress value of the process. Allowing RPL only for gaining access to further learning but not for certification is unfair and discriminatory.
2. Paragraph 11 and 12.c of the National RPL Policy determines that the RPL policies of the three NQF Sub-Frameworks must be aligned with it. Hopefully all three QA Bodies will show the necessary respect for the professional work that SAQA put into reviewing the current National RPL Policy.
3. Paragraph 15.d of the National RPL Policy accepts that the RPL Policies can differ in terms of context. This can easily be misinterpreted as meaning that different QA Bodies can accept only the terms of the National RPL Policy with which they agree, rendering the National RPL Policy ineffective.
4. Paragraph 15.f of the National RPL Policy provides for the use of RPL for diagnostic, formative or summative assessments, to create opportunities for, or towards credit/exemption, access, advanced standing, professional designations or recognition in the workplace. Although not wrong, this extends the purpose for which RPL can be used substantially. Holistic RPL should be flexible, but diagnostics and formative assessment are only steps in the RPL process and not end-results.
5. Paragraph 15.i and 18.c.vi: Maintaining data on how credits were achieved “under strict conditions of confidentiality” creates the impression that there is something wrong with credits achieved through RPL. A certificate is just the written confirmation that an individual has certain knowledge and skills. How the knowledge and skills were obtained is not relevant. Credits achieved through RPL and credits achieved through formal learning are of equal value and status – this should be accepted and supported unconditionally. Transparency is important.
6. Paragraph 19. The role of education and training institutions should be protected and guaranteed, the only precondition being that the learning institutions, be they public or private, need to have the knowledge, experienced and capacity to offer learning in RPL and conduct the process if that is what they wish to do. Currently this is not reflected in the accreditation of private learning institutions, the representation of such institutions in National Coordinating Bodies or the allocation of contracts to offer such services based on merit.

In closing, quality assurance bodies currently have in their RPL Policies certain clauses that should specifically be addressed and precluded in the National RPL Policy, for example:

• Refusing to grant learners credits towards a national qualification if the credits were achieved through RPL. Giving a learner who achieved a degree through formal learning 360 credits, but the learner who achieved 50 of the 360 credits through RPL only 310 credits for the same degree does not make sense.
• Limiting the number of students who can be admitted to further studies through RPL. Not only is this an unnecessary and unfair obstacle in the way of redress of injustices of the past, it is also labeling RPL as inferior to formal learning. Countries with advanced RPL systems in place provide for the RPL of entire groups, which would mean that all students in a particular cohort can be accepted on account of them being assesses through RPL for full qualifications.