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COSATU Parliamentary Submission on theGreen Paper on Further Education and TrainingPresented to the Department of Education, 2 June 1998 |
Contents
- Introduction
- Framework for the Transformation of FET
- Qualifications, learning programmes, curriculum, and quality assurance
- Funding
- Governance
- Way forward
- Conclusion
- Summary of key recommendations
- Introduction
- Framework for the Transformation of FET
- Context for the transformation of FET
We recommend that the key principles that must guide the FET framework should be those of redress, equity and access. This should be stated in the Chapter on a "new framework for Further Education."
Co-operation and partnerships;
Co-ordination and strategic planning;
Flexibility and responsiveness;
Enhanced articulation;
Institutional diversity; and
Quality of provision.
- Role of FET
The White Paper should clearly define the level of skills that should be developed through FET programmes. This should clearly articulate the link with the NQF.
- Role of the state
- Partnership with FET institutions and employers
Unions should be included in any partnership between employers and colleges and other institutions providing FET programmes. If colleges are to meet the need of industry with regard to employees, then it becomes important to include the unions as representatives of the learners in that context.
The Green Paper correctly point out that the context within which the transformation of FET occurs has dramatically changed. To a large extent FET will have to respond to this new realities as much as contribute towards reshaping some of these realities. In broad terms, FET has to respond to the demands imposed by the changing social needs in post-apartheid South Africa; as well as new economic realities, particularly globalisation.
First, it important to engage with the concept of 'globalisation'. Often, globalisation is conceived as something that nations have to no choice but to succumb to on its terms. This THINA (There Is No Alternative) perspective ignores role of the state as the primary agents of globalisation. Secondly, states are increasingly finding ways to subject globalisation to their national programmes. Thirdly, there is a recognition that globalisation accentuates inequality and poverty between and within countries. Therefore, while we recognise the need to consider the impact that globalisation has had, and continues to have; we would argue that there need to be increased emphasis placed on national development, as well as the location of South Africa as part of the Southern African community. Standards, while needing to be internationally comparable, should reflect the national and regional realities and needs. COSATU therefore supports the Green Paper (p.13) when it is argued that "the phenomenon of globalisation should…be viewed simplistically, or overstated."
The second key question in dealing with FET transformation relates to what is the objective of transformation? There are two key areas with regard to the manner in which the Green Paper deals with this issue. Firstly, the Green Paper does not spell out the principles that guide the FET framework.
Recommendations:
The Green Paper neglects these issues. The state's approach of providing "what it can afford" in terms of the MTEF, rather than what is required neglects it responsibility of ensuring increased access and of meeting the needs of those who have been historically disadvantaged. This will ultimately negate the possibility of building equity into the system.
Secondly, the language of the Green Paper appears to see education's role as being only that of meeting the needs of business. We would argue that education and training have an important role to play in ensuring that individuals have the skills and knowledge required to access the economy; we would also emphasise this in terms of the contribution that education and training plays makes to building of the economy. However, we would regard education as a social service, which the state has an obligation to provide. Having said this, we note the central pillars that will underpin the new FET framework:
We will now deal with the role of FET, the role of the state and partnerships with the FET institutions and employers.
COSATU supports the imperative of the FET system articulating with the world of work and of higher education. However, we would argue that there is also need to consider the role that FET plays in ensuring that individuals are able to participate actively in other aspects of life, including the environment, politics, culture, and relationships. The mental, spiritual and psychological well being of individuals should nurtured.
The Green Paper does not clearly define the level of skills that should be developed through FET programmes. We would argue that the skills developed in this band must equip individuals to perform competently in many of the skilled occupations. In this regard, we are concerned with the possible implication that local needs may not require highly skilled individuals. FET should ensure that its contribution to the SME sector is that of enabling SME to develop beyond the "spaza shop" level and to move into high skilled niche markets.
Recommendation:
The role of the state in FET needs to be carefully considered. The role that the state plays will impact upon the entire transformation process, and while we recognise the need for partnerships and for "a new relationship between the state, civil society and the individual" (p.12), we would be concerned if the state were to relinquish its constitutional responsibility to "make (further education) progressively available and accessible". In terms of this, we have two main areas of concern with the envisaged role of the state.
Firstly, there needs to be a clear articulation of the role and competencies of the national government with regards to FET. The relationship between this role and the competencies of the Provinces needs to be spelled out to ensure that this does not result in conflicting policies or approach.
Secondly, in the Green Paper government fails to take responsibility for the financing of the FET band. Thus, while it highlights the need to transform the system, and argues that there should be increases access to FET for adults, it does not commit itself to providing the resources to achieve these objectives. Government needs to accept the important role it has to play in financing the delivery of programmes; ensuring that quality can be improved, and of ensuring the development of infrastructure in areas where this has been lacking. This issue emerges both in the introductory chapters, as well as in the chapter dealing with funding; where the manner in which government is going to ensure that it can meet the needs, that recognised in the Green Paper (p.69), is not dealt with.
In line with the above, we support the need for strong partnership between the state and other institutions and sectors. The nature of these partnerships needs to be clearly defined so as to ensure that these partnerships ultimately benefit the learner. We are however, concerned that the emphasis is primarily on partnership with employers (p.22). While COSATU support the need for colleges to have strong relations with industry, we would not see that as being only with employers. Unions in different companies would also be able to contribute to the skills and knowledge areas that are required and the manner in which programmes should be run.
Recommendation:
- Qualifications, learning programmes, curriculum, and quality assurance
We broadly support the programmes section in the GP and believe it offers a significant step forward in realising the aims of the NQF. However there are a number of areas that we believe should be further clarified.
- Enhanced articulation
There should strong linkages made with General Education and Training band, and specifically with ABET programmes.
- Programmes
The idea of crash courses should be removed as in the main these have not lead to greater opportunities for learners.
- Qualifications
- Developing new qualifications
The SAQA definitions should be used as a starting point, and then work should be done, possibly by the proposed qualifications task team, to attempt to ascertain what qualifications will have value in the "field", and what components ensure their equivalence.
- Fundamental
- Elective
- Support Services
In addition, we would propose that there should also be mention of how learners undergoing programmes to initiate an SME will get access to other forms of support such as longer term mentoring as well as loans. There is also a need to define the support that will be provided in the distance education programmes so as to ensure their transformation from essentially correspondence institutions to distance education institutions.
- Quality Assurance
- Assessment
- Efficiency and repetition
Proper support should be provided to the learner who has been unsuccessful in his/her first attempt, and the institution needs to be held accountable for providing this support. Resources must be committed to improving the level of learner achievement and eliminating the factors or conditions that lead to a high repetition rate.
The Green Paper acknowledges the need for permeable boundaries between FET and HE, and "to a lesser extent with GET" (p.24). While we strongly support the need for this articulation, we would argue that there is a need for very strong links with the GET band, especially in the light of the need for adult learners to move from ABET to FET programmes (this issue also emerges in the governance section, p.78).
Recommendation:
There is strong support for the need for programmes to cover a broad continuum, and to include all 12 fields of learning. However, there is a concern about the notion introduced in the Green Paper that certain programmes will be "crash" programmes. We would argue that all programmes funded as part of the FET band, should either lead to qualifications or part thereof.
Recommendation:
We support the need for colleges to continue to provide certain programmes at a HE level, and the need for CHE to play a key role in this regard. FET institutions should be consulted with regards to the review of programmes offered by these institutions.
As COSATU, we support the proposal for the move away from the current system where there are a myriad of qualifications that do not articulate with each other, towards a system where there is a single FET certificate at each of the FET levels (that is qualifications at levels 2,3 and 4). This ensures that all learners, at a particular level on the NQF, receive an equivalent qualification, which potentially provides access to both higher education as well as the world of work. We believe that this is a very significant step in moving towards an integrated system.
The details of the envisaged qualification are unclear. The manner in which the core and elective is dealt with in the GP is confusing, as the two appear to be interchangeable. The value of core and elective in ensuring equivalence is thus lost, and there is a danger that the qualification structure ceases to provide a guideline to the make up of a qualification.
Recommendation:
In line with the above, COSATU is concerned about the stipulation that the communication and numeracy must be at the level of the qualification without sufficient attention to what the relevant needs are with regards to communication and numeracy. We support the need for communication and numeracy to be part of all qualifications, however we would argue that the level needs to be agreed upon in a more developmental way.
The proposal that work experience is part of the elective, as a distinct area is cause for concern. The work experience should relate to a number of unit standards and should form a major part of the practical component of the standard (s). This informs the method of assessment that should be utilised, as this component should be assessed as an integral part of the theoretical component of the standard (s). Work experience could fall within both the core and elective components of the qualification.
We support the need for career guidance and support services as proposed in the GP.
Recommendation:
There are concerns about the way in which the FETQA is envisaged in the Green Paper. While we would support the need for a FETQA, it is not clear why the FETQA covers levels 1 – 4 on the NQF, rather than 2 – 4. While we are not against this in principle, if this is to be the case, then this quality authority would also need to take responsibility for ABET levels 1 – 3 to ensure proper articulation between ABET levels 1- 3 and NQF level 1.
We are also concerned about the location of the ETQA in the Department of Education. As per SAQA regulations, the ETQA would need to consist of stakeholders. The Department would only be one of those stakeholders, and as a key provider it would be especially important that it not be seen to be both the referee and the player.
Particularly for this band, it will be important to develop clear linkages between this ETQA and the proposed SETAs. This will ensure equivalence across the band, and would assist to advance the integration across the band.
While we recognise the need to have both interim and longer-term strategies in place, there is a concern that the Green Paper argues that assessment in the colleges should be internal for the foreseeable future. Colleges need a form of external assessment so that learners that participate in programmes in these colleges are regarded as having equivalent qualifications. The Green Paper also needs to explicitly state the need for this external assessment at levels 2, and 3, as well as 4, for those learners that are existing the system prior to level 4.
Recognition for Prior Learning (RPL) is critical in facilitating adults, that have been denied access to formal education and training, entry into the education and training system. This should be clearly built into the policy, and mechanisms should be established to enable adults to access assessment for RPL.
While we understand the concern that is being raised in the Green Paper regarding efficiencies and repetition, we are concerned that this needs to be qualified with a statement of the support that the learner will receive. There is a concern that this policy is crudely applied, then it may allow schools to avoid their responsibility to work with the learner to overcome obstacles that s/he is encountering.
Recommendation:
- Funding
COSATU supports the broad thrust of funding chapter and believe that it can assist in improving the efficiency of the system. We concur with the Green Paper that the most "immediate challenge for new funding framework is to redress the bitter legacy of apartheid and to address the range of socio-economic needs" (Green Paper, p.52). Further, that the funding framework will have to cater for the expansion of FET to under-represented target groups, new modes of further learning, information technology, learner support, curriculum development, and higher costs associated with practical work and technical and vocational training."
It is imperative to look at the implication of the Medium Term Expenditure Framework (MTEF) for FET and education broadly. COSATU supports the introduction of the MTEF as an important planning tool. It will allow for reprioritisation of expenditure in line with the goals of the RDP, thus eliminate the rollover of expenditure witnessed in the first few years of the democratic government. It gives government department and provinces the scope within which they should plan their programmes over a three-year programme, which was difficult to achieve under a one-year budget. However, the deficit reduction programme contained in GEAR compromises MTEF’s improved budgeting mechanism. Compounding this is the cap placed on expenditure and revenue targets as a proportion of the GDP. These restrictive parameters leave little leverage for government to deliver basic services to the people.
The net effect of these restrictive parameters is the resultant cuts in social expenditure in order to meet deficit targets. Subsidiary objectives such as deficit targets have supplanted the developmental goals enshrined in the RDP. For instance, education expenditure will have to be driven by the need to meet budget deficit rather than developmental objectives such as teacher: pupil ratios. The mooted teacher retrenchments are indicative of the effects of a programme driven by the desire to satisfy rigid deficit targets. Although allocation to education as a percentage of total expenditure in the 199899 budget has improved from its 1997/98 level of 21.2% to 22.8%, it declines in the last two years of the MTEF. In the 1999/2000 budget the projected allocation to education, as a percentage of total expenditure is 22.4% and then 21.8 percent in 2000/01. It is evident that the present parameters within which the MTEF is required to operate will have adverse effects on education and FET in particular. Therefore the parameters within which the MTEF should operate need to be redesigned with en emphasis placed on developmental objective or the social deficit in areas such as education. These should be taken into account when formulating a new funding framework for FET.
Having said this, COSATU welcomes the funding policy framework outlined in the Green Paper. The funding principles contained in the Green Paper should ensure the adequate allocation of resources to this band and we like to emphasise the principle that "education departments must be enabled to fulfil their constitutional obligation to make FET progressively available and accessible" The Constitution thus place a positive duty on the state to make FET progressively available and accessible and this depends largely to dedication of sufficient resources. The new funding framework will be driven by three methods of funding i.e. formula funding; earmarked funding and student finances. However, while the model is considered useful, we reiterate our concern that there does not appear to a government commitment to funding this band, and this will prevent the achievement of the objectives set for the FET band. In the absence of such a commitment there will be over-reliance on student finance and what can be mobilised from the private sector to fund FET. This will serve to perpetuate current inequalities, as only those who have ability to pay will access FET. We would like to comment on formula funding; earmarked funding and student finance.
- Formula Funding
We endorse the proposal that the possibility of programmatic funding for senior secondary schools be investigated but would propose that clear time frames are provided to ensure that this is attended to as soon as possible.
The definition of performance should be broadened to ensure that it looks at the learners results, as well as factors such as the role that the institution is playing in the community, and the extent that it is transforming in line with the FET objectives.
The money for performance should be linked to earmarked funding for supporting learners so that the fund in fact helps them perform successfully.
- Earmarked funding
A portion of earmarked funding should be set aside to redress the imbalances in infrastructure within the national review of FET institutions.
A mechanism should be developed to compensate provinces, which provides FET to students not necessarily from province.
- Student Finance
The finance task team should further investigate the issue of regulating learner fees; an alternative to a means test to test ability to pay or how it can be made effective and does not exclude the poor; and developing the sliding scale for user fees.
The funding task team should investigate obstacles preventing students at FET level to access private finance institutions and develop clear proposals in this regard;
As part of the investigation into a National Student Financial Aid Scheme for higher education students; the integration of student finance across the two bands should be investigated. A process should outlined on what happens in the interim when FET students cannot access the loan scheme for higher education students; and secondly, outline the framework for developing a comprehensive student financial aid for higher education and FET students.
- Funding of structures and private providers
Funding of structures such as the FET board should be clearly spelt out in the White Paper.
COSATU supports the need for programmatic funding. This provides a means to integrate funding within the band, as it is consistent with proposals in the Skills Bill. However, the fact that this is not consistent across the band, it may lead to a separation of schools ("education") from colleges and other technical training institutions ("training"). This jeorpadises the integration of education and training. There is clearly a need for consistency of funding arrangements across the band to ensure integration and efficiency within the band. We recognise that the Schools Act and the institutional arrangements within schools (GET and FET) programmes within a single institution complicate this), however, we would argue that these problems could be resolved.
Recommendation:
We support the principle of 5% for performance. However, there are two issues that must be dealt with as part of this. It is imperative that the definition of performance includes learners' results, the role that the institution is playing in the community; and the pace of transformation inline with FET objectives. Further, funding should be linked to earmarked funding for supporting learners so that the fund in fact helps them to perform successfully. Without this support, the performance incentives may perpetuate certain inequities in the system with regards to both learners and institutions.
Recommendation:
These funds need to ensure that it allows for redress mechanisms to be put in place. This should apply to learners, as well as institution and practitioners. Concretely, earmarked funding should be used to extend infrastructure to areas, which lacks the basic resources to provide FET. For instance, the distribution of colleges and schools providing FET was skewed in favour of former white areas to the disadvantage of black students. The provision of infrastructure for FET should be done within the context of the review of institution including identification of areas where new institutions should be build.
Secondly, part of earmarked funding should be used to counteract spillover effects of providing FET. Since provinces will be largely responsible for distributing funds for FET, cross-border provision need to be taken into account and provinces compensated accordingly. For example, a student may choose to attend a FET institution that is not located in his/her province but funding is determined by the number of students in FET, which may change due to these cross-border movements. If provinces are not compensated this will place a heavy burden on their resources.
Recommendation:
An area that requires additional work is that of learner fees. Firstly, there needs to be an environment, which provides for the regulation of learner fees. Secondly, the means test is not a viable mechanism to assess learner's ability to pay, as this depends on a number of different factors including the definition of a household. The concept of a sliding scale for user fees has also not been fully developed.
Recommendations:
The Green Paper argues that FET, as the post-compulsory phase, must require learners to pay fees. However, this must be located within the context of the Schools Act which states that no learner will be denied access to schooling because of financial reasons. It should also be understood within the ambit of government's stated commitment to FET, and its awareness of the critical need for FET for individuals.
COSATU recognise the need for learners to contribute, where possible for learning programmes in the FET band. However, the Green Paper does not provide sufficient mechanisms to support those learners unable to pay fees. The dismal failure of the loan scheme, a feature of high education; and the difficulty to access private financial institutions either due to high interest rates or lack of collateral, makes it unrealistic to place the responsibility to assist learners unable to pay fees, solely on the private sector. Government should take responsibility for assisting those learners that cannot access FET, without such a commitment from government, those learners who come from disadvantaged backgrounds will be denied access to FET, and therefore their route to higher education. Although we recognise the fact that with its present 'capitalisation' it will be difficult for students in the FET band to tap the loan scheme at higher education, we not accept the argument that there should be not integration of student funding at FET at higher education level. It is self-defeating to foreclose options that can continue to be researched and developed.
Recommendation:
The Green Paper does not state how structures will be funded, and there is a concern that moneys meant for delivery could be used for structures. The FET Board is seen as an important structure and it is critical that funds are made available to ensure that it can operate effectively.
Recommendation:
COSATU supports the Green Paper that private providers should be able to compete for earmarked funding which will be used for national priority programmes. However, public institutions should be prioritised over private providers and the principle of accountability should be applied to the private sector. Therefore we support the Green Paper when it contends that "if in time private providers are enabled to bid for public funds, they must comply with the same rigorous accountability measures as public providers" (p.66).
- Governance
We support the broad thrust of the governance section, and believe that the principles and approach outlined in this chapter will assist in ensuring that the FET band can be transformed in the manner envisaged in the Green Paper. We would like to emphasize that national government should intervene to ensure provinces adhere to national norm and standards. Provinces should have corresponding powers to intervene into the affair of institutions to ensure that they implement the transformation programme. However there are a number of areas that we would argue should be enhanced.
- Linkages with Department of Labour (DoL)
We would propose clear relationships between the proposed FET board and the NSA as well as the NETC. This ensures that the discussions in the FET board both inform the NSA and NETC as well as are informed by these other structures.
- FET Act
- The FET Board
Firstly, there should be a clear statement about the numbers of people on the board, and from which sectors individuals will be drawn from. This should be clearly stated in the regulations.
Secondly, individuals on the board must be representatives of stakeholders, and not in their individual capacity. The stakeholder should have the right to recall the individual, if for example the individual was no longer in that structure. In addition to representative stakeholders the Minister may appoint a specified number of individual experts. These individuals should have a distinct status on the board, which would be different from those who represent organisations.
The Act must specify the functions of the board, and must ensure, as stated above, that it has the funding to implement these functions. It is important that the board has authority, and that the recommendations that the board makes to the Minister should be implemented. Where this is not possible, the board should receive reasons stating why such a course of action could not be pursued. In order for the board to have authority strong provincial representation on this structure is considered crucial. These should be linked to similar provincial structures.
Clear lines of communication and accountability, between the national board and the provinces, must be outlined. The national board should have the legitimacy and authority to ensure that provinces are assisting to realise certain national goals and imperatives. A mechanism to achieve this should be developed. This includes the possibility of using earmarked funds to provide an incentive to Provinces to act in a manner that is consistent with national goals.
- Role of institutions
- Determining the focus of institutions
- The requirement for transformation
- The right to hire and fire
We would argue that there needs to be clear linkages with the DoL, and specifically with the skills development strategy. While the GP refers to this, it is vague as to how this will be realised.
Recommendation:
In line with comments made earlier about the need for both vertical and horizontal integration and articulation, we would argue that in order to develop a new FET band, as proposed in the GP, it is important to ensure that all institutions within the band fall within the Act. This implies that senior secondary schools should possibly be re-organised so that the senior phase is split from the FET phase. This will enable FET schools to fall under the FET Act, rather than the Schools Act. This is critical in ensuring the overall transformation of the band.
We support the need for a board and believe it will play an important role. However there are two main areas of concern: the Green Paper does not clearly stipulate the powers of the Board and does not give a clear breakdown of representation on the Board. We therefore would like to put forward the following recommendations regarding representation and powers of the Board:
Recommendations:
We support the need for institutions to change, and for the need for a diverse range of providers. The establishment of college councils, and the emphasis on institutions identifying their mission in terms of identified needs is crucial to developing institutions that are responsive to the needs in society. However, this should not be read as a call for institutional autonomy and this issue needs to be clarified at two levels:
The Green Paper emphasises the importance of the role of local communities in determining the mission and plans of a particular institution (p25). However, this needs to be balanced with the need to ensure that institutions are rationalised across the country and nationally. There is a danger that at a local level people will support the need for the provision of all programmes, this will not be affordable, and may result in programmes that are of poor quality.
The Green Paper states that government, and, we would argue, together with the FET Board, "must take responsibility for reorganising the institutional and systemic landscape". The Green Paper states that this must be undertaken in consultation with the institutions and stakeholders concerned. This approach is supported, and as such, there powers of institutions to determine their own missions should be limited to that of developing proposed mission statements, and plans of actions. These should have to be approved at both a provincial and national level. It is critical that in this process, the decision taken with regards to different institutions must be taken with regard to educational and developmental objectives, and not because of budgetary considerations.
This process will need to be undertaken with due regard for institutions that have been historically disadvantaged, and earmarked funds will need to be available to ensure that these institutions can be upgraded. There may also be areas in which infrastructure will have to be developed to ensure that there is equitable access to institutions. In addition to this, where programmes require extensive capital, and as such may need to be centralised, some aspects of a programme should be run at an institution that is closer to the learner. This could be achieved through the usage of creative responses such as distance education methods.
The above rests on the assumption that all institutions in the FET band require transformation. If we are to meet the objectives set out for the FET band, then all sectors of FET must be compelled to reexamine their missions and programmes in line with the objectives agreed upon for FET. We strongly support the need, as stated in the Green Paper, for senior secondary schools to be transformed as part of the FET band, and to cooperate closely with other institutions in this band so as to ensure a shift away from the narrow academic curriculum of the past. The need for schools to actively assess themselves and to change, must be clearly specified in the regulations. The governance section concentrates on how colleges will be compelled to change, but relies on the Schools Act in terms of that sector.
We would argue that the state cannot negate its responsibilities. It is the state’s responsibility to render this service, and as such, employees must remain employed by the state and should fall within the established collective bargaining arrangements for the sector. Where institutions require additional people to perform certain functions for a short period, then the individual should be employed under the conditions that govern temporary teachers. We would further propose that all practitioners must be registered with SACE.
- Way forward
- Capacity building
- Practitioners
In addition to government funding, we would propose that where a practitioner is to be trained in an area that will benefit a particular industry, then the industry should contribute to the training through the relevant SETA. In addition, funding should be sought through the NSF to assist with this retraining.
- Workers
As part of the process of transformation of institutions new roles will have to be agreed upon for workers, and they will require education and training to perform these new roles.
- Department
- Legislative process
- Task Teams (TT)
A key aspect of the new system is to ensure that practitioners in the new system are able to gain access to retraining so as to ensure that they can move into areas that are considered to be important. This form a critical part of ensuring that the programmes that are envisaged for learners can in fact be provided by trained practitioners. This should also allow opportunities for teachers that have been at schools to be retrained so as to meet the needs identified for the FET band. It is crucial that government commits itself to the funding of this retraining.
Recommendation:
The need for workers, in these institutions, to receive training is neglected in this Green Paper. The new institutional arrangements will impact on all workers, and not only on teachers, for example librarians will potentially have to assist learners that are learning through distance education programmes.
Recommendation:
In addition to the practitioners there will need to be a comprehensive capacity building programme for the department at both a national and provincial level to ensure that officials have the capacity to ‘steer" the system as described in the Green Paper. For many in the department this represents a complete shift in the manner that these institutions are run, and the department will be expected to play a key role in assisting these institutions to transform.
We would argue that given the complexity of the band, it is inappropriate to attempt to rush the legislative process (as evidenced by the Bill being released simultaneously with the Green Paper), rather the Green Paper must be translated into a White Paper based on the comments received on this Green Paper. This will facilitate the reaching of consensus prior to the release of the Bill. Past processes have highlighted the advantage of this approach, as well as the problems that develop when these processes are not properly followed.
We would support the need for the speedy establishment of the TT to ensure that work can already begin on transforming the band. We support the task teams proposed, however we argue that there should be an additional TT dealing with institutional transformation. This team would facilitate the process of transforming institutions as discussed in this submission. It would also identify capacity requirements of the institutions to assist the retraining process. We would further propose that these TT be set up with stakeholder representatives so as to ensure that there is maximum agreement built up for the changes that are proposed.
- Conclusion
COSATU has made detailed submission on the Green Paper and we hope that our recommendations will be taken on board. Further, we request a written response to this submission. This will assist further on in the process as we interact with the White Paper and the Bill.
- Summary of key recommendations
- Role of the state
Clearly outline national and provincial competencies regarding FET.
Set out a mechanism that provincial and national cooperates to achieve national goals and objectives;
Be empowered to intervene in many institutions of FET where the state allocates resources. This particularly important in institutions where change is resisted or where national objectives are threatened.
- Role of FET
The role of FET should be broadened to include all aspects of life, and not just to narrowly relate to work and higher education.
- Funding
The state must provide funding at a level that ensures that the transformation of institutions, and increased access, to learning programmes, for adult learners. This requires funding for institutions for development of new curricula, for capacity building, for infrastructural development, for student aid, and for the FET Board.
Consistent with the above, is the need to ensure that the decision to reduce spending on personnel is based on developmental objectives and not on budgetary considerations.
There is a need for a mechanism to determine the learner's ability to pay.
- Governance
There should be clear links with this Green Paper and the National Skills Bill, this relates particularly to the proposed FET Board to relate to the NSA, as well as with regards to quality assurance arrangements.
There is a need to ensure integration through funding arrangements, as well as through compelling all institutions on the band to transform to contribute to meeting the overall objectives set out for FET.
The Board must be made up of a clearly stipulated number of stakeholders;
It must have authority to determine national goals and to ensure the implementation of this in provinces.
Partnership should be with all stakeholders in industry and not only employers.
- Qualifications, learning programmes, curriculum and quality assurance
The quality assurance structure cannot be located within the Department of Education, but must include all stakeholders, including the Department of Labour.
The quality assurance structure must establish clear relationships with the proposed SETAs, as well as with ABET quality assurance arrangements.
All state funded programmes, in the FET band, should lead to qualifications or part thereof. There should be not crash course and other quick-fix solutions.
The details of the proposed FET qualifications should be develop through interaction with different stakeholders. This should be done in a developmental manner and should take into account the need to ensure that qualifications are equivalent, are educationally sound, provide the learner access to a career and learning pathway.
Assessment should be consistent across the band, allow for integrative assessment, and ensure that the learner receives a qualification that has value;
The concern on repetition is that it must be balanced with the need to ensure that there are resources to ensure learner support.
- Capacity building
There should be a capacity building programme for all workers, practitioners, and the Department of Education (national and provincial).
- Status of employees
All employees must be employed by the state and fall within the agreed upon conditions of service.
Employees in this band must fall within established collective bargaining arrangements.
Practitioners must be registered with SACE.
The state must:
The Green Paper on Further Education and Training (hereafter the Green Paper) is an important landmark in the transformation of the education system in South Africa. It is an important contribution to the policy frameworks developed for General Education (GET) and Higher Education (HE). The policy framework on Further Education and Training (FET) should provide for increased articulation between this band of education, GET, HE and the world of work. Ultimately, FET combined with other bands of education and training must contribute to overcoming the apartheid legacy manifest in inequities in training and education, the low level of investments in human resource development; the separation between education training; the low priority accorded to FET; and the highly segregate labour market.
Unequal access to education and training reinforced inequalities in the labour market reflected in the high wage gap between high and low income-earners, and the skewed number of skilled personnel, resulting in the majority of black workers locked at the lower end of the labour market. Therefore creating a synergy between transforming education and training contributes directly to the restructuring of the labour market.
Against this background, COSATU supports the broad vision of the Green Paper. We endorse the need for changes in the FET system, and the importance of transforming the system to meet the challenges facing education and training in this country. This includes the recognition that "if FET is to meet the varied needs of individuals and communities and contribute effectively to social and economic development, a flexible and responsive, multi-pronged strategy it required" (Green Paper, p.14). However, we are concerned that many of the proposals in the Green Paper will prevent the realisation of this vision, and it is these issues that will be dealt with in this submission. The submission will focus on the new framework for FET; qualifications, learning programmes, curriculum, and quality assurance; funding; governance; and way forward.
