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COSATU Submission on theAdult General Education and Training Bill and the General and Further Education and Training Quality Assurance Bill2 May 2000 |
Table of Contents
Introduction
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COSATU Submission on theAdult General Education and Training Bill and the General and Further Education and Training Quality Assurance Bill2 May 2000 |
Table of Contents
COSATU would like to thank the Minister and the Department for the opportunity that has been provided to comment on these Bills. We believe that both of these Bills are significant steps in realising the goal of the transformation of education and training system into one that is of a high quality, and that meets the needs of the majority of South Africans.
However, while we are fully supportive of the Bill, we are concerned that the Bill does not ensure that ABET delivery is increased. It lacks real mechanisms to monitor implementation and to tackle non-delivery where this emerges as a problem. This should include the need for government at the different levels to play a developmental role with regards to the adult education centres. This should include support measures such as the provision of learning materials and educator development.
We would further recommend that there is a clause inserted in the Bill that addresses the need to ensure that ABET is available in all 11 languages, and that the needs of the learners should determine the language of teaching, as well as the language that the learner in fact learns.
More specific issues relating to the Bill are dealt with in the rest of the submission.
Adult General Education and Training Bill, 2000
COSATU believes that this Bill is very important for a number of reasons. Firstly, it makes an important statement about the importance of adult education and training. Secondly, it contributes towards the objective of regulating adult education and training provision against accepted standards.
There are a number of areas that we believe could be strengthened in the Bill. We will be submitting comments that pertain to these areas, and we will therefore refer only to those sections that we believe could be amended.
Preamble
With regards to the clause on redress, we would suggest that equal access does not adequately describe the need to "fast-track" the delivery of education and training to those groups that have been historically denied access to education and training in the past. In this regard we suggest that the clause be rephrased in a manner that is consistent with the approach in the Employment Equity Act.
Access should be broadened to extend beyond the workplace to accessing economic opportunities as well as the ability to participate more actively in all aspects of society.
With regards to the clause on respect, and on encouraging an appropriate environment for adult teaching and learning, we would recommend that this be extended to include a reference to the need to develop a code of ethics that guide the teaching and learning process.
Definitions
In the definition of adult general education and training, a distinction is made between learning and training. We would recommend that this read as all learning (which includes both education and training). This would prevent the perception that training is not regarded as contributing towards the learning process.
Provision of facilities
COSATU supports the efficient usage of resources, and the need to fully utilise resources. We therefore support the clauses that relate to the provision of facilities (4). We believe that this is the most effective manner of ensuring that there are facilities for adult general education and training. However, we believe that these clauses need to be strengthened in the following manner. Firstly, while the governing body of a school will be consulted on the usage of the school, this consultation must take place within the context that the schools are in fact public property, and where a school does not wish to agree to this request they should be legally compelled to provide written reasons as to why this request is not possible. This written submission should then be considered by the Head of Department who should then make a ruling as to the validity of the reasons.
Moreover, there must be a easy and quick process that community members can follow to raise concerns where schools do not adhere to the agreements (as spelled out in (3).
Merger and closure of public centres
While we accept that there may be cases where it is appropriate to either merge or close a public centre, we would recommend that a clause be added, which stipulates that the Member of the Executive Council must provide a written reason as to why the centre will be either merged or closed, and that this must include an account of where learners in the particular area will be accommodated.
Private Centres
We support the need to register private centres and to ensure that they comply with the agreed upon standards for centres. However, we are unclear of the implications of clause 27 (2) whereby it states that the MEC shall determine the grounds on which the registration of a private centre may be granted or withdrawn. It is not clear whether these grounds are to be more onerous than for those of public centres and if this is the case what the rationale is for this. While standards are important, it will be important that these are not developed in such a way that this discourages the provision of education and training for adults.
Clause 27 (3) (b) states that the admission policy should not discriminate on the basis of race. We support this but believe that this should be extended to ensure that there is no discrimination in the admission policy of the institution. This should be guided by the Constitution of the Republic of South Africa.
We would recommend that this clause (32) be extended so as to read, and in a manner that is consistent with the requirements of the South African Qualifications Authority (SAQA). This should include the proviso that where possible education and training should be provided so as to meet the national standards registered on the NQF.
Other areas of comment
We have three broad issues that we would like to raise in this category. These include: national target for the national skills plans, sectoral targets that inform the sectoral plans and facilitate the integration of education and training, and the need for centres to keep information relating to students. These comments do not relate to any specific section of the Bill, and we would recommend that they either be inserted into the existing sections or that an additional section is developed.
Firstly, we would suggest that the NABAET be given the responsibility of developing national targets for the eradication of illiteracy and the general provision of adult general education and training. These targets should both be informed by the Provinces, and in turn should inform the manner in which Provinces tackle the question of AGET. Otherwise there is the concern that the Bill may not reach its objectives as there is no mechanism to assess the extent that adults are in fact able to have greater access to AGET programmes.
Secondly, we are concerned with the apparent lack of synergy between this Bill and the Skills Development Act. The Skills Development Act is conspicuously quiet about matters relating to ABET, and it is with concern that we see a similar approach reflected in this Bill. We would recommend that the Bill discuses the relationship between the NABAET and the NSA. We would further recommend that the Bill explore the linkages between the targets set by the NABAET and the national priorities that are agreed upon as part of the national skills plan that will be agreed upon in the National Skills Authority. This is also important in that it enables AGET partnerships.
The third area that we believe should be strengthened is that of the capacity that centres will require in order to enable them to keep records relating to numbers of students, pass rates, as well as a tracer that provides the NABAET with information about where learners go after completing their studies. While aspects of this is part of the quality assurance requirements, it extends beyond this. It is also worth including in that the adherence to these requirements has a range of capacity requirements.
COSATU is pleased that this Bill has now been released, and are heartened by the commitment demonstrated by the Ministry to the effective delivery of education and training to adults. We welcome this move and offer our full support in this process.
General and Further Education and Training Quality Assurance Bill, 2000
COSATU again welcomes the opportunity to comment on this Bill, and wish to state our appreciation for this opportunity. We believe that it is important that this Bill has been released as we are currently in the process of developing quality assurance systems across the economy and it is important that we begin to understand the full landscape. The need for delivery to learners is clear, and this provides us with an opportunity to meet these needs.
Relationship with SAQA
COSATU has a number of detailed comments, however we would like to begin with a broad area, and then will focus on some of the specific concerns. While the Bill mentions SAQA, it is difficult to understand the manner in which this Bill will articulate with SAQA requirements in terms of the need for all bodies to be accredited by SAQA as a quality assurance structure. This needs to be clearly dealt with so as to avoid the danger of seeming to avoid SAQA processes, thus the Bill must state the requirement that the Council apply to SAQA to be accredited as an ETQA.
Composition of the Council
While we appreciate the concern that the council should not become too large we believe that it would be appropriate for there to be two labour and two business representatives. This is critical in the light of the importance of this structure to industry and to workers in particular. It will be important that this sector’s voice is heard and that this facilitates a greater understanding of the quality assurance linkages and requirements of this sector.
Functions of the council
9 (1) (b): We would like greater clarity about the nature of the council requirements with regards to learner achievement. While we fully accept the need for the learner to be considered competent against the standards registered on the NQF, we are concerned about the possibility of additional requirements. This could undermine the objectives of the NQF and as such need careful consideration. For example, the possibility of entry requirements that are distinct from the learning assumptions spelled out in each of standards has the potential to undermine the rationale for the outcomes approach to standards.
9 (1) (c ): This is another issue that seems to be contrary to the SAQA process. While ETQAs may make recommendations to the NSBs and SAQA with regard to the requirements for a certificate it is the role of the NSB to propose these to SAQA for formal registration on the NQF. We are concerned that this appears to bypass the SAQA process as the council will be empowered to develop its own requirements for a certificate. If the ETQA is to play this role, then we need to understand how these requirements relate to the certificates that exist within these bands across the NQF. This is particularly a concern with regards to qualifications that will be quality assured by a SETA. Again this approach may pose a problem for realising the objectives of the NQF,
9 (1) (d) and (e): These clauses suggest there will be different requirements for the department of education as compared to the private providers. However the rationale for this is not clear. If this is to allow for the need for institutions in the public sector to be improved upon, and that this approach enables a more developmental approach, then this should be a phased out differentiation. Otherwise it is not clear why this is the case, and there is the danger that this will lessen the imperative for quality to be improved upon across the system.
9 (1) (h): We would recommend an additional function for the FETQA. That is the establishment of clear partnership arrangements with the SETAs and other relevant quality assurance bodies. There will be areas in which the council, together with SAQA, will need to take responsibility for ensuring that the quality is moderated across SETAS (for example the fundamentals). However, there will be other areas in which it will be important that the council utilises the quality assurance capacity of the SETAs to ensure that the standards and qualifications are credible. For example tourism.
9 (4): This clause is also viewed with some concern as the requirement of the NQF is that the completion of a level on the NQF, entitles the learner to access the next level on the NQF. This clause suggests the development of an additional barrier for entrance to a higher education institution. This appears to run contrary to the current move to broaden access and to ensure that those students that require support are able to receive adequate academic support. This also has the potential of undermining the value of the FETC and this would also pose a problem for the development of the system.
We once again thank the Ministry for the opportunity to comment on these Bills and we hope that we are provided with the opportunity to take these issues forward in future processes.
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