Detailed roadmap for the eqf referencing of the nqf in fyrom


Opinion on the EQF Referencing Report presented by the former Yugoslav Republic of Macedonia (version of 08/01/2016)



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Opinion on the EQF Referencing Report presented by the former Yugoslav Republic of Macedonia (version of 08/01/2016)

Introduction

Education and training, relevant qualifications, and innovation are recognised in the various national strategies as drivers for growth, better employment outcomes and social inclusion. High unemployment (notably youth unemployment) and mismatches (between available qualifications and demand in the labour market) are among the important challenges that the country needs to continue addressing. Synergy between relevant institutions and policies will remain a fundamental factor of success. The National Qualifications Framework (NQF) is one such catalyst for better-articulated dialogue across the qualifications system.



The interactions between NQF implementation and EQF referencing

Different user groups view the NQF as a platform and motivator supporting a renewed approach to reforms of the qualifications system. The NQF brings: i) governance based on systematic cooperation between education and employment stakeholders; ii) harmonised approach across sub-sectors of education and training to develop, describe and manage qualifications; iii) recognised space for diverse forms of learning – including non-formal and informal - in the system and in peoples’ lives; iv) recognised centrality of the learning outcomes approach.

The NQF for LLL is young but is, gradually but with certainty, pacing forward. The NQF development process was long and intermediate achievements were at times in a state of lethargy - until end 2012. The reactivation of stakeholders’ consultation and dialogue in 2013 and the subsequent adoption of the legal basis for the NQF for LLL (in autumn 2013) were the turn of a new page. But many of most noticeable steps in making the NQF a reality can be associated with the start and acceleration of the EQF referencing process - in the period 2014-2015.

EQF referencing means:



  • Consensual recognition of the process as a new and important trigger for action as regards the provision of the NQF legal basis;

  • Renewed stakeholders consultation mechanism dealing with new themes, inspired by the key criteria of EQF referencing (2, 3, 4 and 5);

  • Systematization in 2014 of existing qualifications and programmes through the Inventory of all qualifications (all sub-sectors / formal and non-formal);

  • Start of revision of existing VET (level 4) qualifications by introducing learning outcomes defined through a transparent and participatory approach involving VET and labour market players (completed the pilot phase);

  • Start of application of concepts and agreed method for leveling of qualifications (VET), focusing on learning outcomes

  • Some synergy with other ongoing NQF support projects, notably those dealing with design of methodological basis for description of qualifications and inclusion in the NQF;

  • Launch of the NQF website, used initially as the database of documentation and information relevant for the EQF referencing report;

  • Update of parts of the Inventory of qualifications in 2015 and its publication on the NQF website as the first model of a unified qualifications database / information system open for the public.

The discussions and consultations, in wider and smaller groups, organized for the EQF referencing process contributed much to better understanding of the content and requirements of the NQF legal basis, the role and meaning of the level descriptors, the new interpretation given to “qualification”, the complementarities for LLL between qualifications of formal and of non-formal contexts.

Comments on critical aspects of the current definition of level descriptors were expressed, and the leading Ministry is aware of these issues. One of such issues concerns the definition of sub-levels: the official position is that sub-levels are indispensable for the time being, as means to ascertain stakeholders’ acceptance of the NQF structure. Sub-levels could be interpreted as a solution for a period of transition. This also means that reflection on the post-transition NQF structure and revised level descriptors needs to be foreseen in the roadmap for further implementation of the NQF.

The numerous discussions on the results of the Inventory of qualifications and on the analysis of a sample of qualifications shed light into the “mysteries” of level descriptors, by making comparisons with learning outcomes of real qualifications and discussing the novelties of the concept of leveling.

This systematization and analysis of qualifications (Inventory) shows the picture - with details, gaps and problems – and this practical information was used in addressing criteria 3 and 4 of EQF Referencing. Later on, in 2016-2017, the Inventory is likely to inspire policy makers and practitioners, to exploit deeper some of the materials and conclusions on critical features of qualifications – when the three large projects directed to education and training reforms (2 EU and 1 World Bank) will effectively start their operations.

While the first complete version of the EQF referencing report is the output of an intensive 20-months process, involving efforts and commitment from several institutions, it is also a beginning and from many points of view, a valuable practice.

Key features of the organisation of the referencing process

The European Training Foundation (ETF) provided advice, analysis, capacity building and support to networking and workshops throughout the process. The ETF team reviewed the various drafts of the report, by providing comments and suggestions.

The EQF referencing roadmap was defined and agreed with the stakeholders in a starting workshop (May 2014). In the meantime the multi-stakeholder working group was announced by the Ministry of Education and Science, so that a good degree of synchronization was rapidly in place between national leadership and participation from one side, and the expertise contribution from ETF – from the other.

The Ministry of Education and Science led the entire process and established a core group of four experienced staff members to draft the report. The core group eagerly interacted with the ETF team throughout the almost 2 years process, and actively participated in the many technical and capacity building meetings directly related to the report, as well as in other debates and workshops related with the Inventory of qualifications and the application of learning outcomes – also related with referencing.

From the start of the process, the Inventory of qualifications was part of the approach proposed by ETF. The output of the Inventory is gathered in a simple database, containing synthetic information from a large documentary base, on all currently existing programmes / qualifications in the formal education system, as well as verified adult education programmes. Although initially received with some skepticism by public bodies, it proved to be very valued by all stakeholders later on. Early discomfort was eventually overcome, via discussions in technical workshops, joint review of the findings and in particular, by finding a viable solution to the identified issues – the small pilot initiative to describe VET-4 qualifications in learning outcomes.

The report combines EQF referencing and self-certification (chapter 5 and 6). This unified approach had, from the start, full support by all stakeholders.

Meetings supporting interactions between stakeholders from higher education with those from secondary education (general and VET) turned out very useful, in particular in sharing knowledge and experience on the application of learning outcomes. Unlike other countries, the higher education domain has larger experience as regards the design of programmes / qualifications using learning outcomes, and legislation is enforced in this respect. Secondary VET has enacted in 2013 some new programmes and qualifications based on learning outcomes, but for now these represent only a minority of the awarded qualifications in VET.

One of the concerns discussed from the start regarded the need to improve the frequency of the country’s participation in meetings of the AG EQF. This aim was reached at the end of 2014. The international workshop in Skopje (October 2014), with participation of AG EQF members from Austria, Hungary, Montenegro), has contributed to this positive change.

The EQF referencing process faced problems, in particular: i) organizational and capacity; ii) effective involvement of some important stakeholders. The members of the core group did not enjoy specific time allocation to deal with the new tasks and themes: the group coordinated the partial drafts for chapters from the relevant agencies and national experts, organized meetings for reviews and in the last few weeks 2015 focused entirely on the finalization and fine-tuning of the report. In parallel, the effective involvement of some of the members of the officially nominated working group was very weak – in particular the Ministry of Labour and Social Policy, which hardly participated in the many workshops and technical meetings.

Qualifications in the NQF

The text of the NQF is inclusive – provides for insertion of qualifications from primary to higher education, academic and professional, and from non-formal and informal pathways.

The text of the NQF establishes two types of qualifications: i) education level type; ii) vocational type (could also be translated as “occupational” type, to avoid misunderstanding with secondary vocational qualifications). The discussions held during the referencing process with the core group with the aim to better understand the place of each type, and to identify real examples of “vocational type” qualifications showed that more discussion is necessary with stakeholders from the various sub-systems of education and training, notably with the adult education and non-formal learning sector.

At the time of writing the inclusion of qualifications in the NQF followed somewhat different paths / logic of allocation to levels. Summarising:



  1. By provision of the NQF Law: all qualifications from formal primary education; secondary arts and general education are automatically allocated to defined levels. (levels 1, 2, 4).

  2. By provision of the law on higher education and QF HE: (re)-accredited programmes / qualifications of the three cycles– allocated in the sub-levels / levels as defined in the legal basis. Note: accreditation requires description of programmes / qualifications in learning outcomes.

  3. Individual allocation: for qualifications from secondary vocational education (3 levels). Allocation is conditional for qualifications of VET-4 years of education, pending revision and definition in learning outcomes (at level 4). New qualifications (VET-3 years) are described in learning outcomes and can be included.

The inclusion of the new sub-sector (verified non-formal programmes for vocational qualifications – in levels 2 to 4) may require more time for decision. The verification procedure requires that programmes are based on occupational standards, follow a common structure, and are described in learning outcomes. By their features these programmes can fit the type “vocational” (or “occupational”), above-mentioned. This sub-sector knows a visible development since 2012: many new programmes have been developed by chambers and private providers – in response to market demand. The Employment Service Agency is one of the main users (customers) of these programmes – for training and retraining of unemployed / job seekers, funded by the Operational Programme for active labour market policies.

Table 39 is an attempt to summarise and link-up the response to three criteria – 3, 4 and 5. The structure of the table - by level and sub-level – attempts to show how this joined-up response influences decisions on the inclusion of qualifications in the NQF. This approach shows a number of open questions for further analysis and action (in the last column “Inclusion in the MQF”, notably at Level 4).



Key issues:

  • Levelling:

    • Methodological framework for leveling: the already existing handbooks need to be used in practice. This may require parallel work on revision of existing qualifications to make them transparent and comparable for leveling. Existing experience and the handbook for development of qualifications will be instrumental, but wider capacity and expertise will be indispensable.

    • Risks of bias in leveling decisions need to be addressed early, to avoid overly subjective decisions from sectoral qualifications committees and the tendency to request allocation to higher levels.

  • Stakeholders’ involvement:

    • Systematic involvement of the relevant institutions of the employment and labour market domain is currently weak. In the future a sustainable solution is needed, given their role in governance foreseen in the text of the NQF Law.

    • Trade Unions – in any format – are not represented in the working group, and were not invited to key meetings and debates. Presumably none of the trade unions is informed about the EQF referencing exercise.

  • Transparency – as regards Higher Education Accreditation and Evaluation Board. (HEAEB)

    • At the time of writing, despite several requests, it was not possible to have access to a dedicated information platform / website or space of the HEAEB, which is a most important institution for higher education quality assurance, and for the coherent compliance with Criteria 4 and 5. The Referencing Report does mention the status of autonomy of the Board’s work and the adopted roadmap to become a full member of ENQA (currently it is an affiliated member). It was not possible to visit / read information on accreditation decisions of the HEAEB.

EQF referencing report

For a pedagogical purpose, the initial outline of the report contained references to Cedefop’s analysis of challenges and issues in referencing, presented by EQF referencing criterion. This attention drawn to Cedefop’s analysis from the start was reinforced through examples and discussions in the many workshops organized throughout the process. In this respect particular emphasis was given to observed weaknesses in meeting criteria 2, 3, 4 and 5. The core group used the findings and examples of several EQF Notes in the referencing process.

The key strengths of this referencing report can be summarized as follows:


  • Attention to clarity and transparency: through use of examples and references to legislative texts, use of education data, formats of diplomas and certificates, examples of learning outcomes, examples of self-assessment reports (schools and higher education institutions).

  • Clear and coherent description of the education and training system (Chapter 2).

  • Detailed description of the process of development of the NQF, with special attention to stakeholders’ involvement in the various types of working groups.

  • Meeting the referencing criteria (Chapter 5): the report builds on the existing real situation, but in in some cases adds elements related to future actions (planned reforms, new institutional development and international projects).

  • Attention to Validation of non-formal and informal learning – in a specially dedicated Chapter

The description of the education and training system (Chapter 2), structured by sub-sectors, is valuable for the specific purposes of EQF Referencing, as well as for other aims, including as a baseline picture for the planned work on a new Lifelong Learning strategy. The information is organized in a format consistently used throughout each of the sub-sectors, making the chapter an easy-to-use reference. Reading the chapter is essential to understand the EQF referencing and self-certification chapters (5 and 6).

To the essential question whether the referencing report conveys a real and tangible state-of-play or rather a roadmap for future actions and intentions – often discussed in EQF referencing sessions – our opinion can be summarized as follows:



  • The report is based on existing and valid legislation, as well as on selected current practice as demonstrated by the examples – presented and listed in the various chapters, particularly in Chapter 2. The analysis in Chapters 5 and 6 (referencing and self-certification) refers to the relevant headings of Chapter 2.

  • The argumentation in Chapter 5 – the EQF referencing criteria – is based on a combination of references to texts of legislation, to results and information from the (independent) Inventory and analysis of qualifications, to practice and to outputs from stakeholder consultation meetings organized during the referencing process.

    • Under Criterion 3 the report honestly specifies weaknesses as regards the application of learning outcomes in part of the qualifications system.

    • Certain incoherencies as regards Criterion 4 are the result of the ongoing debates on the approach to take regarding those qualifications that are not described in learning outcomes (debates concern mainly VET-4). The novelty of the concept of “leveling” within a new paradigm of learning outcomes is in line with the text of the NQF law, but takes time to master in practice within such a short period of time by key stakeholders and decision makers.

    • Criterion 5 is addressed in much detail, referring consistently to input-process and output components of the quality assurance frameworks (primary and secondary education, higher education and adult education).

    • The report refers to the “Register” of qualifications – uploaded in the NQF website. While this register is a detailed and genuine database of qualifications – based on the Inventory above-mentioned – and is therefore excellent as reliable source of information, it could be questioned whether it can be considered a “Register” with a normative role. As it is, this database was originally conceived for systematization, analysis and research. Further development of the information contained in this database will be necessary to transform it into a Register. Further on the country can benefit of relevant grants (Erasmus+) for design of qualifications database.

  • The recent establishment of the NQF Board and election of its chairperson gives new viability to generalize coherent leveling procedures. This is the new door for the future life of the NQF.

The report contains only very sporadic references to links with labour market information and employment policies, which underestimates the importance of these domains as regards the qualifications system and framework. This weakness confirms the above-mentioned limited involvement in EQF referencing of the institutions in charge of employment and labour market policies.

Next steps of NQF implementation need to take account of labour market information, anticipatory studies on demand for skills and results from tracer studies of graduates. Such information is being organized through the new Skills Observatory, under the umbrella of Ministry of Education and Science, but not mentioned in the referencing report.



Eduarda Castel-Branco

08/01/2015

Prof. Dr. Mile Dzelalija - has been leading or participating as an expert in many international research and educational projects related to quality assurance in education, development and implementation of national qualifications frameworks, validation of non-formal and informal learning, recognition of foreign qualifications, joint study programmes, etc. Professor Dželalija has been responsible for the capacity buildings of national experts in various countries, development of methodological tools, theoretical base for NQFs implementation for various purposes, referencing and self-certifications to over-arching, and research analysis on impacts to the economy and society, and other relevant topics. He is a member or leader of different national and international bodies, EQF Advisory Group, ESCO Cross-sectoral Reference Group, management and advisory boards in Croatia and other countries.

Opinion on the MQF Referencing Report to the EQF and

Self-certification to the QF-EHEA
Prof. Mile Dželalija, PhD
The aim of the MQF referencing and self-certification report to the EQF and to the QF-EHEA is to verify the compatibility of the MQF with the EQF, and with the QF-EHEA. The report in many details presents the existing education and training system in the country and description of stakeholders’ involvement during the development of the MQF. Moreover, the report gives background of the fulfilment and response to the EQF referencing criteria (and to the QF-EHEA criteria and procedures) demonstrating that the MQF is compatible with the EQF, and to the QF-EHEA, with some needs for further development. It presents also challenges and next steps for further improvement of quality and relevance of qualifications system in the country, and deeper involvement of employers and other stakeholders more related to the labour market.

The report is a comprehensive document with many details on the existing educational system, its quality assurance mechanisms, roles and responsibilities of main actors. Various examples and additional relevant documents in annexes in the report or on the websites give additional value and better view on the qualifications system and arrangements of the quality assurance mechanisms.

The report clearly presents three development phases of the MQF:


  1. Preparatory phase, which includes the awareness and capacity building on the importance and relevance of development and implementation of NQFs.

  2. Developing phase, focusing to development of all concepts, tools, guidelines and legislative for the MQF.

  3. Implementation phase.

Relevant stakeholders have been involved in a different ways in the referencing and self-certification processes, including higher education institutions, quality assurance bodies, employers, students, ministries, chambers, education and training centres, etc. Some of them have been deeper involved and some less. Employers and other stakeholders more linked to labour market should be deeper involved in next phases of the development and implementation of the MQF.

Tables, illustrations and examples bring better understanding and, thus, the value of the report.

Glossary of main concepts, bring more transparency and understanding of the qualifications system in the country. Methodology and procedures for qualifications levels have been well described.

The eight levels and additional three sub-levels of the MQF cover the range of qualifications system in the country, from primary education to higher education. Each level is defined by level descriptors of learning outcomes, which are classified in three domains: knowledge and understanding, skills, and competence. Sub-levels, within the same level, have the same level descriptors for all domains, but have different requirements on credit value, representing the volume of qualifications. Thus, sublevels are related to the size of qualifications (number of credits). Sublevels are not related to the complexity of learning outcomes, which are usually in NQFs are presented by level descriptors.

Referencing process of the MQF to the EQF has been guided by the Core Group under the Ministry of Education and Science, with the aim to ensure fulfilment of referencing and self-certification criteria and procedures.

For the current time, the MQF is a reforming and communicative framework, giving a platform for better understanding interests of different stakeholders and facilitating implementation of learning outcomes, modernisation of quality assurance, validation of non-formal and informal learning, and other related concepts.

The report presents the aim of the MQF, which includes step-by-step process of creating a coherent and comprehensive system of classification of all qualifications, independently on the way of achievements (formal, non-formal and informal).

The Ministry of Education and Science is responsible for developing and implementing the MQF and for referencing and self-certificating it to the EQF and QF-EHEA.

The report includes seven main chapters (Description of the National qualifications system; Referencing and self-certification processes; National Qualifications Framework; Response to the EQF referencing criteria and to QF-EHEA self-certification criteria and procedures; Brief description of validation of non-formal and informal learning; and Challenges and next steps. In addition there are chapters on Glossary; Acronyms; References and Annexes).

The qualifications system has been described in details. The chapter is very well organised and structured. It includes description of:



  • Formal educational and training system: Preschool education, Primary education, Secondary education (Gymnasium, Vocational, Secondary art, Secondary for students with special education needs, etc.); Post-secondary education; Higher education;

  • Adult learning, and

  • Recognition of foreign qualifications.

All parts of the qualifications system are explained using the same structure of the text, giving information on:

  • Detailed general description;

  • Legal framework;

  • Strategies and other documents;

  • Governance;

  • Learning outcomes implementation;

  • Quality assurance mechanisms;

  • And very helpful summative table for each part of the qualifications system (Entry requirements; Education and training provision; Financing, Teachers qualifications; Expected learning outcomes; Assessment and awards; Progression routes; Labour market, and Quality assurance mechanisms).

As it is described in the report, formal education comprises of pre-school education (age between 0 and 6), primary education (3 times 3 years duration), secondary education (various programmes, gymnasium, vocational, art education, and education for students with special educational needs), post-secondary (specialized education and master exam), and higher education (with two profiles, and short and three cycles).

The report shows many details and characteristics of the education system – general and specific elements of subsystems, including descriptions of quality assurance, learning outcomes implementation and issues, teacher qualifications, etc.

Higher education is described as a system solely provided by autonomous institutions under public law, comprising of two profiles: academic and professional studies. Doctoral studies (qualifications at the eight level) are organised only as an academic strand at universities.

The quality assurance of higher education is conducted through the Higher Education Accreditation and Evaluation Board. The quality assurance body for quality assurance in higher education is an associate member of the ENQA, and the roadmap has been prepared for a full membership in ENQA and EQAR. To become a member of the EQAR, which is crucial for the implementation of the Bologna Process, there is a need for further preparation of the Higher Education Accreditation and Evaluation Board according to the ESG, including its full independent work.

Further, the report presents detailed phases during the design and implementation of the MQF. The consultation that has been undertaken in the process has been extensive, involving all key stakeholders and building ownership of the framework to ensure later better implementation. The work has been very extensive and detailed, from the decision, defining objectives and outcomes, organisation of the work, consultation with stakeholders up to the referencing and self-certification, and implementation. More intensive involvement of employers should happened within the next phases.

Last couple of years, the work on development and implementation of the MQF has been extensively presented in the country and internationally, making the process transparent to all stakeholders and partners.



Fulfilment of all EQF and QF-EHEA criteria and procedures has been presented in details:

  • Criterion 1, the main actors are the Ministry of Education and Science, with the Working Group consisted of representatives from: the Ministry of Education and Sports, the Ministry of Labour and Social Policy, Centre for Adult Learning, VET Centre, Bureau for Development of Education, Employment Service Agency, State Statistical Office, Ministry of Information Society and Public Administration, Chamber of Commerce, Organisation of Employers and Chamber of Crafts. The NQF Law applies as of 30 September 2015, and according to the Law, the Government has established the National Board for the MQF.

  • Criterion 2, the link between qualifications levels (and sub-levels) of the MQF and the level descriptors of the EQF and their comparison, from 1 to 8, have been transparently presented. Sub-levels are not defined by level descriptors, but only by requirements on number of credits. This means that sub-levels are more related to types of qualifications and less to the complexity of their learning outcomes.

  • Criterion 3, it is clear that the MQF is based on learning outcomes, which is a significant change in current education practice in the country (as it is similar in many countries in the EU). It means that the role of the MQF includes reform of qualifications system, with a focus to the implementation of learning outcomes and quality assurance mechanisms, based on common principles. The aim of the MQF is also to develop validation of non-formal and informal learning. ECTS credit system is used in the higher education system, and ECVET is planned. Additional national credit system for general education has been also envisaged. Some of the qualifications and sectors need further steps regarding the implementation of learning outcomes, which is envisaged within the next phase of the implementation of the MQF.

  • Criterion 4, the inclusion of qualifications in the MQF has been piloted extensively, and presented in the report in very details. Further steps have been prepared, including development of the common Register of qualifications.

  • Criterion 5, in the national qualifications system there are quality assurance systems for: primary and secondary education (general/ VET/ art) and for higher education. They are regulated by the national legislations. All sub-systems have internal and external parts of quality assurance. There are external quality assurance bodies: State Education Inspectorate, Bureau for Development of Education, VET Centre, and the Higher Education Accreditation and Evaluation Board. Within the next phases of the implementation of the MQF, the work of quality assurance bodies should be organised more according to common principles of the quality assurance, which is envisaged.

  • Criterion 6, the quality assurance bodies have been involved in the process, and agreed to the referencing process and report. Their statements are presented.

  • Criterion 7, international experts from different sectors and countries have been included – higher education and VET, developed and developing countries, advisory group member, and more and less familiar with the qualifications system.

  • Criterion 8, the report has been certified by relevant national bodies (the Ministry of Education and Science). It is stated that the report will be published on the official website: www.mrk.mk.

  • Criterion 9, the report has been submitted to the Advisory group and, as planned, will be presented in February 2015.

  • Criterion 10, it has stated that the classification of new qualifications will contain a clear reference to the MQF and EQF level.

Fulfilment of the QF-EHEA criteria and procedures has been also presented in a separate chapter.

There are several challenges presented, such as: further harmonisation of existing legislations with the NQF Law, further capacity building, introduction of ECVET system, strengthening the quality assurance system, development of the Register of qualifications and validation of non-formal and informal learning. All those are well presented and planned for next steps of the development and implementation of the MQF

As a concluding, the Referencing and self-certification report of the MQF is a comprehensive report. The report presents the existing education system in the country, including arrangements of quality assurance and learning outcomes implementation. Moreover, the report gives detailed and clear background of the fulfilment and response to the EQF and QF-EHEA criteria and procedures, demonstrating that the MQF is compatible with the EQF and QF-EHEA. As in some of other countries in the EU, further improvement of quality assurance system, according to common principles is planned, have been prepared and presented transparently in the report.

Prof. Dr. Mile Dželalija



(December 31, 2015)

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