Composites

All participants emphasised duplication as one of the major problems with the current system of accreditation and quality assurance. The duplication of requirements leads to the commitment of large amounts of time, effort and resources in compilation of portfolios of evidence and compliance with the requirements of several regulatory bodies, thereby taking the focus off teaching and learning. This is particularly problematic for the small and survivalist providers. The survey asked whether accreditation and quality assurance had helped the provider to increase their pass or throughput rates. The answers by respondents were generally negative, implying that there were other reasons for this – these were not explored.

The developmental support envisaged by SAQA (2004: 7; Chapter 1, Section 1.5) in setting up the accreditation systems as mentioned in Chapter 1 has not been forthcoming, and a one- size-fits-all approach has been adopted. While some providers support this, the results on this specific question, namely “there should be different requirements for small providers” show that there is agreement with this statement by 58.2% of the survey respondents (Table 5.5). This supports the contention that “The cost of gaining accreditation may prove to be unaffordable for the majority of these providers” (SAQA, 2004: 7).

The use of different templates by the various accreditation/quality assurance bodies further exacerbated duplication of requirements (Umalusi, HEQC or the SETAs, Chapter 2, Section 2.8). In addition, there was inconsistent interpretation of the requirements by staff even within the same quality assurance body. This was sometimes accompanied by a dictatorial attitude by staff, many of whom are less experienced in the processes and procedures than the tuition providers they are quality assuring. High staff turnover seems to be prevalent within these bodies. This is borne out by the fact that few providers consistently knew who they were dealing with. Each time they needed information or had a query, they interfaced with someone different who then applied his or her own interpretation of policies or evaluation criteria. This meant starting from scratch because there were no proper handover mechanisms in place to ensure a smooth transition from one staff member to the next. Repeated submissions added to lengthy turnaround times. Provider comments included “the first submission they sent the docs back without evaluating them, and the second time they misplaced the docs”, “the process takes forever”, and “we have been struggling for two years now to offer some courses” leading to a situation where “compliance [is] unnecessarily time- consuming and more tedious than it ought to be / could be”. One provider stated that accreditation is a “horrendous process to follow” and that there is a “total lack of skill and accountability”.

Further problems were pointed out by members of the focus group who commented that information on the SETA websites was often out of date, that junior staff were tasked with providing information without really understanding much of what they were talking about, and were bound by red-tape. As a result, they were not able to solve problems as they could not answer queries that were outside of their stock frame of reference. One of the focus group members stated that the ETQA staff members “are ill-equipped (with their SA grade 12 against people with MBAs – not our local or garden variety but from Harvard, etc.).” There is an underlying sense of anger within the focus group about being dictated to by people with far less experience or expertise, both in terms of educational qualifications or running a business. On the other hand, the frustration is often with the system rather than the person for whom several members of the focus group had some sympathy. A comment by one of the CEOs concisely summed up this opinion: “There are so many hoops one has to jump through, too many registrations, recognitions, affiliations, etc. It has reached a point where organisations must consider whether they will possibly have a better quality system within their own control, than one that is accredited”.

Not only was there a duplication of requirements but an idealistic model had been devised which assumes that “you are perfect from day 1” (CEO interview). One focus group member stated that “the Umalusi template does not make provision for emerging providers and one has to allocate a negative mark for a criterion that is outside the control of the provider” leading to a situation where small providers are not able to become accredited because they fail to meet all the criteria. All samples in the study mentioned the frustrating “one-size-fits- all” approach, because it is almost impossible for small and survivalist organisations to be fully compliant “from day 1”. They therefore largely ignore the developmental approach recommended by SAQA (2004: 7) in the actual implementation of the quality assurance processes. This has also led to a situation where providers have become “compliance orientated” (CEO) or, as one of the focus group members put it, “if you can't tick the box you are out”. Another focus group member stated thus: “In the past I frequently argued against the application of these arbitrary rules and the 'tick the box' way of doing things. After so many 'don't you dare tell me how to do my job' replies, I decided it was easier and more profitable to learn these new rules and abide by them – at least that brings some bread to the table”. This latter statement confirms what was pointed out in Chapter 2, section 2.10.5. Constant changes in the regulatory system exacerbate the situation. This has led to a hiatus in the system causing out-of-date qualifications on the National Qualifications Framework (NQF). The ETQA Manager emphasised that since the establishment of the three quality councils in terms of the NQF Act, 2008, no new qualifications had been registered, and this

was “detrimental to learners” who are now “using outdated qualifications that should and could have been changed, but just weren’t, learning things that are no longer relevant to the workplace” (Chapter 3, Section 3.7). The ETQA manager went on to say that “instead of looking at what works, the regulatory authorities would rather reinvent and change the whole system so we are losing what is good”. At the same time, when these changes take place, there is often an exodus of knowledgeable staff and a consequent “lack of knowledge retention”, which essentially means that any new appointee has to start from scratch.

The establishment of the QCTO drew harsh criticism from the CEO of the professional body and the ETQA manager. The CEO called it an “unrealistic model” while the ETQA manager said that they are “hellbent on implementation of their specific strategy and have not considered whether that strategy is going to work for the majority of their stakeholders”. The fact that this quality council has been established without the necessary funding from the fiscus, coupled with inappropriate staffing has meant that the “way the changes have come about has not been very good” (ETQA manager). Thus, “the model that has been introduced does not take into account the realities of the situation” (CEO), has been implemented without effective structures in place and has left accreditation and quality assurance in a nebulous space where “it seems that nothing exists” (CEO). The goalposts have shifted since December 2012, with the Minister calling for a reevaluation of the QCTO mandate to quality assure qualifications above level 6 on the NQF (DHET, 2012e: 8). This has added further to the confusion, delaying the redesign of qualifications in terms of the QCTO model. According to one of the Quality Development Facilitators, “the ministerial edict of 14 December is hardly helpful. Nor can we get any direction from QCTO staff” (Van Zyl, 2013, email communication). As the ETQA manager said, “the more things change, the more things stay the same”, a saying meaning that “turbulent changes do not affect reality on a deeper level other than to cement the status quo” (WikiDictionary.org, 2013: n.p.).

The majority of private providers (76.9% as per Table 5.3) agreed with the statements that a private provider should need to be quality assured by only one quality assurance body, and 67% (Table 5.2) agreed that single accreditation should be sufficient unless there are complaints about the organisation. This would help to eliminate the duplication of requirements, the complaints about varied and inconsistent interpretation as indicated by 72.5% of the survey respondents (Table 5.3) and the “financial burden” (private provider) imposed particularly on small and survivalist providers.

Several comments were made in the open question on quality assurance, ranging from “it costs us a fortune in time and money”, “costs us many thousands every year” (one provider stated R1 million for the 2011/2012 year), and “my journey to accreditation was costly and

traumatic” to “costs should be reasonable” and “The Skills Levy should suffice for all […] accreditation costs”. Some providers and focus group members stated that a focus on the costs was a side issue but that “the envisaged cost structures of the QCTO” would probably prove to have a “negative impact” on the smaller provider.

In Chapter 3 (Section 3.6), the point was made that an education system must be both affordable and sustainable and that the cost/benefits of “bureaucracy, paperwork, time and additional costs of external and/or internal QA” (Latchem, 2011: 9) need to be assessed. Additional “huge” costs are incurred by having to use accredited assessors and moderators whose services often have to be outsourced. This adds to the cost of provision to learners. Thirty-five of the survey respondents indicated that learners were “self-funded”, often related to being poor or unemployed, although not in every case. The inevitable result of higher costs would mean that such learners may not be able to access education and training, would further exacerbate intimations of inequity (Chapter 3, Section 3.8), and would be counterproductive in the South African economy which is struggling to find sufficient skilled workers (Chapter 1, Section 1.2).

A possible alternative to a government-driven system is the ISO 9000 model, with 59.8% of the providers supporting the statement “as a private provider, we should be allowed to choose our own quality assurance model” (Table 5.5). There was some support for using this model although the majority of providers have only used the regulatory model.