Response to: the AONTAS Community Education Network Document:
‘QQI Re-engagement for Community Education Legacy Providers - A
roadmap of scenarios for effective accredited community education
provision, Version 2 (2015)’
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Introduction
The first meeting of the QQI Community and Voluntary Sector Joint Working Group
was held on 3 March 2015. Following this meeting, as agreed, AONTAS, on behalf of the
Community Education Network (CEN) circulated the document ‘QQI Re-engagement for
Community Education Legacy Providers - A roadmap of scenarios for effective accredited
community education provision, Version 2 (2015)’ requesting a response from QQI. The
core issues and outline proposals raised in the document relate to the reengagement of
‘formerly registered FETAC community education providers, who want to continue to
provide accredited programmes under the National Framework of Qualifications (NFQ)’.
In particular, the AONTAS CEN seeks a response and clarity from QQI on the following
specific issues:




uncertainty regarding fees for re-engagement, this is highlighted as the main
concern for members
clarity with regards to concept of capacity within the QQI re-engagement process
the level of support for groups who wish to enter the reengagement process
effective alternatives for groups who cannot re-engage, the paper noted this as
essential for ‘groups’ continual ability to provide accredited programmes for their
learners.’
QQI Response to Issues raised within the AONTAS/CEN Paper:
QQI endeavours, in this response to address and provide clarity on the issues raised
by the Aontas CEN, in so far as it is within its own legislative remit.
All education and training providers that agreed Quality Assurance (QA), through
former FET awards council processes, self-selected a provider category to belong to. There
are currently 175 providers in that self-selected ‘community and voluntary’ category. There
would seem however to be some variation in this category of providers. A number of these
providers have significant commercial provision, compete with private providers, and/or are
owned by other organisations. In the current context, QQI has decided to examine this list
with the intention of identifying those providers which are correctly categorised as
‘community and voluntary’ and those which should be categorised differently.
It is proposed that the Joint QQI/Community and Voluntary Sector Working Group
(Joint Working Group) would assist QQI in devising criteria for the appropriate classification
of providers as ‘community and voluntary’ (see the draft terms of reference attached as
Appendix A).
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It is important to note, at this point, that formal agreement of quality assurance (QA)
between QQI and providers (reengagement), which identify being from within ‘community
and voluntary’ will not commence until 2016. This is the earliest that such reengagement
will take place.
Draft Quality Assurance (QA) Guidelines for Further Education and Training (FET)
providers will be tabled for consultation with the Joint Working Group at its meeting in April
2015. The date of the meeting is yet to be confirmed.
1. Concept of provider capacity within the QQI re-engagement process
The AONTAS CEN seeks clarity on the concept of ‘capacity’ within the QQI reengagement process, and proposes, that it should ‘not be associated with the ability to pay
fees’. QQI concurs with this.
QQI is required by legislation to protect and develop the National Framework of
Qualifications. QQI therefore has an obligation to all learners and stakeholders to assure
itself that providers of education and training, offering programmes leading to QQI awards,
satisfy a minimum set of requirements and criteria. These must be common to all QQI
providers.
In the context of the 2012 Act, the relationship which any provider has with QQI
differs from the previous relationship which it had with the legacy bodies. Providers are not
‘recognised providers’ or ‘registered providers’. The agreement of quality assurance with
QQI does not give or infer any distinct recognition on the provider. The relationship with
QQI is solely based on the provider offering validated programmes to learners; programmes
leading to QQI awards. Through reengagement, QQI will ensure that it has set a benchmark
for quality assurance that applies equally to all providers, either seeking to offer, or
currently offering, programmes leading to QQI awards. This will happen regardless of the
size of the provider, but appropriate to its context and profile.
Ownership, understanding and management of its quality system by the provider
(and its staff) therefore are crucial to the sustainability of the provider and the process of
continuous improvement. The provider must have adequate resources to support this, and
QQI must be assured of the provider’s capacity to offer quality assured education and
training programmes, consistent with QQI guidelines and requirements. The following, we
anticipate, should provide further detail and clarity on this.
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The concept of capacity requires the providers to show, amongst other things, that, they:
I.
II.
III.
IV.
V.
VI.
VII.
are an established legal entity, with education and training as a principal
function
have appropriate and up-to-date governance systems in operation
can evidence structural and internal quality assurance systems, to ensure
that sustainable provision of education and training programmes, that meet
the criteria as outlined in the QA guidelines, (e.g. demonstration of full
knowledge of providers legislative obligations, a credible system for internal
monitoring, evidence of the involvement of all stakeholders, demonstration
of the full ownership of the QA system), are in place
can design, develop, provide, monitor and review programmes
can assess learners, ensuring the achievement of learning outcomes
consistent with QQI requirements
can continuously self-evaluate towards service improvement
can engage with the formal external review process of QQI (as a provider
entity in its totality). This cyclical formal review is the agreed legal
requirement of all providers with QQI. Current legislation also requires that
the findings and outcomes of all of these reviews must be published.
Therefore to reiterate, the primary responsibility for quality assurance is with the
provider. The quality assurance system is context dependent and is not dependent on size
or on an ability to pay the related fee. QQI, as the external quality assurance and regulatory
body, in evaluating the provider ‘capacity’ to deliver quality education and training, must be
assured that the provider has sufficient resources to support the planning, implementation,
governance, sustainability and review of a robust quality assurance system.
Capacity is at all times linked to the nature and extent of the provision that each
provider is offering, or plans to offer.
Through the recently established Joint Working Group, QQI will strive to work
collaboratively with representatives of the sector to explore a quality assurance framework
and systems that address the specific areas necessary under current Irish legislation and as
set out in the above.
As previously mentioned, draft QA Guidelines for FET providers are currently being
developed by QQI. These Guidelines will establish criteria which all FET providers are
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required to meet. The guidelines will be consulted on, in the first instance, with the Joint
Working Group at a future meeting.
2. Fees for re-engagement
The document clearly outlines the AONTAS CEN position and concern with regards to
the QQI fee schedule; and proposes ‘a waiver should apply to independently managed
community education providers and no reengagement fee should apply’. Provision for this
within the 2012 Act is cited in the paper. The CEN is also of the view, as is outlined in the
document, that fees are being used as a filter [by QQI] for quality assurance and that fees
create an unnecessary barrier for community and voluntary groups.
QQI Response:
QQI published its policy on reengagement [agreement of QA by QQI] for voluntary,
further education and training providers in October 2014. At this point it is important to
note that fees have not yet been agreed for reengagement. QQI can state categorically that
fees are not and will not be used as a filter to determine which providers may engage with
QQI.
QQI is required under legislation to charge fees for a range of services which it
provides. These fees must receive the consent of the Department of Education and Skills
and the Department of Public Expenditure and Reform. To date the fees established have
the necessary Ministerial consent. The possibility of variations in fees for specific categories
of QQI providers can only be considered when there is clarity on a range of issues, including
certainty regarding the composition of the specific provider categories.
QQI is aware of the cost, not only fees, but overall fixed costs, to a provider of the
provision of quality assured education and training in both the public and private education
and training sectors. The fixed cost cannot however be avoided and is not related to the
level of activity or the size of a provider.
As outlined in section 1 above, the capacity of a provider to provide quality
education and training, consistent with QQI guidelines and criteria is core. QQI’s current
focus is on capacity of a provider to reengage, i.e. to enter into a quality relationship with
QQI and to demonstrate sustainability. Though highlighted as the central issue in the
AONTAS CEN document, QQI would suggest that the issue of fees is not the core issue to be
considered at this time, and should not form the focus of discussion and dialogue on
reengagement between QQI and the sector.
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The focus at this time should, in the opinion of QQI, be for each community and
voluntary provider to explore and consider the legacy, and some new requirements
[introduced by the 2012 Act], of quality assurance. They should also determine if their
organisational structure and processes continue to be relevant to these requirements, and
consistent with their mission. The primary responsibility for quality assurance lies with the
provider; quality assurance requires planning, resources and commitment. It needs to be
consistent with a provider’s mission. Provision of quality assured certified education and
training should therefore not be ancillary to other core activities.
QQI records show that there has been very little activity, in terms of programme
validation and certification, in some providers currently categorised within the community
and voluntary sector category. This raises issues and concerns for QQI in relation to ongoing
management, governance and evaluation of a quality system for these providers, and
indeed of the currency of the provider’s own knowledge of QQI policy and practice, in for
example, assessment.
3. Support for groups who wish to enter the reengagement process
The provision of direct support to providers to meet their legal and regulatory
requirements is contradictory to QQI’s role as a regulatory body. As the independent
regulator, it would be unfair and inequitable for QQI to support providers on which it is
required by legislation to conduct external evaluation and review. QQI is however
committed to working in collaboration with all stakeholders, and in particular, providers,
with a view to developing effective mechanisms for collaboration and communication
appropriate to different provider contexts.
QQI recognises the need to strengthen communications and information provision
on reengagement for community and voluntary providers. QQI aims to achieve this in
collaboration with the Joint Working Group, and to work with the Group, to develop and
implement an appropriate information and communications plan on reengagement for
community and voluntary providers; to ensure a broader more inclusive process of
collaboration and engagement, to help identify and address operational issues, as well as to
build a mutual trust-based relationship with the sector.
In particular, QQI welcomes the commitment from the CEN to establish networks at
national and regional level. Such initiatives are an essential element in building communities
of practice to share, develop and enhance QA in the context of the provision of quality
assured education and training.
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4. Alternatives for groups who choose not to re-engage
The CEN paper notes that ‘for community education legacy providers who decide to
opt out of re-engagement real, effective alternatives must be available so that groups can
provide accredited programmes for their learners’.
QQI is the national regulatory body for quality assurance and qualifications in the
further and higher education and training system, with all of the associated legal
requirements. QQI fully understands that a provider, in the context of its own mission, may
decide not to agree its quality assurance with QQI as specified in the 2012 Act
(reengagement). QQI’s requirements are however set out in the legislation.
Where a community education group decides not to pursue reengagement directly,
it will not be in a position to provide QQI accredited programmes. In that context QQI is
happy to explore, through the Joint Working Group, the scenarios proposed or other
options which may emerge.
Scenario 1
QQI has developed a process and associated documentation, which is currently
being refined, for the approval of quality assurance in training and education providers
(reengagement). This process will be tabled for discussion with the Joint Working Group at
is meeting in April. As outlined previously, formal agreement of quality assurance (QA) with
QQI (reengagement) and providers identified as community and voluntary, will not
commence until 2016 at the earliest. Draft QA Guidelines for FET providers are currently
being developed and will also be made available for consultation in April to the Joint
Working Group.
Scenario 2
There are a number of providers in the community and voluntary sector that have
existing relationships with the ETBs through former VEC processes. In some instances these
providers rely wholly and completely on the ETB for programmes, tutors, assessment and
authentication processes. The community education facilitators within the ETBs provide
significant and ongoing support and guidance for larger numbers of community education
providers to enable the provision of accredited education and training programmes.
QQI has recently completed a detailed consultation process on draft QA Guidelines
for the ETBs. A feasibility study, in direct consultation with the ETBs, was conducted by an
external advisory panel, to test the appropriateness of the draft guidelines.
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Within the draft guidelines and consultation dialogue with the ETBs, the complexities
of taking responsibility for other providers has been explored and highlighted. The feasibility
study report makes a number of recommendations for amendments to the current draft
guidelines.
In October 2014 a joint ETBI QQI Forum, with representation from the 16 ETBs and
QQI, was established to facilitate collaboration on a range of operational, developmental
and strategic issues. If the members of the Joint Working Group wish for us to do so, QQI is
happy to facilitate, through the ETBI QQI Forum, national discussion on this option with the
ETBs and the community and voluntary sector.
Scenario 3
As formal reengagement [agreement of QA with QQI] will not commence until 2016
at the earliest, QQI proposes that through the Joint Working Group, this coming year can be
used to explore models of reengagement and collaboration appropriate for community and
voluntary providers, including that of consortia.
As acknowledged in the Aontas CEN paper (Ref: P 7) the establishment of consortia
for the purposes of quality assurance is complex; and it doesn’t reduce quality assurance
requirements on providers, as outlined in section 1 above. Where there is a consortium of
providers, one provider must be the recognised legal entity. Formal engagement in quality
assurance requires a legal entity. One of the main advantages of consortia, however, is the
potential to achieve efficiencies and economies of scale and also to reduce duplication of
scarce resources. The requirements of the legislation remain in place; this topic and option
can be explored further with the joint working group.
Scenario 4
Many providers, both public and private, have relationships with multiple awarding
bodies. Awarding bodies are different and have different requirements. As the national
quality and qualifications body, QQI’s requirements are clearly set out in current Irish
legislation. QQI therefore acknowledges that there are alternatives for obtaining
certification; and this remains a matter for individual providers to decide upon. The Joint
Working Group may however be able to contribute to enable community and voluntary
providers to make such informed decisions.
QQI looks forward to working collaboratively with the community and voluntary
sector through the recently established QQI Joint Working Group.
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Appendix A
Joint QQI/Community & Voluntary Sector Working Group
DRAFT Terms of Reference
RATIONALE FOR THE WORKING GROUP:
QQI is committed to developing effective mechanisms for collaboration and communication
with its stakeholders and to ensuring that these mechanisms are appropriate and accessible.
The purpose of the Joint QQI/Community & Voluntary (C&V) Sector Working Group is to
enable a process of collaboration and engagement between the C&V sector and QQI.
TASKS OF THE WORKING GROUP:
Through this joint initiative, it is intended that QQI and the C&V sector will work together on
a range of operational, developmental and strategic matters in the specific context of
quality assurance and reengagement.
In particular the Joint Working Group will:
 Determine criteria for the identification of providers of education and training as
community and voluntary
 Contribute to the development of a shared understanding of quality assurance,
specifically in the context of the provision of certified education and training within a
community and voluntary context
 Provide clarity on QQI requirements for re-engagement with providers in the
community and voluntary sector
 Build on QQI’s existing communications strategy to develop a communications
approach specifically for the community and voluntary sector, particularly in the
context of re-engagement of voluntary providers with QQI
WORKING GROUP COMPOSITION:
The Working Group participants will be drawn from representatives of the current QQI’s
community and voluntary stakeholder group.
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WORKING GROUP METHODOLOGY:
The Working Group will be coordinated by QQI. The assistance of an independent external
facilitator has been secured. The facilitator’s primary role will be to maximize the impact of
the Working Group meetings.
From time to time sub-groups of the Joint Working Group may need to be established to
explore particular areas of interest relevant to the Working Group tasks.
In addition, other QQI or external stakeholder representatives may also be invited to
participate in Working Group meetings.
SCHEDULE OF MEETINGS:
The inaugural meeting of the QQI Working Group will be in held on 3 March 2015. At this
meeting a schedule of subsequent meetings will be agreed.
TIME FRAME OF THE WORKING GROUP:
Meetings of the Working Group will continue, as required, throughout 2015.
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Please note the terms of reference are in draft and have not yet been formally approved by the Joint Working
Group
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