Dr. Jim Murray:

On behalf of the Technological Higher Education Association and its members I would like to thank the Chair and committee members for the invitation to this meeting to discuss the Qualifications and Quality Assurance (Education and Training) (Amendment) Bill 2018. As indicated in its submissions of 5 October 2018 and 31 May 2019, THEA is supportive of the broad thrust of the legislation in two key respects. First, it holds out the prospect of strengthening the national quality assurance and qualifications systems in education and training by addressing a number of issues that have been identified as impeding QQI in fulfilling its intended statutory role. This is important to guaranteeing a quality experience for all learners across further education and training and higher education and training; clarifying and strengthening aspects of the operation of the National Framework of Qualifications; and ensuring that Ireland’s reputation as a favoured destination for international students is protected and enhanced.

Second, the Bill provides for the granting of award-making powers, excepting doctoral awards, to all of the institutes of technology.

In so doing, together with the recently enacted legislation on the establishment of technological universities, it will put all of the institutes on a more equal footing with the designated awarding bodies and create a more coherent quality assurance and qualifications space among all public higher education institutions.

On the strengthening of the national quality assurance and qualifications systems, they are largely provided for in section 23 of the Bill which amends section 55 of the principal Act by the insertion of nine new sections, sections 55A to 55I, inclusive. The new sections represent the most complex changes to the principal Act and set out the processes whereby awards acquire the status of being included in the national framework of qualifications, NFQ. Since THEA’s initial submission to the joint committee last October, a number of changes have been made to the nine new sections, one effect of which is that the public higher education institutions, whether they are designated as awarding bodies or providers to which QQI has awarded delegated authority, will not now undergo the same process for the inclusion of their awards as the new category of awarding bodies provided for in the Bill, the so-called listed awarding bodies. THEA welcomes this change, as it recognises and acknowledges the fact that the awards of the public higher education providers have been in the national framework of qualifications since its establishment in 2003-04. THEA also notes that the Bill provides for a new, formal procedure whereby designated awarding bodies will make more transparent how they determine the levels at which their awards are included in the national framework of qualifications and how this information is communicated to and ratified by QQI, the custodian of the framework. In principle, THEA does not object to the introduction of this transparency mechanism, but it argues that it should be integrated as far as possible into the existing quality assurance infrastructure overseen by QQI and that it should not lead to the introduction of a new and onerous bureaucratic process. In that regard, THEA is committed to working with QQI and our fellow public providers in order that the new statutory provision will be given appropriate effect in the implementation phase.

Apart from the changes mentioned, THEA notes the introduction of a new section, section 37, which provides the authorisation for an education provider to use the description "university". As predicted in our submission of 31 May, the provision has attracted some debate, given that the context is drawn precisely and that, overall, the provision appears to have been conceived within a defined focus. THEA notes that any such authorisation will be underpinned by a review process which will use the criteria employed to evaluate a technological university ahead of designation. In general, this is a sensible approach, although it is not clear to the technological higher education sector why the critical initial criterion required to be met by institutes of technology that seek technological university designation, namely, merger, is absent in this instance.

THEA makes these points as general observations and wishes the committee well in its deliberations on what is complex legislation. We also thank it for its continuing support for the growth of the technological higher education sector.