Dr. Padraig Walsh:

QQI is grateful for the opportunity to provide a submission to the committee.

Publicly funded higher education institutions such as universities, technological universities and institutes of technology have the power to make their own awards. QQI has no role in the approval of individual programmes offered by these institutions. Private higher education institutions do not have their own awarding powers but many choose to come to QQI to have their programmes validated in order that their learners can receive QQI awards.

There are many professions where the admission of new entrants is legally controlled by professional and statutory regulatory bodies, PSRBs. These bodies admit entrants by approving programmes offered by higher education providers as satisfying the standards for admission to the profession. PSRBs generally oversee the register of practitioners and can conduct fitness to practise inquiries into the conduct and continuing competence of a registrant.

Public higher education providers and QQI validate professional higher education programmes and make awards. The awards they make to learners are permanent. Providers and QQI have no role in the initial or continuing registration of practitioners. PSRBs approve programmes offered by higher education providers for the purposes of admission to their respective professions on the basis of criteria or standards set by the PSRB. While some PSRBs make awards, they do not do so for initial admission to professions in health and social care. I hope it is clear that the process of admission to the professions being discussed today requires both an education awarding body and a PSRB.

When requested to validate a new higher education programme from a provider whose institutional quality assurance procedures it has already approved, QQI assembles an expert panel to meet with the programme design team.

In the case of a programme designed to prepare a learner for a regulated profession, the provider must declare that the programme complies with applicable statutory, regulatory and professional body requirements. The process is termed ex antevalidation. This is because the evaluaon must be completed prior to any students being admitted to the programme.

Following the successful validation of a programme, a higher educaon provider can submit the programme to the relevant PSRB for approval. In the case PSRBs such as the Nursing and Midwifery Board of Ireland, NMBI, or the Teaching Council, this can be done once the programme has been academically validated. That is because these bodies also operate a system of ex anteapproval.

In the case of PSRBs such as the Dental Council of Ireland or CORU, ex anteapproval is not currently employed. Instead, a programme has to be up and running and graduates have to have completed it before it can be approved. This is known as an ex postapproval process. The programme approval processes designed by CORU include a site visit to the relevant provider during which the visiting panel meets current students and graduates of the programme.

In the case of more recently regulated areas like social care, the use of a system of ex postprogramme approval carries the risk that a programme that is already up and running will not pass the subsequent PSRB approval process. This presents a potential barrier for new entrant providers in that students may be understandably unwilling to take the risk of commencing a programme whereby they have no guarantee of entry to the profession upon graduation.

In 2019, QQI began to facilitate the Finding Common Ground programme of engagement with PSRBs. Building on this, QQI has, in conjunction with the higher education institutions, HEIs, and PSRBs, developed a set of high-level accreditation principles aimed at improving quality assurance and eliminating the unnecessary administrative burden between professional and academic approval processes.

QQI validates some programmes offered by private providers in the areas of teacher education, nursing and social care. In the case of nursing and teaching, the QQI validation process precedes the submission of the programme to NMBI or the Teaching Council and QQI sets as a condion of validation that no students can be admitted to the programme prior to the programme receiving accreditation from the relevant PSRB.

To my understanding, there is no legislative barrier to CORU operating an ex anteprogramme approval process. However, CORU's ex postapproval process may be influenced by the current legislation appearing to only permit the binary possibility of approving or refusing to approve a programme, without a statutory power to impose follow-up conditions on the provider.

QQI and PSRBs such as NMBI and the Teaching Council have the power legislatively to refuse or approve a programme but, crucially, can also approve, subject to conditions, which must be fulfilled by the provider within a specified period.

With the imminent statutory regulation of programmes in counselling, psychotherapy and psychology it is imperave that awarding bodies work closely with PSRBs to ensure that the chances of newly validated higher education professional programmes gaining subsequent regulatory body approval are maximised. This may necessitate all regulatory bodies having some form of ex ante approval process for new programmes. It is also important that if legislation governing PSRBs needs to be updated to assist this process, then it should be progressed.