Ms Trish O'Brien:

I thank the Chairman. I also thank Mr. Vaughan for his kind comments about Quality and Qualifications Ireland, which are much appreciated.

Quality and Qualifications Ireland, which I will refer to as QQI, thanks the Joint Committee on Education and Social Protection for the invitation to appear before it. I also apologise on behalf of our chief executive of QQI, Dr. Padraig Walsh, who is chairing a board meeting of the European Association for Quality Assurance in Higher Education of which he is president. Dr. Walsh looks forward to attending the joint committee's meeting on 26 February when it will discuss community and vocational education.

Quality and Qualifications Ireland was established as a result of the amalgamation of the Further Education and Training Awards Council, FETAC, Higher Education and Training Awards Council, HETAC, National Qualifications Authority of Ireland, NQAI, and Irish Universities Quality Board, IUQB. It is a single national body responsible for the external quality assurance of further and higher education and training. It is also an awarding body. As an amalgamated body, QQI interacts with all parts of the education and training and qualification system. This includes the universities and institutes of technology, the newly established education and training boards, private providers that operate in the areas of further and higher education and training and English language training, and the community and voluntary sector.

While the scope of the new organisation's responsibilities is wide, it also presents significant opportunities. At the centre of how Quality and Qualifications Ireland approaches its work is the national framework of qualifications which emerged in 2003 and has become part of the education and training. While the framework is owned nationally, it is the responsibility of QQI to safeguard it. It intends doing so by ensuring it represents more than the association of a level with a qualification. As implementation of the framework continues, it must become a genuine symbol of the standard and quality of the qualification a learner has attained, regardless of where within our diverse education and training system it was achieved. The link, therefore, between qualifications and quality assurance is paramount. We must also ensure the ten level framework and the policies underpinning it keep the learner in focus and act as an enabler for individuals to pursue successfully the learning pathways of their choosing.

On the establishment of Quality and Qualifications Ireland in November 2012, the organisation proactively sought to meet education and training representative bodies. In the community and voluntary sector, it met Aontas and the Community Education Network, CEN. During these discussions and via the submissions received by the community sector as part of our consultation process on QQI's policy development programme, we had the opportunity to engage with the sector and understand further its concerns on a number of issues. These included the charging of fees by Quality and Qualifications Ireland, the range of State funding streams upon which the sector is largely dependent and the concerns on the part of some community providers of the association of this funding with the requirement for learning to lead to qualifications and thus to a relationship with QQI. While it would not be appropriate for Quality and Qualifications Ireland to express an opinion on the extent to which validation of programmes should remain a condition of public funding for the community sector, it is a discussion to which we would be very willing to contribute.

In addition to the challenges routinely faced by the community sector, in which training is often only one part of its service to the community, the shifting environment which all actors in education and training are facing is a further concern. The further education and training environment has seen the establishment of the education and training boards into which FÁS training centres are being moved and SOLAS has been established. The way in which all of this will impact on the community sector is unclear and will, I hope, become clearer in the further education and training strategy to be presented to the Minister for Education and Skills next month.

The establishment of Quality and Qualifications Ireland under the Qualifications and Quality Assurance (Education and Training) Act 2012 also constitutes change. The legislation identifies that any provider of education and training programmes must be able to demonstrate the capacity to quality assure its provision and validate a programme before it is recognised by QQI. Assured and consistent quality of education and training is, therefore, the objective that underpins QQI policy. All providers will need to satisfy QQI that their capacity and quality assurance arrangements are appropriate to their provision. Providers which made the transition to Quality and Qualifications Ireland from the organisations that amalgamated will thus need to have their quality assurance procedures approved by QQI. In accordance with the extensive consultation process to which the organisation has committed, a Green Paper was published on this subject in May 2013. A White Paper will be published for consultation shortly with the details of how we propose to undertake this re-engagement process. The continued effectiveness of providers' agreed quality assurance arrangements will be monitored and externally reviewed by QQI.

In carrying out these legislative responsibilities, the first priority of Quality and Qualifications Ireland is to provide reasonable assurances to prospective and current learners, members of the public, society, employers and international parties regarding the quality of any provider that has access to the privilege of State awards. In implementing this external role in the interests of public confidence, it would be neither feasible nor appropriate for QQI to provide support for individual providers to meet the quality assurance standard required. Having completed this quality assurance transition process, Quality and Qualifications Ireland hopes to invest more of its time and resources in working collaboratively with agencies such as SOLAS and the Higher Education Authority on continually improving quality and facilitating providers to come together to share good practice and expertise.

The charging of fees to providers is enabled by the 2012 Act and is integrally linked with how Quality and Qualifications Ireland intends implementing its quality assurance and quality improvement role. The development of adequate internal and external quality assurance systems incurs costs. QQI has adopted a fee schedule in part on the basis of the cost of engaging with a provider. Some of these costs are fixed, regardless of the scale of a provider's provision. For example, sending a reviewer to visit a provider's facility incurs travel costs. The current fee schedule has been developed for an initial number of agreed policies and will be extended as further policies are agreed through the comprehensive policy development programme. The fees to date have been approved by the board of Quality and Qualifications Ireland, with the consent of the Departments of Education and Skills and Public Expenditure and Reform. It is important to note that from a learner perspective, a certification fee was previously applied by FETAC. Where waivers of this fee were granted by FETAC, this practice has continued in Quality and Qualifications Ireland. This has resulted in a blanket exemption in learner certification fees at levels 1 to 3 of the national framework of qualifications as well as exemptions for holders of medical cards and certain provider centres, including Youthreach and vocational training opportunities scheme centres.

The fee with the greatest impact for providers to date is related to programme validation. To reduce costs, Quality and Qualifications Ireland is incentivising providers to make a number of applications for validation in one submission. In addition to reducing costs, this aims to encourage providers to think strategically about their programme requirements over a longer period.

In imposing fees on providers, the principles of consistency and equity must also be applied. Higher education providers were subject to fees by QQI's predecessor bodies. In addition, within further education and training, private providers are offering the same programmes as those offered by some providers in the community sector. These include qualifications in child care. In the light of this, it would be inappropriate for Quality and Qualifications Ireland to determine a fee schedule which would subsidise one part of the education and training system over another.

This is the first time that any fee has been levied at providers in the further education and training sector by Quality and Qualifications Ireland or its predecessor body, FETAC. In the context of the uncertainty the community sector is experiencing on a number of fronts, it is not surprising that it has reacted negatively to this development. By their nature, community sector providers often have relatively small numbers of learners. This is not a negative comment on the importance of the community sector to the individuals in question or the continued need for this provision. However, it raises questions regarding the multiple small providers with which Quality and Qualifications Ireland is interacting in the community sector and the proliferation of quality assurance systems that will be operating to support this provision. In 2012, approximately 150 providers categorised as "community and voluntary" sought certification for learners from Quality and Qualifications Ireland. This represents 20% of all the providers in the further education and training sector for which QQI made awards in that year. The number of learners for which certification was sought was approximately 5% of the number of certificates issued to learners across the further education and training sector.

With decreasing resources across the public sector, the 2012 ICTU report, Downsizing the Community Sector, makes an important reference to the sector working alongside public services in the face of the cumulative impact of cuts in spending. In this regard, Quality and Qualifications Ireland would welcome the opportunity to work centrally with the ICTU community sector committee, Aontas or any other community sector representative body to establish the feasibility of providers reconfiguring themselves into networks or consortiums which could introduce and sustain quality assurance systems at this level, instead of allocating resources to the development, implementation and review of a multiplicity of quality assurance systems at an individual provider level.

This would appear to be consistent with the view of Aontas, submitted to us as part of the consultation on our strategy statement, that collaborative linkages between providers and the sharing of good practice will be important. The establishment of networks of providers may also provide an effective means of boosting the quality assurance capacity of the community and voluntary sector, increasing the level of quality assurance oversight within and external to the sector, and potentially reducing the overall cost of programme validation. Such a reconfiguration would also require a discussion with SOLAS in the context of the statutory FET strategy and how it envisages the ongoing development of the community and voluntary sector.

QQI has undertaken in its strategy statement to carry out its regulatory and quality improvement functions collaboratively with providers and with Government agencies. With the level of change being experienced by providers in the community and voluntary sector, we suggest that it is in the absolute interest of learners that the relevant parties would come together to constructively consider the impact of these changes in as comprehensive a manner as possible.