Mr. Lewis Purser:

I thank the Chairman and members of the joint committee for inviting us to appear before it.

As per our previous correspondence, dated 4 June 2019, the Irish Universities Association welcomes the Bill insofar as it proposes to address issues that have impeded Quality and Qualifications Ireland, QQI, in fulfilling its intended role in the quality assurance of the further and higher education sectors. We particularly welcome the proposed provisions that will facilitate the introduction of the international education mark, the establishment of a learner protection fund and the establishment of procedures to prevent the provision or advertising of cheating services. These are all welcome in order to ensure the highest standards in Irish education and uphold our strong international reputation.

There are, however, a number of issues with the Bill which we have raised, section by section, in previous correspondence. For the purposes of this meeting, we will concentrate on the most serious of them which are contained in the amended section 55B(3) and (4) which will introduce additional and unwarranted layers of duplication and cost for QQI, the universities and other designated awarding bodies. The amendments mean that the universities and other designated awarding bodies will be required to notify QQI in writing of each of the awards made by them. QQI will then express its agreement or otherwise and notify the university in writing of each of the awards to be included within the national framework of qualifications. QQI will charge a fee to the university for including each of the awards within the framework. While on the surface the amendments appear to be eminently reasonable, to ensure there is a verifiable and reliable method for the placement of university awards in the national framework of qualifications, there is, in fact, already a process which ensures this and has operated successfully since the inception of the framework in 2003. It is managed through the statutory quality assurance process according to QQI’s statutory quality assurance guidelines and is explicitly referenced in QQI’s current and ongoing CINNTE external quality reviews of all universities and other designated awarding bodies through the European standards and guidelines for quality assurance in the European higher education area. The details of the explicit referencing can be found in the endnote to this opening statement, a copy of which members have before them. So far the QQI external quality reviews have not found any evidence of university awards not being correctly placed in the national framework of qualifications. Likewise, senior QQI staff, when explicitly asked by me and other representatives of designated awarding bodies, have not raised specific concerns about the current process for the inclusion of university awards within the national framework of qualifications. We have also agreed with QQI that, if such concerns were to be raised at some stage in the future, it would be a simple task to adjust the QQI terms of reference for the external quality review process and other more frequent QQI quality assurance processes to take any such possible future concern into account.

The universities and other designated awarding bodies pay an annual relationship fee to QQI to cover the cyclical external reviews of quality and other more regular services. In recent years the annual relationship fee has ranged between €450,000 and €616,000 for the designated awarding bodies alone. The fee covers all aspects related to the maintenance of the national framework of qualifications, including ongoing work to create a register of qualifications in the national framework of qualifications, on which the universities are actively working with QQI to ensure the register will be complete, up to date and fit for purpose. From the universities’ perspective, we have a system that has been designed and is overseen by QQI which functions well. No specific concerns have been raised, either by QQI or the external experts appointed by it to examine this issue as part of the reviews of universities. We also pay a substantial fee every year to cover the cost of the existing arrangements. What the Bill, as amended, is proposing is that an additional double layer of administration be added which will bring no added value to the current well functioning processes. It will, however, introduce an additional workload for both QQI and the universities which are all publicly funded bodies and for which QQI will charge an additional fee to the universities.

The introduction of this inefficient and additional cost is being proposed in the context of a looming crisis in third level funding. Members of the committee have publicly voiced their significant concerns about the underfunding of Irish universities. Immediate additional public investment is needed to ensure the quality of higher education to meet the demographic bulge - an additional 40,000 students, according to the Department of Education and Skills' latest figures - which the higher education system will be expected to absorb in the coming decade. We would prefer any such investment to be spent to address the needs of these future students, rather than pay for the introduction of inefficient and unnecessary processes which will bring no additional discernible benefits.

I note that tomorrow in Brussels the Irish ambassador to the European Union will host the launch of a significant report which looks at inefficiencies in European universities in recent years and in which the efforts of the Irish university system, universities and the HEA, together, are being highlighted as examples of best practice at EU level. What is surprising is that I am trying to convince the committee that in a system from which we have been stripping inefficiencies and unnecessary costs for the past ten years, we are planning to introduce an unnecessary, duplicate layer of quality validation, as proposed in section 55B(3) and (4), with the associated doubling of costs. We appeal to members to remove the associated doubling of costs and unnecessary inefficiencies that it is planned to introduce in the sector.