‘It’s a different way of thinking about how we regulate’ – Ofqual’s Jeremy Benson Q&A on new RQF

The Regulated Qualifications Framework (RQF) was unveiled by Ofqual last week and was designed to be more descriptive and less prescriptive than its predecessor, the Qualifications and Credit Framework (QCF).

FE Week spoke to Jeremy Benson (pictured above), Ofqual executive director for vocational qualifications, to find out more about the new framework and what it means.

How would you explain the new approach to regulating vocational qualifications?
Awarding organisation accountability is at the heart of how we regulate. In other words, we hold the awarding organisations to account for the qualifications that they offer. Which means the awarding organisations, they need the skills and experience to design and award good, valid qualifications that the user needs, so it’s focusing very heavily on the responsibility and the capacity of the awarding organisations.

And the reason that’s important is – and one of the reasons why we have a problem with the QCF is because the QCF blurred that accountability. So it prescribed how things should be done. It set some very detailed design rules, everything must be unitised and so on.

But it also required awarding organisations to recognise units awarded by others which made it harder for us to hold them to account for those. So we’re moving to a position where we’re saying to the awarding organisations, right, you go and do good qualifications but you’ve got to be completely accountable for them.

Whereas in the past, with the QCF, they were very detailed, you must do things like this, but now effectively our approach is asking a simple question, which is, are these qualifications any good? And then asking the awarding organisations to show us how they know that they’re good.

That’s really what it boils down to. Obviously there’s a lot of detail on top of that. But it’s a different way of thinking about the way we regulate.

How confident can Ofqual be that the new conditions that you’ve created for the RQF do not become bureaucratic, and that the new framework will not become as restricting as the QCF was?
Of course, we will keep things under review. I’ve got someone in my team whose job it is to look at the burden of regulation and constantly to challenge us to make sure we’re not introducing unnecessary burden.

At the moment I’m pretty confident. The requirements we’re setting are outcome focused, they say what awarding organisations should do. They don’t prescribe in detail how they should try and do them.

What will the move to the RQF mean for a college principal or the managing director of an independent learning provider? How will it affect them, their staff and their organisation?
So in the short-term, it shouldn’t need to affect them very much, because we’re not requiring every qualification to change.

When the QCF was brought in every qualification had to change to meet those requirements. We’re not requiring every qualification to change because we know that there are many good qualifications out there.

So if people have got good qualifications that they’re working with, and they trust, there’s no reason from our point of view why that should change.

What will happen over time is two things.

Firstly, the way that qualifications are described and explained will become clearer. Our bookcase leaflet helps people to understand something about qualifications.

And then we’ve also got our register, which is a list of all the qualifications, which we’re making more user friendly, and more easily searchable. Part of the role of us as the qualifications regulator is to help people understand and choose qualifications, and to find out information about them, and gradually that will improve.

The other thing that will change over time is that qualification will potentially become more different.

So not every qualification will be unitised. Some of them will be developed and assessed in different ways. There will be more flexibility for awarding organisations to design qualifications to meet the particular needs of whatever it is they’re trying to do, particularly the employment sector. So some of the detailed design of the qualification will perhaps become a bit more flexible and will be more different.

Ofqual documentation on the shift to the RQF which, it says, is “like a bookcase in a library, with qualifications indexed by their ‘level’ and ‘size’”. Click on image to view document

But really I would encourage principals and other people in FE almost not to worry as much about the qualifications framework as they have in the past.

How should learners, parents, employers and providers understand the difference between these frameworks?
There will be some people who for some purposes will need to understand different aspects of how the qualifications are regulated, but really people should be focused on the qualifications themselves and what they’re trying to do.

They should be confident that because they’re regulated they will be good. It’s a bit like, I’m driving my car to work, I don’t understand the detail of how the car works, I just understand that I can drive it. It’s a similar thing really. Occasionally I’ll need to open up the bonnet, but really I try to avoid it as I don’t really understand it.

So the answer is that for most learners, parents and employers they shouldn’t need to understand that. They should be confident that it’s happening and it can give them assurance about the qualification.

Almost every qualification has QCF attached as a suffix – does that have to be removed?
From October 1, next week, all new qualifications shouldn’t have QCF in the title because QCF no longer means anything. For existing qualifications that have QCF in the title, we will expect that to have been removed by the end of 2017.

We’re giving the awarding organisations quite a long transition period to shift the current qualifications with the current titles and the current GLH and so on over to the new world where they will no longer be talking about the QCF.

Can you explain what total qualification time (TQT) is, and how is it different from guided learning hours?
Essentially, TQT is the time the awarding organisation would expect to be taken by a typical learner to study for the qualification. So some will take longer, some will take shorter. It’s a guide, really, for how big the qualification is.

Guided learning hours is the amount of time spent, whether it be in the classroom or in tutorial, actually being guided, actually being taught. Guided learning hours doesn’t include time for assessment, and it doesn’t include the time taken for individual study.

So you’ve got guided learning hours, and then TQT is guided learning hours plus the other bits – the assessment time and the self-study time.

Given that some people will take longer, and some people will take less time, why does it matter what TQT a qualification has? Isn’t it indicative, rather than a requirement on each learner?
It’s absolutely indicative, and there’s no requirement on any learner to take a certain amount of time.

But it’s useful for administrative purposes, for people who are funding qualifications or people who are planning curricula, or who are planning performance tables, or indeed for employers who want to have an idea of how long their employees are going to be out of work, to have an idea of whether this is a qualification that can be studied typically in 10 hours, or is it going to take 200 hours.

Qualifications that are used as part of apprenticeships and may have been developed jointly with other AOs and Sector Skills Councils (SSCs) — so who will do the Total Qualification Time (TQT) work? Will it be a lead AO or will the group have to reconvene?
This comes back to the first point I made, which is that every AO is accountable and responsible for its own qualifications. So regardless of how a qualification was developed – whether an AO was working with others or with SSCs – if an AO wants to award a qualification it has to be accountable for it, therefore it has to be accountable for the TQT and the Guided-Learning Hour values as well.

Awarding organisations have said that some of the issues with QCF implementation were heightened because of the impact of funding decisions requiring qualification to be on the QCF by a certain date. What work has been done to make sure that these external pressures do not cause issues again?
We’re actually just based down the road from the Skills Funding Agency (SFA), in Coventry. The decisions about how the funding system should work are for them, so we can’t answer for them.
What I can say is that we’ve been spending a lot of time with them talking to colleagues in the SFA to help them to understand what we do, and help them to think through the sorts of things they need to do, both operationally and then at a higher level to make sure they understand what we do, and make sure they think through what they need to as funder.

I think there’s still some more work for them to do, and there’s some more things that they need to consider once our changes have gone through in terms of what it means for the funding system and how they need to develop in order to achieve their objectives and the government’s objectives.

You’ve set criteria for determining whether a qualification is relevant for the purposes of the Education and Skills Act 2008 – do you have criteria for determining when learning becomes a qualification?
A qualification is effectively a certificate that’s awarded to someone because they’ve done an assessment which shows that they can do something, whether they’ve shown particular skills, knowledge or understanding. And that’s generally based on having done some learning up to that point. So the qualification recognises the learning.

Now you can perfectly well have lots of learning that doesn’t lead to a qualification. It’s not for us to decide whether a particular set of learning should lead to a qualification.

If an awarding organisation decides that there is a market for a particular qualification, if there’s a reason for a particular qualification, then they can put it forward in line with our requirements. A lot of this is driven by government in terms of what they would fund.

I think the sort of expectations that we have of a piece of learning that leads to a qualification is, will having that qualification help someone to progress further?

So if you have some learning that helps someone to rebuild their confidence if they’ve had a difficult time for some reason and that gets them to point where they can start moving into more formal learning, that probably doesn’t need to be a qualification. It doesn’t necessarily add any particular value in having a certificate.

On the other hand if you’ve got learning that leads to a very specific set of skills that helps someone to get a job, then often there will be real value in that being a qualification, because they can then go to an employer and prove they’ve got particular skills.

But as I say, providing that an awarding organisation can be reasonably confident that there’s a reason for a particular qualification and they can assess it well, it’s not for us to judge whether something should be a qualification.

And, slightly off the RQF/QCF topic, what place does Ofqual have in the new Trailblazer apprenticeship standards? If the implication of reform of apprenticeships is to put them in the hands of employers, does Ofqual have a role in this? What action are you intending to take?
We’ve been talking to the apprenticeships unit in government for many years about the apprenticeships reforms, and discussing with them the issues around assessment of apprenticeships, both the individual qualifications and the end-point assessments that will be taken at the end of the apprenticeships, and our advice has been pretty consistent.

The new apprenticeships need good valid assessment to underpin them, and that’s what we’ve said to government, it’s what we’ve said to Trailblazers. And interestingly, when we talk to employers, they agree as well that the assessments need to be good, they need to be valid.

Now there’s various different ways of achieving that and making sure the assessments are quality assured and well-designed.

We have said that we will be happy to regulate the end-point assessments as qualifications if that’s what the Trailblazers want us to do. There are other alternatives available and we are obviously going to be interested to see what decisions government makes over the next few weeks and months in terms of how the quality assurance regime for the new apprenticeships is going to work.

The Department for Business, Innovation and Skills has again asked the Education and Training Foundation (ETF) to review Functional Skills (FS). Do you welcome this?
Yes we do. We were delighted because we worked well with the ETF on the review that they published earlier this year.

So our role is to look at qualifications, and to make sure qualifications are valid and well-assessed. What we’re not responsible for is thinking about what should be assessed, what the curricula should be. So we really need someone else, some other organisation in the system, for any particular qualification to work out what the curriculum should be.

Although we owned the way that the current FS qualifications are described, we don’t own the curriculum decisions that feed into that.


Click here for an expert piece on the new RQF by Gemma Gathercole, OCR’s head of policy — FE and funding

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