REGULATION OF PRIVATE COLLEGES IN SOUTH AFRICA BY MAMPHOKHU PETRONELLA KHULUVHE Research report submitted in partial fulfilment of the requirements for the degree Master’s of Education (MEd) ii DECLARATION I declare that this Research Report titled Regulation of Private Colleges in South Africa is my own original work. All the sources I have used throughout the report or referred to have been documented and recognized in the references section of this report. The report is being submitted for the Degree of Master of Education at the University of Witwatersrand, Johannesburg. This research report has not been submitted before for any other degree or examination in any other university. ___________________ _____________ MAMPHOKHU PETRONELLA KHULUVHE Date iii ACKNOWLEDGEMENTS Dear God, thank you for your wisdom, mercy and provision throughout this journey. You keep on doing great things in my life. I take this opportunity to thank my supervisor, Professor Stephanie Allais, for the critical and constructive comments she has provided until the very end. There is no quitting with Matseleng. To my partner Shavhani and my son Tshedza, you remain the greatest blessing in my life. Thank you so much for loving me enough and granting me time to work on this study, the time that we could have used to create great memories together. To my mother Mphiwa “Matloko”, you are my source of inspiration and I live to make you proud. I would also like to thank all the participants for their time and the way in which they participated in the individual interviews, and most importantly for being so kind and patience with me. Ke a leboga. iv TABLE OF CONTENTS DECLARATION .......................................................................................................................................... ii TABLE OF CONTENTS ............................................................................................................................. iv LIST OF FIGURES ....................................................................................................................................... v LIST OF TABLES......................................................................................................................................... v ACRONYMS ............................................................................................................................................. vi ABSTRACT ............................................................................................................................................. vii CHAPTER ONE: INTRODUCTION ............................................................................................................. 8 1.1 OVERVIEW OF THE SOCIO-ECONOMIC ENVIRONMENT IN WHICH PRIVATE COLLEGES OPERATE .................................................................................................................................... 8 1.2 PROBLEM STATEMENT ......................................................................................................... 12 1.3 RESEARCH QUESTION ........................................................................................................... 15 1.4 THE PURPOSE OF THE STUDY ............................................................................................... 16 1.5 CHAPTER OUTLINE ................................................................................................................ 16 CHAPTER TWO: LITERATURE REVIEW .................................................................................................. 17 2.1 QUALITY ASSURANCE LANDSCAPE IN SOUTH AFRICA ........................................................ 17 2.2 AUSTRALIA AS AN INTERNATIONAL EXAMPLE TO THE QUALITY ASSURANCE ARRANGEMENTS UNDERPINNING THE QUALIFICATIONS FRAMEWORK .............................. 26 2.3 THE SOUTHERN AFRICAN DEVELOPMENT COMMUNITY QUALIFICATIONS FRAMEWORK AND THE EUROPEAN QUALIFICATIONS FRAMEWORK AS REGIONAL EXAMPLES TO THE QUALITY ASSURANCE ARRANGEMENTS UNDERPINNING THE QUALIFICATIONS FRAMEWORK ........................................................................................................................... 30 2.4 GLOBALIZATION AND POST-SCHOOL EDUCATION INTERNATIONALLY .............................. 33 2.5 THE ROLE OF SUPRANATIONAL ORGANIZATIONS IN THE DEVELOPMENT OF EDUCATION POLICY ...................................................................................................................................... 34 2.6 THE IMPACT OF GLOBALIZATION ON PSET .......................................................................... 35 2.7 THE NATIONAL REGULATORY AND POLICY FRAMEWORKS IN THE CONTEXT OF GLOBALIZATION ............................................................................................................................... 37 2.8 POLICY COHERENCE .............................................................................................................. 38 2.9 MY FRAMEWORK FOR ANALYSIS ......................................................................................... 45 CHAPTER THREE: RESEARCH DESIGN AND METHODOLOGY ............................................................... 48 3.1 RESEARCH DESIGN AND METHODOLOGY............................................................................ 48 3.2 DATA COLLECTION INSTRUMENTS ...................................................................................... 48 3.2.1 Document analysis ....................................................................................................... 48 3.2.2 Individual interviews .................................................................................................... 50 3.3 SAMPLING ............................................................................................................................. 51 3.4 DATA ANALYSIS .................................................................................................................... 55 v 3.5 TRUSTWORTHINESS ............................................................................................................. 56 3.6 ETHICAL CONSIDERATIONS .................................................................................................. 57 3.7 LIMITATION OF THE STUDY .................................................................................................. 58 CHAPTER FOUR: FINDINGS FROM DOCUMENT ANALYSIS .................................................................. 60 4.1 HOW DO THE POST-APARTHEID POLICY FRAMEWORK PROVIDE FOR PRIVATE .................. COLLEGES? ............................................................................................................................ 60 4.2 HOW DID THE POLICIES OF PRIVATE COLLEGES EVOLVE FROM 1998 TO 2018? ................ 68 CHAPTER FIVE: FINDINGS FROM SEMI-STRUCTURED INTERVIEWS ......................................................... 71 5.1 HOW DO DIFFERENT ACTORS WITHIN THE PRIVATE COLLEGE SECTOR EXPERIENCE THE LEGISLATIVE FRAMEWORK GOVERNING PRIVATE COLLEGES?.............................................. 72 5.2 HOW DO DIFFERENT ACTORS WITHIN THE PRIVATE COLLEGE SECTOR UNDERSTAND QUALITY ASSURANCE AND ACCREDITATION? ....................................................................... 80 CHAPTER SIX: SUMMARY, ANALYSIS AND CONCLUSIONS ..................................................................... 101 6.1 SUMMARY AND ANALYSIS OF THE RESEARCH RESULTS ................................................... 102 6.2 CONCLUSIONS .................................................................................................................... 105 REFERENCES ........................................................................................................................................ 107 APPENDIX 1: INTERVIEW PROTOCOL AND SCHEDULE FOR PRIVATE COLLEGES .............................. 111 LIST OF FIGURES Figure 1: The Shape of the PSET System .............................................................................................. 10 Figure 2: Analytical Framework for Policy Coherence for Sustainable Development ....................... 41 Figure 3: The Framework Developed for Policy Coherence within the PSET System ........................ 45 LIST OF TABLES Table 1: South African NQF Sub-Frameworks and Qualifications Types ............................................ 20 Table 2: Correspondence between the South African NQF levels and AQF levels ............................ 29 Table 3: Interview Sample ................................................................................................................... 55 vi ACRONYMS APPETD Association of Private Providers of Education, Training and Development CET ACT Continuing Education and Training Act CHE Council on Higher Education CIPRO Companies and Intellectual Property Registration Office DBE Department of Basic Education DOE Department of Education DHET Department of Higher Education and Training DOL Department of Labour ETQA Education Training Quality Assurance FET Further Education and Training GFETQSF General and Further Education and Training Qualifications Sub-Framework GENFETQA General and Further Education and Training Quality Assurance Act HEI Higher Education Institution HEQF Higher Education Qualifications Framework HEQSF Higher Education Qualifications Sub-Framework NATED National Accredited Technical Education Diploma NCV National Certificate Vocational NDP National Development Plan NQF National Qualifications Framework NSC National Senior Certificate OQSF Occupational Qualifications Sub-Framework OECD Organisation for Economic Co-operation and Development PFMA Public Finance Management Act PSET Post-School Education and Training QCTO Quality Council for Trades and Occupations SETA Sector Education Training Authority SAQA South African Qualifications Authority SDGs Sustainable Development Goals TVET Technical and Vocational Education and Training vii ABSTRACT This empirical study focuses on the regulation of private colleges in South Africa. The study aims to answer the research question: What policies and legislation govern private colleges and how do actors within the private Post-School Education and Training System experience them? This study found that there is a lack of policy coherence within the education and training system within which private colleges operate. A key factor causing confusion, contradiction, and inefficiency is the existence of three quality councils with three different set of rules that, at times, contradict each other. This seems to be causing frustration for private colleges, even where they do, at times, value aspects of the quality assurance framework. I argue that the regulatory framework is punitive and counter-productive to the sustainability of the private college sector. The sector is not prioritized and there is insufficient attention paid to strengthening this sector which may create room for private colleges to self- regulate and operate without registration and accreditation in order to avoid dealing with the complexities of the regulatory framework. CHAPTER ONE: INTRODUCTION The focus of this thesis is on the private colleges offering technical and vocational qualifications. According to Umalusi (2008, p. 2), the private college sector in South Africa have not been subjected to thorough research. Baumgardt (2013, p. 1) elaborates, “state policy and the research underpinning policy have tended to focus on public provision as a priority”, and to some extent, on private higher education institutions. Therefore, the focus of this study is to examine the challenges and barriers presented by the policy and regulatory framework that govern the private college sector and explore how various actors operating in the private college environment perceive them. In this chapter, I introduce the study, explain the problem that the study aims to address, explain the purpose of the study and provide an overview of the research report as a whole. I start with a brief overview of the socio-economic environment in which private colleges operate and introduce the significant role played by private colleges as part of the post-school education and training system. 1.1 OVERVIEW OF THE SOCIO-ECONOMIC ENVIRONMENT IN WHICH PRIVATE COLLEGES OPERATE South Africa remains somewhat behind the global average in access to post-school education and training with only 13.9% of South Africans who are 20 years and older having some post- school education in 2017, while 43.6% had Grade 12, and 13.7% were regarded as functionally illiterate (Statistics South Africa, 2017). This presents the social backdrop against which the college sector has to determine its priorities. Figure 1 below shows that although access to Post-School Education and Training (PSET) institutions has increased significantly since the demise of apartheid, the demand for access remains unmet. Figure 1 shows that the PSET system has made significant progress in expanding access to post-school opportunities although provision has always been in the shape of an inverted pyramid since 2010, with higher numbers of enrolments in universities than at the intermediate levels. The inverted triangle shows that the PSET system is not producing sufficient intermediate skills. 9 The total number of student enrolment in public and private universities in 2017 was 1 222 030. This was due to enrolment increases in public universities from 892 936 in 2010 to more than 1 million in 2017, and private universities from 90 767 in 2010 to 185 046 in 2017. Private universities doubled their student enrolment and increased by 103.9% or 94 279 for the period under review. Between 2010 and 2017, headcount enrolments in colleges more than doubled from 405 275 in 2010 to 875 382 in 2017, with private college enrolment increasing from 46 882 in 2010 to 187 354 in 2017. It should be noted, however, that registration of private college institutions with the Department of Higher Education and Training (DHET) has been extended to include the registration of former private Adult Education and Training (AET) centers as private colleges. AET centers refers to all public and private centers initially registered to offer all learning and training programmes for adults on level 1 as registered on the national qualifications framework contemplated in the National Qualifications Framework Act, 2008 (Act No. 67 of 2008). In terms of the Continuing Education and Training Act, 2006 (Act No. 16 of 2006) (CET Act), Public AET centers have been renamed Community Education and Training (CET) colleges, while private AET centers have been renamed private colleges. Enrolments in CET colleges, however, experienced a decline from 297 491 enrolments in 2010 to 258 199 in 2017. 10 Figure 1: The Shape of the PSET System Source: Statistics SA: Quarterly Labour Force Survey Q1, 2017 and DHET: Statistics on Post-School Education and Training (Calculations by Author) Figure 1 above highlights two major weaknesses in the PSET system, namely, the small proportion of students enrolled at colleges providing technical and vocational education and training programmes to learners who completed at least Grade 9 at school level, against students attending universities and the number of youth who are not in employment, education and training. The post-2009 slowdown in the economy has brought allocation and efficiency issues to the center of budget debates in our country, which constrains significant expansion of the PSET system. 2010 University enrolment: 983 703 Public: 892 936 Private: 90 767 2010 College Elrolment: 405 275 Public: 358 393 Private: 46 882 2010 CET Enrolment: 297 491 2017 University enrolment: 1 222 030 Public: 1 036 984 Private: 185 046 2017 College Enrolment: 875 382 Public: 688 028 Private: 187 354 2017 CET Enrolment: 258 199 18 – 24 year olds NEETs 2 781 185 15 – 24 year olds NEETs 3 213 000 11 Currently, the public colleges are chronically under-funded in relation to current enrolment growth targets, and this has made it very difficult to meet policy goals as outlined in the National Development Plan (NDP) and the latest White Paper on PSET (Fees Commission, 2017). Although student enrolment in public colleges has more than doubled since 2010 as reflected in figure 1, the growth of the public college spending has not kept pace and there is a widening shortfall in available resources relative to those needed to attain targets of the White Paper (Department of Higher Education and Training, 2018b). There is a significant likelihood that enrolment targets for public colleges will have to be revised downwards. By implication, it will be beyond the capacity of the public colleges to meet the rapidly expanding demand for vocational education and training on its own, under the current government budget constraints. This creates a fertile ground for the growth in the number of private colleges. The expansion of private colleges could, if affordable to an adequate number of students, contribute towards meeting the demand for post-school education for the majority of students in the country. Currently, private PSET institutions which includes private universities and private colleges, comprise 16% of total PSET student enrolment in the country. More specifically, private colleges comprise 21% of total college student enrolment in South Africa. Every year, the DHET requests registered private colleges to provide disaggregated data for students and staff as an attempt to monitor the performance of this sector and to know its shape and size. This information is provided through the completion of an annual survey. In 2017, the total number of programme enrolment in private colleges was 187 354, which represent a 10.9% (18 443) increase compared with 2017 (168 911). The analysis also showed private college enrolment disaggregated by the following qualification categories: NC(V), report 191, occupational qualifications, AET levels 1-4, Grades 10-12 and Report 550/ NSC. In 2017, the results showed that the highest number of enrolment was for Report 191 followed by Report 550/NSC qualifications. Report 191 had the highest proportion of student enrolment in private colleges in 2017 (41.7% or 78 056), followed by Report 550/ NSC qualification (34.9% or 65 414) and occupational qualifications (21.7% or 40 577), while NC(V) had the lowest proportion (1.8% or 3 307). 12 A further disaggregation of enrolments was based specifically on the following occupational qualifications: agriculture and nature conservation; business, commerce and Management studies; communication studies and language; culture and arts; education, training and development; health sciences and social services; human and social studies; law, military science and security; manufacturing, engineering and technology; physical planning and construction; physical, mathematical, computer and life sciences; and services. Occupational qualifications enrolment accounted for 21.7% of total enrolments in private colleges as mentioned above. A breakdown of the occupational qualifications showed that in 2017, 42.3% or 17 150 enrolled in the fields of business, commerce and management studies while fewer students enrolled for Culture and Arts (0.6% or 259) and communication studies and language (0.7% or 270). This shows that the majority of students in private colleges enroll in the fields of business, commerce and management studies. It should be borne in mind that while the results of the survey provide some useful figures, they do not provide a reliable indication of the size of the system. Such an account would have to be based on sufficiently reliable, consistent, complete and verified data from all private colleges that are registered and have completed the survey as issued by the DHET. This indicates that more has to be done to understand the private college sector better. It is within this context that I chose to analyze the regulation and policies in relation to private colleges in South Africa. 1.2 PROBLEM STATEMENT As an official of the Department of Higher Education and Training, I am entrusted with the responsibility to monitor the performance of the post-school education and training, including the private colleges. In carrying out my responsibilities, I have noted two important weaknesses in the system that sparked my interest. Firstly, I noticed that the college sector has not developed on a clear path as the university sector has. The technical and vocational structure of the institutions has shifted over time. The colleges changed several times from the former technical colleges to FET colleges and now to TVET colleges all within 12 to 15 years. Until 1984, the colleges offered T and S courses which were then allocated to the newly established Technikons. In 1987, some colleges offered the NIC and NSC courses and the 13 Nated courses in engineering. Later on, all colleges started offering NIC and NSC for business and general studies. Additionally, the college sector has had a number of different governance models, for example, prior to 1994 they were a national competence under 17 different racially segregated and geo-politically separated departments. Post 1994, they became provincial competence as part of provincial education departments. In the 2014/15 financial year, they became a national competence again under DHET. In 2007, the NCV was launched but many colleges continued to offer Nated, NIC and NSC courses, and some offered the SETA qualifications as well. Currently, there is insufficient policy direction about which qualifications they should offer and the occupational qualifications are becoming important. Thus, unclear qualification types create an underdeveloped college sector. In addition, attempts to improve the image of this sector and to ensure that those emerging from colleges are provided with the skills they need to be productive, flexible, innovative and able to earn sustainable livelihoods in a fast-changing economy continue to this day. The sector continues to face major policy and governance changes under the democratic government. Secondly, I noted that we do not know enough about private provision. Government hopes that private provision can contribute to increasing access to post-school education and training and that the sector must be regulated to ensure comparable standard to public provision as indicated in the legislation (Department of Higher Education and Training, 2013). However, not enough is known about how the regulation is working and how it is being experienced within the private college sector. In South Africa, both public and private colleges have to adhere to the same rules and standards. These colleges often offer the same courses and follow the same curriculums, and the courses offered must be accredited and the qualifications must be in line with South African Qualifications Authority requirements. In 2002, the transformed college sector in South Africa was established in terms of the Further Education and Training Act, 1998 (Act No. 98 of 1998) (FET Act). The aim of the Act was, amongst other things, to rename and declare all colleges as Further Education and Training (FET) colleges, and to give effect to the merging of 152 former public technical colleges into 50 public FET colleges in pursuance of efficiency and improved access to intermediate level skilling opportunities (Department of Education, 1998b). The 1998 FET Act was later replaced 14 by the FET Colleges Act, 2006 (Act No. 16 of 2006), to transfer public FET colleges’ functions from the provincial competence to the national DHET. Subsequently, changes to policies and regulations have also resulted in name changes within and of the sector. The FET Act, No. 16 of 2006 is now referred to as the Continuing Education and Training Act, 2006 (Act No. 16 of 2006) (CET Act). In terms of the CET Act, public FET colleges have been renamed Technical and Vocational Education and Training (TVET) colleges while private FET colleges have been renamed private colleges (Department of Higher Education and Training, 2006). Whereas FET colleges included both public and private colleges previously, only public colleges are now TVET colleges and private colleges are simply referred to as private colleges. As similar as public TVET colleges and private colleges may be, there is always one defining difference between them. Public TVET colleges do not have to register with the government. They are deemed to be registered for a number of reasons. Firstly, the government funds them. Secondly, they are governed by the Public Finance Management Act, Act No.1 of 1999 (PFMA), an Act that provide for an institutional and regulatory framework for management of public funds, the strengthening of accountability, oversight, management and control of public funds in all public institutions (National Treasury, 1999). The public TVET colleges’ renaming is in line with the interventions aimed at providing public TVET colleges with an identity befitting their new form and mandate and in aligning them to international trends of technical and vocational education and training colleges. There is also an added advantage that South Africans will be able to identify public colleges easily, and thus making it easier to avoid illegal fly-by-night colleges that sometimes masquerade as public institutions. Private colleges, on the other hand, are independent of administrative issues that might arise from being funded or run by the government. They are funded by a group or individual and not by the government. Private colleges have to be registered with the government in line with the CET Act. The registration process serves as a framework to protect the public from illegal and irregular activities, and financial irregularities. The regulatory framework by virtue of registration is imposed on private colleges because they may be viewed as more risky than public colleges. They are regulated through the requirements of registration as a PFMA type 15 of framework for good governance and financial management, and to mainly ensure that their qualification offerings are comparable to the quality required of comparable public institutions. The regulatory context of private colleges in South Africa has hardly been subjected to research. Most of the research that has been conducted is mainly about private universities and not about the private college sector. There is a dearth of research to determine the impact and challenges of the regulatory context on private colleges, and how actors within the private college sector experience these regulations. The private college sector is quite dynamic and changes rapidly and there are continuous changes in the policy, regulation and the environment within which the private colleges operates. This requires continuous research into how the regulatory framework can better support, strengthen and expand the college sector and turn them into attractive institutions of choice. 1.3 RESEARCH QUESTION This empirical study examines the policies and regulation governing private colleges in South Africa. The role played by various actors in the development and reform of the policies and regulatory framework, as well as the key regulation requirements applicable to private colleges and the roles played by these colleges as stated in the regulation will be explored. The central research question posed in this study is what policies and legislation govern private colleges and how do actors within the private PSET system experience them? This question is explored in relation to the following sub-questions:  How do the broad policy frameworks of the post-apartheid government provide for private colleges?  How did legislation of private colleges evolve from 1998 to 2018? 
  How do different actors within the private college sector understand the legislative framework governing private colleges?  How do different actors within the private college sector understand quality assurance and accreditation? 
 16 1.4 THE PURPOSE OF THE STUDY The particular focus of the study is on the regulation of private colleges, previously known as private further education and training colleges. The study aims to critically examine the challenges and barriers of the policies, regulatory framework and practices governing the private colleges. Through a close examination of these policies and the regulatory framework, the study seeks to explore their impact. The study will also focus on the perceptions and experiences of various actors within the PSET regulatory context in South Africa. The research will identify challenges associated with existing policies and regulation, and try to understand how private colleges manage the regulation requirements in their respective institutions. 1.5 CHAPTER OUTLINE This thesis is divided into six chapters:  Chapter One introduces the study, describes its purpose and provides the socio- economic context within which private colleges operates.  Chapter Two provide a focused literature review of some of the key research literature that pertains to the regulation of private colleges, and present an interpretive summary of a set of conditions at international level that shape the terrain of education policy.  Chapter Three present an overview of the qualitative research design and methodology.  Chapter Four offers an analysis of the research findings emanating from the document analysis of the regulations underpinning the private colleges’ environment.  Chapter Five provides the results, analysis and discussion of the results from the semi- structured interviews.  Chapter Six provide a summary of the research results and conclusion. 17 CHAPTER TWO: LITERATURE REVIEW In this chapter I review some of the key research literature that pertains to the regulation of private colleges. I will start by discussing the quality assurance system in South Africa, as the main set of regulatory mechanisms for private colleges. I explain the complexity of the policy environment, and demonstrate that in places there are contradictions, overlapping jurisdictions and conflicting requirements. Referring to a major government evaluation, I also show that providers find it cumbersome. The emergence of quality assurance in South Africa is part of a global trend towards greater regulation of provision. In this chapter, I examined the comparability, similarity and differences between the South African NQF and the AQF as national qualifications frameworks, and I will also compare the South African NQF as a national qualifications framework to the SADCQF and EQF as regional qualifications frameworks to see if they allow for articulation between qualifications across countries and facilitate mobility of students and workers across countries. I will also discuss the global environment and argue that globalization has reshaped the terrain of education policy, and to a growth in private provision as well as a new set of regulatory arrangements for managing this private provision. The South African quality assurance can be understood in this context. 2.1 QUALITY ASSURANCE LANDSCAPE IN SOUTH AFRICA This section provides an overview of how quality assurance takes place in South Africa, explaining that the system is complex and somewhat contradictory, and secondly, the accreditation processes can be costly and time-consuming. In South Africa, the NQF is intended to create a standardized and seamless qualifications ladder across the entire formal education and vocational training landscape from entry-level qualifications to PhDs (Kraak, 2012). The South African NQF was established in 1996 to create a single integrated national framework for learning achievements, facilitate access to, mobility and progression within education, training and career paths, enhance the quality of education and training, and accelerate the redress of past unfair discrimination in education, training and employment opportunities (Department of Higher Education and Training, 2013). 18 The overarching vision stated in the objectives of the South African NQF is ultimately to contribute to the full personal development of each student and the social and economic development of the national at large. The South African NQF aimed to open access to the system for those previously excluded, to register qualifications on the NQF, to establish clear articulation routes for students from schooling into vocational and higher education and from TVET colleges into higher education, and to implement Recognition of Prior Learning (RPL) as one of the key redress and transformation mechanisms in the education and training system. The South African Qualifications Authority (SAQA) is the body with overall responsibility for the implementation of the NQF. The South African NQF is comprised of three sub-frameworks for the General and Further Education and Training, contemplated in the General and Further Education and Training Quality Assurance Act, 2001 (Act No. 58 of 2001); Trade and Occupations, contemplated in the Skills Development Act, 1998 (Act No. 99 of 1998); and Higher Education, contemplated in the Higher Education Act, 1997 (Act No. 101 of 1997). These sub-frameworks define the respective scope of the work for the three Quality Councils, namely, Umalusi, Quality Council for Trades and Occupations (QCTO) and Council of Higher Education (CHE) (South African Qualifications Authority, 2000). Each quality council is responsible for establishing policy governing the quality assurance of qualifications, provision, and learner achievement within its respective framework to promote the quality in respect to teaching and learning in both public and private PSET institutions (The Presidency, 2008, pp. 16–18). All three quality councils are required to collaborate with the SAQA and the other quality councils in order to develop, register and publish qualifications. The system on paper has not been perfectly implemented until now because there is as yet little integration across different types and sites of provision. It is still difficult for students to move between colleges and universities, between different universities, between schools and post-school institutions, and between educational provision and the world of work (Department of Higher Education and Training, 2012, p. 14). 19 The South African NQF is organised as a series of levels of learning achievement, arranged in ascending order from one to ten. All qualifications and part qualifications offered in South Africa are supposed to be registered on the NQF. Some qualifications are registered with subject curricula attached, some consist of unit standards, and others fit into a system of qualification types (Department of Higher Education and Training, 2012). In terms of the NQF Act, the CHE is the quality council assigned with the responsibility for the development and management of the Higher Education Qualifications Sub-Framework (HEQSF). This sub- framework covers qualifications registered at NQF levels 5 to 10 offered in private and public universities. Umalusi is the quality assurance body for level 1 to 4 of the NQF (Umalusi, 2014, p. 8). Umalusi is responsible for quality assuring vocational education offered at NC (V) level 2 to level 4 in both public and private colleges. Qualifications and part-qualifications for trades and occupation registered at NQF Levels 1 to 4 are developed and managed by the QCTO (Umalusi, 2014, p. 9). Thus, Umalusi quality assures learning programmes that are separate from learning associated directly with workplace education and training as well as from that offered in universities. Table 1 below presents the NQF in terms of its 10 levels. As reflected in Table 1, the college sector, including private colleges have an uneasy location, with some qualifications, namely, elementary, intermediate and national certificates at levels 2 and 3, 4, and some at level 5. So, they do not fit easily into the qualifications sub- frameworks. This means that private colleges straddle the line between different types of education. Private colleges offering level 5 qualifications will have to be quality assured by at least two quality councils. Whilst the NQF levels were designed to allow for articulation from different education and training sectors, allow each sector to develop its qualifications and respect differences between different sectors, this has not fully succeeded (Department of Higher Education and Training, 2018c). 20 Table 1: South African NQF Sub-Frameworks and Qualifications Types Source: Author’s own table adopted from SAQA: National Qualification Framework Notes: * Where there is and occupational qualification needed at levels 9 and 10, the developers should contact SAQA and quality councils to motivate. NQF Level General and Further Education and Training Qualifications Sub- Framework Higher Education Qualifications Sub- Framework Occupational Qualifications Sub-Framework NQF level 1 General Certificate Occupational Certificate NQF level 2 Elementary Certificate Occupational Certificate NQF level 3 Intermediate Certificate Occupational Certificate NQF level 4 National Certificate Occupational Certificate NQF level 5 Higher Certificate Occupational Certificate NQF level 6 Diploma Advanced certificate Occupational Certificate NQF level 7 Bachelor’s Degree Advanced Diploma Occupational Certificate NQF level 8 Bachelor Honours Degree Postgraduate Diploma Bachelor’s Degree Occupational Certificate NQF level 9 Master’s Degree Master’s Degree (Professional) * NQF level 10 Doctoral Degree Doctoral Degree (Professional) * 21 The system has created a proliferation of qualifications and unit standards, but there has been no corresponding proliferation of learning or of educational provision (Allais, 2012). Strong occupational qualifications which enable the training, assessment and certification of artisans are still in the process of being developed, and there is great confusion about the differences between apprenticeship, learnerships and Nated courses, some of which have been reintroduced after being phased out by the Department of Labour. In terms of the Skills Development Act (Act No. 97 of 1998), an apprenticeship is a learnership in respect of a listed trade, and includes a trade-test in respect of that trade; a learnership is a learning programme that leads to an occupational qualification or part qualification, and includes an apprenticeship and cadetship; and a Nated course is a nationally assessed and certificated occupationally-directed programmes aimed at students intending to pursue a technical/vocational learning pathway outside of the schooling system, and are offered from N1 to N6, with the latter culminating in the National N Diploma upon completion of the compulsory work place experience component. Some new learnerships and other new qualifications have gained credibility with employers, but often, unless a person was qualified under the old pre-1994 apprenticeship system, employers feel uncertain of the competence of a qualified artisan (Department of Higher Education and Training, 2012). All of this has put the QCTO, established to oversee the design, development and quality assurance of qualifications required for the practice of trades and occupations, in a difficult position as it had to either develop a completely new set of qualifications or work with the qualifications which had been developed through the standards generating bodies of SAQA. In the main, the system has struggled to find ways of developing appropriate qualifications, and the current models are expensive and complex (Department of Higher Education and Training, 2018a). In 2017, the Department of Planning, Monitoring and Evaluation (DPME) and the Department of Higher Education and Training (DHET) jointly commissioned DNA Economics, Mzabalazo and Social Surveys Africa to conduct an implementation evaluation of the National Qualifications (NQF) Act. The purpose of the evaluation was to provide an independent and objective examination of the implementation of the NQF Act relative to its goals and objectives, including its associated policies and regulations. The evaluation also aimed to 22 identify the successes and challenges in the implementation of the Act and offer recommendations regarding improvements to the implementation of Act in the future. As part of the evaluation, DNA Economic et al. (2017) conducted more than 100 semi-structured interviews and focus-group with policymakers, NQF bodies, education and training institutions, subject matter experts and other stakeholders. In addition, telephonic survey of 122 professional bodies and, education and training institutions including private colleges were conducted. The findings of this evaluation shows that the regulatory environment that was introduced with the best possible intentions – to protect learners from unscrupulous providers – has in some instances made it difficult for dedicated private providers to offer educational programmes (DNA Economics et al., 2017). At the same time, the system has not provided much information about educational quality. Some argue that the representation of occupational qualifications on the NQF is not user- friendly to the public, because occupational qualifications are distinguishable only by their NQF Levels, and not by terminology that the public can easily recognise (Department of Higher Education and Training, 2018c). Unlike Higher education qualifications, which have qualifications that have terms for each NQF level, such as a diploma, undergraduate degree, Master’s Degree and Doctoral Degree, occupational qualifications are all called certificates. While in principle occupational certificates can go up to level 10 on the NQF, many higher education qualifications, particularly at a post-graduate level, are occupational, directly preparing learners for work in specific occupations. This distinction is therefore confusing. Additionally, the literature shows that there is confusion and disagreement around the definitions and nomenclature in the system. The terms vocational, occupational, and technical are sometimes used interchangeably, and sometimes used to designate systemic differences (DNA Economics et al., 2017). There is also confusion with regards to the skills development providers and how they fit into the PSET landscape. These skills development providers come in various different forms ranging from parastatal organisations, operating within the auspices of national, provincial, and local government, to non-government organizations, private entities and private individuals. They are currently required to register with the DHET as private colleges, however, not all skills development providers will be able to register as private colleges and very few will be able to register as private universities as 23 there exists no comparable institutions that they can fit under (Department of Higher Education and Training, 2016). The latest White Paper highlights the complexity with respect to the manner in which accreditation functions are implemented within the PSET system (Department of Higher Education and Training, 2013). The NQF Act makes it obligatory for all PSET institutions to submit their programmes for accreditation. Accreditation is a form of regulation that ensures that a programme meets the minimum acceptable criteria. It is intended to safeguard learners from poor-quality qualifications and maintain the public credibility of post-school education and training (South African Qualifications Authority, 2000). This means that quality councils are mandated to accredit private colleges to provide learning programmes leading to the achievement of qualifications and standards registered on the NQF. The analysis from the evaluation conducted by DNA Economic et al. (2017) shows that the accreditation requirements are onerous with inconsistent and duplication application of the criteria. The report further found that accompanying this is a system of bureaucracy and a tick-the-box approach applied by quality councils when evaluating the private colleges’ accreditation applications and the ongoing monitoring of quality assurance. Additionally, the main points that came through the evaluation study conducted by DNA Economics et al. (2017) was the average time taken for students to receive their certificates which appears to be too long and the high cost associated with the accreditation processes were also highlighted as a challenge (DNA Economics et al., 2017) . The survey conducted as part of the evaluation of the National Qualifications (NQF) Act (DNA Economics et al., 2017) also provided responses on the average time taken for students to receive their certificates for different qualifications from both public TVET colleges and private colleges. The data shows that certification delays are particularly significant for the NC(V), with the vast majority suggesting that certification takes more than a year. Delays in certification has created significant challenges for students as it complicates their ability to enter subsequent qualification courses or employment (DNA Economics et al., 2017). Allegations of exam leakages were raised by a number of respondents within the N1-N3 qualifications in the college sector. 24 Soon after the establishment of the QCTO, a decision was taken to delegate the majority of its qualification development and quality assurance functions. SETAs traditionally fulfilled the role of Education and Training Quality Assurance organisations, and they continued to play that role with regards to the occupationally-directed programmes, sometimes referred to as historically registered or legacy qualifications, developed under the auspices of the SAQA Act (Baumgardt, 2013). With regards to trades and occupations, the majority of programmes currently being offered are still based on historically registered qualifications, referring to qualifications not registered as occupational certificates (DNA Economics et al., 2017). Findings from the interviews with skills development providers suggest a relatively positive view of the quality assurance systems being operated by the SETAs in their delegated role as Quality Assurance Partners. It appears that the QCTO at first did not see the quality assurance of legacy qualifications as its responsibility, so initially SETAs and professional bodies simply continued with these functions, though eventually these functions were formally delegated and through the creation of the delegated role of Quality Assurance Partners. These legacy qualifications will eventually expire or will be replaced by new occupational qualifications that are aligned to the Occupational Qualifications Sub-Framework. While the efficiency of quality assurance processes is still reported to vary widely between SETAs, results from the interviews conducted as part of the evaluation study by DNA Economics et al. suggest that the systems are generally well understood and reasonably effective in improving quality. The results of the study shows that the time taken to obtain accreditation from the QCTO or SETAs appears to be shorter than under Umalusi (DNA Economics et al., 2017). These results could suggest that the SETA quality assurance system has reached a certain level of maturity in terms of alignment. The evaluation study conducted by DNA Economics et al. also identified a number of challenges that cut across all the NQF bodies. The first concern is with regard to the lack of feedback from NQF bodies on the time taken to complete processes such as accreditation of programmes (DNA Economics et al., 2017). Secondly, the evidence available as contained in the policies, processes, criteria and guidelines published by the three quality councils, all point to the use of extensive checklists that require a lot of work by those being quality assured and a lot of evidence to be collected. Thirdly, the quality assurance model that is in place in all 25 three quality councils requires a lot of resources and puts a large proportion of available resources into quality assurance, and limited resources into rectifying poor performance and doing follow ups where a need has been clearly established. For example a well-resourced private college can find itself engaged for several weeks with Umalusi and/or QCTO searching for and making available data required for accreditation whereas a college that has 100% failure in various programmes attracts hardly any direct attention (DNA Economics et al., 2017). Therefore, the study concluded that private colleges view the processes more as compliance processes than targeted efforts to achieve improved quality. The NQF Act makes SAQA responsible for two regulatory functions, namely, the registration of qualifications and part qualifications. In South Africa, a registered qualification is one that has been quality-assured by a quality council and reviewed by SAQA to ensure that it meets the criteria for registration. In various countries, a key justification for structures like the NQF is that they are designed to establish equivalence as an aid to credit recognition and learner progression (South African Qualifications Authority, 2000). Placing individual qualifications on levels on a framework was part of an attempt to create and demonstrate equivalence between qualifications in different areas. However, this notion of equivalence is difficult to put into practice, and there is little evidence that the NQF has in fact facilitated judgements about equivalence (Allais, 2011). Literature shows that in some instances attempts to create equivalence between different qualifications have added complexity to the regulatory system, as well as leading to undesirable consequences (Department of Higher Education and Training, 2012). One such consequence is that it has discouraged horizontal progression. Learners feel that they are not progressing by learning a new skill or knowledge area, unless they are moving up the NQF ladder. Thus, the assertion that different types of education and training are equivalent may in some instances have misled learners into believing they are more qualified and competent than they actually are. For example, learners who complete an occupational qualification that is officially registered at level 4 on the NQF believe they have the equivalent of a National Senior Certificate (NSC), and in some cases have requested that they be awarded the NSC. 26 Research conducted for the development of the latest White Paper suggests that many one- year qualifications have been developed, as well as qualifications with exit points after each year, even when this is strongly counter to the training needs of a specific sectoral occupation (Department of Higher Education and Training, 2012). For example, most trainee artisans are generally unable to achieve any recognised level of competence in twelve months, and yet in many instances occupational qualifications have been developed at each of the lower levels of the NQF. Coupled with funding systems which were incentivised to give funding to greater numbers of learners, this has led to a situation where many learners have been obtaining qualifications that in fact do not qualify them to access particular jobs. In conclusion, the analysis above clearly indicates that colleges are subjected to a large number of policy initiatives that are not necessarily coordinated, and often do not provide sufficient information on resourcing requirements, roles and responsibilities, how policy success will be measured or the consequences of not achieving policy goals. It is therefore concluded that private colleges operate in a regulatory landscape that is multi-layered and complex, engendering a host of different approaches and quality assurance concerns. Quality assurance has grown in complexity in South Africa and there are many teething problems as discussed above. The recent introduction and growth of quality assurance is not just a South African phenomenon. In the next section I discuss the international approach to quality assurance and show that qualifications frameworks are becoming a reality globally and that institutions in the future will be facing a situation of multiple accreditation coming from various origins. 2.2 AUSTRALIA AS AN INTERNATIONAL EXAMPLE TO THE QUALITY ASSURANCE ARRANGEMENTS UNDERPINNING THE QUALIFICATIONS FRAMEWORK Qualifications frameworks are rapidly emerging around the world, and the development of NQFs has been a prominent feature of policy and structural developments within national education and training systems since the late 1980s. In 2014, there were more than 150 countries involved in the development and implementation of qualifications frameworks (European Union, 2016). Internationally, qualifications frameworks are an important feature of quality assurance because they allow for articulation between qualifications across 27 countries and facilitate mobility of students and workers across countries. The process through which countries have established NQFs, the manner in which they were introduced, and the extent to which they have been and continue to be regulated, have been as varied as the countries themselves (Allais, Raffe, Strathdee, Wheelahan, & Young, 2009). International comparability of qualifications is important in many countries, and is articulated through the objectives and policies of countries’ qualifications frameworks. According to DNA Economic et al. (2017), qualifications frameworks form part of a country or region’s overall quality assurance framework and can improve stakeholder confidence and trust in education systems. One of the objectives for putting in place qualifications frameworks is to facilitate recognition of qualifications to support mobility of learners and workers, both within and between countries (South African National Alignment Committee (NAC), 2018). The literature on the Australian NQFs is analysed briefly below to document the technical and conceptual characteristics of the Australian Qualifications Framework (AQF) in its operational contexts, and systematically identify key elements of comparability, similarities and differences to that of the South African NQF. The AQF is described as the national policy for regulated qualifications in the Australian education and training system, and encompasses higher education, vocational education and training, and schools (Allais et al., 2009). It was developed at the request of the Ministerial Council on Education, Employment, Training and Youth Affairs and was established via a Charter in 1994, although phased in over five years. An advisory board was established as the custodian of the AQF, on behalf of the ministers. The Charter was revised in 2000 and an AQF Advisory Council was established in 2008. The council had authority delegated to it by the relevant ministers, and is comprised of experts from the various relevant sectors (DNA Economics et al., 2017). In 2014, the Advisory Council was disbanded and the management of the AQF came under the national Department of Education and Training, in consultation with the Department of Industry and Science (European Union, 2016). Thus, the Australian Government Department of Education and Training is the responsible body for governance of the AQF, in conjunction with state and territory governments and the education sector, with a clear mandate to develop and maintain the AQF. This is different in the case of South Africa as SAQA is responsible for monitoring and maintaining the AQF. 28 The underlying principle for the comparability of the AQF and the South African NQF is that the processes and outcomes are transparent, relevant and enables the levels within each framework to be easily compared. Both the AQF and the South African NQF are the national policies for regulated and quality assured qualifications across all education and training sectors. They both have 10 levels as shown in Table 2 below and the levels on both the AQF and NQF are defined by descriptors in terms of learning outcomes. These learning outcomes broadly reflect what is acquired when a learner completes a qualification type that is situated on or referenced to the framework. To illustrate the correspondence between AQF levels and NQF levels, examples of qualifications are used as illustrated in table 2 below: 29 Table 2: Correspondence between the South African NQF levels and AQF levels Source: Author’s own table Level South African NQF AQF Senior Secondary Certificate of education 1  General Certificate  Occupational Certificate level 1 Certificate I 2  Elementary Certificate  Occupational Certificate level 2 Certificate II 3  Intermediate Certificate  Occupational Certificate level 3 Certificate III 4  National Senior Certificate  Occupational Certificate level 4 Certificate IV 5  Higher Certificate  Occupational Certificate level 5 Diploma 6  Diploma  Advanced certificate  Occupational Certificate level 6 Associate Degree Advanced Diploma 7  Bachelor’s Degree  Advanced Diploma  Occupational Certificate level 7 Bachelor Degree 8  Bachelor Honours Degree  Postgraduate Diploma  Bachelor’s Degree  Occupational Certificate level 8 Bachelor Honours Degree Graduate Certificate Graduate Diploma 9  Master’s Degree  Master’s Degree (Professional) Master’s Degree 10  Doctoral Degree  Doctoral Degree (Professional) Doctoral degree 30 There are conceptual and functional differences between the AQF and the NQF that need to be considered in determining the comparability of the levels of the two frameworks. Qualifications might include learning outcomes related to different levels. Different dimensions or categories of learning outcomes may be emphasised in qualifications placed at the same level. Therefore, qualifications allocated to the same level are not necessarily similar, but can be considered as comparable in terms of level of learning outcomes achieved. It does not mean that the qualifications are equivalent or interchangeable. The textual comparison revealed in table 2 above shows that there are many linguistic similarities between the South African NQF and the AQF in terms of level descriptors but also some differences. It was found that the levels of the South African NQF compared well to the levels of the AQF. There was a high level of correlation identified for South African NQF and the AQF levels 1-4 as well as levels 9 and 10. However, there were some circumstances where South African NQF levels were compared to more than one AQF level. For example, South African NQF level 8 was comparable to both AQF levels 7 and 8. 2.3 THE SOUTHERN AFRICAN DEVELOPMENT COMMUNITY QUALIFICATIONS FRAMEWORK AND THE EUROPEAN QUALIFICATIONS FRAMEWORK AS REGIONAL EXAMPLES TO THE QUALITY ASSURANCE ARRANGEMENTS UNDERPINNING THE QUALIFICATIONS FRAMEWORK On a regional level, free trade agreements, enhancing the mobility of learners and workers and support to global business have all provided the impetus for enhanced cross-border recognition of qualifications. Here regional qualifications frameworks are increasingly playing a role. Examples include the Southern African Development Community Qualifications Framework (SADCQF) and the European Qualifications Framework (EQF). These frameworks are developed as meta-frameworks that provide a neutral reference point for the relevant countries. The objective of this meta-frameworks is to create a common reference framework which should serve as a translation device between different qualifications systems and their levels, whether for general and higher education or for vocational education and training (South African National Alignment Committee (NAC), 2018). Both the SADCQF and the EQF calls on member states particularly to link their national qualification frameworks to the SADCQF and the EQF. 31 In 2011, the SADC Ministers responsible for education and training approved the Southern African Development Community Qualifications Framework (SADCQF). The SADCQF is a comprehensive Regional Qualifications Framework (RQF) for schooling, technical and vocational education and training, and higher education. Its purpose is to enable easier movement of learners and workers across the SADC region and internationally. It is a 10-level Regional Qualifications Framework underpinned by learning outcomes and quality assurance principles that will provide a regional benchmark for qualifications and quality assurance mechanisms in SADC. The vision is that, in the SADC region, all new qualification certificates, diplomas and other documents issued by competent authorities will show the relevant SADCQF level (South African National Alignment Committee (NAC), 2018). Alignment will enable recognition of achievement at a regional level. The resulting transparency and information about the qualifications and quality assurance of aligned Member States will further assist in embedding mutual trust among SADC Members. Regional alignment will also enable institutions and individuals to make comparisons of their learning and competence levels, and will reduce unnecessary duplication of learning and effort when moving through SADC for study or work purposes. According to the NAC (2018), The South African NQF levels are one level higher than the SADCQF for all the levels from Level 1 to Level 7, however, the degree of difference in cognitive challenge in the two frameworks narrows as the learner progresses from Level 1 to Level 7. This results in the SANQF Level 7 falling between SADCQF Level 7 and SADCQF Level 8. The European Qualifications Framework is one of the core European instruments for supporting mobility and lifelong learning and has been the main catalyst in the development of NQFs for lifelong learning in Europe. It has eight levels and does not contain qualifications. The eight EQF levels are described using learning outcomes in terms of knowledge, skills and competence. The EQF has been designed to act as a reference for different qualifications systems and frameworks in Europe. It takes into account the diversity of national systems and facilitates the translation and comparison of qualifications between countries. This regional framework enables qualifications systems with their implicit levels or/and national and sectoral qualifications frameworks in which qualifications are classified to relate to each 32 other. Qualifications are not directly allocated to EQF levels, as they are only linked to EQF levels via the referencing of national qualifications levels to the EQF levels. By acting as a translation device, the EQF aids in the understanding of qualifications allocated to national levels across the different countries and education systems in Europe (European Union, 2016). To date, 28 European countries have referenced their national qualifications levels to the EQF. These countries were Austria, Belgium, Bulgaria, Croatia, the Czech Republic, Denmark, Estonia, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Montenegro, the Netherlands, Norway, Poland, Portugal, Slovenia, Sweden, Switzerland and the United Kingdom (European Union, 2016). The comparison of the South African NQF to the EQF shows that there is a high level of correlation identified for levels 1-4, and South African NQF levels 9 and 10 also compared well to EQF levels 7 and 8. However, the EQF level 5 compares to both the South African NQF level 5 and 6, while the EQF level 6 compares to both South African NQF level 7 and 8. The development of NQFs in Europe reflects the Bologna process and the agreement to implement qualifications frameworks in the European higher education area (Harman, 1998). All countries involved in EQF implementation are participating in the Bologna process. The Bologna Process is a process of cooperation and reform in the field of higher education bringing together 48 countries (National Commission for Further and Higher Education, 2014). It established and seeks to consolidate the European Higher Education Area with comparable and compatible systems of higher education in order to facilitate mobility, increase employability, allow equitable student access and progression and strengthen Europe’s attractiveness and competiveness worldwide (European Union, 2016). This process encourages cooperation in higher education quality assurance, with a view to developing comparable criteria and methodologies. To conclude, this section examined the comparability, similarity and differences between the South African NQF and the AQF. In addition, I looked at the comparability, similarity and differences between the South African NQF as a national qualifications framework and the SADCQF and EQF as regional qualifications frameworks. Although there are differences 33 between the South African NQF to that of the other three qualifications frameworks analysed in this section, there is evidence of compelling similarities between the South African NQF to the AQF, SADCQF and EQF. This suggests that a comparison of the South African NQF to the AQF, SADCQF and EQF provides the grounds for improved mobility of learners and workers between South Africans and Australia, and improved articulation and mobility of South Africans across the SADC region and across the EU member states. 2.4 GLOBALIZATION AND POST-SCHOOL EDUCATION INTERNATIONALLY In this section I present the literature in relation to globalization and its impact on post-school education and training provision. I start by briefly defining globalization and then show that the demand for post-school education is growing, and private provision is a major component of that growth. Government are responding in different ways, and in many cases their regulations do not deal adequately with international markets. The term globalization can appear as a buzzword subject to different interpretations. Consulting the huge literature that has been written, it is hard to find a unified definition for it. Fischer (2003, p. 2) defines globalization as the ongoing process of greater interdependence among countries and their citizens. Similarly, Romer (2010, p. 3) emphasizes “Globalization is driven by the gains from reuse of ideas”. Romer (2010, p. 3) further argues that the flows of ideas are the part of globalization that matters for poverty reduction and catch-up growth. This point is illustrated further by Deaton (2004, pp. 83–84) who argues that the “health and life expectancy of the vast majority of mankind, whether they live in rich or poor countries, depends on ideas, techniques, and therapies developed elsewhere, so that it is the spread of knowledge that is the fundamental determinant of population health”. In this sense, education policies take center stage because of their impact on individuals and societies’ capacity to adapt to the changes and to take advantage of the opportunities brought about by globalization. 34 However, the forces and tensions understood by the umbrella concept of globalization constitute a dramatically different environment for PSET institutions and policy makers to operate in. The changes to which post-school education and training is increasingly exposed to all over the world are complex, varied, and contradictory at times. There are two key trends that define the social environment in which PSET system has to operate within the overall force of globalization. Firstly, the rise of the network society driven by technological innovation and the increasing strategic importance of information. Secondly, the growing mobility of people, capital and knowledge made possible by the new transport facilities and an increasingly integrated world community provoked by the will among the hopeless to escape poverty. Globalization also means that institutions and countries no longer can give their own answers to all these challenges, but that they also have become interdependent in their policy-making processes. The next section looks at the role played by international organizations in education policy development. 2.5 THE ROLE OF SUPRANATIONAL ORGANIZATIONS IN THE DEVELOPMENT OF EDUCATION POLICY Traditionally, policy has been produced within the authority of the country. However, over the last two decades globalization has witnessed some challenges to such country bound policy making in education (Rizvi & Lingard, 2010). Globalization has resulted in the strengthened influence in policy terms of international organizations such as the United Nations (UN), the World Bank, and Organization for Economic Co-operation and Development (OECD). The decisions of these institutions to varying degrees today shape and constrain the policy options for any particular country. Their role and mission vary between the different service sectors of countries. Regarding education, these organizations develops multilateral agreements and policies in education for the whole world, promoting educational discourses about human capital and economic development. Mundy (2005) states that there is a great need for multilateral institutions to help the world cope with the new global context. Dakopoulou (2009) points out that the policy goals of these organizations are achieved in two ways. The first one is powers of persuasion and the second one is conditionalities attached to loans. With regard to education, multilateral organizations have played a large role by offering educational programs and being the largest aid provider for reforming education in most 35 developing countries. For example, the World Bank has set its own desired policy goals and countries must implement its policies and programs so they can get financial assistance (Jones & Coleman, 2005). According to Bonal (2002), the conditionality associated with the aid of the World Bank has put it as one of the top subjects of globalizing education, by being in charge of formulating and delivering a hegemonic model of educational development. The discourse of globalization and the role played by supranational organizations underscored the growth of private education provision. During the 1990s the World Bank-led reforms of African TVET called for greater responsiveness to the market. Part of this was a growing encouragement of the opening up of a private provider market (Bennell et al., 1999). Thus private provision was considered to be much more efficient than its public counterpart. As opposed to the uncoordinated and inefficient supply of skills under state provision, the Bank’s view was that the governments in Africa that formally disallowed or discouraged private education before the 1990s should shift their position, especially those more in need of international donor funds. In Kenya, for instance, the higher education sector saw the rapid development of private provision and this move enabled them to draw on international sources of funding. In Zimbabwe, the further education and training sector saw a rapid expansion of private provision in the 1990s (Bennell et al., 1999). There has also been a considerable growth in flows of privately funded students out of Africa at both TVET and higher education and training levels (Akoojee, 2007). This latter phenomenon is being actively developed by OECD providers, who are increasingly under pressure to generate incomes to sustain themselves in context of reducing incomes from the national fiscus. 2.6 THE IMPACT OF GLOBALIZATION ON PSET The impact of the various trends and challenges related to globalization on PSET institutions and policies is profound, but also diverse, depending on the specific location in the global arena. Three trends that are of concern to this research are an increase in the demand for PSET internationally and the emerging borderless post-school education market. In the developed world, the knowledge society asks for more highly qualified knowledge workers. Economic development, modernization and demographic pressure fuel the demand for PSET. However, these are limited by the inability of the poor to finance the cost of PSET. Public 36 institutions or government do not have enough resources to deal with this massification of demand in many countries, leaving an unmet demand in the upper and middle classes of many countries. In other parts of the world, credentialism is still on the rise, sometimes leading to a kind of paper chase, fueled by the expectation that degrees and diplomas are the gateway to economic prosperity and social security by promising a job in the public sector (Van Damme, 2001a). New communication technologies and the Internet provide new opportunities for a more flexible delivery of PSET, thereby creating a new demand in some countries and meeting demand in others where traditional institutions are incapable to do so (CVCP/HEFCE, 2000). All together, these developments underpin the prediction that PSET will become one of the booming markets in the years to come. This expansion and massification will not be matched by a proportional rise in public expenditure, leading to an increase in private and commercial provision. An additional visible element of globalization is the emerging borderless post-school education and training market. The huge increase in the worldwide demand in post-school education, the budgetary and capacity problems of many countries to meet this demand, and the opportunities created by new communication technologies shape an environment in which private education providers, mostly for-profit providers successfully can expand post- school education provision. Most PSET institutions from North America, Europe and Australia take initiatives to reach out their post-school education provision to this international PSET market, by active recruitment of international, fee-paying students to the home institution, by establishing branch campuses or franchising and twinning agreements with local institutions or via distance education and e-learning and other transnational activities (CVCP/HEFCE, 2000). The international demand for post-school education and training has also invited new providers from outside the PSET system to enter the scene. The business of borderless education comprises various forms and developments, among which also combinations are possible, such as new for-profit private colleges, government colleges, media companies delivering educational programmes, professional associations becoming directly active in 37 post-school education, and companies with high training needs establishing their own training facilities (CVCP/HEFCE, 2000). Many of these new providers extensively use the internet as delivery channel. In some cases they develop into real cyber PSET institutions with a very limited physical presence. In some niches, such as information technology and business administration studies, their substantial growth poses a direct threat to the market position of existing public PSET institutions (Vlasceanu & Wilson, 2000). Their presence is substantial due to insufficient public supply and the growth of demand in middle classes willing to pay for post-school education and training. Van Damme (2001b) has argued that “although there are also less reputable private PSET institutions, to some extent, their development even enriches the PSET system, awakes innovation also in public PSET institutions and challenges productively the academic tradition”. Thus, important issues of access and equity on the one hand and quality on the other are raised by the global rise of private PSET institutions. 2.7 THE NATIONAL REGULATORY AND POLICY FRAMEWORKS IN THE CONTEXT OF GLOBALIZATION Globalization affects the national regulatory and policy frameworks in which private colleges are embedded. Most modern PSET institutions are product of national developments and policies, and are fully integrated in national education systems. In an increasingly international environment, marked by a globalized and liberalized marketplace, globalizing professions, mobility of skilled labour, and international competition between PSET institutions, and between PSET institutions and other institutions and companies, the national character of policy frameworks creates more and more tensions (Van Damme, 2001b). Institutions already acknowledge this and are developing partnerships, consortia and networks to strengthen their position in the global arena. Mobility programmes, such as Erasmus and schemes such as the European credit transfer system have tried to stimulate internationalization in post-school education and training with full respect to the various national policy frameworks (Vlasceanu & Wilson, 2000). Thus, globalization in PSET education does not necessarily imply international standardization and uniformity, but asks for policies balancing the global and the local. Countries have responded in different ways. In countries like Greece and Israel, there is an almost total refusal to include private providers in the national PSET system or to recognise 38 their diplomas and degrees. On the contrary, countries like Malaysia recognise the incapacity to meet the increasing demand by their public providers and welcome private providers (Van Damme, 2001a). The distinction between public and private, which has been perceived as essential in PSET policy for such a long time, becomes very blurred in the age of globalisation (Duczmal, 2006). According to Pachuashvili (2009, p. 27), funding, governance, ownership and mission are the four differentiating dimensions used to distinguish public and private PSET institutions. Public PSET institutions are established, funded and managed by the government while private PSET institutions receive no subsidies or grants from government “even though low-cost providers address the needs of the poor who cannot access public universities”(Fees Commission, 2017, p. 102). According to Shankar (2016, pg. 1) the private PSET system is characterized by a profit- motive, and private colleges and universities often step in “when the government has limited resources to provide universal access to education”. Most private PSET institutions are self- funded, relying heavily on tuition and fees. Therefore, they often need to deal with trade-offs between providing good instructional quality and ensuring return on investment. This consequence has triggered governments’ concern about the quality and efficiency of private PSET institutions in many developing countries and resulted in tightening the regulations governing the private PSET institutions (Asian Development Bank, 2012, p. 1). Above I have demonstrated the rising importance of quality assurance systems and regulatory frameworks for education and training, at least in part driven by rising private provision. This has led—as is particularly clear in the South African case—to a complex policy environment. I therefore briefly considered literature on policy coherence in the next section. 2.8 POLICY COHERENCE The global context has changed since the year 2015 when the 2030 Agenda for Sustainable Development including its Sustainable Development Goals (SDGs) and 169 associated targets were adopted by the world leaders at a historic United Nations Summit. The 17 SDGs and 169 associated targets, which form the core of the 2030 Agenda, are an indivisible set of global priorities that incorporate economic, social and environmental aspects, and recognize their 39 inter-linkages in achieving sustainable development (OECD, 2016). The Sustainable Development Goal 17 which seeks to strengthen the means of implementation and revitalize the global partnership for sustainable development includes institutional and policy coherence as an integral part of the means of implementation. It also includes a cross-cutting target 17.4 that aims to enhance policy coherence for sustainable development which apply to the whole SDG framework. In achieving this target, the OECD asserts that governments will have to ensure that their policies in all public domains are consistent with, and do not undermine the achievement of sustainable development goals (OECD, 2016). In the previous section on globalization, the literature showed that the world is facing unprecedented and inter-related challenges with implications for all countries. These include new population dynamics, modernization, growing inequalities, climate change, and unsustainable production and consumption patterns. Technological advancement, amongst others, make the global economy to be increasingly interconnected, meaning that global shocks can reverberate quickly, and externalities such as macroeconomic instability, social and economic inequality, and conflicts can have wide-ranging spillover effects (OECD, 2016). These complex challenges as well as the emergence of new actors are changing the landscape in which countries operate. They are bringing to light new dimensions that call for more integrated approaches to policy making breaking out of policy silos, strengthened coordination mechanisms, and long-term perspective to cope with them. The OECD (2016) argues that the multi-sectoral and cross-cutting nature of sustainable development as well as the need to achieve a better balance between its diverse dimensions calls for policy coherence and integration. In 2016, the OECD published the report titled Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence. The report introduces the framework for policy coherence for sustainable development, and suggests options for monitoring and tracking progress for SDG Target 17.14. The purpose of the framework for policy coherence for Sustainable Development is to support governments and various actors in their efforts to design, promote, implement and assess coherent and mutually supporting policies to contribute to sustainable development. It aims therefore to help adapt and strengthen current policy coherence efforts to support the implementation of the SDGs. It is also 40 intended to facilitate constructive dialogue between policy-makers and key actors – from different parts of the government, community, business and labour, among others – to enhance synergies and reduce conflicts between interacting policy domains (OECD, 2016). The OECD (2016, p. 83) defines policy coherence for sustainable development as an “approach and policy tool to integrate the economic, social, environmental and governance dimensions of sustainable development at all stages of domestic and international policy making”. It aims to increase governments’ capacities to achieve the following objectives:  Foster synergies across economic, social and environmental policy areas.  Identify tradeoffs and reconcile domestic policy objectives with internationally agreed objectives.  Address the spillovers of domestic policies. The framework recognizes the need to foster synergies across economic, social and environmental policy areas and identify trade-offs in order to address negative spillovers between policies in different sectors and at different levels (The Commonwealth, 2018). It also implies managing potential conflicts among diverse policy objectives in pursuing sustainable development goals. The focus of the framework is to help increase capacity of policy-makers to balance and reconcile divergent objectives, and provide a tool for informed decision-making. The OECD (2016) argues that policy makers need information and analysis to know what their realistic options are, what inconsistencies might result from their decisions, how the cost of those inconsistencies can be mitigated, and how they can explain the trade-offs they have had to make. Figure 2 below depict the analytical framework for policy coherence for sustainable development. It encompasses the fundamental elements that need to be borne in mind when analyzing and assessing policy coherence for sustainable development. 41 Figure 2: Analytical Framework for Policy Coherence for Sustainable Development Source: OECD, Better Policies for Sustainable Development 2016: A New Framework for Policy Coherence. Figure 2 shows the following key elements to be considered by policy-makers, key actors and stakeholders when designing policies: Actors According to the OECD, the implementation of the SDGs requires breaking out of policy silos and greater involvement of key actors and stakeholders (The Commonwealth, 2018). This could mean that when designing coherent polices, policy-makers needs to determine key actors who have to be involved and influenced. The diversity, roles and responsibilities of different actors need to be taken into account. In developing a practical framework for policy coherence for sustainable development, the OECD (2016) suggests that actors includes governments at all levels, parliamentarians, civil society, business and industry, philanthropists, international organizations, bi-lateral and multi-lateral agencies, among others, that are involved and/or influence policy-making and implementation. 42 Policy inter-linkages OECD (2016) defines policy inter-linkages as channels through which policies influence each other’s performance and objectives. Policy inter-linkages addresses the interactions between economic, social and environmental policies. It assesses whether the economic, social and environmental policy synergies and trade-offs considered, how the planned policy outputs contribute to achieve sustainable development goals, and whether governmental organizations are moving from sectoral perspectives towards a more integrated and issues- oriented agenda. Sources of finance When designing coherent policies, the OECD (2016) argues that policy-makers needs to assess the complementarities among sources of finance. They need to ascertain that all the potential sources for finance (public, private, domestic, international) been identified, avoid fragmentation of international, regional, and national funding instruments, and have in place the framework conditions to ensure contributions from private sources. Systemic conditions The OECD (2016) considers the system conditions as the disablers that can hamper the sustainable development outcomes at the global, national, local and regional levels. These are the set of social, political, economical, environmental and institutional conditions at the national and international levels that affect sustainable development and have a significant influence in policy performance and outcomes. Enabling environments In developing a practical framework for policy coherence for sustainable development, the OECD (2016) considers enabling environments as the enablers that can contribute to the sustainable development outcomes at the global, national, local and regional levels. The enablers are a set of necessary and interrelated conditions in the political, legal, economic, and social domains that can influence positively the policy outcomes. 43 Policy outcomes Policy effects are the economic, social, and environmental impacts resulting from the implementation of policies (OECD, 2016). Policy outcomes will allow policy makers to assess whether policies produce unintended effects, positive or negative, that could affect the well- being of people, the groups that would be affected and how, how can the unintended negative effects can be mitigated, and whether the potential direct or indirect long-term effects on well-being of future generations been identified. Policy inputs Policy inputs are institutional factors such as resources, including knowledge, expertise and capital assets that feed into the policy making process. Policy outputs Policy outputs are goods or services provided by governments to their citizens. Policy outcomes Policy outcomes are intended changes in society that governments seek to generate through laws, policies or official directives. Based on the definition provided above and on the analytical framework introduced in this section, the OECD (2016) identified five complementary levels of coherence that need to be addressed in the implementation of the SDGs. The argument presented by the OECD (2016) is that governments as well as key actors, will have to prioritize and focus on those levels of coherence that require greatest attention for ensuring progress. These five levels emphasize vertical coherence across multiple levels of governance (from local to global), and horizontal coherence across sectors and between diverse sources of finance. Vertical policy coherence relates to alignment between global, international, national and sub-national policies (The Commonwealth, 2018). At each of these multiple levels, there is also a need for horizontal coherence across different policy goals, sectors and actors. Horizontal policy coherence requires breaking out of sectoral silos and adopting integrated approaches to consider more systematically complex inter-linkages, trans-boundary and intergenerational impacts, and trade-offs at different policy levels. As the SDGs overlap and targets interact, policy coherence 44 is fundamental to ensure that progress achieved in one goal (e.g. water) contributes to progress in other goals (e.g. food security or health). The five complementary levels of coherence are described as follows; 1. Vertical coherence between the SDGs and national policies including at the local level determines that consistent actions across multiple levels of governance at the local, regional, national and international level will be fundamental for a successful implementation of the SDGs. 2. Horizontal coherence between the 2030 Agenda for Sustainable Development and other international agendas recognizes that the SDGs cannot be achieved without complementary actions at the global level and without supportive international normative frameworks and regimes. These international frameworks are critical for creating international enabling environments through a fair and well-functioning global trading system, a more transparent global tax system, stable financial systems, equitable access to knowledge, innovation and technology, responsible investment, effective climate action, amongst others. 3. Horizontal coherence between economic, social and environmental policies identifies that the 2030 Agenda needs to be implemented in a way that synergies can be realized across the environmental, social and economic dimensions of sustainable development. There is a need for inter-ministerial committees at the highest level to understand key policy linkages, to map out plans with long-term horizons, and to link national budgets and national statistic systems. 4. Horizontal coherence between diverse sources of finance (public, private, international and domestic) ascertains that one of the main challenges in achieving the SDGs will be to increase and mobilize private investments, and a PCSD approach can help countries reduce inefficient legal and policy barriers in order to enhance synergies between the provision of ODA and private financial sources. 5. Horizontal coherence between actions of multiple actors (governments, international organizations, civil society and the private sector) establishes that multi-stakeholder partnerships, including public-private partnerships can help mobilize resources, collective action and means for creating the necessary enabling environments to achieve the SDGs. 45 Above, I have demonstrated that the framework for policy coherence provide guidance for governments and various actors on improving policy and institutional coherence as well as integrated approaches to policy-making for the pursuit of sustainable development goals. In the next section, I present my framework for analysis adapted from the OECD framework for policy coherence that I will use to analyse the findings for this study. 2.9 MY FRAMEWORK FOR ANALYSIS In light of the depth and breadth of the South African education policy framework, I adapted the OECD framework, as it seemed to provide a useful way to think about policy in relation to the regulation of private provision. I have opted to adapt the OECD framework and added the three levels of policy coherence to aid in the assessment of the South African regulatory framework governing private colleges. Figure 2 below presents my framework for analysis that I have developed to assess coherent and mutually supporting policies in the context of the regulation of private colleges. Figure 3: The Framework Developed for Policy Coherence within the PSET System Source: Author’s own table adopted from OECD: The framework for policy coherence for sustainable development •Government regulatory bodies • PSET institutions Actors • Internal policy coherence • Vertical policy coherence • Horizontal policy coherence Policy inter- linkages Coherent education & training sysem Policy outcomes 46 A complex system such as the PSET system needs a coherent policy framework to direct and guide its development. The framework presented in Figure 2 encompasses the categories that I will consider when analysing policy coherence for PSET system. In terms of the key categories of the framework depicted in Figure 3 above, in my study, actors refers to government regulatory bodies and PSET institutions that are involved and influence policy-making and implementation. The government regulatory that I considered for this study includes the Department of Higher Education and Training, SAQA, Umalusi, QCTO and Council for Higher Education, while the PSET institutions considered are the private colleges. In the context of my study, policy inter-linkages are channels through which policies by the government regulatory bodies influence each other’s performance and objectives in the context of regulating private provision. Internal policy coherence corresponds to whether various actors share a common understanding of the purpose of the regulation of private provision and how these fit with their interests and objectives. It also assesses whether the concepts of quality assurance are well understood by the private colleges and across levels of the government. In respect to regulation of private provision, vertical policy coherence assesses the extent to which the different policies set by SAQA and the quality councils are aligned with the broader and higher-level policy framework of the PSET system. For example, vertical policy coherence would link the Constitution and/or the latest White Paper to the NQF Act. On the other hand, horizontal policy coherence evaluates how different policies set by SAQA and the three quality councils are coordinated and aligned to each other for ease of implementation by private colleges. In terms of my framework for analysis, a coherent education and training system is the desired policy outcome resulting from the implementation of policies and regulations. It is the ultimate result against which progress for the implementation of policies and regulations is measured. In this chapter, I discussed the literature review of some of the key research literature that pertains to the regulation of private colleges, and presented an interpretive summary of a set of conditions at international level that shape the terrain of education policy. Three key findings emerged from this chapter, firstly, that the system is complex and contradictory, 47 secondly, the accreditation processes are costly and time-consuming, and lastly, internationally, the demand for post-school education is growing and private provision is a major component of that growth. Government are responding in different ways, and in many cases their regulations do not deal adequately with international markets. As part of the discussion in this chapter, I presented the OECD framework for policy coherence for Sustainable Development. I then adopted the OECD framework to develop my framework of analysis as it provide a useful way to think about policy in relation to the regulation of private provision. My framework of analysis that will be used to organize the findings and frame the discussions in Chapter Four and Chapter Five. In the next chapter, I present my research methodology and the research design adopted in this study. 48 CHAPTER THREE