1. DEPARTMENT OF HIGHER EDUCATION Portfolio Committee on Higher Education
AND TRAINING
Portfolio Committee on Higher Education
National Qualifications Framework (NQF) Amendment Bill: Response to capacity, resource, relational and autonomy issues
12 September 2018

2. Purpose
To present responses and solutions to the Portfolio Committee on Higher Education and Training on issues related to SAQA’s capacity, Quality Council autonomy, relationships, verification by external bodies, raised in the public hearings on the NQF Amendment Bill on 5 September 2018

3. Background to the development of the NQF amendment Bill
In 2015 Cabinet approved the request of the Minister of Higher Education to:
institute measures to address the matter of misrepresentation of qualifications and presentation of invalid qualifications in the broader Public Sector;
that the Minister should approach his counterparts in all national departments to institute and/or strengthen measures in regards to the verification of qualifications of all employees, members of Boards of public enterprises and state-owned entities, and consultants to departments and entities, across national, provincial and local government spheres; and
strengthen the NQF Act, with a view to improve measures to deal with issues of misrepresentation, impose consequences on persons who misrepresent their qualifications or organizations that issue qualifications that are invalid.
This NQF Amendment Bill (20 OF 2018) therefore seeks to address issues of misrepresentation, consequence management of such, and related issues to strengthen the State’s ability to deal with these issues

4. Consultation process
The first draft National Qualifications Framework Amendment Bill was published for public comment in the Government Gazette No on 18 November 2016
Pursuant to the publication of the draft Bill, the Department of Higher Education and Training (DHET) received 48 comments and inputs from various interested individuals and organisations. The comments were duly considered and many were incorporated into the revised draft Amendment Bill
The revised draft was workshopped with SAQA and the QCs again and new additions were added
The DHET concluded the Socio-economic Impact Assessment System (SEIAS) process and the processes with the Office of the State Law Advisor
The SEIAS and DoJ certificates were received and the Amendment Bill was submitted to the Speaker of the National Assembly for presentation to Parliament

5. Key areas of focus in the Amendment Bill
The Amendment Bill seeks to amend the Long Title, to provide for:
New definitions
For the registration of private education institutions or skills development providers to offer qualifications or part-qualifications or any component thereof as contemplated in the principal Act
For the verification of all qualifications or part-qualifications referred to SAQA
To provide evaluation of foreign qualification by SAQA, and the formulation of evaluation criteria of foreign qualifications

6. Key areas Cont…
The establishment and maintenance of separate registers of misrepresented and fraudulent qualifications, and professional designations by SAQA
The legal duty to report misrepresented qualifications by education institutions, providers and employees
The referral of certain employees qualifications or part-qualifications to SAQA for verification
To create offences and impose penalties which have a bearing on fraudulent qualifications; provide for transitional arrangements and for matters connected therewith

7. Generic Issues raised in public hearings
A number of issues were raised in the recent public hearings, which are broadly categorised as:
SAQA’s capacity
Relationships
Autonomy
Verification services

8. SAQA’s Capacity and turn-around and time-frames
SAQA: Registration of qualifications: 100% done within 2 to 4 months; (CHE: 6 to 12 months to accredit learning programmes)
Verification of national qualifications: 91% done within 2 to 5 working days; rest within 20 working days
Evaluation of foreign qualifications: 15 days depending on the country of origin
Priority
Timeframe (Working days)
Extra
Up to 2 Working days
Special
3 to 5 WDs
Standard
6 to 20 days
Bulk
Up to 20 days

9. Pricing structure
This pricing structure refers to qualifications obtained in South Africa. The evaluation and verification of foreign qualifications by SAQA are dealt with separately
Quoting will be based on the requested timeframe, while invoicing will be based on the actual turnaround times. The upper end of the range of days indicated is for the maximum time envisaged for the verification of the record; however, actual times may be shorter
Individuals requesting verification of their qualifications do not pay; a charge is levied to third parties such as companies and organisations requesting verification

10. Pricing structure
Should a record not be able to be verified within the turnaround time selected by a client due to external delays or dependencies, then the next best turnaround option will become applicable. SAQA will invoice the client for the achieved turnaround times
A Bulk submission is a verification submission of 125 or more records either for National Senior certificates or tertiary records. The minimum fee for a Bulk submission is R , for the initial 125 records found, with a further R40.00 per record found thereafter. (National Senior certificate bulk is only undertaken for school leaving certificates onwards and the certificate numbers must be included in the submission)

11. Formulae that SAQA uses to quote and invoice
Qualification Category
Verification Category
Priority
Timeframe (Working days)
Research Required
Cost per Record
Senior Certificate (Pre-1992)
Individual record
Extra
Up to 2
Fieldwork required
R215.00
Special
3 to 5
R160.00
Standard
6 to 20 *
R130.00
National / Senior Certificate ( onwards)
Fieldwork – electronic & manual method
R90.00
R80.00
Fieldwork - electronic & manual method
R70.00
NSC Bulk records
Fieldwork - electronic method (R6 000.00/ application for min 125 records)
R40.00

12. Individual Tertiary record
Formulae cont…
Tertiary (SA National)
Individual Tertiary record
Extra
Up to 2
No fieldwork required
R500.00
Fieldwork required
R800.00
Special
3 to 5
R250.00
R650.00
Standard
6 to 20*
R125.00
6 to 20 *
R400.00
Tertiary Bulk records
No fieldwork required (R6 000/application for min 125 records)
R40.00
Inconclusive
ALL categories
When a result is recorded as inconclusive
When a record
R70.00

13. Formulae cont… Priority Timeframe (working days) Research Required
Cost per LETTER
Cabinet letters Qualifications: School leaving and Tertiary records.
Urgent Extra
1 (Up to close of business the day after the request)
Fieldwork required
As per Qualifications Table for each Extra Priority item ,Minimum R
Special
2 to 5
As per Qualifications Table for each Special Priority item, Minimum R650.00
Standard
6 to 20 *
As per Qualifications Table for Standard Priority item, Minimum R550.00
Letters of Verification
As per Qualifications Table per item , Minimum R240.00
Request for appeal
R per record (Refundable if successful)

14. Capacity: SAQA’s E-Certificate
SAQA has developed and successfully piloted the e-Certificate for verification
It is a world first
As soon as the evaluation is done a link is sent to the client who can register immediately and then the Esaqa certificate of evaluation is available

15. Capacity: Digitisation project
SAQA is busy with a digitisation project that includes teacher qualifications records, held by DHET and Grade 12 records held by DBE
SAQA is scanning and digitising these records, and then they will also be able to be electronically verified
The QCTO is digitising the trade certificates
A distinction is made between digitisation of national qualifications pre and digitisation of national learner records pre-1992
National quals pre-1992 followed the interim registration process where all legitimate and previously registered qualifications were collected and consolidated over a 5 to 10 year process.
All these quals are currently registered on the NQF

16. Other Verification agencies
UJ and TUT set up a company called QVS which signed up other universities
QVS was bought out by PURCO which then set up PurQ as a base
PurQ recruits other institutions
Institutions outsource verification and transcripts to PurQ who in turn charges the individual learners and companies
Splits the income between the individual institutions and themselves
MIE and QVS/PurQ are competitors
Umalusi has a contract with MIE; MIE pays Umalusi to conduct its verifications
In the Umalusi model, the State pays over and over again to do the verification of one learner
SAQA pointed this out to Umalusi, as an unacceptable practice

17. Currency of The NLRD
The issue was raised that SAQA’s NLRD is not up to date. SAQA responds that:
They get their information for HE quals from the DHET HEMIS system
The HEMIS information is provided by the Universities to the HEMIS system
Universities only provide their Data to DHET 8 months after graduation
They provide the same information to PurQ and MIE immediately after graduation
SAQA deals with this by contacting individual institutions if the information has not been uploaded timeously

18. Currency of The NLRD
A distinction is made between digitisation of national qualifications pre and digitisation of national learner records pre-1992
National quals pre-1992 followed the interim registration process where all legitimate and previously registered qualifications were collected and consolidated over a 5 to 10 year process
All these quals are currently registered on the NQF
Single quals that are not on the NQF, then they were not submitted
Learner records pre-1992 the digitisation processes deal with this

19. Difference between SAQA & other agencies’ verification processes
Other agencies only establish whether the learner has obtained a qualification
They don’t establish whether the qualification is a registered qualification on the NQF, whether the provider is accredited or the qualification is at the appropriate level
The example is of Tshwane Municipality was serviced by MIE
SAQA does all verifications of high level employee in government line function departments
There has been no comeback
Public outcry has arisen when public entities use service providers outside of the public services
For evaluation/verification of foreign quals. Other agencies do not first verify the authenticity of the qual. And the institution; SAQA does this
SAQA is linked to international, continental and regional verification agencies, such as GDN, AQVN and SADCQVN

20. Autonomy issues
The CHE is not autonomous in matters related to management of its sub-framework, as the Sub-framework is part of the wider framework and the CHE should consult with other bodies including SAQA
Examples of misalignment are the RPL and CAT policies and December close-out date of alignment

21. Thank you