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Submission to the Joint Oireachtas Committee on Education and Skills Qualifications and Quality Assurance (Education and Training) (Amendment) Bill 2018 Opening Statement: Dr Jim Murray, Director of Academic Affairs and Deputy CEO, THEA 18 June 2019 Chair and Committee members On behalf of the Technological Higher Education Association and its members, I would like to extend our thanks to you for the invitation to your meeting today to discuss the Qualifications and Quality Assurance (Education and Training) (Amendment) Bill 2018.
As indicated in its submissions of 5 October 2018, and 31 May 2019, THEA is supportive of the broad thrust of the legislation in two key respects.

First, it holds out the prospect of strengthening the national quality assurance and qualifications systems in education and training by addressing a number of issues that have been identified as impeding Quality and Qualifications Ireland (QQI) in fulfilling its intended statutory role.
This is important in terms of guaranteeing a quality experience for all learners across further and higher education and training; in terms of clarifying and strengthening aspects of the operation of Ireland’s National Framework of Qualifications; and in ensuring that Ireland’s reputation as a favoured destination for international students is protected and enhanced.

Second, the bill provides for the granting of award making powers, excepting doctoral awards, to all of the institutes of technology.
In so doing, and together with the recently enacted legislation for the establishment of technological universities, it will put all of the institutes on a more equal footing with the Designated Awarding Bodies, including the universities, and create a more coherent quality assurance and qualifications space amongst all public higher education institutions.
This development is something that THEA and its predecessor organisation, Institutes of Technology Ireland (IOTI), has sought over a long period of time, and the inclusion of this provision in the bill (section 36) is very much welcomed by the technological higher education sector.
Regarding the strengthening of the national quality assurance and qualifications systems, these are largely provided for in section 23 of the bill which amends section 55 of the Principal Act by the insertion of nine new sections: sections 55A to 55I.

These new sections represent the most detailed and complex changes to the Principal Act, and set out the processes whereby awards acquire the status of being included in the NFQ.
Since THEA’s initial submission to the Joint Committee last October, a number of changes have been made to the nine new sections, one effect of which is that the public higher education institutions, whether they be designated awarding bodies or providers to whom QQI has awarded delegated authority, will not now undergo the same process for inclusion of their awards as the new category of awarding bodies provided for in the bill, the so-called ‘listed awarding bodies’.
THEA welcomes this change, as it recognises and acknowledges the fact that the awards of the public higher education providers have been in the National Framework of Qualifications since its establishment in 2003-4.
THEA also notes that the bill provides for a new, formal procedure whereby designated awarding bodies will make more transparent how they determine the levels at which their own awards are included in the 1 | P a g e National Framework of Qualifications, and how this information is communicated to, and ratified by QQI, the custodian of the Framework (sections 55B (3) and (4)).
In principle, THEA does not object to the introduction of this transparency mechanism, but would argue that it should be integrated as far as possible into the existing quality assurance infrastructure overseen by QQI, and that it should not lead to the introduction of a new and onerous bureaucratic process.

In this regard, THEA is committed to working with QQI, and with our fellow public providers, so that this new statutory provision will be given appropriate effect in the implementation phase.
Apart from the above changes, THEA also notes the introduction of a new section, section 37, which provides for the authorisation to an education provider to use the description ‘university’.

As predicted in our submission of 31 May, the provision has attracted some debate, given that the context is drawn quite precisely, and that, overall, the provision appears to have been conceived with a very defined focus.
THEA notes that any such authorisation will be underpinned by a review process, which will use the criteria that are employed to evaluate a technological university ahead of designation.

In general, this is a sensible approach, though it is not clear to the technological higher education sector why the critical initial criterion that is required of institutes of technology that seek technological university designation, namely, merger, is absent in this particular instance.
Conclusion In conclusion, THEA makes these points as general observations, and wishes the Joint Committee well in its deliberations on what is a complex piece of legislation.

We would also like to thank the Committee for its continuing support for the growth of the technological higher education sector.

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