BUSA COMMENTS ON THE NQF BILLS

1
BUSA COMMENTS ONTHE NQF BILLS - General
Comment - Specific Comments on the NQF Bill

2
BUSA COMMENTS ON THE NQF BILLS

• GENERAL COMMENTS
• NQF integrates and gives meaning to all education
  and training qualifications.
• There must always be ONE NQF to ensure a single
  unitary qualification system.
• BUSA is concerned about the potential removal of
  the accountability of Quality Assurance from
  SAQA.
• - Accountability of SAQA needs to be
  emphatically stated in the Bill. There needs
  to be clarity on SAQA as an Apex Body.
• - BUSA support the QCs and feel that they have a
  critical role in enhancing the work of SAQA and
  accelerate the approval and registration of
  qualifications on the NQF.

3
BUSA COMMENTS ON THE NQF BILLS

• SPECIFIC COMMENTS
• Sub framework
• Going to an extent of naming the sub-framework in
  line with the Quality Council is a concern.
• The division of the NQF into sub-frameworks has a
  potential of fragmenting the NQF, especially
  where the role and responsibility of SAQA is
  merely that of co-ordination.
• It is important to clearly distinguish between
  the NQF levels and the QCs. This distinction is
  not very clear when one reads Chapter 2 Section 7
  and Chapter 3 section 8 (d).

4
BUSA COMMENTS ON THE NQF BILLS

• SPECIFIC COMMENTS
• SAQAs role should really be to co-ordinate the
  work of QCs regarding standards and
  qualifications. This role cannot be separated
  from Quality Assurance.
• One NQF that allows for articulation and
  integration is required. The creation of
  sub-frameworks within the NQF runs the risk of
  creating unnecessary boundaries that will thwart
  the spirit and intention of the NQF.

5
CONCLUSION
Once the concern of sub-frameworks is addressed
it should enable an easier review of the other
two Bills. e.g. GENFET will occur within the
NQF QCTO will occur within the NQF. This will
further enhance co-ordination and collaboration
between and amongst all the QCs.