by Jeremy Hoad

QAA Qualifications Frameworks Consultation

The National Postgraduate Committee supports the intention of the Quality Assurance Agency in producing these proposals. We believe that postgraduate qualifications must be clarified and reorganised to allow comparability and consistency within the higher education sector. We further believe that it is essential that the issue of nomenclature is addressed and the sector accepts its responsibilities to provide clear, unambiguous information to students, employers and the wider public.

Although we have reservations about some of the proposals and do not agree with the entire document as it stands we would like to stress that we are in full support of the initiative and would welcome the opportunity to work with the Quality Assurance Agency and other constituent bodies in developing a framework which meets the needs of all those who have an interest in postgraduate qualifications, most particularly current and future students who must be at the heart of any proposed reform.

The Principles

Principle I: Definition of postgraduate qualification
"A postgraduate qualification is one that is built from credit that is largely at a level above that of the honours degree; it may include no more than a defined maximum level of credit at undergraduate honours level."

  • Agreed

The definition of this principle is welcomed as a general basis for a postgraduate qualifications framework. The statement of limitation (at least in principle) of credit at undergraduate honours level is particularly welcomed. We feel that it is fundamental that postgraduate level courses must be of a clear and distinct nature to undergraduate level courses.

This principle is based upon the assumption and incorporation of "credit" as a measure of learning outcomes and "levels" as a distinguishing indicator of postgraduate courses and between different postgraduate courses. We accept that the principle of using levels has been agreed by previous consultations and agreements. Nevertheless, although we agree with the intentions to establish a method by which postgraduate courses can be measured and defined we feel that it is problematic to seek agreement to this principle when the nature of different levels and the means by which credit is to be measured are both only vaguely defined at the moment. We will comment further on the issue of credit and levels in questions 8 13.

Principle IV: Module credit at one level
"A module or unit of learning will be uniquely defined at one level of credit by its learning outcomes."

  • Agreed

The issue of undergraduate content within postgraduate courses is addressed elsewhere in this document. However, we agree that it is inappropriate to assess participants in the same module or unit of learning in different ways. If, for example, there are to be undergraduate elements within a postgraduate course it is best to take account of this separately rather than have students confused as to how their work is to be assessed.

We do not believe that it is necessarily practicable to apply this same method to higher research courses such as PhDs. Although students taking courses with a largely research based content will undoubtedly undertake specific courses as part of their training there is not the same structured approach to these courses as there is with masters level courses. Therefore it is difficult to see how this system can be applied at PhD level where learning is much more self-directed and less structured.

Principle VI: Differentiation of intermediate awards
"Qualifications that are regarded as signifying a stage of progression to a higher award should be differentiated from the qualifications above and below them by level and / or volume of credit."

  • Agreed

Although, as noted, there are qualifications which are seen as part of a progression towards a higher level it is important that these qualifications stand in their own right. Individuals should be able to undertake a qualification sure in the knowledge that it will be recognised independently of any other awards. The best way of doing this within the current framework proposals is to differentiate relevant courses by level.

Principle XI: Consistent nomenclature is required
"The nomenclature of postgraduate qualifications should be consistent across the UK."

  • Agreed

The National Postgraduate Committee believes that this must be one of the fundamental driving forces of any reform of postgraduate qualifications framework in the UK. The reasons for this have been extensively discussed but it is worth stressing that the current system is both inconsistent and confusing to students, institutions, employers and the wider public. If higher education in the UK is to continue to command the worldwide respect that it currently does we believe that the consistency of nomenclature for postgraduate awards is essential.

Principle XII: Qualifications with the same title
"All qualifications sharing the same title and level should specify the same minimum credit level requirement(s)."

  • Agreed

If the system of levels and credits is to be adopted, as seems likely, we believe that it is crucial that the same minimum credit requirements are applied to all courses identified as being at the same level. Without this requirement the whole basis of consistency and comparability between courses at the same level would be undermined.

Principle XIV: Restricted use of masters title
"The masters title should be restricted to postgraduate qualifications as defined in Principle 1."

  • Agreed

We hope that the QAA will not shy away from the more contentious issues that this principle implies such as Scottish MA qualifications, DPhils and honorary MAs from Oxford and Cambridge and anomalous qualifications such as MEng or MBA which are essentially undergraduate level courses. If the new framework is to command respect and be consistent then the titles of qualifications such as those mentioned must be changed to reflect the true nature of the qualification both in terms of level and credit.

Principle III: Character of study, levels
"The distinction between teaching and research is an inappropriate basis for differentiating level of postgraduate qualification."

  • Agreed

The level of a postgraduate qualification does not directly relate to the learning methods employed or the experience of the student. Although it is accepted that the taught content of a postgraduate course is often a distinguishing feature of the level of the qualification this does not, by itself constitute a defining feature and should not be used as such. As has been stated:

"The use of a set of levels in a framework is a means of clarifying:
- the expectations and demands of a postgraduate programme;
- the achievements and attributes associated with qualifications."

(3.1 p4 QAA Consultation Paper on Qualifications Frameworks: Postgraduate Qualifications)

Therefore the method of provision employed in any particular course does not necessarily relate to the level of the qualification.

Principle VIII: 180 credits per full time equivalent year
"The minimum credit volume of a full-time equivalent year of postgraduate study should be 180."

  • Not Agreed

We understand that in order to establish comparability and for the construction of credit volumes and credit ratings for different courses a notional figure is the easiest way of doing this. We believe that this system of credit rating is only really applicable to courses which have a high taught element in them. Taught Masters courses and Masters courses which have a significant taught element may be judged according to the credit system in much the same way that undergraduate courses are assessed and compared. However, for higher postgraduate qualifications where either a majority or the entire provision is by research and associated independent learning it is unclear as to how this credit based system could be applied.

Therefore we do not agree with the application of this principle to all postgraduate qualifications and have similar concerns about Principle VII: "All postgraduate provision should be credit rated".

Principle XV: Restricted use of PhD title
"The title of PhD is internationally recognised as an award for original research normally examined by thesis and should not to be extended to other forms of advanced study."

  • Not Agreed

We agree that the PhD qualification is internationally recognised as an award for original research. However, we feel that the supporting statements under point XV in the consultation document are inconsistent and confusing. Furthermore, although much attention is given to distinguishing between different Masters qualifications this document does not address the issue of the wide range of experience associated with PhD qualifications.

We believe that there needs to be far greater explanation as to what exactly is understood to constitute a PhD qualification. The consultation document states that:

"The PhD title should be awarded exclusively for published or unpublished research work (normally) examined by thesis."

(XV p8 QAA Consultation Document)

We accept this point and agree with the limitation of the scope of the PhD qualification in terms of what would constitute appropriate work. However, the document does not explain sufficiently why there should be exceptions to the examination of PhD work by thesis. We accept absolutely that in the performing arts it is not appropriate to expect assessment of work for a PhD qualification to be based solely on a written thesis. However, we believe that in order for PhD awards to be consistent and comparable it is essential that there is a substantial written account or explanation to accompany any artifact or other form of work. If the PhD qualification is to be maintained as the highest postgraduate qualification it is essential that work or research that carries this award is able to be communicated to a wider audience other than a discipline specific group. Therefore we do not understand why there is the further statement that PhD qualifications may be awarded in some instances where:

"an account making it clear why a thesis is not required"

is included. This appears to conflict with the statement:

"The award of PhD would not be appropriate for programmes of work where an artifact or creative work is the sole outcome."

We believe there needs to be absolute clarity here as to what constitutes a PhD qualification and how it is to be assessed, particularly since the submission and assessment of a thesis with accompanying oral examination is the commonly the only means of assessment employed for PhD qualifications.

Principle XV is also inappropriately worded because it says that:

"The title of PhD... should not to be extended to other forms of advanced study."

This implies that the title of PhD is strictly limited at the moment with regard to what work would qualify. This is not the case as there is not a single form of PhD at the moment. For example students may currently submit a novel with an associated written account in some English or Creative Writing Departments and be awarded a PhD.

Principle XVI: Titles of doctorate awards
"An award bearing a doctoral title should be at a level comparable with PhD/DPhil in terms of scale and rigour."

  • Agreed

In order to maintain the consistency of the proposed qualifications framework this principle is essential. We are, however, concerned that the QAA makes reference to "PhD/DPhil" as the continued use of the title DPhil would conflict with Principle XI. We assume that the reference to DPhil reflects the level of work expected for a doctoral award but propose that because of the importance of the stated principles reference to titles which may be abolished are removed from Principles.

We would also like to see further clarification of what is meant by "scale and rigour" in the absence of clear definitions of postgraduate levels and look forward to working with the QAA in clarifying these matters.

Principle XVIII: Honorary titles
"The honorary nature of honorary titles and awards should be clearly distinguished by their nomenclature. They are not included within the qualifications framework."

  • Agreed

It is essential that honorary titles are clearly distinguished by their nomenclature. Although we accept that following the precedent of the Harris committee higher doctorates are not included within the qualifications framework at this time we feel that it is important that they are incorporated as soon as possible. At the very least the QAA will need to pay careful attention to the practices of awarding bodies to ensure that honorary titles and awards are clearly distinguished.

Principle XIX: No award by default
"No qualification should be awarded as compensation for failure or by default."

  • Not Agreed

We agree with this statement in principle but do not agree with the second of the explanatory comments associated with it in the consultation document. This says:

"Failure to demonstrate sufficient achievement for a particular qualification does not preclude the possibility of demonstrating achievement of outcomes at a lower level, or in lower volume. Thus, for example, where there is insufficient achievement to justify an award at doctoral level it may be possible to demonstrate sufficient achievement for a masters award either by level or volume. In such cases it is essential that achievement is identified in positive terms; this would require resubmission of work for reassessment at the lower level."

(4.5, XIX, p8, QAA Consultation Document)

We cannot agree that it would be desirable to require resubmission of work for reassessment at a lower level. In the example cited, where a masters qualification may be awarded after the failure of an assessment for doctoral level the award of the masters qualification is in recognition of the level and volume of work submitted. If these criteria were not met the examiners would not or should not award a masters qualification and the option is available to them to fail the candidate outright. Resubmission and examination in this instance would be both highly stressful and time-consuming to the candidate and place unnecessary administrative burdens on the staff and institution concerned. There are also cost implications for the student and institution which are unnecessary.

If the QAA is not satisfied that all Masters qualifications awarded following submission at doctoral level are justified then we feel this is a matter of maintaining quality and ensuring that the procedures that are in place are strictly adhered to. It should not be a matter of changing the requirements for gaining an award in this case.

Therefore, although we agree with the intentions behind Principle XIX we do not feel able to agree with the principle itself at the moment.

Principle XX: 25% maximum to mix of u/g with p/g
"No more than 25% of the taught element of a postgraduate programme should be delivered through classes or other learning experiences shared with undergraduates."

  • Not Agreed

This principle is essential to ensure confidence in the nature and level of postgraduate qualifications. Institutions that offer postgraduate level qualifications must be able to demonstrate that they are investing in both the courses offered and the systems of provision and assessment at a postgraduate level.

Having said this, we believe that 25% is too high a figure. If a postgraduate qualification had this proportion of its taught element shared with undergraduates this would constitute a significant proportion of the provision and a level which we believe is unacceptable. If institutions are not prepared to design, provide and support courses at an appropriate level then we would have serious doubts as to the intentions of the institution. Our members have reported to us instances of dissatisfaction from postgraduate students who start a postgraduate course and are then perturbed at the amount of teaching shared with undergraduate students. When this is the case it is crucial that potential postgraduate students are provided with sufficient information which is clear and unambiguous so that they can judge the nature and level of the teaching provision and the educational experience they will have.

We believe that 10% should be the maximum permitted proportion of the taught element of a postgraduate programme that is delivered through classes or other learning experiences shared with undergraduates.

Another related issue here is the practice of grouping teaching provision at a postgraduate level from different existing courses together and linking this with a limited number of specific units to make up a package which is then marketed under the banner of a different postgraduate qualification. This has been common practice in recent years as the number and range of postgraduate courses has expanded. We recognise that very valuable interdisciplinary experiences can be gained here and also that institutions can share the best teaching between a number of different courses. However, it is important that this practice does not dilute the specific nature of individual courses. If a postgraduate course is marketed under a new title or has different learning aims and outcomes there must be a clear structure to its constituent elements which form a coherent whole.

The Models

14. Which is your preferred model?

Model 1
PG3: doctoral qualifications
PG2: 'higher' masters qualifications based on research, taught or practice-based components
PG1: 'standard' masters and lower postgraduate qualifications.

Model 2
PG4: doctoral
PG3: 'higher masters'
PG2:standard masters
PG1:lower postgraduate awards (eg PGCert, PGDip)

Model 3
PG3: doctoral qualifications and higher masters
PG2:standard masters
PG1: lower postgraduate awards (eg certificates, diplomas)

  • The preferred model of the National Postgraduate Committee is Model 2.

We accept that the Models outlined are not absolute commitments at this stage and would welcome the opportunity to clarify the further development of a Model for postgraduate qualifications. The reasons for our expressed preference of Model are explained in the comments to the questions below.

Levels, Credit and Nomenclature Within the Framework

15. How many postgraduate levels are required?

  • 4 postgraduate levels are required.

We believe that 4 postgraduate levels are required. Distinctions can be made between lower postgraduate qualifications (eg PGDip), standard masters qualifications (eg MSc), higher masters qualifications (eg MPhil) and doctoral level study (eg PhD). Each of these levels may have different intellectual requirements, volumes of work and learning outcomes. In addition there is a progressive difference in time. Although, in itself, this is not a credible means of judging level it can play a significant part in facilitating the level of study.

We further believe that the higher education community would be more open to accept proposals which reflected as far as possible current practice and experience. The driving force behind these proposals should be to ensure comparability, consistency and quality. In proposing a system of levels the Quality Assurance Agency must gain the understanding and support of participators in the sector to enable this.

Having said this we believe that determining the specific features of the levels adopted for postgraduate qualifications will be an enormous task. Each postgraduate qualification serves a different purpose. This may be in terms of the intellectual advancement of knowledge, practice based experiential learning and training or vocationally orientated training and development among other functions. The allocation of levels to postgraduate qualifications implies that these functions are different and may be of higher or lower standing in terms of their comparability. However, what this may fail to recognise is the fact that alternative postgraduate qualifications are different in nature and not necessarily different in their level. There has to be an element of comparing and trying to rank apples with pears when one tries to rank postgraduate qualifications which may not have the same aims or basic framework.

16 How many levels are required to differentiate only masters awards?

  • 2 levels are required to differentiate only masters awards.

Masters awards should be identified by two levels relating to standard and higher masters qualifications such as MSc or MPhil awards respectively. There are differences in intellectual requirements, expected outputs, teaching content and learning outcomes which merit a distinction between different masters awards. There is also often a difference in time which contributes to a distinction in level.

17 If more than one level is required for masters, should they be differentiated by:
- level of outcomes

  • Yes

- mode of study (mode: based mainly on taught, or research or reflective outcomes)

  • Yes

We believe mode of study should be taken into account when determining the levels for masters awards, although we stress that in no way should this criteria be seen in isolation to judge level.

18 Should a differentiation of level be drawn between masters awards and lower postgraduate awards (eg postgraduate certificates and diplomas)?

  • Yes

It is accepted at the moment that lower postgraduate awards are at a different level to other postgraduate qualifications and we believe that the system adopted should reflect this. Although many postgraduate diplomas are seen as a stage in other study, for example as part of a masters course, they are distinguished by the nature of the experience, the learning outcomes, the level of intellectual work and the length of study. Bearing these things in mind we believe they should be recognised as at a different level to other postgraduate qualifications.

If other awards such as four year science and engineering degrees or MBAs are to be retained as postgraduate qualifications or bearing a Masters title then we feel it may be appropriate to situate them at this level.

19 Should all masters awards be differentiated from doctoral awards by level?

  • Yes

We accept that there might be a case for placing higher masters qualifications at the same level as doctoral qualifications. However, where higher qualifications are concerned which are largely or solely made up by research the length of study has a significant impact on the level of work. Time is not a sufficient measure in itself to determine level but it can have a bearing on the opportunity and ability of students to consolidate material, familiarise themselves with relevant academic work and to form and reflect on ideas. Furthermore it is generally accepted that where a doctoral level qualification should entail a significant original contribution to knowledge higher masters level qualifications such as the MPhil will not demand the same level of intellectual work and output. They may have a significant reflective or analytical intellectual element to them but do not generally require the same level of originality. In addition to this the volume of work required is significantly less for higher masters qualifications. As such we believe there is a clear distinction between higher masters and doctoral level qualifications and different levels are required to reflect this.

20 The credit volume of a notional year of fulltime equivalent postgraduate study should be: 180 or other

  • Not agreed

We accept that a figure of 180 for the credit volume of fulltime equivalent postgraduate study is comparable with the figure of 120 credits for undergraduate courses which is widely adopted. However, we do not believe that it is either possible or desirable to impose a credit volume such as this on all postgraduate qualifications. Unlike undergraduate courses where the experience is based around taught modules or units which are assessed it would be impractical use the same system for many postgraduate courses, particularly at the higher levels, where learning is much more self-directed and independent.

We also believe that this proposal might contribute to a change in perception and/or practice for higher level postgraduate qualifications where a greater degree of structure and training might be expected or imposed. We feel that this would not be desirable if it were to undermine the fundamental nature of higher level research based qualifications, leading to a limitation on the freedom of the individual to pursue their research in the manner in which they think most appropriate with the support of their department.

21 Postgraduate qualifications should be based only on credit at postgraduate level(s).

  • No

The framework proposed for combining levels and credit ratings to judge all postgraduate qualifications is a systematic way of ensuring comparability and consistency. Nevertheless, we believe that the use of credit as a means for judging all postgraduate courses is potentially problematic.

Where courses have a high taught element to them the allocation of credit as a combination of taught units is understandable. However, for many masters qualifications and particularly for higher masters and doctoral level qualifications students are often working independently on research. If a qualification is to be based on credit the credit associated with these more research orientated qualifications could only realistically be based on time at the moment. It is absolutely crucial that if this system of credit is to be adopted a rigorous system is in put in place to judge the quality and level of experience at the higher levels. One possible solution is that credit in these cases would be likely to take account of research facilities and support, quality of supervision and training available to researchers. Even if this were to be adopted to overcome these difficulties we do not feel that a reliable means of allocating credit to higher level courses can be easily determined.

If credit is to be based on learning outcomes we believe that it will be almost impossible to determine reliable measures for all postgraduate awards. Awards may be composed of different modules at different levels. They may be taught, research or practice-based. Additionally any of these elements may take different amounts of time which may not directly relate to either the learning outcomes or the level. Bearing these difficulties in mind we feel that it is inappropriate to base all postgraduate qualifications on credit.

If No, what is the maximum proportion of credit assessed at undergraduate level allowable within a postgraduate award at level:

22PG110%
23PG210%
24PG30%