by Jeremy Hoad

The response document broadly follows the format and order of questions laid out in the consultation document. We have not responded to all the questions posed but where we have the questions are listed prior to our response.


1 The particular qualifications proposed for inclusion within the NQFs (paragraph 48).

  • Agree

2 The numbers of HE levels proposed (paragraphs 49 and 50).

  • Disagree

We believe that, as stated in our earlier response, there should be distinct levels for different types of Masters course. It is unclear how there can be justification for situating a two-year research-based MPhil at the same level as a one-year vocationally orientated training course. These courses have different learning outcomes, different durations and different goals. We therefore still maintain that there is sufficient distinction between these types of courses to merit another level being included.

We further believe that the Agency will face problems in where to position postgraduate qualifications such as Diplomas and Certificates. Clearly these are different to Bachelors degrees and of an extended or more advanced nature. However, they are to be understandably excluded from the masters level. Although the consultation asks for advice on how they should be titled (consistent with statement xii on postgraduate qualifications that "they should not use the word 'postgraduate' in the title of the qualification") there is no suggestion as to where they will be situated in the proposed system of levels. The only option would appear to be to situate these qualifications however they may be titled at level HE3 (EWNI) / level Scottish HE4 (Scotland). We are not convinced that this would recognise the nature of these courses sufficiently and would like to see further explanation from the QAA and justification as to their decision.

3 The phasing-out of those degrees (generally called 'pass' degrees) that are awarded to students on an honours programme who marginally fail to achieve the requirements for the award of an honours degree (paragraphs 52 54).

  • Agree

We agree that the unclear nature of 'pass' degrees needs to be sorted out. The situation in Scotland is much more sensible and transparent where Ordinary degrees are awarded.

4 The development of a new, positively defined 'General degree' in England, Wales and Northern Ireland (EWNI) (paragraphs 55 59).

  • Agree

Effectively the consultation paper appears to be proposing degrees for England, Wales and Northern Ireland which are equivalent to the Scottish Ordinary degrees. In order for this to be consistent we would strongly recommend that the same title, 'Ordinary degree' is adopted and that this is allocated a separate level between HE3 and HE2 as identified in paragraph 50. It seems nonsensical to further confuse the issue by establishing a new title for the EWNI framework. If this happens then the proportions of credit should also be consistent with the Scottish system.

Definitions of Qualifications

5 The definition of the Bachelors degree with Honours in England, Wales and Northern Ireland (EWNI) (paragraph 62), and in Scotland (paragraph 63).

  • Disagree

The levels of credit associated with qualifications in EWNI and Scotland appear to be inconsistent. For a Bachelors degree with Honours the proportion at that level is 28% for EWNI and 21% in Scotland. For Non-honours degrees the proportion of credit at Scottish level HE3 is 28% and for EWNI it is 50% at level HE2 and 17% at HE3 which is a level greater than that of the qualification being undertaken. The only qualifications where there is consistency are Diplomas of HE and Certificates of HE. We would like to see greater explanation as to why these differences occur. It would seem a reasonable expectation that the minimum proportions of work at each level required for equivalent qualifications across the UK are the same.

There also seems to be inbuilt unfairness to the system if, bearing in mind the low proportions of credit required at an 'Honours' level (HE3 / Scottish HE4) for satisfactory achievement of that qualification the requirement for doctorates is 100% at doctoral level (HE5 / Scottish HE6). We believe that this disadvantages individuals studying at doctoral level and reduces the flexibility and coherence of the system. It is unreasonable to expect 100% of a doctorate to be studied at 'doctoral level' ( HE5 / Scottish HE6). This seems all the more surprising since the PhD / DPhil "will be neither credit rated nor achievable by credit accumulation" so there will be no reliable means of assessing the experience of PhD / DPhil students or the level at which they are studying.

6 The definition of the proposed General degree in England, Wales and Northern Ireland (EWNI) (paragraph 65)

  • Disagree

If a new 'General degree' is to be introduced it should be equivalent to and rated in the same way as the Ordinary degree in Scotland. It should therefore have a distinct level between HE2 and HE3 and have the same relevant proportions of credit as the Scottish Ordinary degree.

7 The definition of the Ordinary degree in Scotland (paragraphs 60 and 64).

  • Disagree

We seek explanation as to why a qualification for an Ordinary degree should only have 27% of its study at that level.

8 The definition of the Diploma of HE (and similar Diploma titles in general use) in England, Wales and Northern Ireland (paragraph 66).

  • Agree

and in Scotland (paragraph 67)

  • Agree

9 The definition of the Certificate of Higher Education in England, Wales and Northern Ireland (paragraph 68)

  • Agree

and in Scotland (paragraph 69)

  • Agree

Specific questions of terminology

10 Would it be desirable to distinguish generic and specific qualifications? (paragraph 76)

  • Agree

12 Would it be desirable to agree a limited number of ways of describing the subject focus and purpose of major HE qualifications and to establish means by which these should be employed consistently? (paragraph 77)

  • Agree

14 What titles should be used for qualifications that are postgraduate in time but not in level? (paragraph 78)

The titles used for different qualifications should reflect the level at which they are situated. If a qualification is only postgraduate in time but not in level it is unfair and misleading to continue the practice of calling it postgraduate or associating it with postgraduate level study defined as HE4 or HE5 / Scottish HE5 or HE6.

Therefore we propose that an additional distinguishing element is introduced to identify such qualifications. A possible solution is to identify such qualifications as 'Intermediate', reflecting the nature of the study as being between the levels of honours degrees and masters qualifications, neither wholly undergraduate nor wholly postgraduate. This could solve two problems. First, it would preserve the distinctiveness of existing titles (apart from those using the word 'postgraduate'). Second, it would identify that further study had been undertaken and recognise that achievement.

15 What titles should be used for 'extended' and 'enhanced' first degrees that currently bear a masters title but do not satisfy the future requirements for the use of that title (paragraph 78)?

Masters titles should be removed from all qualifications that are not at a masters level (HE4 / Scottish HE5).

If the sector wishes to distinguish these spurious postgraduate qualifications they should use the equivalent honours level title with the added descriptor 'enhanced' or 'extended'. Therefore an 'extended' BSc. could be titled BSc (enhanced) or BSc. (extended).

16 Is there a need for a 'low-volume' qualification, or qualifications, at doctoral level (fewer than 540 credit points at EWNI HE level 5 or Scottish HE level 6) (paragraphs 79 and 80)?

  • Agree

It is essential that the nature of the PhD or other doctoral qualifications is made more flexible. The traditional model of three years full time study leading to a thesis and PhD qualification is both restrictive and outdated.

If the availability of funding for doctoral level study remains as severely limited as it is now or is further restricted the situation will arise whereby the only people who can pursue doctoral level study are those who can afford it. Opportunity for the rich and exclusion for the poor.

There is no evidence to suggest that wealthy people are inherently more intelligent or suited to research than others who may wish to undertake doctoral level study. Unless greater opportunity and flexibility are introduced into the system there will be an increasing disincentive for many individuals to pursue doctoral level work. The impact of tuition fees for undergraduates is yet to be felt here but even without this as a contributory factor the costs of doctoral level study both in time and finance prevent many individuals from extending their knowledge and skills.

It is clear that there will not be a huge injection of cash into postgraduate studentships for doctoral level work. Indeed, it is not necessarily appropriate for the state to fund large numbers of doctoral students when other priorities are more urgent. However, it is disingenuous for the higher education sector to offer doctoral level study to people in such a way as makes it impossible for most to participate.

The need for a low-volume qualification at doctoral level is evidenced by the existence of the MPhil qualification which frequently fulfils the criteria identified for the new qualification. It is unfortunate that the QAA has decided to propose only one level for Masters qualifications contrary to our suggestions. The situation now is that a replacement seems to be sought for a qualification which already exists and which is now potentially severely undervalued by the suggested system.

If so:
16.1 How could they be distinguished clearly from doctoral degrees?

Such new qualifications should be distinguished by credit volume and level, as with all other qualifications. The study should be at doctoral level but have a lower volume of credit.

The difficulty comes in how much credit should be associated with the new qualification. The two clear options are either 180 credits or 360 credits reflecting one or two years full time study respectively.

Option A: 360 credits

We believe that 360 credits would allow more time for students to undertake other courses for training purposes which is an increasingly important part of doctoral level work. This would make it possible for an individual to undertake training and research in an intensive and focussed way.

The disadvantage of this option is that this might not be seen as sufficiently distinct from the existing PhD or other doctoral qualifications available. If the only difference were to be one year of study or 180 credits then it would seem likely that some students would opt to study for one of the existing qualifications. However, since the average submission time for many PhDs is over four years we are really comparing a two year course with a four year course rather than the formal period of three years full time study so this makes a two year 360 credit option more attractive.

If a qualification based on 360 credits were to be introduced then we would envisage that the existing MPhil qualification would either disappear with time or have to be radically reassessed as a one-year qualification by research.

Option B: 180 credits

There is also a strong argument for establishing a qualification with 180 credits. This would introduce a qualification which was at doctoral level but which did not entail a further substantial or extended commitment of time and / or money from the student. This would allow maximum flexibility for study at doctoral level.

With the move towards lifelong learning a one year, 180 credit qualification at doctoral level would open up enormous potential for individuals to tailor their learning to their personal circumstances. There would be the potential for individuals to study for three related 180 credit qualifications over an extended time, split by periods of work. These could then be combined to qualify for a full doctoral qualification equivalent to the existing PhD.

There already exists the opportunity in some institutions to do a doctorate by publication. We would like to see such flexible forms of doctoral level study extended and enhanced so that the idea of continuing professional development in a manageable form is available throughout the higher education system. It seems that one of the main reasons for this flexibility not being adopted already is the inertia of academics and institutions combined with unfounded snobbery and elitism perpetuated by people who wish to preserve an outdated ideal for doctoral level study which is both restrictive and unfair. We therefore hope that the opportunity will be grasped by the sector to extend the ideals of lifelong learning and widening access to all levels of study.

16.2 What title(s) should they carry?

The title LD could be used to denote a lower doctorate, e.g. LDMus

17 Should the title MPhil be reserved (like the PhD/DPhil title (see paragraph xiv in the boxed section)) for programmes of work at masters level and requiring a minimum of the equivalent of two years' full-time study that are assessed solely by a final dissertation (or by published work, artifact or performance that is accompanied by a written commentary placing it within its academic context).

  • Disagree

It seems that the MPhil qualification would substantially conflict with the proposed new doctoral qualification as referenced in paragraphs 79 and 80. If many existing MPhil programmes fulfil the function of the proposed new qualification then the continued existence of the MPhil as described here would appear to be redundant. It is difficult to see why an individual would choose to study for two years to gain a Masters level qualification based solely on research when the same time (or a shorter period of study if Option B above were adopted) could be devoted to a new qualification at doctoral level.

An alternative would be to actually restrict the length of time devoted to an MPhil to one year and 180 credits but retain the other descriptors regarding assessment and mode of study. This would provide a qualification which was at Masters level and by research which would balance the other vocationally orientated Masters courses and training courses such as the MRes.

This could then provide a coherent set of postgraduate qualifications which complimented each other and did not conflict in their learning outcomes, levels or durations.

18 If so, should all such programmes at masters level also adopt this title?

  • Agree

If this proposal is adopted then it would be essential that programmes which met these specifications carried the same title. Even if, as we suggest, the MPhil becomes a one year, 180 credit qualification at Masters level the same requirement would hold.

19 Should certain titles be reserved for earned higher doctorates? (paragraph 82)

  • Agree

The practice of using the same title for qualifications which are different and distinct from each other is confusing, contradictory and cannot be sustained. Different qualifications must have different titles. If this applies at the Masters level it must also apply at the doctoral level.

20 If so, what should these be? (paragraph 82)

A simple solution would be to add the descriptor 'Higher' before titles already in use. Therefore an earned higher doctorate could be, for example, HDEng compared with the existing title of DEng which would then be restricted to doctoral level qualifications.

By this means nomenclature would be transparent and straightforward for all types of doctoral study:

LDxxx(lower doctorate);
Dxxx(doctorate) and PhD / DPhil
HDxxx(higher doctorate)

21 Should other distinctive titles be reserved for honorary awards? (paragraph 82)

  • Agree

The practice of using the same titles for honorary awards as for earned degrees is insulting to all postgraduate students. We believe absolutely in the right of institutions to award honorary degrees. However, we further believe that these honorary degrees should be clearly distinguishable from earned degrees.

22 If so, what should these be? (paragraph 82)

There are two options:

Option A: DUniv / MUniv

As is noted in the consultation paper some honorary degrees already have titles reserved for their use. All honorary doctorates could bear the same title and to minimise the difficulties in doing this the title of DUniv could be used. Honorary MAs such as those awarded by Oxford and Cambridge Universities would have to be abolished unless they were retitled MUniv.

Option B: ***(Honorary/Unearned/Conferred)

Alternatively it could be made compulsory for all honorary degrees to carry a qualifying descriptor such as 'conferred', 'honorary' or 'unearned' [e.g. MA (honorary), DLitt (unearned), DEng (conferred)]. This would retain the element of choice for institutions to award any honorary degree they wished (including honorary MAs) while making absolutely clear that the qualification was not equivalent to existing earned qualifications.

If this were to be done the regulations of institutions would have to make clear that any person who received such an honorary degree would have to include the qualifier at all times.