Unit standard-based degrees: summary of submissions

On 2 May 2011, the Ministry of Education sent a letter to universities, industry training organisations (ITOs), institutes of technology and polytechnics (ITPs), wānanga, private training establishments (PTEs), and peak bodies.

The letter advised that the Minister for Tertiary Education had asked the Ministry to consult on a proposal to amend the Education Act 1989 to preclude the grant of an award in the form of a degree made up of unit standards.

It outlined the current arrangements and the concerns regarding unit standard-based degrees, particularly whether unit standard-based degrees:

• fulfil the requirement in section 254(3)a of the Act for approval of research-led teaching of degrees
• are compatible with the depth and breadth requirement for degrees that are recognised internationally and used as the foundation for post-graduate study
• are compatible with the coherence and integration requirements for degrees
• pose a risk to the integrity of degrees awarded in New Zealand due to a lack of known international equivalents
• whether the proposed extent of credit transfer and recognition of prior learning in unit standard-based degrees, including recognition of sub-degree study, is in excess of the level for university degrees.

Submitters were asked to provide their feedback on seven specific questions:

1. What would be the disadvantage of not having the option to include unit standards as part of a degree?
2. Would an amendment of legislation to prevent unit standard-based degrees impact negatively on the qualifications offered by your organisation?
3. Should any restrictions on unit standard-based degrees also apply to other qualifications at Level 7 and above, particularly certificates and diplomas?
4. What would be the effect on education pathways from certificates and diplomas up to and including level 6 into degrees and/or other study if these cannot be credited towards a degree?
5. What would be the impact on the design of qualifications at levels 5 and 6 if unit standards are not able to be included as part of a degree?
6. Do you support the amendment of legislation to preclude the award of unit standard-based degrees?
7. Are there any other comments you would like to make about the proposal to preclude the award of unit standard-based degrees?

Consultation closed on 31 May 2011 and a total of 25 submissions were received. Submitters were made up of:

• Seven ITOs - Forest Industries Training Education Council (FITEC); Extractives Industry Training Organisation (EXITO); Funeral Service Training Trust of New Zealand; Careerforce; Social Services Industry Training Organisation; Electrotechnology Industry Training Organisation (ETITO); Aviation, Travel and Tourism Training Organisation (ATTTO).
• Eight ITPs – Unitec Institute of Technology; Ara Institute of Canterbury;Aoraki Polytechnic; Western Institute of Technology at Taranaki (WITT); Tai Poutini Polytechnic; Manukau Institute of Technology; Whitireia New Zealand; Otago Polytechnic; Eastern Institute of Technology (EIT).
• Two PTEs – SAE Auckland; AIS St Helens.
• Two universities – University of Auckland; University of Waikato.
• Four peak bodies - New Zealand Association of Private Education Providers (NZAPEP); Industry Training Federation (ITF); New Zealand Union of Students’ Associations (NZUSA); Universities New Zealand.
• One individual – Dr Amanda Torr.
• The Social Workers Registration Board.

Of the 25 submitters, 11 submitters fully supported the proposed amendment and nine did not support it. Four submitters supported the amendment but included provisos regarding the extent to which unit standards should be allowed to contribute to a degree, either through recognition of prior learning or as part of the make-up of a degree itself. One submitter said they required more information to have a position on the proposal.

The responses by type of submitter varied, as illustrated in Table 1. Both PTEs who made submissions supported the proposal, as did both universities (although one included an explicit proviso regarding the continued ability to recognise prior unit standard-based learning as part of its support). The majority of ITPs supported the proposal (although two included provisos as part of their support, one regarding a proportion of unit standard credits being allowed ton contribute to a degree, the other that the ‘detail of any legislative change’ not undermine outcome based degrees ¹ ), while the majority of ITOs and peak bodies did not support the proposal.

Table 1 : Proposal to preclude the award of unit standard-based degrees – consultation responses by submitter type

Views of submitters who support the amendment

The views of those who expressed support for the proposed amendment were generally aligned with the concerns outlined in the consultation letter.

These submitters felt that unit standards were incompatible with degree-level teaching and learning (particularly the requirement that degrees be taught mainly by people engaged in research), and that those who have studied unit standards in the past need to move to the style of study and requirements of degree-level learning.

The effect on the organisations themselves of precluding unit standard-based degrees was not seen as a concern due to the fact that there are currently no unit standard-based degrees on offer.

It was generally agreed that any restrictions on unit standard-based degrees should also apply to other qualifications at level 7 and above, mainly to ensure consistency. In particular, MIT commented, "in general, level 7 qualifications should operate within the same intentions as degrees and are frequently made up of degree originating courses." The University of Auckland commented that "these qualifications are often linked closely to postgraduate study, with some postgraduate diplomas forming the first part of Masters’ programmes."

In terms of the effect on education pathways, many of the submitters who supported the proposal noted that, as long as the ability to recognise prior learning continued to exist at the discretion of individual institutions, pathways would not be disrupted. WITT commented that "internal policies of recognition of prior learning would still enable credits towards a degree. This process does not recognise the unit standard but the learning and its relationship with the learning in the degree."

Impacts on the design of qualifications at levels 5 and 6 if unit standards could not be included as part of a degree identified by those who supported the amendment included:

• Additional unit standards at these levels may need to be designed that involve initial research skills to ensure a smooth transition into degree programmes.
• Unit standards would primarily be contained within programmes at levels 1 to 4 – Ara Institute of Canterbury suggestedAoraki Polytechnic suggested that this "may be a distinct advantage in the future and avoids the current overlap of systems that is confusing for both the international and domestic markets." Whitireia Community Polytechnic noted that there are already level 5 and 6 ITO qualifications without unit standards being designed.
• There was concern from MIT and the University of Waikato that pathways from level 5 into degrees would be affected if the ability to transfer unit standard credits into a degree was lost and that institutions offering unit standard-based qualifications would be under pressure to redevelop or discontinue qualifications if they are in subject areas that are intended as pathways to degree level study.

In the section for other comments on the proposed amendment, submitters voiced concerns that unit standard-based degrees could be detrimental to New Zealand’s international reputation for degrees, that unit standards can be "atomising and constraining"² and continue to be a challenge at all levels, and (like a number of the submitters who do not support the amendment) that unit standard-based degrees as a concept have not been sufficiently debated.

Views of submitters who do not support the amendment

As well as answering the specific questions in the consultation letter, a number of submitters who do not support the proposed amendment addressed the concerns about unit standard-based degrees outlined in the letter.

Tai Poutini Polytechnic commented that the competency-based learning outcomes associated with current New Zealand unit standards are "entirely consistent" with section 254(3)a (that a degree ‘is taught mainly by people engaged in research’) and 254(3)b (that a degree ‘emphasises general principles and basic knowledge as the basis for self directed work and learning). Tai Poutini believes unit standards and these concepts are “mutually compatible, not mutually exclusive.”

The Social Services ITO, ATTTO, and the ITF responded that unit standards describe a set of outcomes ("A unit standard is a measured competency outcome of set learning objectives just like a module or a paper in any Degree"³ ) and do not prescribe delivery. The degree provider is responsible for the development of the curriculum, mode of and approach to delivery, and ensuring that their teaching staff is of high calibre and reputation and engaged in research.

This point was reinforced when addressing the concerns regarding the breadth and depth requirement for degrees and the compatibility of unit standard-based degrees with the coherence and integration requirements for degrees. The ITF commented that "rather than standards alone, it is the combination of standards when considered with the curriculum and programme of study that must be compatible with the depth and breadth requirements"; and ATTTO noted that "this is a design issue which should be managed by NZQA when a degree is registered."

The extent of credit transfer and recognition of prior learning in unit standard-based degrees, including recognition of sub-degree study, was not seen as a valid concern given that recognition of prior learning is at the discretion of individual institutions.

A number of submitters identified overseas examples of competency-based degrees and programmes offered by universities in response to the concern that there is a lack of known international equivalents of unit standard-based degrees. These examples included Oklahoma City University, Western Governors University, Global University of Management and Technology TCI-UK, and the University of the Caribbean. Other examples of competency-based degree programmes included the Framework for Social Work Education in Scotland, and Engineers Australia.

In terms of the specific questions asked in the consultation letter, submitters who opposed the amendment felt that not being able to include unit standards as part of a degree would:

• devalue the status of unit standards
• weaken ties between industry and the tertiary sector
• close off pathways
• impinge on institutions’ academic freedom (in terms of their choice of assessment tool) and autonomy
• narrow the choices available to students
• be detrimental to national consistency in qualifications and counter to the Targeted Review of Qualifications’ aim to reduce the proliferation of qualifications.

The organisations who felt that preventing unit standard-based degrees would impact negatively on their offered qualifications cited reasons such as restricting the future development of qualifications at higher levels, limiting vocational-based pathways and reinforcing the perception that vocational training and education is of lower value than academic training which would “result in all ITOs needing to rethink their approach to qualification development and vocational education and training pathways.” ⁴

The Social Services ITO commented that:

Those who did not support the amendment were also opposed to any restrictions being placed on other qualifications at level 7 and above. A strong view from submitters was that restricting unit standards to qualifications offered at level 6 and below would devalue the status of unit standards and “exacerbate the existing gap between competency-based training and assessment and ‘university style’ degree level provision.” ⁵ It was also felt that it would “further complicate the transfer of learning and achievement from secondary to tertiary and the workplace.” ⁶

Otago Polytechnic (who supported the proposed amendment overall with the proviso that the detail of any legislative change not undermine outcomes-based degrees) did not agree that any restrictions placed on unit standard-based degrees apply to other qualifications at level 7 and above. They commented that, ‘many of these higher level qualifications have been developed for a specific purpose to address industry and legislative requirements.’ This point was echoed by EIT, whose overall position on the proposed amendment was that they needed more information. They commented that restrictions on all unit standard-based qualifications at level 7 and above would ‘prevent access to professional development for significant numbers of employees in industry.’

Submitters pointed out that "many of these higher level qualifications have been developed for a specific purpose to address industry and legislative requirements"⁷ and to restrict unit standards to level 6 and below would “prevent access to professional development for significant numbers of employees in industry.” ⁸

Dr Amanda Torr (whose submission has been treated as that of an individual due to her past experience in New Zealand but current position as Director Higher Education at the Polytechnic of Western Australia) asked why level 7 should be given special status:

Dr Torr suggested that a less prescriptive approach to writing unit standards may be more useful than restricting unit standards to level 6 and below: "The current models used are ridiculously detailed and appear to be based on a requirement for prescriptive detail that removes the professional judgement element associated with assessment."

The Social Services ITO commented that, if the suggestion was that ITOs be restricted to developing unit standards only up to, and including, level 6, it "surely deserves more debate and consideration than this consultation alone will allow."

Those who do not support the proposed amendment felt the effect on education pathways if certificates and diplomas up to, and including, level 6 could not be credited towards a degree would be significant and undesirable. It was pointed out that such a change would be counter to a number of the Government’s priorities as outlined in the Tertiary Education Strategy.

In terms of increasing the number of young people (aged under 25) achieving qualifications at levels four and above, particularly degrees, submitters felt it would impede young people who have been progressing through unit standard-based qualifications from moving smoothly into degree level provision.

Submitters believed it would also impact on the priorities of ‘increasing the number of Māori students enjoying success at higher levels’ and ‘Pasifika students achieving at higher levels’ because these learners "often come into higher education through vocational pathways and…will have gained lower level (national) qualifications in good faith, believing these would give them a start to further developing their employment opportunities."⁹

It was noted that part of the development requirements for unit standard-based qualifications is having input from Māori, Pasifika and industry, which makes these qualifications particularly relevant to and successful with Māori and Pasifika learners.

Cost to students was also raised as an issue. Submitters argued that students who have previously completed unit standard-based programmes at levels 5 and 6 may have to re-do up to two years of study if the unit standards could not be credited towards a degree and this would be an added cost and time burden that may discourage such students from moving into degree-level learning.

As well as submitters who opposed the amendment, some who generally supported the amendment held strong views about being able to credit certificates and diplomas up to, and including, level 6 towards a degree. The University of Waikato stated:

The University of Auckland also noted that: ‘The University will continue to recognise pathways which provide appropriate preparation for entry to its programmes and seeks actively to increase the number and visibility of such pathways. There are already arrangements for cross-crediting work completed for other qualifications to degree qualifications offered by the University of Auckland.’

The impact on the design of qualifications at levels 5 and 6 if unit standards were not able to be included as part of a degree was also seen as significant. Submitters commented that unit standard qualifications at levels 5 and 6 would no longer be designed with pathways to degree-level learning in mind and unit standards would have to be removed from some current qualifications at levels 5 and 6. The Social Services ITO, ETITO and the ITF commented that "it would remove any focus on common and generic skill recognition in ITO qualifications at levels 5 and 6, as students will not have these skills recognised formally when progressing onto degree programmes."

In the section for other comments on the proposed amendment, submitters reinforced their concern that precluding the award of unit standard-based degrees and/or limiting the level to which unit standards can be designed, would harm the links and current collaboration between ITOs, TEOs and industry.

They also commented that there has been little public debate on the concept of unit standard-based degrees and "what there has been, has rested largely on assertions from each side"¹⁰ and a misunderstanding of competency-based learning which has lead to ‘myths’ about its scope and value.

A number of submitters felt that unit standards have been ‘misused and abused’ and this is the real issue that needs addressing. Otago Polytechnic commented that "they have been used as curriculum building blocks which was never intended" and this type of programme design is inappropriate for learning at any level.

1 Otago Polytechnic submission
2 Unitec submission
3 ATTTO submission
4 ITF submission
5 Tai Poutini Polytechnic submission
6 ATTTO submission
7 Otago Polytechnic submission
8 EIT submission
9 Dr Amanda Torr submission
10 Social Services ITO submission