Malta Qualifications Framework Referencing Report to the EQF: GRTU submits feedback following consultation with members

GRTU welcomes a more concise version of the MQF  Referencing Report which makes it more practical and user-friendly.  There are a number of positive developments yet through a number of issues have also been flagged by GRTU members.

Maintaining the Descriptors for Levels 1-8

There has been widespread acceptance of the Level Descriptors from Levels 1 to 8 and courses have been transposed in terms of learning outcomes using the current level descriptors.

Introduction of Entry Levels A and B beneath Level 1

The introduction of Entry Levels is considered as a natural step for the framework to be more inclusive and provide recognition for more basic learning which would have occurred yet does not reach Level 1.

National Qualifications and Respective Credits (Levels 5 and 7)

Clarifying the different forms of qualifications at these two levels and their respective expected credits makes it clearer for everyone. Nevertheless one has to clarify what, if any, establishes a full level, as well as provide a better understanding of the derivation of how a specific qualification is pegged to a specific number of credits.

There needs to be more elaboration and consultation on this point in general.

Reducing Number of Minimum Contact Hours to 5 per credit

This reduction is envisaged to make it more straight-forward in terms of contact hours against the notional hours of one credit. One has to consider how this is going to courses which are already accredited with the previous minimum of 6.25hrs.

Nomenclature of Qualifications and Awards

This is envisaged to provide a clearer picture of what constitutes a qualification (full level) and an award which perhaps was previously more difficult to comprehend especially for persons who are not very much  acquainted with the MQF.

On the other hand, there is clear need of communicating with the general public, learner, workers and      employers about what these reflect as otherwise there will be misconceptions on the ground. The influence of nomenclatures from other European systems should also be taken into consideration.

Minimum Credits for Accreditation Decreased from 4 credits to 1 credit

This is also a positive initiative which gives value to shorter learning experiences which may be in effect of value to that particular individual and sector, which was previously being unaccounted and not accredited.    Without adequate awareness-raising, this may be intentionally or unintentionally, abused of.

ECTS/ECVET

Some thought needs to be given on how ECVET and ECTS are used in comparison to how these are used in other European countries. It is also necessary to consider what other credit systems (e.g. different number of hours) are mostly used in Malta and promote an understanding of this         nationally to ensure understanding.

Validation of Informal and Non-Formal Learning

Validation of Informal and Non-Formal Learning needs to be implemented in practice.

Quality Assurance

A lot of developments have been undertaken particularly by NCFHE in this field. QA implications have to however be discussed with training providers prior to changes. NCFHE itself has to be more transparent to instil confidence that a level-playing field is entertained, especially between public self-accrediting institutions and small private providers.

General Education

General Education levels are not given specific credits. This may be a positive decision as otherwise the number of hours undertaken during such learning would result in perhaps far greater hours (and thus credits) than that of credits to be reached for a qualification at these levels. Nevertheless one should also consider how other forms of qualifications at these levels can be compared to a full level in terms of credit.

Fees

A specific change that has been implemented during the period covered in this update is that licensing and accreditation is no longer free of charge. Accreditation and licensing fees that have been implemented, even without consultation and proper justification, are not even reflected in the resources at NCFHE and thus the efficient and timely service to operators. It may also cause unfair competition with public or self-accrediting institutions.

For the full version of feedback, for further information or suggestions, kindly contact GRTU on 21232881 or          .