August 31, 2020
31 August 2020
Ant Bagshaw
Director, Nous Group
Dear Ant,
Go8 Submission to the General Capabilities Framework for Tertiary Education
The Group of Eight (Go8) thanks the Nous Group for the opportunity to submit to this consultation regarding the General Capabilities Framework proposal. Please note that this submission represents the views of the Go8 network and is provided at a strategic level. Member universities may also make their own submissions which may provide more of a detailed response.
The Go8 universities are major higher education providers, collectively enrolling over 400,000 students and educating more than one quarter of all higher education students in Australia. Go8 universities deliver Australia more than 100,000 quality graduates each year, including more than half of Australia’s science graduates, and more than 40% of engineering graduates. And many of our graduates go on to have distinguished careers. The Go8 has educated more than 80% of the domestically educated Chief Executives of the nation’s top companies, and every Nobel Prize winner educated at an Australian university. For this reason, we care about the path that our graduates take long after they have left our campuses.
The Go8 appreciates that the purpose of the Framework is to provide students and employers with a trusted source of information regarding their general skill capabilities. This will exist as part of a larger repository which will also provide a record of their academic achievements, and provide a common language between institutions, graduates and employers to aid in job-seeking, recruitment and retention of key staff. We also understand that the intent is to capture students across the broader tertiary sector, including Vocational Education and Training (VET) providers as well as those in Higher Education.
We certainly appreciate any opportunity to highlight the abilities and skills of our graduates and, in increasingly uncertain times, the types of competencies outlined in the Nous consultation paper will be critical.
However, there are many complexities to be considered in terms of how this can be achieved in practice. There are significant differences between the two sectors in terms of focus, delivery, assessment and regulatory provisions, so that what will work well for one sector may not be appropriate in the other.
Many universities already quantify general capabilities through their Graduate Attribute frameworks. These describe sets of qualities and skills that graduates develop throughout the course of their studies that are additional to the academic content and in some cases are embedded into the curriculum. Any requirement to map, assess, record and report general capabilities potentially represents a large additional workload, largely replicating the work that already exists. It is difficult to see the value-add for institutions with Graduate Attributions already embedded into the curriculum.
It is also important to note the broader context into which the Framework will operate. By way of example, the University of Queensland’s (UA) accredited Engineering programs have to map to:
- UQ Graduate Outcomes;
- Engineers Australia [EA] competencies; and
- UQ Engineering graduate outcomes (an additional EA requirement).
Learning outcomes and the Australian Qualifications Framework (AQF) already provide a framework for understanding the development of attributes across the educational landscape. Any concern with the efficacy of these from the perspective of employers (possibly their decontextualized nature and academic language) would be unlikely to be assuaged by adding another matrix of learning outcomes.
The Go8 is therefore uncertain what need the Framework is attempting to address, at least for the higher education sector. We concede that it may well be addressing an area of need in the VET sector.
The Go8 would also like to draw attention to the issue of where the Framework will sit in the broader regulatory framework. While we understand that this is a decision for the Department of Education, we wish to highlight the following points:
- It would be very unwise to adopt a regulatory approach without compelling evidence that reliable and valid assessment of generic capabilities using any particular to-be-developed framework is even possible. The evidence must come first, and it must be persuasive.
- This task is further complicated by the intention to include generic capabilities that are “self-assessed”, ie., declared by the student themselves. Such self-assessment is unlikely to contain the validity and reliability described above, and therefore risks undermining the intention of the Framework being a trustworthy, verified source.
- Even more importantly, a framework will only be useful if, at the level of individual subjects or units of study where assessments are to be made, educators see the framework as useful and therefore work to design tasks that afford students the opportunity to demonstrate any of its to-be-assessed capabilities. Since every assessment task is necessarily different (not least for educational integrity reasons), it is vital that educators retain full design control and judge the suitability of the framework in each assessment where it is to be used. As a result, adoption of any framework must be on an opt-in and continuous improvement basis. If the work is done carefully and its value can be demonstrated, then opt-in will be an effective strategy.
We are also concerned that a move towards standardisation of generic capabilities, such as this Framework represents, even if based on good intentions, risks stymying precisely the kind of innovation that students and industry are looking to universities to deliver in their education. The world evolves quickly, and student and employer needs along with it; qualifications evolve more slowly and regulatory frameworks slowest of all. While an employment-focused capabilities framework might be the right thing for now, it is unlikely to be so in 10 years’ time. The consultation paper appears to emphasise immediate ‘job-readiness’ as the key goal – this is too narrowly defined from the perspective of a Go8 education where the commitment is to education over training and to developing high-level capabilities for career-wide and lifelong learning.
The Go8 therefore considers that we can most usefully contribute to this process by working closely with the experts at the University of Melbourne’s Assessment Research Centre to work through these complexities.
Yours sincerely
VICKI THOMSON
CHIEF EXECUTIVE