August 15, 2022
Dr Daniel Edwards
Research Director, Tertiary Education
Australian Council for Educational Research (ACER)
Dear Dr Edwards
RE: Australian Qualifications Framework (AQF) Architecture and Taxonomy Consultation
The Group of Eight (Go8) is pleased to have an opportunity to provide a submission to ACER’s consultation on potential models for a revised AQF architecture and taxonomy. Please note that this submission represents the views of the Go8 as a whole.
The Go8 represents Australia’s world-leading research-intensive universities. Collectively we are consistently Australia’s highest ranked institutions in the major international ranking systems. The Go8’s commitment to excellence means we welcome quality students from all backgrounds who become quality graduates and international leaders of tomorrow. We enrol 425,000 students; educating more than one quarter of all Australian higher education students in Australia. Go8 bachelor completion rates are higher than the national average. In post graduate education, Go8 universities enrol over one third of all post-graduate students, and almost half of all students in higher degrees by research.
While the Go8 does not think the AQF in its current form is ‘perfect’, it is certainly well-established and our institutions, students, employers and international peers are familiar with its current bands, levels and descriptors. As indicated in your survey instrument, ‘the AQF is used as a reference point for qualification recognition policies, processes, data collection, course design and accreditation’. The AQF is important, and well established, as a means of facilitating international comparisons. Global recognition of Australian qualifications is critical to facilitating student, academic, education provider and labour market mobility, and underpins the success of Australia’s international education sector. The AQF also now underpins Australia’s quality assurance framework for vocational and higher education qualifications, providing students, employers and Governments with the confidence to invest in, or otherwise support, these regulated awards.
Any revision of the AQF must be carefully and collaboratively designed and implemented over an appropriate period, recognising that there will be significant administrative costs and regulatory impacts for providers, Governments, vocational and professional accrediting bodies and a need to build knowledge and trust about any changes with students, employers and international peers.
The Importance of the Current Context
I note that the Review of the AQF was commissioned by the previous Australian Government. While the incoming Government has announced some of its priorities for post-secondary education and learning options, it is not clear what priority the new Government places on revisions to the AQF. Knowing the Albanese Government’s attitude towards AQF reform is vitally important, however, given the significant impact and wide-ranging implications that the proposals outlined in ACER’s consultation documents would have for so many stakeholders. Go8 universities are currently prioritising additional resources to areas such as re-invigorating campus life, frontline services for students, and strategies for increasing our equity student cohorts. The Go8 does not view revision of the AQF as a current priority for delivering a world-leading education to its students or the higher education sector more broadly.
Additionally, the Go8 believes that the Government’s position on potential AQF revision may be shaped by the outcomes of the upcoming Jobs and Skills Summit, as well as its vision for the role of the newly created Jobs and Skills Australia. In this context, our member universities agree that providing detailed and well-rounded feedback on the three models presented through ACER’s consultation materials is premature at this time.
By holding the Jobs and Skills Summit, the Government has signaled its interest in collaborative solutions to the broad area of skills creation and solutions. In terms of any future changes to the AQF, the Go8 believes it is important, as a first step, for all providers in the post-secondary education field to collaboratively identify the purpose of the AQF and the benefits that may accrue from any changes.
The Go8 recommends that ACER:
- Establish whether revision of the AQF’s architecture and taxonomy is a higher and further education priority for the new Government; and
- Be informed by the outcomes of the Jobs and Skills Summit and the focus of the newly created Jobs and Skills Australia in potentially reconsidering its current three proposed alternative models for AQF architecture and taxonomy.
Feedback on Principles for Revision of the AQF Architecture and Taxonomy – if it is to be pursued
If revision of the AQF architecture and taxonomy is to be pursued, and in response to some of the questions posed in the ACER survey, the Go8 recommends the following guiding principles be applied and responses noted:
- The key higher education qualifications are well recognised in Australia and internationally.
- A false separation of ‘skills’ from ‘knowledge’ should be avoided. Our institutions would see them in many cases to be deeply intertwined.
- The change from ‘years’ to ‘hours’ is not adequately explained and not supported. ’Years of study’ is well understood in the sector domestically and internationally and there is no apparent reason to change.
- A highly prescriptive framework is not supported.
- There must be a clear distinction between undergraduate versus graduate level qualifications. The value proposition in the domestic full-fee graduate market relies on this.
- Based on our use of the AQF, there is little value in pursuing new definitions, names of qualifications and general capabilities in the AQF.
- If there is to be a change it should be minimal and the case for the need for change should be better made to all post-secondary providers of education.
- If minor changes to the AQF were to be pursued in the future, the Go8 would be an active contributor to that process.
I trust this feedback is helpful in shaping ACER’s next steps in considering the potential revision of AQF architecture and taxonomy. If you have any questions regarding this submission, please do not hesitate to contact me at vicki.thomson@go8.edu.au or 0417 808 472.
Yours sincerely
VICKI THOMSON
CHIEF EXECUTIVE