DHET Directive on pre-2009 (legacy) qualification transition arrangements

The Department of Higher Education and Training has finally gazetted the long-anticipated Directive confirming the transitional arrangements for pre-2009 qualifications to be replaced by qualifications in the Quality Council for Trades and Occupations (QCTO) occupational qualification format. Please see the document attached.  

The document first spells out the history of the transition, which commenced with the National Qualifications Framework (NQF) Act 67 of 2008, which repealed the South African Qualifications Authority (SAQA) Act 58 of 1995. The NQF Act recreated SAQA, and created three quality councils responsible for three sub-frameworks of the NQF - one of which is the QCTO, and provided for transitional arrangements regarding qualifications to take place between SAQA and the QCTO. 

The NQF Act was followed in 2012 by the creation of a ten level NQF, replacing the eight level NQF and requiring all qualifications on the old framework to fall away and be replaced. This officially - although not in practice - was the commencement of the occupational qualifications under the QCTO. Replacement was originally to take place by 2015, extended until 2018, and then finally to end 30 June 2023. Registration for the old qualifications to take place until 30 June 2024, with teach out until 30 June 2027.

The position from the point of view of the private Skills Development Providers (SDPs) is that all the pre-2009 qualifications have not been replaced, and the large number of regulatory unit standards have not been converted into skills programmes. These regulatory unit standards are essential for employer compliance with Department of Employment and Labour requirements in a large number of areas, including all the moving machinery lifting operations, such as cranes, forklift trucks, and so on. 

The document does concede that the SETAs have been slow to produce the qualifications - there is certainly a flurry of activity currently. 

What is particularly problematic is that there does not appear to be one place where one can see:

• which programmes are in progress with each SETA,
• what programmes have been identified by SETAs as not requiring replacement at all,
• what regulatory unit standards are in progress with each SETA,
• are there any regulatory programmes that are falling away - and if so, why?

An additional problematic issue is the QCTO requirement that all Skills Programmes should be at least 8 credits, i.e. 80 notional hours. (10 notional hours - 1 credit.) This will substantially increase the time required away from work - a major issue for employers, losing both employee working time, and  unproductive costs during the extended training period. Additionally, the new skills programmes will not be registered on the NQF.

The QCTO does have the new occupational qualifications registered on their very sophisticated website, but there is no one place where all the questions are being answered. 

SDPs have protested and submitted a detailed presentation and signed representation to the DHET, requesting a further extension; the response has been very slow in coming and does not grant that request.

Annexure A sets out the various options, pre-2009 qualifications:

• those already replaced will fall away, a statement refers to the Department of Finance request for an extension of the enrolment date - the meaning is unclear;
• those that have not been used (dormant) will fall away;
• those not related to SETAs (e.g. professional bodies) still require investigation and confirmation;
• those not prioritised by SETAs also require further clarification;
• those that are in process may have the registration date extended - on a case by case basis, and applies to NATED programmes as well;
• all provider-based qualifications will fall away; and
• as mentioned above, regulatory programmes may be converted into skills programmes.

The failure to grant the full blanket extension is quite reasonable, and unnecessary as a number of qualifications have been completed and registered already, and further qualifications are in progress. The problem will, however, arise with the accreditation of private providers to present the newly registered qualifications, as there are also new requirements for accreditation. 

The Directive admits that despite the SETAs being aware from 2009 of the QCTO implementation; being specifically charged with the qualification redevelopment since 2018 to complete by 2023; and further charged by the Ministerial Determination to complete; the SETAs " ... they have not all adequately taken up this function" (Clause 1.8). 

Finally, the directive states that the remainder of the directive from this background puts in place "... a structured process to track and support the full implementation and transitional arrangements" (Clause 1.9).  

This is essentially a major project that needs to be managed as such, and there is a need for a more transparently managed process, with regular progress reports. 

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