A:
Name: Jim Flanagan
Title (Mr/Ms/Mr/Dr/ etc): Mr
Position (if applicable): Director
Organisation (if applicable): Teagasc
Address: 19 Sandymount Avenue, Ballsbridge, Dublin 4
County: Dublin
Telephone: 01 6373000
Fax: 01 6603673
Email: jflanagan@hq.teagasc.ie
WWW: teagasc.ie
Date: 10/06/03
Is this submission a personal view or is it made on behalf of your organisation?
Organisational
Submission: Fees Review - Review of Fees to be Charged by the Further Education and Training Awards Council and the Higher Eduction and Training Awards Council.
Appendix 2 - Fees Review
Question 1 - Functions of Awards Councils
Do you agree with the description of the functions of the awards Councils described in this chapter? Are there other functions which the Authority should consider? Do you agree with the analysis of these functions as set out in this Chapter? How should this analysis be developed further?
Teagasc agrees that the main functions of the two awards councils are as set down in the Qualifications (Education and Training) Act 1999. However, in some instances, the description of the functions underestimates the extent of the major providers involvement/interaction with the Councils and the Authority. This is particularly so during the establishment phase of the Authority and the Councils. In addition the major providers will have a major work load when the time comes to determining standards for awards. Currently with some providers the 'assessment of the learner' process - setting, administering and correcting exams, inservice training, internal and external verification - is fully funded by the provider with no examination/award fee charged to the learner.
In relation to 'delegation of authority' the development of policies and criteria for delegation of authority should be regarded as a service and should not be charged for. Providers seeking 'delegated authority' could justifiably be subject to a charge from the Councils.
A function, which is not mentioned in the 1999 Act, which could be included under the functions is the provision of a technical support service to providers. Areas where technical support might be required include - quality assurance, validation, assessment of people with disability, candidate appeals, etc.
Further Development Analysis
1. Establish the position in relation to fees charged by providers whose awards are now FETAC awards and their rational for charging/not charging fees.
2. Establish a consultative group, under NQAI, to input into recommendations on fees to be made to the Department of Education and Science.
Question 2 - Issues Arising
Do you agree with the range of issues identified in this chapter? Are there other issues which the Authority should consider? Do you agree with the discussion on the issues set out in this Chapter? How should this discussion be developed further?
The issues identified are the main issues. However, the issue of increased cost on further education and training providers due to the establishment of FETAC should be included. Additionally the issue of involvement/input of some providers with NQAI and FETAC should be discussed.
More discussion needs to be given to the diversity of learners and the implications of the imposition of fees for categories of learners.
The assumptions under 'volume of providers/learners availing of services of Councils' may be wide off the mark. A fee structure may not lead to 'increasing demand on the Councils from new and emerging providers'.
Further development of the discussion
It is imperative that a wide range of stakeholders - particularly the small providers, are consulted to enable their views to be adequately aired.
Question 3 - Consideration of Way Forward
Do you agree with the possible principles set out, in relation to the approach should be taken by the Authority in recommending a balance for the funding of the Councils between fees on the one hand and grant on the other? Should these be further developed or are there other principles which the Authority should consider? What is your view on the options set out? Do you agree with the analysis of the options? What steps do you think that the Authority should take now?
Principles
While Teagasc agrees with some of the principles outlined it could not agree with the following 3 principles:
(i) 'Those availing of the services of the Councils to pay fees ??. and the level of fees to be paid linked with the extent of the services provided'. This would lead to learners of small providers having to pay higher fees than learners of larger providers.
(ii) 'Where a provider has a programme ??? any charge which is passed on to a learner would be a matter for the provider'. In all justice this could not be a principle which Teagasc could agree with.
(iii) 'Where a State is funding providers ??? that any costs are not passed on to them'. There is no equity in this principle for disadvantaged learners with providers who are not funded by the State. In any event funding of fees for disadvantaged learners should go directly to the Councils and not be routed through the providers.
Teagasc is of the view that there should be principles on:
(i) Equity for learners and providers
(ii) Access, transfer and progression
(iii) Ease of administration of fees.
All the principles outlined in the NQAI document need to be further developed and discussed.
Options
Of the 4 options set out Option 3 is the best. Teagasc would propose a variation of Option 3 i.e. if fees must be charged. Have a single composite charge for learners across all providers and across all levels within each of the Councils. The fee level should relate in some way to the credit system when it is agreed. There should be no separate charge for validation or for procedural agreement of quality assurance. These are effectively a once off charge and are difficult to levy on learners especially for small providers or programmes with small numbers of students.
Teagasc has no difficulty with one-off charges associated with:
Following feedback from interested stakeholders NQAI should establish a consultative group to discuss issues further.