Chapter Four

Implementing the Quality Standards: Possible Strategic Directions

 Introduction 

In the previous chapter, we have focused on developing a set of standards which can be used as the starting point for improving and assuring the quality of educational provision using distance education methods. The research group is, however, fully aware that the existence of such a framework in a vacuum is unlikely to make any contribution to improving the quality of provision using distance education methods. Consequently, in this chapter, we build on that work by suggesting various processes which, if initiated within the framework of the quality standards outlined in the previous chapter, we believe will facilitate the growth of quality distance education provision in South Africa. The first issue of importance in this regard relates to the establishment of the National Qualifications Framework (NQF) and the South African Qualifications Authority (SAQA).   

 External bodies focusing on assuring quality 

SAQA and the NQF 

In chapter one, we outlined the purpose of SAQA and the NQF, as well as describing some of the intended functions of National Standards Bodies (NSBs), Standards Generating Bodies (SGBs), and Education and Training Quality Assurance Bodies (ETQAs). We also pointed out that changes are occurring very frequently, with the result that ideas and statements rapidly become outdated. There is, however, sufficient consensus to allow for some consideration of how quality standards for distance education could most usefully play a role within SAQA and the NQF. 

Quality standards to support the ETQAs 

Clearly, the quality standards proposed in the previous chapter are the about the quality of distance education methods used in the provision of education and training and not a form of unit standard or qualification in themselves. This suggests that there is no specific use for the distance education quality standards framework in the work of NSBs and SGBs. Consequently, the most appropriate structures for integrating quality standards for distance education into the framework of SAQA’s operations are the ETQAs and the bodies to which they delegate functions.[1] SAQA has proposed that the establishment of any ETQA will depend on various principles and criteria. Importantly, it will depend on ‘advancing the objectives of the NQF as stated in the SAQA Act’.[2] These objectives include enhancing the quality of education and training, which covers both the structure and content of educational programmes and courses, and facilitating access to education and training. 

Clearly, such quality standards could support the work of ETQAs in several key areas, but particularly in: accreditation of providers in terms of quality management; facilitation of moderation across constituent providers; monitoring of provision; and the undertaking of quality systems audits. They would allow ETQAs in all sectors of education and training to operate within a common framework in these areas, thus standardizing SAQA’s efforts to build and assure quality in the use of distance education methods to provide learning opportunities. To work most successfully, the quality standards framework should not be used to support the work of ETQAs as part of a punitive set of quality control measures. Rather, it should be used as one supporting tool in developmental processes designed to build and assure the quality of educational provision in South Africa. 

The process might work as follows. An educational provider approaches the relevant ETQA seeking accreditation for its courses and programmes. As part of the process of accreditation, the ETQA requests the provider to complete a questionnaire derived from the distance education quality standards framework contained in the previous chapter. In considering the application, the ETQA decides that the provider’s qualifications meet the requirements of the unit standards developed by the appropriate Standards Generating Bodies. According to the findings of the questionnaire, however, it appears that, in certain areas, the structure of distance education provision does not meet the quality standards set out, and that this is creating unnecessary barriers to the success of potential learners. These deficiencies are, however, not considered serious enough to withhold accreditation. 

Consequently, the ETQA recommends to SAQA that the provider be accredited. However, it also indicates clearly those areas in which the methods used to provide courses and programmes is deficient. A provisional licence is granted to the provider, together with a clear statement indicating these deficiencies, supportive tools to help the provider improve its quality in this respect, and a deadline by which the required changes should be effected. The licence is then reviewed by the ETQA immediately after the deadline, and is either renewed or revoked according to progress that has been made by the provider in remedying the problems identified. 

We recommend, therefore, that the distance education quality standards be used by all ETQAs set up by SAQA as a supportive framework to enable them to assess better the quality of educational provision of providers seeking accreditation through SAQA. Of course, these standards should not be used in a vacuum, but as part of a broader process of considering all of the methods of educational provision used by a specific provider. As we have already suggested, experience indicates that conceptualizing all methods of educational provision as part of a continuum which has, as imaginary poles, distance education and face-to-face education is more useful than maintaining artificial distinctions between distance and face-to-face education. Thus, these quality standards would only be one tool used by ETQAs to assess the quality of methods used to provide education and training opportunities. We propose, therefore, that processes similar to this one be established to develop quality standards frameworks for face-to-face education and that, ultimately, they be integrated as a single quality standards framework which allows quality assurance bodies to follow different pathways according to the methods of provision used in the programme or by the educational provider concerned. 

The type of approach sketched out above is supported by the following statement from SAQA: ‘the accreditation of an ETQA will depend on, the separation of the quality assurance and provision functions to ensure that an ETQA is not a direct provider’.[3] Using the distance education quality standards framework successfully as part of SAQA’s work will depend on these external quality assurance functions not being coopted by educational providers with obvious conflicts of interest resulting. Thus, we fully support the move to establish ETQAs which are not direct providers on the basis that this is essential to effective use of the quality standards framework. 

It will, however, be necessary to take into account another proposed condition for the accreditation of an ETQA which is ‘the demonstration of need, capacity and viability’.[4] In analysing trends affecting distance education in chapter one, it became clear that, in general, the quality of distance education provision in South Africa leaves much to be desired. Thus, there is a strong argument to support the integration of assessment of the quality of distance education provision into the work of all ETQAs on the basis of need. Nevertheless, it is highly likely that the majority of people appointed to ETQAs will not be experts in, or even have any real experience of, distance education provision. In this regard, it might be argued that ETQAs will lack the capacity to perform this assessment. We believe that this should not become a stumbling block in the establishment of ETQAs. Rather, a professional agency might be appointed to support the ETQAs in their efforts to use the quality standards framework to assure the quality of distance education provision, particularly by developing the capacity of the ETQAs to do this work effectively through professional development programmes. 

The HRD strategy 

The HRD Strategy being developed by the Department of Labour includes two structures - Sectoral Learning Organisations and the HRD Council - which will relate directly with SAQA in various ways. Of most relevance is that the SAQA Liaison Committee, which is to be established by the HRD Council, is envisaged as playing a role in the accreditation of ETQAs. We believe that that the distance education quality standards framework can play an important role in supporting the work of these bodies, despite the fact that descriptions of them make no specific reference to distance education. Many of the ideas in the HRD Strategy (for example, the notion of learnerships) could be usefully enhanced by a clearer understanding of how best to build and assure the quality of distance education methods. Similarly, the clear relationships between SAQA and bodies proposed in the HRD Strategy indicate that it will be important for such bodies to develop a clear understanding of such quality issues as part of their liaison with SAQA and, more specifically, the ETQAs. 

Higher education quality Committee 

•       As was noted in chapter one,  the Green Paper on Higher Education has proposed the establishment of  a Higher Education Quality Committee (HEQC). The distance education quality standards framework could again play an important role in supporting the work of this Committee as one tool, amongst many, used to assess the quality of methods used to provide education and training opportunities. Indeed, the Green Paper notes that the HEQC should become the Education and Training Quality Assurer for Higher Education. Thus, we believe that the proposals made above for ETQAs in general also apply to the HEQC. Consequently, the quality standards for distance education should be used by the HEQC (and bodies to which it delegates functions) as a framework for assessing the quality of education and training making use of distance education methods.

Summary of recommendations 

•       There is, in current descriptions of SAQA structures, no use for the distance education quality standards framework in the work of NSBs or SGBs - and any effort to establish separate standards-generating structures for ‘distance education’ should not be supported.

•       The quality standards for distance education should be used by all ETQAs (and bodies to which they delegate functions) as a framework for assessing the quality of education and training making use of distance education methods.

•       In employing the framework, ETQAs should focus on developmental, ‘quality-building’ functions rather than using the quality standards as a set of punitive measures or as a gate-keeping mechanism.

•       Quality standards for distance education should ultimately be integrated into a broader framework covering the entire continuum of methods of educational provision - and this should allow users (whether from ETQAs or institutions) to construct their own quality standards frameworks based on the specific methods of provision being used by the educational provider or programme concerned.

•       An agency should be appointed by SAQA to run professional development programmes for ETQAs to build their capacity to use the distance education quality standards framework effectively in their work.

•      The various bodies proposed in the Department of Labour’s HRD Strategy should be familiarized with the distance education quality standards framework, both to support their general work and to strengthen their relationships with various SAQA bodies, particularly the ETQAs.

•       The quality standards for distance education should be used by the HEQC (and bodies to which it delegates functions) as a framework for assessing the quality of education and training making use of distance education methods.

 Legislative considerations 

There was, throughout the research process leading to this document, much discussion about the relative value of attempting to develop legislation for the distance education quality standards framework. Finally, however, consensus was reached that the pointlessness of setting universally applicable measurements for these quality standards means that it would not be possible to develop such legislation. It was also felt that legislation developed to enforce minimum standards would be likely to be unnecessarily prescriptive, without contributing to building and assuring quality in the use of distance education methods. This view is supported by the findings of the scan of international approaches to assuring quality in distance education (documented in chapter two), and has been integral to the approach taken to developing the distance education quality standards framework. 

Nevertheless, the reality remains that, in a country where educational levels are generally quite low, massive opportunities exist for exploiting students for financial or other gain. Consequently, some minimum legislation is required to lessen the possibilities of exploiting people’s desire to upgrade their levels of education and training. Of course, such legislation is not specific to distance education, but the recommendations made below are relevant for two reasons: first, because legislation specific to distance education provision, in the form of the Correspondence Colleges Act, already exists; and, second, because the physical separation of educational provider and learner heightens the possibilities of successfully operating exploitative educational practices. 

The Correspondence Colleges Act 

It is important that existing legislation be brought in line with the new South African Constitution, as this represents an essential first step in protecting the rights of South African people. Consequently, we believe that the process amending the Correspondence Colleges Act to achieve this should continue as a matter of priority. Nevertheless, the Act is flawed in various respects. First, it is limited to ‘correspondence tuition for reward’.[5] Although some private educational providers are covered by other legislation (private schools are, for example, covered by the new Schools Bill), no provision has been made for a range of other colleges and institutions offering education and training through methods other than correspondence. This discriminates unfairly against correspondence colleges. Second, the Act takes no account of the existence of SAQA. There is every likelihood that, given the functions of SAQA, the activities of the Correspondence College Council will need to be reviewed and amended once ETQAs are functioning effectively. 

We recommend that, in the light of these problems, the entire Correspondence College Act should be replaced, in the medium to long term, by an Act governing all private colleges and other private institutions not covered by existing legislation. When this happens, it will be possible to review the entire role of the Correspondence College Council, particularly in respect of the extent to which its roles have been taken over by developing SAQA structures. We envisage that its focus might broaden to take responsibility for registering all institutions governed by the new legislation, but that this would become an administrative function primarily intended to enable the country to keep track of private provision of education. Educational providers wishing to register with such a body would need to meet certain minimum requirements set out by the new legislation, but these would focus on protecting students by preventing the establishment ‘fly-by-night’ colleges, misrepresentative advertising, and other such exploitative practices. It would not extend to evaluating the quality of provision. 

In setting up and maintaining a database to perform these functions, however, the Council might keep a record of which colleges’ programmes are accredited by SAQA. As a further protection to students, the new legislation could also legally require all private providers to state clearly in prospectuses and other marketing material the accreditation bodies with which they are registered. 

The resulting legislation should also not discourage the establishment of councils and associations made up of the private providers themselves. Indeed, membership associations might continue to play an important role in respect of internal quality assurance processes, allowing private providers to develop their own codes of conduct and quality standards for educational provision. Any Act covering private colleges and other private institutions should make provision for, and recognize, such structures, as well as regulating their establishment. Structures already in existence which might play a role of this kind include the Association of Distance Education Colleges of South Africa (ADEC) and the Association of Private Colleges of South Africa (APCSA). 

We believe that responsibility for replacing the Correspondence Colleges Act with new legislation should be included in the terms of reference of the National Task Team on Further Education, particularly because most private educational provision by private providers of this type falls within the field of Further Education. The Task Team will be well placed to make more detailed recommendations on this during the course of 1997.  

Standardizing other legislation 

As has been mentioned in chapter one, there are several other Acts governing education, as well as various processes which are likely to result in new educational legislation. The discussion above has focused on ways in which new legislation replacing the current Correspondence Colleges Act might regulate the activities of private colleges offering education and training in South Africa. If legislation focused only on these providers, the effect could be that state-aided colleges and other institutions might become exempt from enquiry into complaints or allegations against them of improper conduct, particularly with regard to exploitation of students for financial or other gain. 

Clearly, there is a need to ensure that legislation governs the conduct of state-aided educational providers in ways that do not discriminate unfairly against private providers. The South African Qualifications Authority Act provides some of the legislation necessary to ensure this common legal treatment of private and state-aided providers of education and training. Nevertheless, once legislation for private colleges and other private institutions is enacted, it will be valuable to scan all planned legislation, and review existing legislation, to ensure that there is equality between private and state-aided institutions in terms of how they are regulated - even though the regulations themselves might vary. 

Importantly, this process of scanning existing and planned legislation could serve to ensure that any references to distance education provision is in line with the ideas contained in this document. In this respect, it might be looking not only to ensure that there is some regulation of the activities of distance education institutions, along the lines of what has been sketched out for private providers, but also that, where legislation appears to be unnecessarily prescriptive, this is amended.  The essential point is that such an activity should focus on standardizing legislation pertaining to the use of distance education methods. Ensuing legislation should make reference, where appropriate, to the existence and uses of the distance education quality standards framework in an effort to encourage its use at different levels within the education and training system.  

Funding and legislation

In chapter one, we noted that, in its proposals on funding, the National Commission on Higher Education recognizes a distinction between contact and distance education and a further distinction between ‘true’ distance education and correspondence education. This proposal has been made in the belief that the costs of ‘true’ distance education are much higher than those of correspondence education. It proposes that an investigation be conducted to test this hypothesis. Following this, the development of a new funding formula should examine the possibility of incorporating this differentiation in determining the funding of higher education institutions. These investigations are clearly important ones which might potentially have a significant long term impact on the nature of funding, not only in higher education but throughout the entire education and training system. 

In principle, we support the implementation, after appropriate research, of a funding formula which differentiates between correspondence and ‘true’ distance education. Clearly, though, there are several potential pitfalls in such an approach, depending on how it is implemented. We believe that the distance education quality standards framework outlined in the previous chapter could play an important role in supporting the implementation of a new funding formula based on such differentiation. By separating out those standards referring to distance and correspondence education from those referring exclusively to ‘true’ distance education, it could become possible to use the framework as the basis for distinguishing between the two ‘modes  of tuition’ for funding purposes. This could go a long way towards ensuring that the potential dangers of changing funding formulae according to this type of differentiation are not realized. In this way, it will be possible to ensure that new funding strategies work constructively to improve the quality of distance education provision in South Africa. 

Summary of recommendations 

•       The amendment of the Correspondence Colleges Act to be brought in line with South Africa’s new constitution should continue as a matter of priority.

•       In the longer term, the Correspondence Colleges Act should be replaced with an Act governing all private colleges and other private institutions operating in South Africa and not covered by existing legislation. The National Task Team on Further Education should be tasked with developing more detailed recommendations on the nature of the new legislation.

•       A review of existing legislation and scanning of planned legislation should be undertaken to ensure that there is legal uniformity in terms of distance education provision and in terms of the treatment of private and public providers of education and training.

•       As part of the investigation into funding formulae proposed by the NCHE report, the possibility of using the distance education quality standards framework as a tool to differentiate between correspondence and ‘true’ distance education for funding purposes should be investigated.

 Other departmental processes 

The technology-enhanced learning investigation

One of the key policy processes of 1996 was the release of a report by a Ministerial Committee on Technology-Enhanced Learning in South Africa. This report has been discussed  in chapter one, where reference was made to a decision-making framework and to various proposed initiatives. Both of these have relevance to this report. 

This decision-making framework is a comprehensive tool to facilitate decision-making about the use of different technologies in education and training programmes, regardless of whether the decisions are being taken at local, provincial or national level by government departments, single institutions, consortia of organizations, or individuals. It demands a rigorous approach to decision-making which takes account of all of the elements of the teaching and learning environment: the people involved (learners and educators, educational managers, course developers, and support staff, to name but a few), the teaching and learning processes, the course materials required, sites of teaching and learning, and the different elements of the educational provider such as management and administration. We believe that the distance education quality standards framework and the decision-making framework should be considered as complementary tools, and that the two might effectively be used together in planning and evaluating courses and programmes which make use of distance education methods. 

In addition, many of the initiatives proposed in the Technology-Enhanced Learning Investigation report are of direct relevance to the effective growth of distance education, as they focus on developing an enabling infrastructure which will support the development and use of distance education methods. In brief, the initiatives are as follows:

1.   Encouraging new approaches to making decisions by:

•       developing the ‘decision-making framework’ tool further,

•       running introductory workshops on the decision-making framework,

•       researching and evaluating the tool.

2.   Information networking projects:

•       establishing a clearing-house of information,

•       developing a technology-enhanced learning website,

•       conducting an audit of existing resources.

3.   Course design and development for the following courses:

•       a ‘technology-enhanced learning’ course for educators in all sectors,

•       an instructional design course, covering course materials design and development for a range of media and technologies,

•       a generic information literacy course,

•       a course on the professional development of community centre managers,

•       a course introducing the Internet to first-time users.

4.   Professional development of educators, educational managers, and support staff, administrative and technical, focusing on the following:

•       professional development of community centre managers,

•       a ‘technology-enhanced learning’ course,

•       an instructional design course,

•       an information literacy course.

5.   Promoting information literacy through the following activities:

•       developing an information literacy course,

•       developing an introduction to the Internet,

•       creating a information technology national qualifications framework.

6.   Encouraging research and evaluation by:

•       conducting research and evaluation in all proposed initiatives,

•       evaluating the SABC educational broadcasting plan.

7.   Using technology to support transformation of the management and administration of education and training by running a monitored provincial pilot project.

8.   Contributing to the development of  a network of community centres by:

•       surveying existing community centre initiatives,

•       establishing a macro coordinating function for educational contributions to community centres,

•       running professional development for community centre managers.[6]

An understanding of the potential of distance education methods, together with a grasp of quality standards for distance education provision will be valuable in the implementation of several of these projects. For this reason, we believe that planning to take forward the work of the Technology-Enhanced Learning Investigation should actively integrate the distance education quality standards framework wherever feasible and appropriate. 

The learning charter 

One of the activities targeted by the Department on Education for 1997 is to draw up a learning charter, the primary purpose of which will presumably be to protect the rights of learners. In some countries, such charters have been drawn up specifically for learners enrolled in programmes offered at a distance, while many institutions around the world have also developed learning charters in conjunctions with their student bodies. 

We support the development of such a charter for South Africa, as it is a vital mechanism for safeguarding the rights of students. In keeping with the general spirit of this document, we do not believe that a separate learning charter is required for students enrolled in programmes offered at a distance. Nevertheless, given that such students are usually geographically dispersed and, due to delays in communication, often particularly prone to exploitation, we do believe that the learning charter which is developed in 1997 should take special cognisance of their rights and needs. As an extension of this process, distance education institutions should be encouraged to draw up their own learning charters in conjunction with student bodies representing students enrolled at their institutions. In both cases, the distance education quality standards framework should be used as the basis for drawing up such documents. 

Summary of recommendations 

1.   The work of this project and that of the Technology-Enhanced Learning Investigation should be regarded as complementary. Specifically:

•       the possibilities of using the decision-making framework and the distance education quality standards framework together in planning and evaluating courses and programmes which make use of distance education methods should be examined;

•       integration of the distance education quality standards framework into the initiatives proposed by the Technology-Enhanced Learning Investigation should take place wherever feasible and appropriate.

2.   Learning charters should be developed in an effort to protect the rights of students enrolled in educational programmes offered at a distance. Specifically:

•       the national learning charter to be drawn up in 1997 should make specific reference to the rights and needs of such students; and

•       distance education institutions should develop learning charters in conjunction with their student bodies. 

      In both cases, the distance education quality standards framework should be used as basis when such charters are developed. 

 Conclusion: Internal quality assurance processes 

A clear trend emerging from the analysis of international experience of quality assurance was a growing move towards internal processes of quality assurance. This move has resulted from an awareness of the limitations of external quality assurance procedures such as those outlined above. The research group believes that this shift is also an important one in the context of South African education and training, and therefore recommends that the establishment and growth of processes of building and assuring quality within institutions be encouraged at all levels of the system. This should not be limited to those institutions using distance education methods, but, for those which are, the distance education quality standards framework could be used as a basis from which internal quality assurance processes might develop. 

Internal quality assurance processes are very complex, detailed discussion of which is beyond the scope of this document. They need to be carefully structured with a clear sense of purpose. Self-evaluation might help an institution prepare for external audit, but should, more importantly, also contribute to the continuous improvement of the teaching and learning processes in the institution. Quality assurance should be built from the bottom up by concern for quality within departments and course development and delivery processes. In addition, however, there needs to be a top-management focus on the whole institution to ensure consistency and to minimize duplication of efforts across the institution. 

In addition, bottom-up quality assurance cannot take place without staff development - but the development needs to be focused on the tasks at hand. Thus, it should aim to educate staff for the particular work or roles they will perform. If an institution is very unused either to distance education practice or to quality assurance, staff development might have to be very extensive. If an institution deals with external clients or teams drawn from outside as well as inside (such as mentors or part-time tutors), particular care needs to be taken to provide training to these teams, as well as to provide clearly defined checkpoints at various stages in the process. 

The research group believes that the development of internal quality assurance processes should be actively encouraged at all levels of the education and training system, supported by tools such as the distance education quality standards framework provided in this document. Due account needs to be taken of the complexity of implementing such processes, but it is vital that this does not become an impediment to progress. By way of conclusion, it is worth quoting from a collection of essays on quality assurance in higher education. Although aimed at higher education, the following observation is more generally applicable:

It is critical for South Africa to start the process of quality assurance immediately.  Institutions should be warned against a tendency in South African Higher Education to wait for someone else to decide what has to be done. Instead of waiting, institutions and programmes should start a self-evaluation process of looking at themselves within themselves.[7] 

Summary of recommendations 

•       All educational planners and decision-makers should actively encourage the ongoing development of internal processes to build and assure the quality of education and training at all levels of the system.

•       Internal quality assurance processes implemented by institutions using distance education methods should be based on the guidelines provided in the distance education quality standards framework.

 Footnotes 

[1]Refer to the SAQA Consensus Document dated 8 November, 1996, which makes provision that ‘an ETQA may, with the approval of SAQA, delegate selected functions to a provider or other body’.

[2] ibid.

[3] ibid.

[4] ibid.

[5] National Education Department, 1965, Correspondence Colleges Act, Act No. 59 of 1965, p. 1.

[6] For full details, consult: Ministerial Committee on Technology-Enhanced Learning, 1996, Technology-Enhanced Learning in South Africa: A Discussion Document, pp. 97-116.

[7] Strydom, A.H. Lategan, L.O.K. & Muller, A. 1996, Quality Assurance in South African Higher Education: National and International Perspectives, Bloemfontein, University of the Orange Free State, p. 375.