Bundesinstitut für Berufsbildung (BIBB)

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47/ 2005
Bonn, 16.12.2005

European Qualifications Framework (EQF)

- Official position of the board of the Federal Institute for Vocational Education and Training -

In its meeting of 14 December 2005, the board of the Federal Institute for Vocational Education and Training (BIBB) dealt with the topic of the "European Qualifications Framework" (EQF) and came to a conclusion as to its official position regarding the matter.

The text of the official position of the board with regard to the "European Qualifications Framework" (EQF) is as follows:
The board of the Federal Institute for Vocational Education and Training welcomes the development of a European Qualifications Framework, believing it represents a comprehensive instrument which will aid transparency, comparability and translation, promoting occupational mobility on the European labour market as well as occupational mobility between the various training systems themselves. This dual aim, however, can only be realised if, in school-based and academic training, sufficient weight is given to workplace related qualification processes within initial and continuing training.

The board's view is that the structure of the EQF also offers potential at a national level for promoting transferability between initial and further vocational training and higher education. At a national level, tried and tested forms of occupational qualification and extensive professional action competence (in line with the principle of the regulated occupation) need to be more firmly established. Social responsibility is an indispensable factor for vocational training.
If these conditions are fulfilled, the board is in favour of developing a cross-occupational national qualifications framework for the Federal Republic of Germany.

The board advises the Federal Government in fundamental issues relating to vocational training, requesting involvement in the subsequent secondary formulation of the official German position within the EQF consultation process at a European level. In view of the short deadline set by the Commission and the wide-ranging implications of the proposals, the board reserves the right to make further statements as to its official position. The success of a national qualifications framework, however, substantially depends on the close integration into the national and European opinion shaping process of all the major stakeholders in the area of initial and continuing vocational education and training, in particular the federal states and economic and social partners. In particular, the board of the Federal Institute for Vocational Education and Training calls upon the Federal Government to make provision within the scope of European training policy for procedures ensuring the participation of the stakeholders in the field of initial and continuing vocational education and training mentioned above in the national decision-making process.

The basic principle of the EQF

1. Are the major aims and functions which an EQF needs to fulfil identical with those submitted in the consultation document?

•  According to the Commission's draft version, a positive aspect is that the aim of the EQF does not merely focus on training cooperation and mobility between the various training systems, but also encompasses cross-border mobility on the European labour market.  In light of the fact that EQF is to serve as an instrument of transparency, comparability and translation, we propose that it is logical for it to include learning outcomes acquired in workplace related qualification processes ("employability").
• The EQF will only be in a position to fulfil the function of an instrument of transparency, comparability and translation as mentioned above if the levels are able to map the training systems of all member states. On this basis, the EQF should make it clear that, in line with the principle of lifelong learning, all levels are achievable via a variety of training paths (in-company or school-based training and further vocational training or academic education).

2. Which measures need to be put in place to enable the EQF to work in practice (for individual citizens, education and training systems and the labour market)?

• Assuming the EQF needs to be suitable for the recognition of learning outcomes achieved in workplace related qualification processes (response to question 1), descriptors should also be developed for Table 1 which specifically map professional action competence acquired during working life. In line with the justified approach of the Commission, these may also be descriptors formulated in a sufficiently general way so as to reflect the multiplicity of national and sector-based qualifications.
• Close integration of economic and social partners in the consultation and decision-making process both at European and at a national level is crucial to the acceptance of national qualifications frameworks. The function of the EQF as an instrument of cross-border mobility on the European labour market can only be fulfilled if learning outcomes are also recognised in terms of their relevance to the world of work and employment.

3.  Reference levels and descriptors
Does the structure of the EQF, which is described in terms of eight reference levels, reflect the complexity of lifelong learning in Europe?

• Clarification that all levels are achievable via a variety of training paths (in-company or school-based training and further vocational training or academic education, as in response to question 1) is more significant than the number of levels themselves.
• In addition to this, the number of levels in which weighting is applied to lifelong learning is of significance. In the Commission's proposal, however, there are four levels relating to a basic level of qualification and an equal number of levels encompassing further training and academic education. More scope should be accorded to learning via occupational experience in the way in which the descriptors are designed.

4. Do the descriptors for the individual levels of Table 1 describe learning outcomes and the differences between different levels in an appropriate way?

• The proposed descriptors require reworking and amendment. As things stand, there is no overall harmonious qualitative increase between individual levels (for example from level 3 to 4 in the responsibility subcategory). Sometimes different stages are even addressed within the same level (for example, in the "independence" and "responsibility" subcategory in level 4). Experience based ability should not be categorised lower down the scale than cognitively acquired skills.
• If they are to expressed in concrete terms via national qualifications frameworks, there also needs to be a guarantee that the descriptors are easy to handle and are capable of being implemented in practice in accordance with objective criteria and procedures.
• For this reason, it is necessary to investigate whether an additional quantitative descriptor subject to objective criteria and procedures should be introduced to supplement the qualitative descriptors.
• With regard to a national qualifications framework, the descriptor system in particular requires an intensive process of development and testing. We propose the Federal Government sets up a support programme involving the federal states and the economic and social partners with this aim in mind.

5. What should be the nature and role of "additional and explanatory information" (or supplementary information) on training, initial and continuing training, the learning structure and input (Table 2)?

• A point of criticism is that Table 2 uses input oriented information, which places the main emphasis on formal qualifications and places of learning within a classification. We regret that this counteracts the desired outcome oriented descriptive approach of the EQF. For this reason, Table 2 needs to be deleted.
• Using Table 2 to express the descriptors in concrete terms would lead to the same learning outcomes being classified under different levels in the EQF within the individual member states, depending on the place of learning and qualifications. This would mean that the aim of the EQF, to create greater transparency of qualifications, would not be achieved.
• In addition to this, the classification of national qualifications and other skills is a matter reserved for the member states and is based purely on a level determined within a national qualifications framework. From a German point of view, a particularly important aspect is that in terms of international comparison, when learning outcomes are categorised in a national qualifications framework, it is possible to classify dual training and continuing training qualifications in line with the skills levels of school-based vocational education and training and higher education qualifications of other member states.
• For this reason, the EQF must not contain even any indirect stipulations restricting the decision-making parameters of the Federal Government with regard to the classification of training and further training qualifications within the dual system of vocational education and training in a national qualifications framework or diminishing the value of these qualifications in European comparative terms.

6. How can your national and sector based qualifications be classified in terms of the proposed EQF level and the descriptors relating to learning outcomes?

• From a German point of view, it is crucial that the function of the EQF remains restricted to that of an instrument aiding transparency, comparability and translation. For this reason, learning outcomes achieved at a national level or sector based qualifications are directly and exclusively classified in terms of a national qualifications framework rather than according to the EQF.
•  The descriptors for the levels need to be formulated in such a way that formal qualifications acquired within the scope of certain training paths are not reserved for individual levels. It would, for example, be unacceptable for levels 6, 7, and 8 to encompass the three cycles of the Bologna qualifications framework exclusively. It is far more important to subject academic qualifications to rigorous checks, in the same way as all other qualifications, in order to ascertain whether their individual learning outcomes fulfil the requirements set by the descriptors relating to the respective reference level, particularly with regard to employability (response to question 1).
• In order to take more account of the aspiration of lifelong learning, occupational experience should be a compulsory pre-condition for achieving the highest level.
• In order to enable German dual training and continuing training qualifications to be evaluated in line with the skills levels of school-based vocational education and training and academic qualifications of other member states, it should be possible to achieve all levels within the EQF via different training paths (response to question 1).

National qualifications frameworks

7. Building upon the principles of the EQF, how can national qualifications frameworks for lifelong learning be developed in your country?
 
In Germany, development of a national qualifications framework should take place with the close involvement of the major stakeholders. In the area of initial and continuing vocational education and training, these are predominantly the federal states, economic and social partners, linked together by the Federal Government. The process should also investigate whether and to what extent results from national, regional or sector-based projects can be used to advance the preparation of a national qualifications framework.
 

8.  How and within which period of time can your national qualifications system be developed in the direction of a learning outcomes centred approach?

A particularly important factor for a learning outcomes related national qualifications framework is the recognition of formal and non-formal learning. The board proposes that the Federal Government commissions the Federal Institute for Vocational Education and Training to draw up a survey of the instruments and methods used for the measurement and evaluation of formal and non-formal learning, involving the federal states and economic and social partners in the process, and to submit proposals for further activities to the board.
Sector based qualifications

9. To what extent can the EQF act as a catalyst for developments at a sector-based level?

10. How can the EQF be used to support a more systematic development of knowledge, competence and skills at a sector-based level?

11. How can stakeholders at a sector-based level be integrated into supporting the introduction of the EQF?

12. How can the link between sector-based developments and national qualifications be improved?

• In order to be able to make a final evaluation of the effects the EQF will have at a sector-based level, it would be desirable if the EQF included a practically manageable definition of the term sector.
• There is a minimum initial risk of parallel structures if sector-based initiatives are developed independently of a NQF.
• This particularly applies if there is to be a "clear and verifiable link between sector based frameworks and EQF levels", as detailed in the Commission draft. Such a link would be a contradiction of the basic principle that learning outcomes can only be classified within the national qualifications frameworks.
• Due to their international networks, sector-based initiatives can, however, make valuable contributions to the development of NQF's and cross-border mobility.

Mutual trust
 
13. What contribution can the EQF make to the development of a climate of trust (on the basis of joint quality assurance principles, for example) between those involved with lifelong learning at European, national, sector and local levels?

14. How can the EQF become a reference for quality improvement at all levels of lifelong learning?

• It needs to be underlined that decisions relating to the introduction of a quality assurance system and to procedures to monitor such a system remain a matter for individual member states.
• Consequently, the decision as to whether it is sensible to introduce quality assurance principles for the application of the EQF at a European level beyond the higher education sector remains with the member states. Before taking such a decision, it would be necessary to monitor whether the existing quality assurance instruments within member states were sufficient for reciprocal recognition and a climate of mutual trust.
• A main characteristic of the system of vocational education, training and continuing training in Germany is that the Federal Government and the federal states closely involve economic and social partners in the development process of state regulations relating to further training, thus guaranteeing that the contents of initial and further training regulations are in tune with the current requirements of companies providing training and are in line with the latest training research.