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Connecting lines between the DQR and the Recognition Act

Georg Hanf

The debate surrounding the German Qualifications Framework (DQR), which took place in the autumn of 2011, centred solely on the - relative - value of the upper secondary school leaving certificate within the structure of the German qualifications system. This completely lost sight of the fact that the German Qualifications Framework has its origins in the European Qualifications Framework (EQF) and pursues objectives and purposes which are not merely national. Germany subjected itself to the European process in order to improve the comprehensibility and comparability of qualifications of the different countries within the respective other countries and thus foster the mobility of citizens. The DQR debate coincided with preparations for the "Law to improve the assessment and recognition of vocational education and training qualifications acquired abroad" (BQFG). Although the two processes took place completely independently of one another, the correlations are obvious. It is precisely these correlations that the present paper will attempt to make clear.

Recognition - equivalence

A distinction may be drawn between 'strict' and 'soft' recognition of vocational qualifications acquired abroad. Recognition in the strict sense of the word means legal equality, whereas soft recognition refers to an agreement that qualifications are equivalent in principle.
Legal recognition applies, for example, in the case of regulated occupations, i.e. occupations which cannot be exercised without specific certification. It involves certain procedures, such as those regulated in the EU Directive 2005/36/EC on the recognition of professional qualifications, and has also been included in German legislation within the scope of the new BQFG.
The EQR covers non-regulated occupations at a European level and has created an instrument for the transparency and therefore for the establishment of equivalence of qualifications. The qualifications framework approach, however, does not play any part for non-regulated occupations in the BQFG. The mechanism contained within the EU Directive has instead also been transferred to such occupations.
A look back into history would appear useful in order to obtain a better understanding of 'recognition' and 'equivalence' within the European context (cf. box).

'Recognition' and 'equivalence' within the European context - a look back into history

In its early days, the European Community attempted to harmonise training within key areas. Since the national systems wished to retain curricular sovereignty, however, a new process was adopted whereby recognition regulations were issued for individual occupations. These culminated in the integrated Directive of 2005. For vocational qualifications not covered by this Directive, especially relating to occupations at skilled worker and skilled employee level, an information system comprising five levels was established in 1985 in the form of the Council Decision on the "comparability of vocational training qualifications between the Member States of the European Community". This brought together a description of prior learning requirements and employment destinations. The 'equivalences' of qualifications enshrined within this Council Decision enjoyed only partial acceptance and were ignored by Germany. The equivalence procedure was halted in 1992 (cf. WESTERHUIS 2001).

This initially seemed to be the end of the line for recognition in the field of non-regulated occupations. Nevertheless, the Commission continued to pursue this objective below the level of qualification by bringing about a paradigm shift which saw qualifications become competences and ultimately learning outcomes. Learning outcomes and levels of learning outcomes are the principles upon which the European Qualifications Framework and all national qualifications frameworks are constructed. Learning outcomes are described irrespective of how they are acquired, the basic assumption being that they are capable of being credited to or 'recognised' within another context. The aim is for this to apply to learning outcomes which are bundled to form qualifications, to parts of such bundles (credit transfer) and to learning outcomes which have been acquired by non-formal and informal means and which can be related to qualifications.
Recognition and equivalence of qualifications therefore belong together, although they represent different principles. "Whereas the principle of recognition is derived from thematic translatability, the principle of equivalence and transparency is based on the principle of negotiation" (cf. HARNEY 2000, p. 52).
Recognition is time-consuming. The EU Recognition Directive of 2005 runs to 121 pages in the Official Journal of the European Union, whereas the 2012 Directive amending the Directive takes up 71 pages. By way of contrast, the EQF Recommendation manages with only seven pages. It is clear that the EQF is in pursuit of the principle of equivalence, albeit at an extremely high level of abstraction.

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EQF Recognition Directive - DQR - BQFG

Although qualifications frameworks do not themselves contain any recognition mechanism, they are able to offer basic information for individual credit transfer rights by acting as a transparency instrument. What now are the explicit correlations which exist between the Recognition Directive and qualifications frameworks, both of European and national kinds?
As early as the beginning of 2005, even before the first draft of the EQF was available, the German Confederation of Skilled Crafts (ZDH) went public with a decisive plea for a national qualifications framework (cf. ESSER et al. 2005). The Vocational Training Department at the ZDH believed that the competence orientation of the qualifications framework approach represented a suitable way of presenting the value of German qualifications in an internationally appropriate form. The plan was for this to counter the Recognition Directive being negotiated at the same time, the five-level educationally oriented classification of which aligned the German qualification of master craftsman in the craft trades to level 2, the same level as a journeyman1.  For this reason, appeals were also made during the subsequent period for the national qualifications framework to be structured in a "clearly labour market oriented" manner and for it to be taken as a benchmark for a revision of the Recognition Directive (cf. SCHLEYER 2008).
At a European level, the developments of the Qualifications Framework and the Recognition Directive continued independently of each other in different Directorate Generals (Education and Culture and Internal Market). The Directive was adopted in 2005, when the EQF was still in its infancy. For this reason, it is the final version of the EQF (European Parliament and Council 2008) which contains a reference to the other document rather than the Directive of 2005. It its opening section, the Recommendation on the establishment of the European Qualifications Framework for lifelong learning states that development and recognition of knowledge, skills and competences "should facilitate transnational mobility for workers and learners" (p. 1), and goes on to say that "the objective is to create a common reference framework which should serve as a translation device between different qualifications systems and their levels" (p. 2), although: "This Recommendation is without prejudice to Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional qualifications.  Reference to the European Qualifications Framework levels on qualifications should not affect access to the labour market where professional qualifications have been recognised in accordance with Directive 2005/36/EC" (p. 2).
In the Proposal to amend the Recognition Directive (cf. European Parliament and Council 2011), consideration is now accorded to the EQF which has in the meantime been adopted. It is stated that the five levels contained within the Recognition Directive "should have neither effect upon the national education and training structures nor upon the competence of Member States in this field, including a national policy for implementing the European Qualifications Framework". The levels established for the operation of the general system should in principle no longer be used as a criterion for excluding Union citizens from the scope of Directive 2005/36/EC when this would be contrary to the principle of lifelong learning (cf. p. 17).
The "Law to improve the assessment and recognition of vocational education and training qualifications acquired abroad" (BQFG) relates in many ways to the European Recognition Directive. The European procedures are, in principle, generalised within a national context. This means that functional, formal and material equivalence between 'foreign' and German qualifications are checked and certified where necessary. The BQFG does not, however, contain any references of any kind to the German or European Qualifications Framework.
The introductory passage to the German Qualifications Framework (DQR) states that the DQR is a "national implementation of the European Qualifications Framework", assists in "achieving appropriate evaluation and comparability for German qualifications in Europe" and thus helps "promote the mobility of learners and employees between Germany and other European countries" (DQR Working Group 2011, p. 1). At the same time, it is emphasised that the DQR "should not (sic!) replace the existing system of access qualifications" (p. 4). The consequences of 'appropriate evaluation' remain excluded. This is applied to the educational system, but can also be transferred to the employment system, the terrain of the BQFG.

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National qualifications frameworks worldwide - significance for recognition

As already stated above, qualifications frameworks may be interpreted as an instrument for the 'soft recognition' of foreign qualifications on the basis of a fundamental equivalence of requirements levels. This is precisely what happens in many countries in the world, in countries characterised both by immigration and emigration. There are today approximately 120 countries which have such a framework in place, are in the process of developing such a framework or else are considering the development of such a framework (European Training Foundation 2012).
Some countries which have already developed a national qualifications framework make clear statements regarding the use of the national framework and the EQF for the recognition of qualifications. The Danish 'Referencing Report' on the alignment of qualifications to levels has the following to say: "The Danish Qualifications Framework is facilitating mutual recognition between Danish and non-Danish qualifications" (Danish Evaluation Institute 2011, p. 14).
The Irish Referencing Report contains a similar comment: "The NFQ provides the main reference point for recognising international qualifications in Ireland: the qualifications recognition service, provided by the Qualifications Authority, utilises the NFQ in offering recognition advice to migrants, educational providers and employers" (cf. National Qualifications Authority of Ireland 2009, p.12).
The worldwide development of qualifications frameworks is bringing about a context of communication between countries. This will mean an improvement in the prerequisites for 'recognition' in the medium term.

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A 'common language' of learning outcomes/competences?

For all those seeking 'recognition' of their qualification/competence in another country, the qualifications framework approach contains an inherent promise that such a goal will become closer via the use of a common language of learning outcomes.
The language deployed in the learning outcomes descriptors of the EQF is extremely abstract. The EU Commission is now undertaking an attempt to become more specific by introducing a detailed nomenclature to relate the requirements of the (European) labour market and the results of learning processes (in different educational systems) in the form of the ESCO-Initiative (European Typology of Skills, Competences, Occupations) (European Commission 2010). Although a 'common language' differentiated in such a manner could foster the transnational 'recognition' of qualifications and competences, can this language really act as a vehicle for the transfer of national qualifications from one national context to another? Can a common language of this type exist at all? Whereas globalisation promotes the possibility and necessity of communicating about training and qualifications, the other side of the coin is that communication difficulties persist. Even given careful translation and identical terminology, "translation is only able to encapsulate cultural context(s) in an inadequate manner" (cf. CLEMENT 1999, p. 210).
The EQF, which aims to use a common learning outcomes language to relate all qualifications within national systems according to type and level, is giving rise to questions regarding the transnational validity of the categories on which it is based. This even applies to the core terms of knowledge, skills and competence - the relevance of and connotations attached to these terms within the various systems vary enormously - and is even more true when they are broken down to individual occupations (on this problem area cf. BROCKMANN/CLARK/WINCH 2011).
Proper use of qualifications frameworks is reliant on information on the contexts from which the qualifications originate. There is (thus far) no talk of this within the scope of the DQR. In the wake of the implementation of the BQFG, however, such information is being provided on behalf of the Federal Ministry for Economics and Labour by the Cologne-based German Institute for Business Research in the form of the 'Country and occupations information' included on the portal for foreign vocational qualifications (BQ Portal), where it forms the knowledge basis for identification and recognition by the competent bodies (cf. MICHALSKI/RIESEN/STRAUCH in the present publication).

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Qualification types - the bridge between levels and individual qualifications

The German Qualifications Framework would fail to make use of its opportunities were it to be reduced to placement of existing qualifications on one of the reference levels. Many possibilities are conceivable for making full use of its potential. The intention here is merely to indicate one possibility for further development which would enable a convergence of the DQR and the BQFG.
Because of the highly abstract leaning outcomes descriptors necessarily used in the EQF, although relating qualifications of different countries via alignment to a reference level provides basic information about relative value, this remains extremely vague. We would come closer to establishing 'equivalence' if types of qualifications were defined and described for the respective levels (in all countries).

This has, for example, happened in Ireland, where four categories of qualifications or qualification types were defined in the process of developing the NQF. These are as follows.

  • Major award types: main qualifications (e.g. the Leaving Certificate)
  • Minor award types: parts of major awards
  • Supplemental award types: types of additional qualifications
  • Special purpose award types: special qualifications for clearly defined purposes

Each qualification type is defined on the basis of a set of characteristics.

  • For whom is the qualification type?
  • What is its significance and purpose?
  • Where is it normally acquired?
  • What are the typical learning outcomes (knowledge, skills, competences)?
  • By which other qualification types could it be followed?

Although the grid used to identify occupational information in the BQ Portal contains categories which are very similar in nature, the focus is always on the individual 'occupation' or qualification. 1:1 equivalence of individual qualifications, however, occurs only in the rarest of cases. For this reason, it would appear useful to define qualification types to act as an abstraction level between the individual qualification and the DQR/EQF level. What are the essential characteristics of a skilled worker qualification? How are parts ('modules') of qualifications defined? What types of additional qualifications are there? This could support the assessment procedure by enabling (partial) comparability to be established in the case of non-accordance of initial and target qualification and would make the search for reference qualifications easier for those seeking recognition (and their advisors).
In his classification of qualifications frameworks, DAVID RAFFE (2009) drew a distinction between regulatory and facilitating frameworks. Germany has opted for a facilitating framework which leaves much open. In the case of the BQFG, the decision was taken to extend the procedure for the recognition of regulated occupations to all qualifications. It would, however, be possible both to lend more weight to the DQR and make the assessment process for non-regulated occupations easier by going one stage further and thinking of both in terms of facilitating 'recognition'. Would that be possible?

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Literature

  • ARBEITSKREIS DQR [DQR Working Group]: Deutscher Qualifikationsrahmen für lebenslanges Lernen. [German Qualifications Framework for Lifelong Learning] Adopted on 22 March 2011
  • BROCKMANN, M., CLARKE, L., WINCH, CH.: Knowledge, Skills, Competence in the European Labour Market - What's in a qualification? London and New York 2011
  • CEDEFOP: Development of national qualifications frameworks in Europe. Overview and main tendencies. Thessaloniki 2011
  • DANISH EVALUATION INSTITUTE: Referencing the Danish Qualifications Framework for Lifelong Learning to the European Qualifications Framework. Copenhagen 2011 - URL: www.nqf.dk und www.eva.dk (Consulted 8 August 2012)
  • ESSER, F. H. et. al.: Überlegungen für die Konstruktion eines integrierten NQF-ECVET Modells [Considerations for the construction of an integrated NQF-ECVET model]. Berlin 2005
  • EUROPEAN COMMISSION: ESCO, the forthcoming European Skills, Competencies and Occupations taxonomy. EMPL D-3/LK D (2009). Brussels 2010
  • EUROPEAN PARLIAMENT AND COUNCIL: Directive 2005/36/EC of 7 September 2005 on the recognition of professional qualifications. In: Journal of the European Union L 255 of 30 September 2005, p. 22
  • EUROPEAN PARLIAMENT AND COUNCIL: Recommendation of 23 April 2008 on the Establishment of the European Qualifications Framework for Lifelong Learning. In: Journal of the European Union 2008/C111/01 of 6 May 2008
  • EUROPEAN PARLIAMENT AND COUNCIL: Proposal for a Directive of the European Parliament and of the Council amending Directive 2005/36/EC on the recognition of professional qualifications and Regulation on administrative cooperation through the Internal Market Information
    System COM 883, final 2011/0435 (COD) of 19 December 2011
  • EUROPEAN TRAINING FOUNDATION (ETF): Qualifications Frameworks - From concepts to implementation. Luxemburg 2012
    Gesetz zur Verbesserung der Feststellung und Anerkennung im Ausland erworbener Qualifikationen [Law to improve the assessment and recognition of vocational education and training qualifications acquired abroad] of 6 Dezember 2011. In: Federal Law Gazette, BGBl., 2011 Part I, No. 63 of 12 December 2011, pp. 2515-2551
  • NATIONAL QUALIFICATIONS AUTHORITY OF IRELAND: Referencing of the Irish National Framework of Qualifications (NFQ) to the European Qualifications Framework for Lifelong Learning (EQF). Dublin 2009
  • RAFFE, D.: Towards a dynamic model of National Qualifications Frameworks. In: ALLAIS, S.; RAFFE, D.; YOUNG, M. (Eds.): Researching Qualifications Frameworks: some conceptual issues.
  • ILO Employment Working Paper No. 44. Geneva 2009, pp. 23-24
  • SCHLEYER H.-E.: Positionen [Positions]. In: Bund-Länder-Konferenz [Federal Government-Federal State Conference] (Ed.): Der Deutsche Qualifikationsrahmen für Lebenslanges Lernen [The German Qualifications Framework for Lifelong Learning]. Berlin 2008, pp. 25-27
  • WESTERHUIS, A.: European structures of qualification levels, volume 1, CEDEFOP Reference Series. Thessaloniki 2001

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footnotes:

1 www.zdh.de/presse/beitraege/archiv-beitraege/der-meister-wird-inder-eu-aufgewertet.html (consulted: 08.08.2012).

Last modified on: December 18, 2012

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