Technical Assistance Consultant s Report

Size: px
Start display at page:

Download "Technical Assistance Consultant s Report"

Transcription

1 Technical Assistance Consultant s Report Project Number: September 2016 India: Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs (Financed by the Asian Development Bank) Prepared by Ernst & Young India For Ministry of Skill Development and Entrepreneurship National Skill Development Corporation This consultant s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents.

2 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs

3

4 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs

5

6 Chapter Contents Abbreviations iv I. Introduction 1 II. Regional Qualifications Frameworks 3 A. European Qualifications Framework 4 B. Gulf Qualifications Framework 4 C. Southern African Development Community Regional Qualifications Framework 5 D. ASEAN Qualifications Reference Framework 6 III. Regional Recognition Approaches 7 A. European Credit System for Vocational Education and Training 7 B. The University Mobility in Asia and the Pacific 7 C. United Arab Emirates and Kuwait Skills Certification Pilot Project 8 IV. Mutual Recognition Agreements 10 V. Transnational Education 13 A. International Professional Standards Network 13 B. Malaysia 14 C. United Arab Emirates Qualifications Framework Emirates 15 VI. Conclusion and Recommendations 16 A. Recommendations 16 B. Progress on Current Engagement Models 18 C. Long-Term Activities 18 Appendix 1: Criteria and Procedures for Referencing National Qualifications Levels to the European Qualifications Framework 19 Appendix 2: The European Credit System for Vocational Education and Training Methodology Overview 20 iii

7 Abbreviations ADB Asian Development Bank AQRF ASEAN Qualifications Reference Framework AEC ASEAN Economic Community ASEAN Association of Southeast Asian Nations ECVET European Credit System for European Credit System for Vocational Education and Training EQARF European Quality Assurance Reference Framework EQF European Qualifications Framework GCC Gulf Cooperation Countries GQF Gulf Qualifications Framework IPSN International Professional Standards Network LLL Lifelong Learning MOU memorandum of understanding MRA mutual recognition agreement NOS National Occupational Standards NQF national qualifications framework NSDC National Skill Development Corporation QP Qualifications Pack RQF regional qualifications framework SADC Southern African Development Community SSC sector skills council TVET technical vocational education and training UAE United Arab Emirates UMAP University Mobility in Asia and the Pacific iv

8 I. Introduction There are numerous reasons for seeking international recognition of qualifications, such as to continue studies overseas for individuals; and to improve the flow of skilled workers between countries, to benchmark between countries or institutions, develop partnerships between individual training institutions, and facilitate transnational education arrangements between institutions. This review outlines several of the key approaches for the recognition of skills, particularly in the Asia Arab migration context. This volume distinguishes between (i) harmonisation of standards or qualifications between countries through regional qualifications frameworks (RQFs); (ii) mutual recognition of national skills standards and/or certificates; (iii) establishment of joint minimum standards; and (iv) skills recognition of returning migrants. These guidelines are part of a series of volumes on skills development in India as carried out by the National Skill Development Corporation (NSDC). All the volumes in this series complement each other and should be used as a whole package. The volumes are the output of a technical assistance project funded by the Asian Development Bank (TA 8010: Skills Development for Inclusive Growth) on quality assurance for training providers, assessment bodies, assessors, and assessment practices. The project aimed to assist NSDC in setting the national agenda in skills development and to lay the foundation for future skills recognition processes. There are several approaches to mutual recognition of national skills standards being piloted around the world. India s review of international recognition options for National Occupational Skills (NOS) and Qualification Packs examines a number of these so that the NSDC can identify strategies that may be useful for the NSDC or sector skills councils (SSCs) to pursue in seeking recognition. This volume provides an overview of the different pilots and initiatives, including qualifications frameworks, the European Credit System for Vocational Education and Training, the United Arab Emirates (UAE) and Kuwait Skills Certification Pilot, and the International Professional Standards Network (IPSN). Many aspects can contribute to the recognition of learning in a country, including national or sectoral policy on qualifications, institutional arrangements, quality assurance processes, assessment and awarding processes, and skills recognition and other mechanisms that link education and training to the labour market and civil society. 1 In the case of individual recognition, organisations that assess individual overseas qualifications proceed on the basis of why the qualification needs to be assessed. For study purposes, universities and other education providers assess overseas qualifications for admission purposes. For those seeking recognition for work purposes, registration, or licensing, professional bodies may assess overseas qualifications to work in specific occupations. Professional assessing authorities, professional registration and/or licensing authorities, and industry bodies are usually listed on immigration ministry websites. For general employment, there is usually no assessment of qualifications. 1 OECD Qualifications Systems: Bridges to Lifelong Learning. Paris. 1

9 2 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs In India, remittances are larger than earnings from information technology exports. Remittances to India were estimated to reach $71 billion in Migrant worker flows from India are of two kinds. The first is the emigration of highly skilled professionals with tertiary and higher educational qualifications migrating mainly to Australia, Canada, New Zealand, the United Kingdom, and the United States. The second is the flow of low-skilled and semiskilled workers going mostly to the Gulf countries and Malaysia. 3 More than 90% of these Indian workers are in the Gulf countries and Southeast Asia. According to the Ministry of Overseas Indian Affairs, 747,041 workers emigrated from India during Of this, 357,503 went to Saudi Arabia; 141,138 to the UAE; 84,384 to Oman; 63,096 to Qatar; and 21,241 to Malaysia. 4 Furthermore, the major outflow of emigrant workers in the last few years from India has been to the Gulf countries where about 4 million workers are estimated to be employed. The vast majority of migrants to the Middle East, including the Gulf countries, are semiskilled and low-skilled workers. Most of them are temporary migrants who return to India after expiry of their contractual employment. 5 Additionally, in destination countries of the Organisation for Economic Co-operation and Development, India has approximately 3.4 million migrant workers, of which approximately 2 million are highly skilled. 6 Clearly, the skills of migrant workers relevant to the technical vocational education and training (TVET) sector are primarily concentrated in the Gulf countries and Malaysia, hence the focus of this review. 2 World Bank Migrants from Developing Countries to Send Home $414 Billion in Earnings in feature/2013/10/02/migrants-from-developing-countries-to-send-home-414-billion-in-earnings-in Ministry of Overseas Indian Affairs Annual Report Ministry of Overseas Indian Affairs Annual Report Footnote 4. 6 OECD UNDESA World Migration in Figures.

10 II. Regional Qualifications Frameworks The move to regional frameworks in the Association of Southeast Asian Nations (ASEAN), Europe, and the Gulf States will enable India to develop a consistent approach for the recognition of Indian qualifications at regional levels once national quality systems are also in place. A number of countries have documented the process for recognition of overseas qualifications. The UAE, for example, sets out criteria for both the accreditation of qualifications and the organisations in the public and private sectors that are to deliver them. It provides guidance and a reference tool for accreditation and awarding bodies and qualification designers and developers. An important dimension to mutual recognition between different qualifications frameworks is referencing, which involves a correlation between two or more frameworks in terms of levels, sometimes credits and qualifications types. At present, referencing is done mainly between national-level systems, and is limited largely to Australia, the Caribbean, Europe, New Zealand, Southern Africa, and more recently within ASEAN. Differences in the structure, content, and status of different national qualifications frameworks and RQFs still present challenges to straightforward comparability and transferability of qualifications across borders. As indicated in the Asia-Pacific Economic Cooperation forum (APEC) report, Mapping Qualifications Frameworks across APEC Economies, qualifications frameworks may differ in (i) emphasis on learning outcomes vis-à-vis inputs in qualifications descriptors; (ii) applicability to different sectors, with some frameworks covering all national qualifications and others focusing on higher education or vocational education and training only; (iii) association with a credit framework; (iv) ownership and management by a national agency or by stakeholders; and (v) support by legislation, or dependence on voluntary compliance. 7 Additionally, the quality assurance and compliance requirements surrounding the development and configuration of qualifications also vary across countries and sometimes across different levels within a qualifications framework. According to a European Commission report, Referencing National Qualifications Levels to the European Qualifications Framework, trust is dependent on the technical reliability of learning outcomes at a national level and transparent procedures used in referencing. 8 7 APEC Mapping Qualifications Frameworks across APEC Economies. Singapore. 8 European Commission Referencing National Qualifications Levels to the EQF Update DOI /

11 4 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs Qualifications frameworks share significant common features and objectives, and it is these common features and objectives that provide a basis for a deeper integration through training reform. 9 One common feature is a shared commitment to transparency, and the building of mutual trust between national education and training systems. The earliest move towards European cooperation was to increase student mobility through the Erasmus exchange programmes. Through transparent engagement and development of a shared understanding of the quality systems in different countries, national governments could be convinced that the courses studied by their students in other countries were of sufficient quality to gain the same level of recognition as courses studied in their own national system. 10 A. European Qualifications Framework The European Qualifications Framework (EQF) was established as a common reference point to enable qualifications frameworks and systems at multinational and sectoral levels to relate to one another. A principal function of the EQF is to improve transparency and strengthen mutual trust, reduce barriers to learning, and promote labour market mobility across borders. The core of the EQF is a structure of learning outcomes (incorporating knowledge, skills, and wider personal and professional competencies) in an eightlevel hierarchy. Individual qualifications awarded at national or sectoral levels include a clear reference to the EQF. The EQF has a common set of principles and procedures, notably on quality assurance, validation, guidance, and key competencies. There are transparent processes for aligning qualifications to each level of the National Skills Qualifications Framework, which are nationally agreed, and mapping these processes and criteria to the EQF provides another reference for transnational recognition purposes (see Appendix 1). Within the European Union, Directive 2005/36/EC is the main legal instrument organising the recognition of professional qualifications. This Directive covers all regulated professions, except professions for which the recognition of professional qualifications is governed by specific legal provisions at a European level (e.g., sailors, statutory auditors, insurance intermediaries, air controllers, some professions in the field of transport, and those linked to activities involving toxic products). It defines the conditions for the recognition of professional qualifications in cases of permanent establishment in another member state, as well as the conditions for moving to another member state on a temporary basis. Under the establishment regime, the Directive includes three different recognition systems. Seven professions (doctors, dentists, pharmacists, nurses, midwives, veterinarians, architects) benefit from automatic recognition on the basis of harmonised minimum training requirements. Other professions (in the craft, trade, and industry sectors) benefit from automatic recognition based on the years of professional experience. All other professions fall under the general system, which uses a case-to-case assessment of the training contents supporting the qualification of a professional. B. Gulf Qualifications Framework The six Arab states of the Persian Gulf (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the UAE) formed the alliance of Gulf Cooperation Countries (GCC) to strengthen relations among its member countries and to promote cooperation among the countries citizens. All these countries are moving forward with TVET training reforms and have agreed on a regional meta framework of qualifications. The UAE is taking the 9 J. Murray Quality Assurance in Qualifications Frameworks. Paper presented at the Dublin Conference, held March, Dublin, organised by Quality and Qualifications Ireland, on behalf of the Irish Presidency of the European Council, with the support of the European Commission 10 D. Kristoffersen From the First Pilot Projects to the Founding of ENQA ( ) in ENQA: 10 Years ( ). A Decade of European Cooperation in Quality Assurance in Higher Education. Helsinki: ENQA Publications.

12 II. Regional Qualifications Frameworks 5 lead through the establishment of its own qualifications framework 11 and is drafting the Gulf Qualifications Framework (GQF). The GQF will enable GCC countries to relate their national qualifications and systems to a common reference framework. The framework is still in the conceptual phase and a background report on different meta qualifications frameworks has been prepared to inform the development process. Given its early stages of development, there may be room to commence a policy dialogue on recognition arrangements between the Gulf States and India. C. Southern African Development Community Regional Qualifications Framework The Southern African Development Community (SADC) is a regional grouping of 14 countries in the Southern African region with the aim of promoting regional cooperation and integration. One goal of the SADC is to achieve equivalence and standardisation between education and TVET systems in the region. One of the main benefits is considered to be worker and student mobility. In 2011, education and training ministers in SADC approved the establishment of the SADC Regional Qualifications Framework. The SADC approach to RQF is focused on standardising and matching the inputs to the awarding of qualifications. This contrasts with the EQF approach outlined above, which concentrates on declaring mutual recognition of certificated outcomes. The Southern African methodology involves developing a single system of standards and qualifications for skills development across the entire Southern African region. The SADC RQF is a reference framework described by level descriptors and includes (i) quality assurance guidelines that set minimum standards for quality assurance in the region; and (ii) a SADC Qualifications Portal that will incorporate full- and part-time qualifications to be formally recognised in SADC member states. The SADC RQF is expected to contribute to the effort of developing a continental qualifications framework for mutual recognition of degrees and qualifications in higher education. In 2001, the Ministers and Senior Officials of SADC member states agreed that an RQF offered an important mechanism that will enhance mobility, harmonisation, and recognition of qualifications across the region. A SADC RQF concept paper was developed in 2005 with revisions in 2011 following consultation with stakeholders. The paper outlines the background and rationale and key components of the SADC RQF. The SADC RQF has 10 levels and defines broad level descriptors to facilitate easy referencing, as most countries in the region use a 10-level framework. The level descriptors that have been agreed upon will be further developed to include quality descriptors and qualification types. Member states have been tasked with translating the 10-level descriptors to their existing qualification systems. Quality assurance will also be included in the RQF to ensure that there is trust, confidence, and consistency in outcomes. It will have agreed quality assurance guidelines that set minimum standards for quality assurance in the region. Countries will benchmark their own quality assurance systems through peer review. 11

13 6 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs D. ASEAN Qualifications Reference Framework An ASEAN Qualifications Reference Framework (AQRF) is still under consultation but is expected to facilitate the transfer and the mutual recognition of the skills and qualifications of workers through the acceptance of broad equivalence or comparability of outcomes of national qualifications. ASEAN countries could potentially adopt the ASEAN Qualifications Reference Framework, in whole or in part, for their own qualifications arrangements. In the interest of further promoting mutual trust in national qualifications, the AQRF will also need to provide guidance in such areas as the setting of standards for skills and wider personal and professional competencies, as well as the quality assurance of training, student assessment, and certification. The regional model should make it possible for modules or smaller sets of skills, and not just full qualifications, to be recognised. This will promote the mobility of workers with fair recognition of their competencies. Given the diversity across ASEAN in training structures and organisation, it is the learning outcomes and competencies acquired through training programmes, through structured training in the workplace, in the community, or through experiential learning, which should be regarded as important for determining the comparability of skills and qualifications. 12 The AQRF was endorsed by the ASEAN Economic Ministers and the ASEAN Education Ministers in August and September The AQRF Task Force is determining the architecture and mechanisms to implement the framework, including governance structure, quality assurance arrangements, referencing process, and communication strategies. The Task Force members are expected to undertake national consultations on the agreed proposed approach. There are several important purposes for an AQRF: (i) it will provide a common reference point, but not restrain the diversity of national training and qualifications systems; (ii) it will strengthen mutual trust and cooperation among ASEAN nations; (iii) it will support and inform reform in individual countries, providing guidance and promoting good international policy and practice in human resource development; (iv) it will facilitate commonality of qualifications systems among the countries in the region; (v) it will accommodate national requirements and not force a standardised system onto all ASEAN countries; (vi) it will reduce barriers to the mutual recognition of the skills and qualifications; and (vii) it will promote labour market mobility with fair recognition of competencies. 12 D. Lythe Assessment of the Readiness of ASEAN Member States for Implementation of the Commitment to the Free Flow of Skilled Labour within the AEC from Bangkok.

14 III. Regional Recognition Approaches A. European Credit System for Vocational Education and Training The European Credit System for Vocational Education and Training (ECVET) is a voluntary European initiative, which allows for the accumulation and transfer of credits gained through the recognition of learning outcomes in TVET across Europe. ECVET was developed to facilitate the recognition of achievements in vocational education and training, and in formal, informal, and nonformal learning. The initiative was adopted in 2009 and is being implemented through pilots and refinement of the instrument before widespread implementation. The ECVET aims to facilitate the mobility of a TVET-certified workforce throughout Europe by enabling the accumulation of credit points from different training providers in different countries. Credit points are validated by each awarding institution and recognised by the body awarding the final qualification. A number of pilot projects have been funded through the Lifelong Learning Programme and also individually through national initiatives. The ECVET also includes the development of support tools such as the ECVET Users Guide. In 2015, the Commission will report to the European Parliament on the results of testing and assessment of actions taken at the member state level. An overview of the ECVET methodology can be found in Appendix 2, which provides information on the process for recognition of credit towards qualifications in the European Union. B. The University Mobility in Asia and the Pacific The University Mobility in Asia and the Pacific (UMAP) organisation was founded in 1993 as a voluntary association of government and nongovernment representatives of the higher education sector across the Asia and Pacific region. UMAP has developed a pilot UMAP Credit Transfer Scheme to facilitate greater student mobility in the region by providing a framework for establishing credit transfer arrangements. The scheme has adopted the outcomes-based European Credit Transfer and Accumulation System in order to assist and facilitate student mobility and create a flexible means of transferring grades between participating universities, countries or territories, and governments. The European Credit Transfer and Accumulation System functions in a comparable manner to the ECVET and is designed to achieve similar aims for students studying in the higher education sector. 7

15 8 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs C. United Arab Emirates and Kuwait Skills Certification Pilot Project The Government of the State of Kuwait and the UAE under the Abu Dhabi Dialogue are undertaking a pilot project on skills recognition and certification, which aims to support the skills development and recognition of migrant workers. It aims to lead to productivity gains for UAE companies through the recruitment of the right people for different jobs. Six occupations in the construction sector scaffolder, general worker, mason, steel fixer, carpenter, electrician, and plumber were selected based on 21 occupations for which the UAE National Qualification Authority has developed competency standards, and which centred on UAE company recruitment forecasting. In this model, workers will be assessed in the country of origin (India) and awarded certificates that certify their competencies match the skill standards required by the technical or vocational specifications of the destination country. The country of destination may then conduct additional competency assessments upon the worker s arrival for validation purposes. The assumptions behind the model include (i) availability of assessment centres, assessment tool designers, and assessors in the countries of origin who are skilled in competency and holistic assessment; (ii) availability of specific competency standards (NOS) in the country of destination, (iii) a certain level of trust between the two countries that institutions and assessment practices meet the required standards of quality assurance systems; and (iv) a system of working permits for countries of destination issued in the countries of origin that can be linked to the certification achieved through the assessment process. Countries of origin that have signalled their interest to participate in the pilot include India, Pakistan, and the Philippines. The Construction Skills Development Council of India and the Ministry of Labour and Employment have recently been approached to participate. Five contractors in the UAE have also indicated that they want to participate, who would recruit between 400 to 500 hundred workers each. Half would be assessed and provided certification with a Skills Passport. The evaluation at the end of the project will measure its net impact of the relationship between skills and productivity. If the results are positive, the UAE could link the issuance of work permits to skills certification. The financing arrangements have not been fully clarified, possibly because the UAE government does not want to create a precedent in subsidising skills testing. However, the unit cost for skills testing for construction workers is notably high (around $625 in Singapore 13 ) implying that skills assessment for migrant workers may be an expensive process. Employers are not likely to be willing to pay for skills testing, and workers may not be interested because of the comparatively low wages in the UAE, while countries of origin might be interested only for returning migrants. However, if there is a correlation to pay increases for skilled workers, a country of origin could potentially train and conduct the assessment on behalf of the UAE. This project is in the early implementation stage and will be monitored as it progresses. The Third Ministerial Consultation of the Abu Dhabi Dialogue, the Kuwait Declaration, brought together the ministers and heads of the delegations of Afghanistan, Bahrain, Bangladesh, the People s Republic of China, India, Indonesia, Kuwait, Nepal, Oman, Pakistan, the Philippines, Qatar, Saudi Arabia, Sri Lanka, Thailand, UAE, and Viet Nam in Kuwait in November 2014 to review progress on a Framework for Regional Collaboration based on the above pilot project. The meeting reviewed proposals for collaborative regional initiatives presented by the participating governments aimed at improving the administration of the contract employment cycle in a manner that increases development outcomes for workers, employers, and 13 According to an unpublished briefing paper of the International Labour Organisation.

16 III. Regional Recognition Approaches 9 labour in origin and destination member countries. These initiatives were undertaken by the governments of six member states: Bangladesh, Oman, the Philippines, Saudi Arabia, Sri Lanka, and UAE, and will inform future activities in this area. The countries attending agreed to adopt the Pilot Project on Skill Development, Documentation and Recognition as a regional initiative of the Abu Dhabi Dialogue and committed to monitor its progress and outcomes with a view to developing collaborative policies and schemes that empower workers through training, certification, documentation, and mutual recognition of their initial and acquired skills.

17 IV. Mutual Recognition Agreements With the adoption of an ASEAN Economic Community (AEC) in 2015, the commitment to the free movement of skilled labour is paramount. Mobility of skilled labour is considered essential for effective implementation of services as well as for deeper economic integration in the AEC. As ASEAN countries move from developing-country to middle-income-country status, their demand for globally competitive skills continues to increase. Foreign talent will be needed to augment the domestic pool, both at the lower and higher skills levels. Strategic actions on the free flow of skilled labour outlined in the AEC Blueprint include facilitating visa approvals and employment passes; mutual recognition arrangements (MRAs) for major professional services; core concordance of services skills and qualifications; and enhancing cooperation among ASEAN universities to increase regional mobility for students and staff. Mutual recognition arrangements have been a major instrument for skilled labour mobility in ASEAN and APEC. However, recognition of qualifications and experience does not necessarily ensure market access, yet it often benefits transnational services, such as the telecommunications industry. The following MRAs have been established in ASEAN in key areas of professional services: (i) MRA on Engineering Services (9 December 2005 in Kuala Lumpur, Malaysia); (ii) MRA on Nursing Services (8 December 2006 in Cebu, Philippines); (iii) MRA on Architectural Services (19 November 2007 in Singapore); (iv) Framework Arrangement for the Mutual Recognition of Surveying Qualifications (19 November 2007 in Singapore); (v) MRA on Medical Practitioners (26 February 2009 in Cha-am Hua Hin, Thailand); (vi) MRA on Dental Practitioners (26 February 2009 in Cha-am Hua Hin, Thailand); and (vii) MRA Framework on Accountancy Services (26 February 2009 in Cha-am Hua Hin, Thailand) These agreements are subject to country-specific policies and regulatory frameworks that constrain and slow skilled professional labour mobility, such as policies that close or place numerical caps on foreign professionals and skills in sectors and occupations; economic and labour market tests that limit employment of foreigners and requiring to have them replaced by locals within a stipulated period; licensing regulations of professional associations; and language proficiency requirements. All 10 ASEAN member states are participating members of these seven MRAs. Different mechanisms have been established to administer the implementation of MRAs in the services sector to ensure that professionals across ASEAN derive tangible benefits from the agreements. The MRAs for engineers and architects provide a coordinating mechanism, while the MRAs for medical and dental practitioners focus on 10

18 IV. Mutual Recognition Agreements 11 cooperation, with the aim of facilitating the recognition of qualified practitioners in other ASEAN member states. The MRAs on accountancy and surveying services provide a framework of broad principles for further bilateral and multilateral negotiations among ASEAN member states. In all seven professions, work is proceeding to promote common standards to encourage the 10 ASEAN countries to adopt accepted standards and procedures. 14 Although India is not part of ASEAN, India has formally signed a Trade in Services and Trade in Investments Agreement with ASEAN. The Services Agreement will open up opportunities of movement of both manpower and investments from either side. 15 This agreement appears to cover the movement of professionally qualified workers. Perhaps more relevant to the NSDC skills ecosystem is the MRA for tourism professionals, which aims to facilitate mobility of tourism professionals within ASEAN based on competence-based tourism qualifications; and at the same time, improve the quality of services delivered by tourism professionals in the region. This is achieved through the development of regionally agreed competency standards in tourism that are grouped to form qualifications. ASEAN member states compare and standardise their tourism qualifications with the ASEAN competency standards groupings. In order for a foreign tourism professional to be recognised by other ASEAN member states and to be eligible to work in a host country, the professional needs to possess a valid tourism competency certificate in a specific tourism job title as specified in the Common ASEAN Tourism Curriculum, issued by the Tourism Professional Certification Board in an ASEAN member state. There are 32 job titles covered under this MRA, ranging from housekeeping, front office, food and beverage services, and food production for a hotel division; to travel agencies and tour operator for a travel division. Qualifications for tourism professionals are at five levels (three levels for certificate, followed by two diploma levels). In the ASEAN India Action Plan: Plan of Action To Implement the ASEAN India Partnership for Peace, Progress and Shared Prosperity ( ), point 29 may offer an avenue to commence dialogue on the alignment of Indian tourism NOS with the Common ASEAN Tourism Curriculum as it identifies (support for) continued consultations between ASEAN and India to promote tourism cooperation, including in the areas of joint marketing, crisis communications, tourism investment and tourism standards activities. Subsequent dialogue on this will involve contacting the ASEAN Secretariat whose mission is to initiate, facilitate, and coordinate ASEAN stakeholder collaboration. The International Labour Organisation has developed a series of regional models of competency standards that countries in the Asia and Pacific region can use as a regional reference. The regional models can be contextualised by countries for inclusion in national qualifications or for benchmarking purposes. They may also be used to validate the content of national skills standards. Furthermore, occupational classifications vary considerably across countries in terms of the number of occupational definitions and terminology used. For example, common references to concepts such as basic, advanced, skilled, and unskilled are used as occupation or qualification descriptors in a number of countries, yet the definition of these terms is not consistent internationally. Regional standards work to standardise terminology. Existing regional models of competency standards cover industries including manufacturing, tourism, and construction and mechanical skills, with standards in the area of domestic workers to be released shortly. Joint minimum standards can play an important role in cross-border skills recognition as they provide a guide to the scope of skills and knowledge required by regionally located industries. Joint minimum standards can 14 Footnote

19 12 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs be designed to allow for diversity between national frameworks while enabling cross-border comparison. This approach does not include systematic recognition of certificates, but acts as a common translation tool to allow the skills gained in different countries to be evaluated. Furthermore, joint minimum standards provide an opportunity for countries in the early stages of developing skills standards to acquire a detailed appreciation of the standards in other countries. An example of this is the work occurring between the Australian Industry Skills Councils and Indian SSCs. The identification and development of transnational standards assists in the benchmarking of national qualifications. Joint minimum standards and qualifications mappings are, like the MRA example above, subject to countryspecific policies and regulatory frameworks, in particular quality assurance frameworks and qualification issuing requirements. Licensing regulations of professional associations in the receiving country and language proficiency requirements often impede the benefits of these processes as secondary bodies have a decision-making role in the acceptance and issuance of qualifications, particularly at the professional and semiprofessional level.

20 V. Transnational Education Transnational education arrangements may inform recognition approaches that could be trialled in the Indian context. Transnational education arrangements include models such as foreign subsidiary or foreign branches; blended learning; e-learning; distance learning and training; franchise cross-border group; joint venture; cooperation agreements; twinning; and virtual education offers. Any pilot in this area would be on a training provider to training provider basis. The Recommendations for Quality Management in Transnational Education with Reference to ISO 29990: notes that harmonisation of standards and the standardisation of certification procedures is an important means of strengthening cooperation ties, thus facilitating the development of cooperation and enhancing its effectiveness. The recommendation goes further and suggests transnational learning service providers should strive for cooperation that meets uniform quality criteria, and ideally apply the same quality management standards. Transnational education hotspots are generally those with a well-developed regulatory environment, which is often a response to increasing transnational education activity in the first place. Helpful regulatory conditions include a clear strategy for transnational education with specific government departments or organisations that promote it, and reliable quality assurance and accreditation of courses. 17 Hong Kong, China; Malaysia; Singapore; and the UAE have shown the most favourable environment for transnational education. A. International Professional Standards Network The International Professional Standards Network (IPSN) is made up of standards-setting bodies recognised by government and industry from member countries. The IPSN is open to all industry sectors that are part of the vocational education sector. The network s aim is to raise the standards of training, assessment, and delivery through the mapping of competencies between the participating countries to ensure equivalence. The initial industry sectors actively engaging and building their benchmarks are the beauty and hairdressing sectors. An international hairdressing certification has been developed and agreed to by the network. Countries can submit the relevant information in order to have their qualifications assessed against the criteria required to receive the IPSN International hairdressing certification. Each country participating in the network has mapped its hairdressing and/or beauty qualifications and industry recognition processes against an agreed IPSN benchmark. The purpose of this benchmarking is to assist individuals in having their skills recognised by industry in those countries that are members of the IPSN. 16 RKW Berlin GmbH Quality Guideline. Recommendations for Quality Management in Transnational Education with Reference to ISO 29990: rd revised edition. 17 J. McNamara, J. Knight, and R. M. Fernandez-Chung The Shape of Things to Come 2: The Evolution of Transnational Education. London: British Council. 13

21 14 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs The IPSN industry coverage currently consists of hairdressing and beauty; however, it is the intention that other industry areas will join the IPSN. The tourism and hospitality industries have shown considerable interest in becoming part of the network, along with sport, fitness, and recreation. Current member countries of IPSN include Australia; Canada; Hong Kong, China; Japan; and New Zealand, where the mapping of hairdressing qualifications except for Japan has occurred. The Japanese qualifications are currently being mapped. The mapping used an agreed common framework, and gaps in content between each country were identified along with missing underpinning skills and knowledge between each country across all levels. The network has also identified independent benchmarks with best practice assessment and quality assurance. For India to participate in the IPSN network, the Beauty and Wellness SSC would initiate contact with the network to become a member, as only organisations that are recognised by government and industry as the standards-setting body for their industry within their country can be members. B. Malaysia The majority of migrant workers in Malaysia are low-skilled or semiskilled. The low-skilled workers are mainly employed in the rural agriculture and plantation sectors, while the semiskilled workers are employed in the manufacturing, construction, and services sectors. The construction sector hires both general and semiskilled workers such as welders, brick layers, carpenters, etc. Potential candidates are often requested to show proof of their skills, either through basic training certificates or through previous employer attestation. Bigger recruitment companies provide basic hands-on training in welding, brick-laying, plastering etc. to the workers in origin countries before deployment. Such training programmes are carried out through collaboration with local training institutions. In the case of the manufacturing industries, workers are screened for their ability to respond to instructions from their supervisors. Hence, candidates must have a minimum of secondary education and must pass simple IQ and mathematics tests, apart from the physical tests. As a long-term measure and to ensure sustainable growth as well as minimise socioeconomic implications, a medium- to longer-term policy on foreign workers has been introduced to reduce the overdependence on foreign workers while attracting more skilled and trained professionals. As of end-july 2012, a total of 47,157 expatriates were employed in the country versus 40,938 in end-july This indicates that only 3% (end- July 2011: 3%) of foreign workers in Malaysia were highly skilled while the remaining workers were low-skilled. The expatriates were mainly employed in the services (28,298; 60%); manufacturing (10,350; 21.9%); and construction (3,406; 7.2%) sectors. The majority of them were from India (9,360; 19.8%); followed by the People s Republic of China (5,396; 11.4%); and Japan (3,384; 7.2%). 18 Malaysia has a well-formulated qualifications framework established under the Malaysia Qualifications Agency, which manages recognition of foreign higher education qualifications. TVET qualifications are recognised through the National Vocational Training Council. On a case-to-case basis, foreigners with specific skills also can seek accreditation as skilled workers, such as construction workers seeking accreditation through the Construction Industry Development Board (CIDB). According to the website of the CIDB, to do this, a foreign construction worker must apply through the employer for the Competency Test for Skilled Foreign Construction Personnel; submit the necessary requirements (passport, visitor s pass, etc.); pay the processing and other fees; and then undergo the accreditation assessment. A CIDB Foreign Personnel Skills Recognition certificate is issued to applicants who pass the assessment, which primarily focuses on health and safety rather than technical skills. 18 Ministry of Finance. Economic Report 2012/2013. Kuala Lumpur.

22 IV. Mutual Recognition Agreements 15 The NOS are the bases of qualifications and competency-based delivery and assessment, and are nationally maintained. A national training provider accreditation process is also in place, along with a national recognition of prior learning process. All of these provide a favourable foundation for piloting a system of skills recognition processes. C. United Arab Emirates Qualifications Framework Emirates One of the aims of the UAE s Qualifications Framework Emirates (QFEmirates) is that the architecture of qualifications framework defines the requirements that will enable UAE qualifications to be compared with and valued alongside foreign qualifications. Significantly, the QFEmirates enables a coherent and consistent approach to be taken in the design of qualifications for higher education; general education; and technical, vocational, and professional education and training. It sets out criteria for both the accreditation of qualifications and for organisations in the public and private sectors that are to deliver them. QFEmirates provides guidance and a reference tool for accreditation and awarding bodies, and qualifications designers and developers. The qualifications framework sets out descriptor statements for 10 levels. The statements or level descriptors are set out in five strands, building a grid of 50 statements. The five strands describe knowledge and skill, with three describing aspects of competence (autonomy and responsibility, role in context, and selfdevelopment). These level descriptors form the foundation for the QFEmirates. The framework requires the descriptor statements defining any particular level to be read concurrently across all five strands of learning outcomes to affirm a level. Furthermore, the level descriptors are cumulative, e.g., the descriptor for Level 5 assumes the inclusion of all of the outcomes in the preceding levels. In terms of the vocational education and training sector, there are no formal structures or processes in place to confer equivalence, mutual recognition declarations, and/or attesting of qualifications. This has been addressed with the establishment of the Vocational Education and Training Awards Commission. Vocational education and training qualifications and/or awards gained overseas are typically reviewed and attended to by the Commission. The categories for foreign recognition are as follows: (i) Foreign awards and/or qualifications obtained by individuals while overseas that are deemed national in the origin country from an approved, registered, or accredited institution or training entity; where the qualifications may be managed by a separate national entity (such as an awarding body) or the like; and that form an integral part of the national qualifications system, e.g., Scottish Vocational Qualifications. (ii) Foreign awards and/or qualifications obtained by individuals while overseas that are unique to an institution or training entity, and which are accredited but not deemed national in the origin country, but recognised and/or approved by the country of origin s education and training authorised agency. (iii) Foreign awards and/or transcripts obtained by individuals while overseas that are unique to an institution or training entity and which are not accredited or deemed national in the origin country and not recognised and/or approved by the country of origin s education and training authorised agency (i.e., private education and training providers offering their own fee-for-service products).

23 VI. Conclusion and Recommendations This volume has highlighted a number of different approaches to recognising skills and qualifications being implemented in different regions and countries. One common feature in all models is the emphasis on a unified and internationally referenced quality assurance system for skills development. Moreover, competency-based assessments feature predominately in some of the models and underline the importance of meeting international norms in competency-based assessment. The development of international recognition processes appears to rely on consistency in the outcomes demonstrated by TVET graduates. This volume has presented a range of available models used for transnational skills recognition purposes with the aim of providing insights on how the NSDC might engage in similar activities. Following the progress of the initiatives documented in this review may help inform skills recognition initiatives for the NSDCs skills ecosystem partners. This review outlined several approaches for the recognition of skills, particularly as relevant to the Asia Arab migration context. The review focused on the harmonisation of standards or qualifications between countries through RQFs; mutual recognition of national skills standards and/or certificates; establishment of joint minimum standards; and skills recognition of returning migrants. Several of these approaches could be explored further with a number of countries such as Malaysia, which has a strong demand for Indian TVET graduates. A. Recommendations The following recommendations provide two sets of activities for the National Skill Development Corporation (NSDC) and sector skills councils (SSCs). Near-term activities are for quick gains and learning for an eventual deeper engagement for international recognitions. Long-term activities are planned interventions impacting workforce movement at macro levels. (i) Mutual Recognition Agreements with the ASEAN Economic Community on Tourism-related Job Roles As countries of the Association of Southeast Asian Nations (ASEAN) move from developing-country to middle-income-country status, the demand for globally competitive skills will continue to increase. Foreign talent will be needed to augment the domestic pool, both at the lower and higher skill levels. Strategic actions on the free flow of skilled labour outlined in the ASEAN Economic Community (AEC) Blueprint include: facilitating visa approvals and employment passes; mutual recognition arrangements (MRAs) for major professional services; core concordance of services skills and qualifications; and enhancing cooperation among ASEAN universities to increase regional mobility for students and staff. 16

24 IV. Mutual Recognition Agreements 17 The ASEAN India Action Plan: Plan of Action To Implement the ASEAN India Partnership for Peace, Progress and Shared Prosperity ( ) may offer an avenue to commence dialogue on the alignment of Indian tourism NOS with the Common ASEAN Tourism Curriculum, as stated in point 29: Support continued consultations between ASEAN and India to promote tourism cooperation, including in the areas of joint marketing, crisis communications, tourism investment and tourism standards activities. The lead for this initiative may be taken by India s Tourism and Hospitality SSC, based on their Qualification Packs, and examination of the MRAs created by ASEAN countries in these Qualification Packs. To commence dialogue on this, the ASEAN Secretariat will initiate, facilitate, and coordinate ASEAN stakeholder collaboration. This may be facilitated by Ministry of Skills and NSDC. There are 32 job titles covered under this MRA, ranging from housekeeping, front office, food and beverage services, and food production for hotel division; to travel agencies and tour operator for a travel division. Qualifications for tourism professionals are at five levels (three levels for certificate, followed by two diploma levels). (ii) Alignment with the International Professional Standards Network The International Professional Standards Network (IPSN) is made up of standards-setting bodies recognised by government and industry from member countries. The intention is that the IPSN will be open to all industry sectors that are part of the vocational education sector. The initial industry sectors of the IPSN actively engaging and building their benchmarks are the beauty and hairdressing sectors. An international hairdressing certification has been developed and agreed to by the network. Countries can submit the relevant information in order to have their qualifications assessed against the criteria required to receive the IPSN International hairdressing certification. Each country participating in the network has mapped their hairdressing and/or beauty qualifications and industry recognition processes against an agreed IPSN benchmark. The purpose of this benchmarking is to assist individuals in having their skills recognised by industry in those countries that are members of the IPSN. Current member countries of IPSN include Australia; Canada; Hong Kong, China; Japan; and New Zealand. There is an opportunity for Indian workers in each of these countries. The IPSN industry coverage currently consists of hairdressing and beauty; however, it is the intention that other industry areas will join the IPSN. The tourism and hospitality industries have shown considerable interest in becoming part of the network along with sport, fitness, and recreation. The mapping of hairdressing qualifications between Australia; Canada; Hong Kong, China; and New Zealand has occurred. The Japanese qualifications are currently being mapped. For India to participate in the IPSN network, initial engagement can commence with the Beauty and Wellness SSC initiating contact with the network to become a member. Only organisations that are recognised by government and industry as the standards-setting body for their industry can be members. Tourism and hospitality SSC, and sports SSC may also explore aligning their standards with IPSN. This engagement will serve two purposes. First, it will allow Indian workers to achieve international standards and work abroad. Second, this would serve to improve India s standards in these sectors.

25 18 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs B. Progress on Current Engagement Models The following initiatives to provide international recognition to Indian standards are in progress: (i) transnational standards with Australia in sectors including retail, telecommunications, agriculture, and mining, under the auspices of the Australian International Education Conference; (ii) transnational standards in the healthcare and security sectors, under UK India Education Research Initiative funding; (iii) the Government of the State of Kuwait and the United Arab Emirates under the Abu Dhabi Dialogue for a pilot project on skills recognition and certification, which aims to support the skills development and recognition of migrant workers; and where the Construction Skills Development Council of India and Ministry of Labour and Employment have been invited to participate. C. Long-Term Activities Long-term activities are critical for international recognition of Indian standards. Although the impact is long-term, the activities need to commence immediately. Some activity on this may have already begun with reports in the press about the Ministry of Foreign Affairs and Ministry of Skills looking at certifying the skills of all workers going abroad. Suggested steps are as follows. (i) Create a transnational standards integration team at NSDC, with the role of strategising and executing transnational standards with partner nations. (ii) Develop a strategy for India for engagement with partner nations on transnational standards. The starting point of this strategy is to identify nations and job roles that are deficient today, or are likely to be deficient in the future. Typical examples would be: shortage of key trades like plumbers etc. in Germany; sign a memorandum of understanding (MOU) with the European Union team to align EQF to NSQF as all countries in the European Union are likely to face a skill shortage in agriculture, manufacturing, and services; shortage of hospitality staff in Switzerland; and shortage of manufacturing, construction, and service staff in Malaysia. (iii) Execute this strategy by signing MOUs at the level of the Ministry of Skills, with respective ministries in corresponding nations; and drive a time-bound approach to ensure creation of transnational standards with relevant SSCs; as well as pilot test workforce migration, based on these standards and certification.

26 Appendix 1: Criteria and Procedures for Referencing National Qualifications Levels to the European Qualifications Framework The responsibilities and/or legal competence of all relevant national bodies involved in the referencing process, including the National Coordination Point, are clearly determined and published by the competent public authorities. There is a clear and demonstrable link between the qualifications levels in the national qualifications framework (NQF) or system and the level descriptors of the European Qualifications Framework (EQF). The NQF or system and its qualifications are based on the principle and objective of learning outcomes and linked to arrangements for validation of nonformal and informal learning and, where these exist, to credit systems. The procedures for inclusion of qualifications in the NQF or for describing the place of qualifications in the national qualification system are transparent. The national quality assurance system(s) for education and training refer(s) to the NQF or system and are consistent with the relevant European principles and guidelines. The referencing process shall include the stated agreement of the relevant quality assurance bodies. The referencing process shall involve international experts. The competent national body or bodies shall certify the referencing of the NQF or system with the EQF. One comprehensive report setting out the referencing and the evidence supporting it shall be published by the competent national bodies, including the National Coordination Point, and shall address separately each of the criteria. The comprehensive report outlining the national referencing process must be certified by the national body responsible for the qualifications framework within the country. The aim of this criterion is to ensure that countries cover the entire range of qualifications levels (and types) in their framework or system, thus reflecting the overarching, lifelong learning character of the EQF. The official EQF platform shall maintain a public listing of member states that have confirmed that they have completed the referencing process, including links to completed referencing reports. Following the referencing process, and in line with the timelines set in the recommendation, all new qualification certificates, diplomas, and Europass documents issued by the competent authorities contain a clear reference, by way of national qualifications systems, to the appropriate EQF level. 19

27 Appendix 2: The European Credit System for Vocational Education and Training Methodology Overview The methodology for any given qualification is based on the following technical specifications. This methodology overview is a concise version of the ECVET technical specifications that can be downloaded from specifications_en.pdf The first component of consideration is units of learning outcomes. Under the ECVET, a unit is a component of a qualification, consisting of a part of the knowledge, skills, and competence required for a given qualification. In principle, a qualification comprises several units and is made up of the whole set of units. This is similar to the NOS forming a Qualification Pack, but instead of learning outcomes, the NOS contain performance outcomes that incorporate the required skills and knowledge. Thus, a learner can achieve a qualification by accumulating the required units, achieved in different countries and different contexts (formal, nonformal, and informal). In the ECVET, technical specifications units that make up a qualification should be: (i) described in understandable terms by referring to the knowledge, skills, and competences contained in them; (ii) constructed and organised in a coherent way with regard to the overall qualification; and (iii) constructed in a way that enables discrete assessment and validation of learning outcomes contained in the unit. A unit may be specific to a single qualification or common to several qualifications. The specifications for a unit should include: (i) the generic title of the unit; (ii) the generic title of the qualification to which the unit relates; (iii) the reference of the qualification according to the EQF level and, if appropriate, the NQF level, with the ECVET credit points associated with the qualification; (iv) the learning outcomes contained in the unit; (v) the procedures and criteria for assessment of these learning outcomes; (vi) the ECVET points associated with the unit; and (vii) the validity in time of the unit, if relevant. In the ECVET model, units of learning outcomes achieved in one setting (or country) are assessed and then, after successful assessment, transferred to another setting (or country). In this second context, they are validated and recognised by the competent institution as part of the requirements for the qualification 20

28 Appendixes 21 that the person is aiming to achieve. Units of learning outcomes can then be accumulated towards this qualification, in accordance with national, sectoral, or regional rules. Procedures and guidelines for the assessment, validation, accumulation, and recognition of units of learning outcomes are designed by the relevant competent institutions. Hence the importance of ensuring Indian assessment, validation, accumulation, and recognition accord with international good practice. Credit transfer based on ECVET and applied to learning outcomes achieved in formal learning contexts should be facilitated by establishing partnerships and networks involving competent institutions, each of which is empowered, in their own setting, to award qualifications or units or to give credit for achieved learning outcomes for transfer and validation. The competent institutions are encouraged to form partnerships with other competent institutions to: (i) accept each other s status as competent institutions; (ii) accept each other s quality assurance, assessment, validation, and recognition criteria and procedures as satisfactory for the purposes of credit transfer; (iii) agree the conditions for the operation of the partnership, such as objectives, duration, and arrangements for review of the MOU; (iv) agree on the comparability of qualifications concerned for the purposes of credit transfer, using EQF to establish the reference levels; and (v) identify other actors and competent institutions that may be involved in the process concerned and their functions. With regard to learning outcomes achieved in the nonformal and informal learning context or outside the framework of an MOU, the competent institution empowered to award qualifications or units or to give credit should establish procedures and mechanisms for the identification, validation, and recognition of these learning outcomes by awarding the corresponding units and the associated ECVET points. The second part of the ECVET technical specification relates to the learning agreement and personal transcript of the students. When applying for credit transfer involving two competent institutions and a specific mobile learner, a learning agreement is established by the two competent institutions, using the framework of an MOU, and the learner. The agreement must distinguish between competent home and hosting institutions. The home institution is the institution that will validate and recognise learning outcomes achieved by the learner. The hosting institution is the one that delivers training for the learning outcomes and assesses the achieved learning outcome. The agreement must specify the particular conditions for a period of mobility, such as the identity of the learner, the duration of the mobility period, learning outcomes expected to be achieved, and the associated ECVET points. The learning agreement should establish that if the learner has achieved the expected learning outcomes and these have been positively assessed by the hosting institution, the home institution can validate and recognise them as part of the requirements for a qualification, according to the rules and procedures established by the competent institution, and then award a qualification.

29 22 Skills Development for Inclusive Growth Volume 5: Review of International Recognition Options and Arrangements for National Occupational Standards and Qualification Packs In summary, the transfer of credit for achieved learning outcomes has three stages. (i) The hosting institution assesses the learning outcomes achieved and awards credit to the learner. The learning outcomes achieved and the corresponding ECVET points are recorded in a learner s personal transcript (a personal transcript is a document that details learners assessed learning outcomes, and the units and ECVET points awarded). (ii) The home institution validates the credit as a suitable record of the learner s achievement. (iii) The home institution then recognises the learning outcomes that have been acquired. This recognition gives rise to the award of the units and their corresponding ECVET points, according to the rules of the home system. Validation and recognition by the competent home institution depends on the successful assessment of learning outcomes by the competent hosting institution, in accordance with the agreed procedures and quality assurance criteria. The final component of the ECVET is the points system which, while having no independent value, provides a convention for weighting qualifications. To enable a common approach for the use of ECVET points, a convention is used according to which 60 points are allocated to the learning outcomes expected to be achieved in a year of formal, full-time vocational education and training. In ECVET, the allocation of points usually has two phases. ECVET points are allocated, first, to a qualification as a whole; and then second, to its units. For a given qualification, one formal learning context is taken as a reference and, on the basis of convention, the total number of points is assigned for that qualification. From this total, ECVET points are then allocated to each unit according to their relative weight within the qualification. For qualifications that do not have a formal learning pathway reference, ECVET credit points can be allocated through estimation by comparison with another qualification that has a formal reference context. To establish the comparability of the qualifications, the competent institution should refer to the equivalent EQF or NQF level, or to the similarity of the competencies, or to the professional fields or the learning outcomes. With regard to the qualification, the relative weight of a unit of learning outcome should be established according to the following criteria or to a combination thereof: (i) the relative importance of the learning outcomes that constitute the unit for labour market participation, for progression to other qualification levels or for social integration; (ii) the complexity, scope, and volume of learning outcomes in the unit; and (iii) the effort necessary for a learner to acquire the knowledge, skills, and competence required for the unit. Any qualification acquired through nonformal or informal learning for which a formal learning pathway reference can be identified, and the corresponding units, carry the same ECVET points as the reference, since the same learning outcomes are being achieved.

30