Education reform: location of the Scottish Qualification Authority’s accreditation function

Introduction

In response to Professor Muir’s 2022 report “Putting Learners at the Centre: Towards a Future Vision for Scottish Education” the Scottish Government committed to reviewing the location of the SQA’s accreditation function.

The Scottish Government undertook this review between March and September 2022 and identified six options. To inform this work the views of a range of organisations and accreditation stakeholders were sought. This included nine standard setting organisations, twenty-five awarding bodies, other public and charitable organisations, and the staff in the SQA’s accreditation team.

An assessment of the opportunities and risks of each option was undertaken. In November 2022 the Scottish Government announced the decision to locate the accreditation function in the new qualifications body, Qualifications Scotland.

The analysis of each option is presented below. This informed the Scottish Government’s decision to proceed with option two.

Option 1: create a new small Non-Departmental Public Body (NDPB) to act as an independent regulator / accreditation body.

Position in education sector

Opportunities

No known conflicts of interest. Independence would strengthen the perception of the accreditation body operating as an independent regulator in line with other regulators in England and Wales.

Separate identity from other bodies resulting in greater visibility, profile and understanding of benefits of accreditation. This could form the basis for improved public engagement and consultation.

Risks

At odds with recommendation from the Public Bodies Review not to create small NDPBs due to disproportionate cost/benefit.

Risk of further ‘cluttering’ the education and regulation landscape by creating a new body.

Governance

Opportunities 

The new body would have a governance structure focused only on the delivery of accreditation functions.

As an NDPB, the existing governance and accountability relationship with SG would be retained and the body would remain operationally independent.

Risks

As the new body would be operationally independent, success of the new body would be reliant on the effectiveness and performance of the new governance arrangements.

Resource

Opportunities

The body would have the flexibility and autonomy to invest in its own assets e.g. creation of a bespoke accreditation database to support service delivery.

No longer competition within wide parent body over prioritisation of resources for accreditation function (as currently could be the case).

Risks

There will be additional running costs from overheads and corporate requirement (as an illustration, Bord na Gaidhlig’s corporate costs including HR and finance etc. make up 33% of its total budget). Shared services may mitigate a portion of these costs.

Significant resources required from both SG and the new body for initial creation of the body. A new body will require accommodation, IT systems, a sponsor team, board recruitment etc. The set up costs of NDPBs of comparable size are circa. £400-600k.

Staff

Opportunities

Greater flexibility to build staff capacity and capability in response to the needs of the accreditation function.

Risks

In a smaller organisations there will be fewer opportunities for progression for staff.

Risk of significant disruption to staff and uncertainty around terms of employment.

There is a limited pool of staff with expertise in the accreditation of Scottish qualifications. The independent body would potentially be competing with the larger qualifications body for staff.

Delivery

Opportunities

Autonomy in decision making and funding allowing the organisation to respond to changes in specific sectors of the education and training systems.

Potential to increase levels of public engagement and consultation and research to better inform delivery of the accreditation and regulation functions and provide input into discussions on the quality assurance of qualifications.

Enforcement actions available could potentially be strengthened.

Risks

Transitional period could be disruptive to delivery of functions.

Reduced resilience due to limited access to the resources of a larger organisation e.g. a smaller organisation will have smaller expert teams (e.g. for IT). Shared services may mitigate this risk.

A smaller organisation may not have the resources or capacity to respond quickly to changes in qualification and skills needs.

Option 2: part of the new qualifications body with increased separation from awarding function

Position in education sector

Opportunities

Avoids creation of a new public body, in line with the recommendation of the Public Bodies Review.

Opportunity to give accreditation a separate and distinct identity.

Risks

Perception that little structural reform has taken place with the new Qualifications Body retaining all of the original functions of SQA.

Risk of continuing perception of conflict of interest with accreditation arm regulating the awarding body.

Risk of continued shared identity resulting in a lack of awareness of accreditation and its functions.

Governance

Opportunities

Revision of the governance structure would strengthen accreditation autonomy.

Opportunity to introduce new finance arrangements between the Scottish Government, accreditation and the new qualifications body on resource allocation. This could empower accreditation to make a case for additional resource and build its capacity.

New qualifications body will be an NDPB therefore a governance relationship with Scottish Government would be retained.

Risks

Accreditation function requirements will continue to be balanced against the wider qualification body’s requirements.

New governance structures could add complexity to the relationship between the qualifications body and accreditation potentially delaying decision making.

Corporate changes are driven by the parent body with limited input from accreditation staff.

Resource

Opportunities

Limited resource required to take forward – the changes required (e.g. to legislation) can be incorporated into existing work streams.

Accreditation retains access to the qualification body’s corporate services, reducing cost and supporting resilience.

Potential to build resource capacity to take forward accreditation specific intelligence gathering including: public engagement and consultation, research and policy development to inform delivery of the accreditation function and input into wider sectoral decisions on the quality assurance of qualifications.

Risks

Potential competition over the resources of the parent organisation.

Staff

Opportunities

Existing staff terms and conditions retained.

Staff will have access to the training and development opportunities available in a larger organisation.

Risks

Staff perception that accreditation requirements are not being given sufficient priority, leading to dissatisfaction.

Delivery

Opportunities

Limited risk of disruption to delivery of services.

Risks

Ability to introduce innovative practice is constrained by the Qualifications Body e.g. by limited investment in measures which support the accreditation function.

Option 3: Part of new education agency

Position in education sector

Opportunities

No new bodies created in line with the recommendation of the Public Bodies Review.

Risks

Risk of continued shared identity resulting in a potential lack of awareness of accreditation.

There is a lack of appetite amongst stakeholders for this option. It could therefore be seen as not based on sector need.

The Education Agency’s general focus is on primary and secondary education whereas the accreditation function is primarily focused on vocational, professional and tertiary education.

Governance

Opportunities

Possible streamlining of oversight and committee structures.

Risks

The new education agency will be an Executive Agency, leading to risk of a perception that the accreditation of qualifications and regulation of awarding bodies would the influenced by Scottish Ministers.

Accreditation management and the accreditation committee would need to be aligned with new structures.

Although Ministers already have a power of direction over the accreditation committee, this proposal would represent a greater degree of integration into the system of central government.

Resource

Opportunities

Retains access to the corporate services of a larger organisation, reducing cost and supporting resilience.

Risks

Potential competition over resources of the parent organisation.

Risk that the forecast resources for the new agency are not sufficient to meet the needs of both the agency and accreditation.

Staff

Opportunities

Staff will have access to the training and development opportunities provided by a larger organisation.

Risks

Risk of significant disruption to staff and uncertainty around terms of employment.  Staff will also become civil servants, which may be attractive to some but not all, and will influence the perception around independence from Ministers.

Risk that staff become an isolated “silo” within the larger agency with limited real interaction or realistic opportunities for progression.

Delivery

Opportunities

Possible opportunities for greater connection to practice informed advice and expertise, particularly on assessment.

Risks

Transitional period could be disruptive to delivery of functions.

Risks impacting on operational independence.

Option 4: Part of new independent inspectorate

Position in education sector

Opportunities

No new bodies created in line with the recommendation of the Public Bodies Review.

Common focus on quality assurance albeit of different aspects of education.

Risks

Risk of continued shared identity resulting in a potential lack of awareness of accreditation.

There is a lack of appetite amongst stakeholders for this option. It could therefore be seen as not based on sector need.

The new Inspectorate’s general focus is on school and college education whereas the accreditation function is primarily focused on vocational, professional and tertiary education. 

Governance

Opportunities

Possible streamlining of oversight and committee structures.

Risks

The Inspectorate will not be an NDPB.

It is likely the Inspectorate will function under the responsibility of a Chief Inspector and therefore will have different governance arrangements.  There may also be a change to the functions’ relationship with Scottish Ministers albeit there is already a power of direction in legislation.

Accreditation management and the accreditation committee would need to be aligned with new structures. The governance structures for the new Inspectorate have not yet been confirmed.

Resource

Opportunities

Retains access to corporate services, reducing cost and supporting resilience.

Risks

Potential competition over resources of the parent organisation.

Risk that the forecast resources for the new Inspectorate are not sufficient to meet the needs of both the Inspectorate and accreditation.

Staff

Opportunities

Staff will have access to the training and development opportunities provided by a larger organisation.

Risks

Risk of significant disruption to staff and uncertainty around terms of employment given that they would become civil servants under the model currently proposed for the Inspectorate.

Risk that staff become an isolated “silo” within the larger organisation with limited real interaction or realistic opportunities for progression.

Delivery

Opportunities

Possible opportunities for greater connection to practice informed advice and expertise, particularly on assessment.

Risks

Transitional period could be disruptive to delivery of functions.

The framework and operation of the accreditation of qualifications and regulation of awarding bodies is very different from the inspection of education establishments.

Option 5: Part of an existing public body such as the Scottish Funding Council (SFC) or Skills Development Scotland (SDS)

Position in education sector

Opportunities 

It would meet the requirement Public Bodies Review not to create small NDPBs due to disproportionate cost/benefit.

Could help declutter and rationalise the education landscape.

Ministers have announced an independent review of the skills delivery landscape, focusing on SDS’s functions and remit and its interface with the wider system. The timescales for this work may not fully align with the Education Reform programme.

Risks

Risk of continued shared identity resulting in a potential lack of awareness of accreditation.

There is a lack of appetite amongst stakeholders for this option. It could therefore be seen as not based on sector need.

Muir did not consider whether SQA’s accreditation function should join with an existing organisation working in tertiary education. It is unclear what impact this option would have on the tertiary education sector.

Both organisations have existing relationships with SQA Accreditation. Joining accreditation to one of these organisations would change the dynamic of these existing relationships and potentially impact the balance of quality assurance responsibilities across the bodies.

Choosing one existing organisation over another would involve a redistribution of resources which may have a negative impact on relationships between and perceptions of those organisations.

Governance

Opportunities

SFC and SDS are NDPBs therefore a Governance relationship with SG would be retained.

Risks

Accreditation management and the accreditation committee would need to be fitted within existing governance structures.

Potential conflicts in interest in handling qualification accreditation and quality assurance issues within the sectors SFC and SDS represent.

Additional changes to legislation required.

SDS is currently subject to review and at this early stage it is unclear how this may impact its functions.

Resource

Opportunities

Retains access to the corporate services of a larger organisation, reducing cost and supporting resilience.

Risks

Potential competition over resources of the parent organisation.

Risk that the resources of the existing bodies are not sufficient to meet the needs of both the agency and accreditation.

Staff

Opportunities

Possible opportunities to draw on and share experience of other education professionals.

Risks

Risk of significant disruption to staff and uncertainty around terms of employment.

Risk that staff become an isolated “silo” within the larger body with limited real interaction or realistic opportunities for progression.

Delivery

Opportunities

Shared quality assurance role with SFC presenting opportunities to share best practice.

Risks

Transitional period could be disruptive to delivery of functions.

Option 6: Join with the Scottish Credit and Qualifications Framework Partnership (SCQFP)

Position in education sector

Opportunities

It would meet the requirement Public Bodies Review not to create small NDPBs due to disproportionate cost and benefit.

Could help declutter and rationalise the education landscape.

Common focus on quality assurance albeit on the credit rating rather than provision of qualifications.

Risks

Risk of continued shared identity resulting in a potential lack of awareness of accreditation.

Muir proposed that SCQFP be merged with the new Education Agency (currently Education Scotland), The SG response to the Muir review ruled out this option. SCQFP was intentionally established as an independent charitable organisation which assures the quality of all credit rating bodies (CRBs): both publicly funded agencies and private providers. There would be a perception of conflict of interest as SCQFP would potentially be assuring the CRB status of an accreditation unit in its own organisation.

It is not guaranteed that the SCQFP  would agree to take on the accreditation functions and it may not be possible or advisable to impose this.

Governance

Opportunities

Smaller scale may provide opportunities for simplification.

Risks

Accreditation management and the accreditation committee would need to be fitted within existing governance structures.

SCQFP is a charitable organisation not a public body and therefore is not subject to the same governance and accountability relationship with the Scottish Government as a public body.

Resource

Opportunities

Retains access to corporate services, reducing cost and supporting resilience.

Risks

SCQFP is a small organisation and merging with SQA Accreditation would double its size. There is a risk the existing organisation would not have the resources to meet the needs of both the SCQFP and accreditation.

Staff

Opportunities

Possible opportunities to draw on and share experience of other education professionals.

Possibly greater opportunities to influence corporate and policy developments.

Risks

Risk of significant disruption to staff and uncertainty around terms of employment.

Delivery

Opportunities

Shared quality assurance role, presenting opportunities to share best practice.

Risks

Transitional period could be disruptive to delivery of functions.

Risks impacting on operational independence.