Response to

UUK Consultation on Proposals for National Credit Arrangements -

 

We believe it is timely for England to develop a more coherent approach to credit in the light of the various developments taking place at present in relation to credit both in the UK and in Europe and welcome the opportunity to input to this consultation.  We concur with Professor Burgess that the emphasis should be on the application of credit in supporting students in their progression into and within higher education and through lifelong learning.  It is important to ensure that any arrangements are not perceived as adding unnecessarily to the bureaucratic burden and that they do not impose unjustified constraints on innovative programme developments.

 

Q.1  Would national credit arrangements for HE in England better be organised as:

• a system, that should include guidelines on credit and its application
• a framework, that should include such guidelines and also indicative credit numbers for the main HE awards

Our preference would be for a national framework that would include guidelines on credit and its application and indicative credit values for the main HE awards.  We believe this would help to promote more consistent use of credit. 

 

Q.2  Should national credit arrangements for (English) HE be integrated with the Framework for Higher Education Qualifications

Yes.  An integrated credit and qualifications framework would seem the best way of making the necessary linkage between a credit framework and the FHEQ.

 

Q.3  Should the primary basis of national credit arrangements for England be:

• the current arrangements used predominantly within UK higher education (ie one credit represents the notional learning associated with 10 notional learning hours; a full time equivalent undergraduate study year is represented by 120 credits; a full time equivalent postgraduate study year is represented by 180 credits; detail of level of learning is indicated by a credit level),  OR
• ECTS credits (ie 60 credits per full time equivalent study year (undergraduate or postgraduate); no reference to credit level.

The primary basis of national credit arrangements should be the current arrangements used predominantly within UK HE, in terms of notional learning time and level of learning.  The association of ECTS credits with the FTE study year (irrespective of the actual learning time) and lack of reference to credit level does not provide a robust basis for the consistent use of credit.

 

Q.4  Should national credit arrangements for English HE include guidance and recommendations on the use of level descriptors.

It would be helpful, but the use of any descriptors provided should not be prescriptive.

 

Q.5a  Should national credit arrangements identify the typical credit values of the main HE awards.

Yes.

 

Q.5b  Should these credit values be expressed as a minimum total credit typically associated with the award of each main qualification.

Yes, provided that institutions have discretion to condone marginal failure within a programme of study.

 

Q.6  Should national guidelines on credit provide an indication of expectations about the volume of credit typically associated with the level of the award for those HE awards that span different levels of study?

Yes.  In the context of an integrated credit and qualifications framework, this would seem to be a logical step.  The figure put on the volume of credit expected at the exit level should not impose unnecessary constraints on the curriculum structure, however.

 

Q.7  Should national guidelines on credit recommend use of the NICATS level descriptors as reference points to assist in establishing credit levels.

We acknowledge the widespread use made of the NICATS credit level descriptors and would have no objection to their being adopted as national reference points, subject to our answer to Q.4. 

 

Q.8  Are there any additional comments/observations you would like to make.

Proposal 6

We believe it appropriate and sufficient for information about credit to be contained within programme and module specifications.

 

Proposal 8 (and Q.4 and Q.7)

We foresee potential confusion between the FHEQ qualification descriptors, the ‘Dublin (qualification) descriptors’ and the NICATS credit level descriptors, particularly in the context of an integrated credit and qualifications framework.  This will need to be addressed in the interests of clarity.

 

A position should be adopted in the framework in relation to the use and re-use of credit where practice is inconsistent across the sector.