The QAA's thoroughly bad Apel

November 9, 2001

A code of practice section on accrediting prior learning dismays Geoffrey Alderman.

It is amazing what you come across on the streets of Manhattan these days. I recently happened upon the draft of a new section to the Quality Assurance Agency's mammoth Code of Practice for the Assurance of Academic Quality and Standards in Higher Education . Its subject is Apel - the accreditation of prior experiential learning. So far no fewer than ten sections of the code have been enacted. Taken together the sections will, the agency says, "provide an authoritative reference point for institutions".

The "precepts" that form the guts of the code "identify those key matters that the agency expects an institution to be able to demonstrate it is addressing effectively". The QAA regards the precepts as a definitive checklist against which institutions will be evaluated.

Of all the initiatives associated with the John Randall era, the code of practice epitomises the former chief executive's approach to quality assurance and explains cogently why the sector reacted to it so negatively. Parts of the code contain much common sense. But there is also a goodly quantity of arrant nonsense, and some highly controversial formulae have been elevated to precept level.

The section on collaborative provision, for example, enjoins institutions to identify on award certificates instances where the language of instruction is not English (or Welsh). This precept has been rightly criticised on the grounds that it fosters the cultural imperialism of the English language. Does it matter what language a student is taught in, so long as s/he is well taught and the standard of the award is assured?

The section on placement learning demonstrates a lack of sensitivity to the needs and expectations of private and public-sector providers of student placements. Such providers no doubt assist institutions from a range of motives. That is no reason to take liberties with their generosity by imposing a layer of intrusive bureaucracy.

The Apel draft takes us into the theatre of the absurd. Precept two enjoins that "all learning that an institution decides to recognise as contributing towards the requirements for completion of one, or more, of its programmes of study... will, irrespective of where it took place, meet the same general standards". First, awarding credit for prior non-certificated learning is a matter of academic judgement. No two cases are ever the same. A judgement must be reached. A risk must be taken. These are matters beyond regulation.

Second, the place where the learning took place is in fact of central relevance in reaching that judgement and in taking that risk.

Precept three would be funny if its formulation were not so tragic: "An institution's decision to recognise/accredit (or not) learning that has taken place in a non-teaching setting (typically referred to as 'experiential learning') is, by definition, a decision based solely and exclusively on assessment of demonstrably achieved learning. It is not concerned with the nature or duration of the experiences the candidate may have undergone... only the learning that may have resulted from these and that can be assessed."

Surely, if Apel is concerned with anything it is with learning, the achievement of which may not be capable of explicit demonstration. But even if this were disputed, the nature and duration of the "experiences" are, again, of central relevance in reaching a judgement when accrediting them.

There is no one prescriptive model of quality assurance. In seeking to confine institutions within a judgemental straitjacket, the code of practice threatens also to deprofessionalise academia.

My copy of the Apel draft is dated August 20 2001. The following day Randall announced his resignation. Though a historian, I forbear from commenting on the symbolic proximity of the two events. But I would strongly advise the QAA to withdraw the Apel draft and rethink the "code" project, which, I am afraid, I would not award as much as 20 credit points at level one.

Geoffrey Alderman is vice-president of Touro College, New York, and professor at Middlesex University, London.

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