Ros Ollin argues for a regulatory anchor to keep NVQs steady. The report, Learning to Succeed after Sixteen, by the National Commission on Education reiterates the need for schools, colleges and universities to work together to improve provision and progression and is just one of many recent reports reflecting a consensus on the priorities in education and training.

These include the development of a national qualifications framework, the facilitation of access and progression between further and ÖйúAƬ, and the promotion of learner choice, embedded in the context of debate on quality measures and the validity of the competence-based approach.

These initiatives are occurring in a political environment that emphasises competition, free market forces and consumer-led provision, of which the National Council for Vocational Qualifications is itself a product.

As part of the process towards developing a national qualifications framework, the ÖйúAƬ Quality Council report, Choosing to Change, on credit accumulation and transfer last year recommended aligning higher-level National Vocational Qualifications and academic qualifications. Work is being done on this by bodies such as the south-east England consortium NVQ working party. However, emerging difficulties have been indicated in the most recent HEQC report, Vocational Qualifications and Standards in Focus.

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This emphasises the difference in purpose of these qualifications and hence the problems in establishing equivalence. Unfortunately, there is one big potential problem, flagged in the Committee of Vice Chancellors and Principals' strategy paper on vocational ÖйúAƬ last year, when it talked of the "profound implications for ÖйúAƬ in terms of accreditation of prior learning and experience". This has already started as universities are having to decide the amount of credit to award students arriving with NVQs.

NVQs focus on functions derived from occupational roles. Whatever one's criticisms of functional analysis and competence, this idea has an apparent egalitarian merit, suggesting that all areas of work are equally important, although different.

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However NVQs are intended to be developed from levels one to five and it is here that the confusion arises. In academic terms, a level implies progression from lower to higher levels of achievement, in NVQ terms the word is more ambiguous. For example, exactly the same units can exist in more than one level of NVQ as in the "assessor" units which occur at both level three and level four in the NVQ in training and development. Hence the idea of level four being higher than level three cannot be the case.

What then does "level" mean? It does not imply a different rigour in assessment because as long as one meets the performance criteria (with underpinning knowledge) and the range, then one is judged competent. For NCVQ it means a description of role, where level four is described as "the application of knowledge in a broad range of technical and professional activities". However NCVQs have also indicated parity of level four with the first two years of a degree programme and level five with the final and post-graduate years.

None of this semantic confusion would have any implications if we were not dealing with a considerable disjunction between the rhetoric of NCVQ's level descriptors and what is occurring in practice. Levels four and five can be offered by any organisation with awarding body approval, and that means small private training organisations as well as large companies and further or ÖйúAƬ establishments.

Standardisation of NVQ assessment practice has been notoriously difficult to assure as exemplified by the Department of Employment survey carried out by the Association of Business Schools. These location and assessment variables, together with the lack of a clear indication of where they fit in relation to other qualifications, means that there is no clear national perception of the status of NVQs. They are adrift in a free market qualifications economy.

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In an environment where learner choice and competition is promoted, students are encouraged to use the flexibility of a credit system and are already shopping around with their NVQs. The confusion over their status means that students with an NVQ level 4 in training and development may, at present, go to one university and be awarded accreditation of prior experiential learning worth 40 credits at Credit Accumulation and Transfer Scheme level one, while another university is equating the same qualification in the same subject area with 40 credits at CATS level "M" (postgraduate level).

The obvious danger here is that without a proper articulation of levels, interpretations of the value of higher level NVQs by individual institutions, catalysed by competition to offer the best deal for the students, will artificially inflate their national currency.

But the educational world is not the same as the money market and it is dubious whether the credit value of qualifications should be decided through the laws of supply and demand.

Decisions made by individual universities may play a significant role in defining a national market value for an NVQ outside the educational system.

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Perhaps what is needed here is a national voluntary regulatory mechanism. A national qualifications framework is a sensible, and hopefully attainable, ideal. CATS is an imaginative and empowering development. It would be a pity if the flexibility of the one had an adverse effect on the quality of the other.

Ros Ollin is a senior lecturer in education at the University of Huddersfield and an executive member of the Universities Professional Development Consortium.

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