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A Documentary Study for Arrangements for Credit Accumulation and Transfer in Higher Education



Transfers of credit between universities in Australia, and between Australian universities and those overseas, is a matter for negotiation between the institutions concerned (which may result in a standing arrangement for the recognition of work done on a specific programme at the sending institution for credit on a specific programme at the receiving institution); or between the individual student and the institution he wishes to attend. The extent and variety of the inter-institutional arrangements can be seen in the example from Monash University (see Appendix 1). It will be observed, however, that the arrangements provide mostly for "vertical" transfer from institutions both in Australia and overseas: there is little provision for "horizontal" transfers from other degree-granting institutions. Griffith University gives an example (see http://www.gu.edu.au/ua/aa/ppm/pae/content/Credit_Policy.html and Appendix 2) of conditions applying to the granting of credit to an individual student. It is worth noting that this statement also states that the aim of the policy is to:

  • assist the student to progress through award courses with maximum efficiency by recognising that students may attain the objectives of components of the course by means other than formal study and assessment in the course;

  • facilitate the movement of students between institutions and between courses of various types and levels; and

  • assist in the efficient use of educational resources.

In recent years, however, a series of reforms have been undertaken to the vocational education and training (VET) system in Australia, which have been designed to reinforce national competency standards as the benchmarks for VET, increase flexibility so far as modes of delivery are concerned, and provide greater choice on the part of clients of the system, within an agreed 'National Training Framework'. One expression of this development was the establishment, in 1995, of an 'Australian Qualifications Framework' (AQF) which

    'provides a comprehensive, nationally consistent, yet flexible, framework for all qualifications in post-compulsory education and training ... incorporating qualification levels, titles and guidelines.' (AQF Implementation Handbook 1998, p.1) (See http://www.aqf.edu.au/implem.html and Appendix 3).

The Framework was first introduced in January 1995: its introduction is due to be completed in the Year 2000.

The same period saw the development of formal policies within the higher education system for the recognition of credit gained outside the system. One expression of this is the promulgation by the Australian Vice-Chancellors' Committee (AVCC) of the details of a series of 'National TAFE-University Credit Transfer Schemes' which set out arrangements for the granting of credit by 'participating universities' to the holders of TAFE (Technical and Further Education) qualifications in 13 fields of study (see Appendix 4). It is claimed that this has resulted in

    'a more than five-fold increase during the 90s in the number of TAFE entrants to universities who have received credit for their prior studies'.(Preliminary Report of the AVCC/ANTA Articulation and Credit Transfer Project, June 1999 (Appendix 5)

Despite the comparative success of the AVCC's efforts in this area, it was felt that its approach suffered from a number of limitations, in that:

  • it was restricted to the recognition of TAFE qualifications, to the award of credit for completed qualifications only, and, for the most part, to the interface between Diploma/Associate Diploma and degree levels;

  • it had been conceived in an environment in which accredited private providers were relatively few in number and TAFE institutions had operated on the basis of national curricula.

The AVCC has therefore joined with the Australian National Training Agency (ANTA) to establish a project to examine credit transfer and articulation arrangements between VET and higher education and to produce a draft policy statement for the consideration of AVCC and ANTA. The project has so far produced a Preliminary Report (which is referred to above). A description of the scope and methodology of this project (attached as Appendix 6) refers, amongst other things, to the 'Australian Recognition Framework' (ARF), and quotes the ARF's '[silence] over the issue of credit transfer/articulation' as 'a gap in policy which needs to be addressed' and which the project is intended to address. Information about the ARF is available at http://www.tafensw.edu.au/traiin/trai111.html [obsolete link] (attached as Appendix 7).

Possible Points of Interest for Hong Kong

It will be clear from the above that policy on the issues of CAT in Australia is still evolving, and it would therefore be worthwhile to maintain a watching brief on developments, particularly with regard to the establishment of 'national frameworks'.


Education in Canada is the responsibility of the provinces, rather than of the central government. As a result, arrangements for credit transfer tend to be focussed on intra-province, rather than inter-province, needs, with the emphasis on articulation between the province's community colleges on the one hand, and its universities on the other. Arrangements vary, therefore, from one province to another.

British Columbia has particularly good provision, in the form of an 'Online Transfer Guide: BCCAT Online', which gives both general guidance and 'Institution-Specific Transfer Notes' in respect of the universities in the province (see http://www.bccat.ca/tg/tgfs.html and Appendix 8). At the other end of the scale, however, the province of New Brunswick also publishes a 'Guide to Transfer of Credits', which sets out a set of 'guiding principles', which it states were announced in the province's Legislative Assembly in 1994, after having been approved by the Senate of each participating university (sc. in the Maritime Provinces) and the relevant Department of the provincial government. Amongst the principles enunciated are that

    'each university [under the purview of the Maritime Provinces Higher Education Commission] agrees to consider a priori that another university's courses at the first and second year levels are of a quality equal to its own.'

but that

It will be seen, therefore, that, as in the case of the USA (for which see below) although the province/state may legislate to specify that the transfer of credit should be possible, care is taken not to infringe institutional autonomy and the right of universities is recognised to specify both the range of previous studies, and the standard of attainment, required for admission to specific courses.

As a result, much depends on negotiations between individual institutions to secure agreements about how much credit will be earned by the successful completion of course A at institution B by a student who wishes to go on to take course C at institution D. Examples of the sorts of arrangements which result are set out in Appendices 10 and 11 relating to the courses at Selkirk College in British Columbia and Loyalist College in Ontario. It will be seen that students are warned that

    'programme requirements differ among the universities and are subject to change'

and that

    'admission to university courses generally requires a grade of 'C' or better in prerequisite courses'.

Notwithstanding the above, some measure of agreement has been reached at national level, so far as concerns the recognition of credit gained at university, in the form of a 'Pan-Canadian Protocol on the Transferability of University Credits' (attached as Appendix 12) (http://www.cmec.ca/postsec/ transferability.stm). This document sets out the rationale for obtaining the agreement of the Ministers of Education of each of the Canadian provinces to an arrangement designed

    'to have all degree-granting institutions in Canada approve, adopt and implement ... a pan-Canadian protocol providing for the transferability of first- and second-year university courses ...'

in terms of increased accessibility, equity and student mobility. The document is nevertheless framed as a 'request' to

    'all member institutions of the [Association of Universities and Colleges of Canada] to adhere to this protocol'

and ends with a reassurance on the subject of 'academic autonomy', which is probably a sine qua non of any such arrangements between governments and universities which remain within the Commonwealth tradition.

The Ministers of Education of the Canadian provinces collectively maintain an organisation (CMEC), which itself maintains a 'Canadian Information Centre for International Credentials', which has published a statement of 'General Guiding Principles for Good Practice in the Assessment of Foreign Credentials' (attached as Appendix 13) (http://www.cmec.ca/cicic/ pubs/prncpen.stm).

Although this document is concerned with foreign credentials, it

    'recognises the importance of linking principles developed in Canada to models of good practice currently under development in other parts of the world,'

and pays tribute to the value of a set of 'Draft Recommendations on the General Procedures and Criteria for the Evaluation of Foreign Qualifications' produced by the Council of Europe and UNESCO, which were

    'where possible ... incorporated into [their] document'.

Further evidence of Canada's wish to demonstrate its membership of the wider global community was provided by its ratification in 1989 of the 1979 Council of Europe/UNESCO 'Convention on the Recognition of Qualifications Concerning Higher Education in the European Region', which stipulated that

    'mutual recognition of qualifications must be granted by contracting states unless significant difference [could] be proved. The burden of proof lies with the ... receiving country'(Appendix 14).

The Association of Universities and Colleges of Canada (AUCC) maintains a register of over 2000 exchange agreements between Canadian and overseas universities (http://www.aucc.ca), but reports (private communication) that an increasing number of overseas partners are seeking to use established international frameworks, such as the European Union's ECTS (for which see later) to govern such exchanges.

Possible Points of Interest for Hong Kong

  1. The possibility of preserving institutional autonomy - notwithstanding the enactment of national or provincial legislation prescribing that arrangements for credit transfer should be introduced - in respect of:
    • the range of previous studies; and

    • the standard of attainment required for admission to a specific course.

  2. The possible value to be obtained from adopting existing regional (e.g. European) arrangements for CATS, or of subscribing to extra-territorial conventions and adopting the principles underlying them, even though the country adopting the arrangements is outside the region concerned.


The main characteristics of the Higher Education system in each of the countries of Europe - including the existence (or otherwise) of arrangements for credit accumulation and transfer - are helpfully summarised in part II of a paper by Kirstein, which was prepared for the Bologna Conference of European Ministers of Education which was held in 1999 (http://www.rks.dk/sider/publikationer/english/edutrends.html) (attached as Appendix 15). As reported by Dalichow (1997) two years earlier, 'academic credit systems' exist in most European countries. Most of them are credit accumulation (as opposed to credit transfer) systems, although a few countries operate both credit accumulation and credit transfer, in some cases confined within their national boundaries, in others operating also extra-territorially. Thus, in 1990, the Swiss universities developed subject-related credit transfer arrangements, in order to encourage mobility amongst Swiss students in advance of their joining the EU's ERASMUS scheme: the physics-related section of the Swiss scheme went on to form the basis of a scheme for subject-related exchanges which extended throughout Europe and beyond. The UK's interest in credit accumulation and transfer (which is detailed elsewhere in this report) pre-dated the development of the European Union's ECTS scheme (for which see below). Elsewhere in Europe, however, (e.g. in Belgium, Czechoslovakia, Hungary and Slovenia, in addition to Switzerland) ECTS provided the basis and, in some cases, the inspiration, for the development of national schemes. In other parts of the world (including North America) the principles underlying ECTS, and the experience gained in its operation, have informed the development of other regional arrangements. The rest of this section will therefore focus on ECTS.

The European Credit Transfer System (ECTS) is an instrument available to institutions in countries which are members of the European Union. They may choose to use it, or not, as they wish, but, if they choose to do so, they must abide by the system's rules. It is intended primarily to facilitate student exchanges between institutions located in different countries of the Union, but may be used also, if desired, for exchanges between two institutions in the same country.

Institutions - and students - who use it must sign a 'Learning Agreement', which provides, in respect of each student exchange which takes place, details of the studies to be undertaken during the period of exchange and of the credit which the students will receive for them when they return to their home institutions. The 'scheme' is essentially, therefore, a framework within which bi-lateral arrangements can be made between pairs of institutions.

The impetus for the establishment of the system was the need to provide recognition for periods of study undertaken under various student exchange programmes introduced by the European Commission (e.g. Erasmus, Socrates) as a means of fostering European integration. Another factor in this development was the publication of the Commission's Directive 89/48/EEC concerning the mutual recognition of diplomas by member states. It has, however, taken a great deal of time and effort to establish the current arrangements, and substantial effort and resources are also deployed - both by individual institutions and by the European Union - in maintaining them. (There are, for example, 'National Academic Recognition Centres (NARICs)' in each of the countries participating in the scheme, and a network of ECTS 'Helplines' to provide information and advice, as well as (in most institutions) an office whose responsibilities include the task of servicing the setting up and maintenance of the institutional relationships on which the exchanges depend). Thus the 'Convention on the Recognition of Qualifications Concerning Higher Education in the European Region', which was adopted by the Council of Europe at its meeting in Lisbon in April 1997, rehearses in its preamble a number of previous such conventions, of which the first is the 'European Convention on the Equivalence of Diplomas leading to Admission to Universities', which was dated 1953.

The 1997 Convention enunciates some useful principles for governing the assessment and recognition of qualifications (e.g. that the holder of a qualification obtained in one signatory country should be entitled to have it 'assessed' in another; that this assessment should be undertaken without discrimination on non-educational grounds; and using procedures and criteria which are 'transparent, coherent and reliable') and might form a useful point of reference for Hong Kong, if any consideration is to be given to the possibility of central policy-making in this area.

The main features of the ECTS scheme and its development are summarised at http://europa.eu.int/comm/ education/socrates/ects.html. Some of the main points are that:

  • institutional autonomy is preserved in decisions regarding the acceptability of studies elsewhere and the conditions which need to be fulfilled for admission to a specific course of study, or for the award of a specific qualification.

  • these matters are negotiated and agreed between the institutions and the student concerned before the period of exchange study begins.

  • the use of ECTS can be a catalyst for reflection by academic staff, and their institutions, on course curriculum structures, student workload and learning outcomes.

  • 60 ECTS credits represent one year of study (defined in terms of workload).

  • the transfer of credit is effected by issuing, and presenting to the institution to which the student is then returning or proceeding, a transcript recording the credits (and grades) earned.

  • grades are awarded, in accordance with local norms and criteria, by the institution at which the study was undertaken.

  • there is an ECTS grading scale, designed to help institutions interpret grades awarded by an institution in another country, which

    'provides additional information on the student's performance to that provided by the institution's grade, but does not replace the local grade ...institutions make their own decisions on how to apply the ECTS grading scale to their own system.' (ibid. p.4)

An initial problem in setting up 'Learning Agreements' was a lack of information on the part of the institutions involved, concerning the higher education systems in the other countries of the EU, and the nature of the institutions and courses available. This problem was addressed by introducing a programme for the systematic exchange of 'Information Packages' by institutions taking part in the scheme, designed to thoroughly brief each party to a Learning Agreement before the Agreement was concluded.

The scheme has been extensively trialled and extensively reviewed. It began in 1988, with a pilot scheme involving 145 institutions. In 1996, it was expanded to 219 institutions (of whom 36 were non-university institutions) and by 1998 more than 1200 institutions were taking part in the scheme. In a report on the experience of those institutions who took part in the first extension of the scheme, Blok (1996) stressed the importance of the exchange of the 'Information Packages' (and of their quality) to the success of the scheme and of any exchanges initiated under it. He also quoted examples of difficulties that had arisen (e.g. in particular, relating to the judgements that needed to be made about how much credit should be awarded for a specific course) and of ways in which they had been resolved in specific cases. Particular problems arose over the use of workload as the criterion for the award of credits (with no attention paid to the complexity or level of the studies involved); and in respect of the allocation of ECTS grades (which are intended to indicate the student's level of performance, rather than the amount of work undertaken). The point was also made that it was important to have a mechanism within each institution which monitored the actions of individual departments and faculties in the context of an exchange agreement, in order to ensure that there was reasonable equality of treatment across the institution. In a report on the second phase of extension of the scheme, Blok and his colleague Scholten (1997) looked at problems encountered by individual institutions in administering the scheme, and the solutions that had been adopted.

Although the scheme has included, from an early stage, institutions other than universities, there is little information about the extent (if any) to which 'vertical' transfers of credit are provided for, and the implication must be that the scheme's major concern is with 'horizontal' transfers, and that the non-university institutions included are nevertheless institutions of higher education.

Possible Points of Interest for Hong Kong

  1. Notwithstanding the introduction of national (and regional) arrangements, matters of academic judgement, such as the amount of credit to be allocated to a course, the grades to be awarded, and the requirements for admission to a specific course of study and for the award of a specific qualification, remain in the hands of individual institutions.
  2. The transfer of credit is negotiated in advance, on the basis of an exchange of information about the courses taken, and to be taken, the institutions from which, and to which, the student is proceeding, and the educational systems of which they are part.
  3. No attempt is made to amend any aspect of the national, local or institutional arrangements, in order to facilitate student exchanges and the transfers of credit which they make necessary. Instead, a 'common currency' of credits and grades is established into which local arrangements can be converted and, by this means, compared.
  4. The exchange of information between each pair of institutions participating in the scheme, and the quality of the information exchanged, are crucial to the success of any arrangements for the transfer of credit, and for solving problems of comparability between disparate systems.


The Japanese education system consists of elementary schools (six years from the age of six), followed by three years of junior high school (making nine years of compulsory education); this may be followed by three years of senior high school, four years of undergraduate study, and five years of postgraduate courses. There are also colleges of technology, offering five-year courses for those who complete junior high school; and two- or three-year junior colleges for those who complete senior high school. Finally 'special training colleges' (of which about 90% are private) offer courses on three levels - for graduates of junior high school; of senior high school; and open access. (See Appendices 16 and 17).

Universities award Bachelors' degrees on the basis of credit accumulation (except in the case of Medicine, Dentistry and Veterinary Science). The number of credits required for graduation is specified by each university, and may vary: usually however, it is set at 124 for a four-year course comprising 35 weeks of instruction per year (at six days a week). Graduates of colleges of technology, of junior colleges and of special training colleges, are eligible to apply for admission to the second, or third, year of a university Bachelors' degree course.

Since the early 1990s the whole of the Japanese education system has been undergoing a series of reforms initiated by the Ministry of Education, Science and Culture (Monbusho). The reform of Higher Education is designed to meet international criticisms which have been made of a number of features of the system, and to enable it to fulfil its role of developing 'superior human resources' and the promotion of scholarship (Monbusho, 1998). It is said to be 'the greatest reform of Higher Education since the establishment of the present university system after World War II' and is intended to introduce more diversity and flexibility into the system (ibid. Pt II, Chapter 4).

As part of the move to increase diversity the Ministry streamlined the 'Standards for the Establishment of Universities and other regulations' (in June 1991) and, in June 1990, enacted a 'Lifelong Learning Promotion Law', of which one objective was to enhance 'administrative and service interfaces' (ibid.). An interesting summary of the reasons for moving in the direction of lifelong learning (which are said to include 'the need to remedy the harmful effects of Japanese society's preoccupation with academic credentials') and of the measures taken to promote it, is contained in 'Toward the Achievement of a Lifelong Learning Society' by Monbusho (1999). (See http://www.mext.go.jp/english/org/lifelong/11b.html and Appendix 18).

A National Institution for Academic Degrees (NIAD) was established in the mid-90s in order to provide for the award of degrees in respect of courses of study undertaken outside the university system; to undertake research into systems of learning in other countries; and to disseminate information on learning opportunities in Higher Education. It approves course of study and specifies entrance requirements on courses leading to NIAD degrees (e.g. an associate degree from a college, or 62 credits from a university). (http://www.niad.ac.jp/index_e.html and Appendix 19).

A University of the Air was established in 1983, but broadcast only to one region of the country until 1998, when its coverage was extended nationwide. In addition, a National Institute of Multimedia Education was established, which operates an inter-university network 'through which institutions can use satellite communications to conduct simultaneous, interactive, joint lessons and seminars' (see Appendix 17).

Under the heading 'Development of a More Open University System' Monbusho (1998) reports that:

    'In recent years a growing number of graduates of junior colleges and colleges of technology have been seeking access to further higher education through transfer admission to four-year universities. Universities are increasingly establishing special admission quotas that allow transfer admission as third-year students. More and more universities are also introducing special selection systems for adult applicants. By fiscal 1993 a total of 183 universities (34.5% of all universities) were administering such selection systems. Many universities are responding to society's learning needs by actively promoting admission of adult students through the development of innovative selection procedures that reflect the abilities and aptitudes of adult applicants' (ibid., Section 2, para.3)

Ako (Appendix 20) reports that, by 1996, the number of universities which had introduced credit transfer schemes had risen to 342 (Table 13). The number of students successfully transferring, since the opportunity to transfer credit was first introduced in 1992, following the establishment of NIAD in 1991, totalled 3189 in 1997 (Table 8), which represents a microscopic proportion of the total post-secondary student population. As can be seen from Tables 9 and 11 moreover, the phenomenon of undergraduate credit transfer between universities (if the 50 re-enrolling drop-outs are excluded) appears to be wholly unknown. Transfers (without transfer of credit) are undertaken by kamen ronin - i.e. students who, although they accept a place at University A, spend all their time on studying to take the entrance examinations again, in the hope of getting in to University B (which was their first choice) where they are willing to start again in the first year - and, indeed, have no choice, since they have earned no credit at University A. (Ako, private communication).

Reforms are continuing, however. The University Council (a body advisory to the Government) recommended in 1998 that a 'cumulative credit system' be developed [for universities], and that, in the interim, the 'Standards for the Establishment of Universities' (which are enshrined in law) should be amended so as to permit (N.B.) universities to increase from 30 to 60 the number of credits granted to students who had undertaken extra-mural study either before or after admission. ('A Vision for Universities...', October 1998). And the Ministry, as part of a programme to 'create a lifelong learning society' is promoting the introduction of special selection procedures for adults, day and evening courses, public access to lectures and public educational facilities, and a credit system amongst secondary schools ('Toward the Achievement ...',1999).

New Zealand

The situation in New Zealand is currently in a state of flux, with consultations ongoing on the development and implementation of a National Qualifications Framework (NQF). The NQF is

    'a structure designed to bring coherence to qualifications. Qualifications are registered at eight levels, from Year 11 of schooling or vocational entry to postgraduate. Qualifications are defined in terms of learning outcomes and credit totals. It is a quality-assured framework, in which qualifications are registered, providers accredited to assess and award credits, and moderation systems ensure nationwide consistency.' ('About Framework' at http://www.nzqa.govt.nz/ framework/about/about.html).

A more detailed explanation of the NQF is contained in 'Framework Explained'
(see http://www.nzqa.govt.nz/services/ frameworkexplained.html and Appendix 21). Amongst the 'providers' who will be 'accredited to assess and award credits' and will be expected to 'register' the qualifications which they award, will be the 'Committee on University Academic Programmes' (which is a committee of the New Zealand Vice-Chancellors' Committee), the Polytechnic Programmes Committee (with a similar relationship to the Polytechnics) and the Colleges of Education Accreditation Committee (ditto). The New Zealand Qualifications Authority (NZQA), which is an independent body, established in 1990

    'to put in place and manage a structured, flexible approach to qualifications development that would recognise a diverse range of achievement'

will be responsible for 'unit standard based qualifications'. ('Common Questions on the NQF White Paper')(Appendix 22).

The NZQA has published a 'Consultation Draft' on 'Registering Qualifications in New Zealand' (http://www.nzqa.govt.nz/ circulars/natregnquala.html, attached as Appendix 23). The aim of the consultation exercise is said to be

    'to facilitate the implementation of a broadened framework of qualifications that will become a national Register of all nationally quality assured qualifications and courses' (op. cit. p.1)

The document builds on an exercise conducted in March 1999, designed to develop consistent definitions and credit requirements for degrees and postgraduate qualifications, and responds to a government policy that requires that all types of qualifications should be registered in terms of level, credit, outcome and field (ibid.). The document is open for consultation until August 2000.

In the meantime, the universities in New Zealand continue to operate arrangements for the recognition of credit obtained elsewhere (both within and without the university system) which have been a feature of the higher education scene since the disestablishment in 1961 of what was originally a single, national university, with constituent colleges in different parts of the country. The arrangements are discretionary, and depend on consideration of the circumstances and record of individual students - except where twinning, or articulation, arrangements have been negotiated between pairs of institutions (whether within New Zealand or between a New Zealand and an overseas institution). The situation is summarised in the attached statement from the Academic Officer of the New Zealand Vice-Chancellors' Committee (NZVCC) (Appendix 24), to which is also attached (at 24a) a statement from the NZVCC's Committee on University Academic Programmes on the subject of 'Functions and Procedures' dated September 1999, which gives details of university practice and requirements for both 'horizontal' and 'vertical' transfers as at September 1998.

United Kingdom

The systematic use of credit in the UK as a common transferable measure of learning achieved in higher education has its antecedents in the establishment of the Open University in 1969 and the various developments in modular higher education provision during the 1970s. The development of the CAT movement in the UK over 30 years since it was foreshadowed in the Robbins report (1963) is documented in the seminal work on the credit transfer movement in the UK : 'Choosing to Change - Extending Access, choice and mobility in Higher Education' Robertson (1994). At that time the author found that

    'credit transfer in the UK remains heavily circumscribed by traditions, regulations, and the absence of a culture of mobility and choice.'

About 80% of universities in the UK had already introduced or were committed to introducing modular degree programmes based upon credit accumulation by the early 90s (Trowler 1998). Nevertheless, there was little evidence of student demand for inter-institutional credit transfer within the UK university system despite its formal availability. There was however a high demand for international arrangements to facilitate study abroad programmes, particularly within Europe; and for US students who wished to spend one year (usually their Junior year) at a university in the UK.

The development of CATS schemes in the Higher Education (HE) sector in Britain has gone hand in hand with a period of expansion of HE provision which has resulted in a change from an elite system enrolling up to 15% of the age group (Trow 1973) to a mass system. As the student population has expanded, it has become more diverse. The 1996 HEFCE report on 'Widening Access to Higher Education' (Appendix 25) notes that while A-levels continue to be the main entry qualification for HE, a significant number of students enter without A-levels. Moreover, the age profile is shifting, as over a third of entrants to UK higher education are over 21 years. The report also notes the increase in the size and scope of part-time education to meet the needs of the new clientele.

CAT schemes owe their early development to the modular degrees pioneered in the then polytechnics in the early 1980s, and the work of their accrediting body, the Council for National Academic Awards (CNAA), which introduced its 'CATS' initiatives in 1986. It is not surprising therefore that it is the new universities which have been at the forefront of the movement to develop a national credit framework which can deliver the government's pledge to provide lifelong learning opportunities to meet the aspirations of a growing proportion of the population.

Until the late 1990s, the movement has been largely based on regional consortia of autonomous institutions, namely SEEC (Southern England Consortium for Credit Accumulation and Transfer), NUCCAT (Northern Universities Consortium for Credit Accumulation and Transfer), HECIW (Higher Education Credit Initiative Wales), NICATS (Northern Ireland Credit Accumulation and Transfer System) and SCOTCAT (Scottish Credit Accumulation and Transfer scheme). Such consortia typically consist of a group of institutions within a particular geographical area who share a common interest in improving access to higher educational opportunities within their region.

The SCOTCAT scheme was an early example of an attempt to develop a national credit framework (relating to HE in Scotland). The basic principle underlying the Scottish scheme is that ' appropriate learning at a Higher Education level, wherever it occurs, provided it can be assessed, can be given credit towards an academic award'. (SCOTCAT Quality Assurance Handbook 1995). Nevertheless the particular ways in which the framework is applied by different institutions vary according to the individual structure and focus of institutional provision. Thus, the recognition of credit points for specific credit towards an award of an HE institution will be governed by the admissions and quality assurance procedures in that institution.

A critical point in the development of SCOTCAT was the agreement in 1991 of all the HE institutions in Scotland to join together in establishing a common framework within which credit-based learning would be developed across the sector. This provided a coherent, transparent and integrated framework for credit-based learning within the institutions themselves and in collaboration with other bodies including those in FE, and in the professional and employment sectors. The consortium approach has also facilitated the negotiation of articulation arrangements with universities in the rest of the UK, with ECTS in Europe and with North American credit accumulation schemes.

Fundamental to all CATS schemes are the definitions of 'credit points' and 'credit levels'. In SCOTCAT credit points are awarded for the achievement of appropriate learning outcomes. The number of credit points is determined by the notional student effort required by the 'average learner' to achieve these outcomes. The volume of learning outcomes that would be achieved through the notional effective student effort of one standard full-time undergraduate year is 120 Scottish credit points (SCP).

Credit levels refer to the location of learning outcomes within the progressive structure of HE in Scotland for which 6 levels (Access, 4 levels of under-graduate study [SD1-4] and one post-graduate level [SM] have been defined.

As an early example of a regional credit framework, SCOTCAT may be seen as a direct descendant of the credit framework approach which existed in the HE sector in the UK and which was inherited from the former CNAA. Within this approach, Level was linked to the year of study or the title of the award rather than the relative complexity of the academic content of the module studied. The system is defined by Robertson (1994) pp120-121 as the 'impositional' credit system approach. Such systems use 'credit' to superimpose a numerical partition on a programme by allocating to each course a volume of credit in direct relationship to the proportion of the total workload in the particular year of the degree programme which it represents. Credit values are determined by subdividing the honours degree into 360 credits and attributing to each module an appropriate credit-rating. Since each undergraduate year is deemed to involve 1200 hours of study, 120 credits are awarded at undergraduate levels 1, 2, and 3 to build up the necessary profile. Consequently one credit, at any particular level, is equal to 10 hours of study. This approach is 'top down' as it implies the division of the existing provision and the credit rating of each segment with reference to its contribution to the achievement of a degree.

More recently, the work of the regional consortia has been further developed and refined by the Inter Consortium Credit Agreement (InCCA) Project, funded by the Department for Education and Employment (DfEE). This project was led by consortia based on universities in Southern England (SEEC), Wales ( HECIW )and the North of England (NUCCAT) with the additional involvement of the national consortia in Northern Ireland (NICATS) and Scotland (SCOTCAT). The aim of this Project was

    'to work collaboratively across the UK for the development, promotion and acceptance of credit guidelines which encompass all forms of learning at higher levels' (InCCA draft interim report, 1997).

The InCCA final report, 'A common framework for learning' (September 1998) (see Appendix 26) includes agreed guidelines for a national HE credit framework but observes that a common credit framework will only become a reality if the Government endorses the agreed principles and incorporates them into the current development of the National Qualifications Framework by the Quality assurance Agency (QAA) as recommended in the 1997 Report of the National Committee of Inquiry into Higher Education (NCIHE) - the 'Dearing Report', see http://www.leeds.ac.uk/educol/ncihe/.

As a result of the InCCA Project, all the UK HE credit consortia have reached agreement on the major elements of a credit framework and contend that qualifications should be developed using a 'bottom up' approach. Programmes are composed of units or modules which have clearly defined learning outcomes and assessment criteria to enable the ascription of the correct level and credit value.

This approach has been defined by Robertson (1994) as the 'compositional' approach. Credit is defined independently of any overall qualification, can potentially be built up towards different qualifications and is recognised as an award in its own right. The publication 'Credit in Higher Education' (HEQC, 1997) reviewed the position of credit and suggested that the

    'role of credit has widened from an emphasis on institutional CAT schemes to being an organising and unifying feature of curriculum arrangements¡K credit has a further equally important role to play in the contexts of academic standards and in any UK-wide framework of awards' (HEQC 1997 Page v).

The Government in the UK is faced with a need to provide a highly skilled workforce for a competitive economy, and is pledged to support greater equity and social mobility through the provision of lifelong learning opportunities. It wishes to increase the participation rate in HE to 35% by 2002 (Times Higher Education Supplement 10/12/99). It has therefore supported the findings of the 'Dearing Report' (http://www.lifelonglearning.co.uk) and announced the development of a national qualifications framework to be implemented by 2006 which can provide for progression through various levels, incorporating provision for credit accumulation and increasingly offering scope for transfer of credits earned in one institution to another. Awards within the framework will be made on the basis of the achievement of defined learning outcomes, with less emphasis on the length of study required. In theory, credit based frameworks allow individuals to move easily into and within the plurality of learning opportunities available to them.

The work of the CATS consortia in facilitating the movement of students between institutions, "not least in the context of lifelong learning," is acknowledged in the position paper on a National Qualifications Framework for England, Wales and Northern Ireland (EWNI) published by the QAA on July 4 2000 (www.qca.org.uk/493.html) The framework includes credit definitions for typical qualifications at each of the levels in the framework, to prescribe the total volume of credit required for the qualification and the minimum volume of credit required at the level at which the qualification is awarded. The QAA notes that while credit systems are used widely, but not universally, within higher education, credits are included within the framework because they are a currency that is generally recognised, even by those institutions that choose not to calibrate their programmes in this way.

The descriptors of the characteristics of learning at each level, proposed in the EWNI paper are broadly consistent with the level descriptors used by the main credit consortia, but the QAA states that the development of more detailed level descriptors belongs more appropriately to institutions, 'individually or in voluntary consortia'.

The Scottish Qualifications Framework (SCQF) (http://www.scqf.org.uk) has adopted unchanged the SCOTCAT definition of the credit point whereby one credit point represents the learning outcomes achieved by the average learner at the relevant level in 10 hours of total learner effort. Thus the use of SCQF credit points allows the framework to define the volume of outcomes of all qualifications, modules or other programme elements to be described.

Like the EWNI framework it leaves to the individual institutions the responsibility for structuring programmes "in whatever ways are appropriate to the achievement of the aims of the qualification, the teaching and learning strategies, and the characteristics of the associated learner groups".

From their introduction, CAT schemes in the UK have elicited strong reactions for and against.

Modularisation has brought with it semesterisation and the standardisation of module size and shape. For managers facing a declining unit of resource, the credit framework holds out the hope of developing a more manageable curriculum structure and a more economic, efficient and effective approach to the delivery of higher education. It has been perceived by academic staff however to bring relatively few advantages (Gregg 1996). Indeed the introduction of credit frameworks has been viewed as an attempt

    'to undermine the central assumption of much of the UK higher education system, namely that learning takes place within one institution, over a fixed and limited period of time, according to rules best determined by academic staff.' (Trowler 1996)

The paradigm shift required to embrace credit-based systems is not insignificant. It is quite clear that moving from a traditional curriculum framework to a credit-based modular framework is a step change requiring not only radical changes in academic, administrative and managerial practices, but significant shifts in professional cultures and values.

The introduction of a national credit framework will doubtless be seen by some as a further erosion of institutional autonomy. The QAA seeks to allay the fears of these institutions that they will be forced into accepting CATS students into their programmes against their will, by stating clearly in its NQF proposals that institutional autonomy is a long-accepted principle of CAT.

The SCQF paper notes that its Framework is designed in part to support lifelong learning by enabling, where appropriate, the transfer of credits between programmes and between institutions. It points out however that "individual institutions remain solely responsible for all matters of credit recognition towards their awards." In addition, the EWNI paper reminds its readers that " recognition of prior learning, whether or not measured by credit, remains a matter of academic judgement of the extent to which such learning contributes to the intended outcomes of a programme."

While the introduction of a National Qualifications Framework may fulfil the United Kingdom's obligation, as a signatory to the Bologna Declaration on the development of European higher education (http://www.unige.ch/cre), to adopt a system of easily readable and comparable degrees, it seems unlikely that it will provide a resolution to the ongoing debate on the role of CATS in a higher education system consisting of independent autonomous institutions.

Possible Points of Interest for Hong Kong

  1. The long time-frame and cooperative effort required to develop the definitions of levels and learning outcomes which will form the basis of the national credit-based qualifications frameworks.
  2. The need to enshrine institutional autonomy at the heart of any system-wide CATS initiative.
  3. The impetus for CATS development provided by a major expansion in the provision of tertiary places, without matching additional funding.
  4. The importance of distinguishing between credit points (representing student workload input) and credit levels (representing learning outcomes).
  5. The shift away from the 'top down' or 'impositional' approach to the design of CAT schemes, in which an existing qualification is divided into credit units, towards a 'bottom-up' or 'compositional' approach in which a credit is defined independently of any overall qualification and is recognised as an award in its own right.


The system of academic credits may be said to have been invented in the US, and dates from an initiative at Harvard University in 1886, which introduced the notion of 'elective' subjects within an otherwise wholly prescribed curriculum (Dalichow, 1999). It gradually spread throughout the US during the remainder of the 19th century, and, with the advent of the 20th century, began increasingly to be exported. It is very much a credit accumulation system, in which, according to Dalichow, credit transfer is the exception, rather than the norm (ibid.). It seems likely, however, that, in making this generalisation, he may have been thinking more of 'horizontal' than of 'vertical' transfers, since there seems to be barely a State which does not provide for the transfer of credit between its two-year and its four-year institutions.

As in Canada, education in the USA is the responsibility of individual states or provinces. There is therefore no national system for the transfer of credit. Arrangements are instead negotiated between individual institutions (or classes of institution within a specific state or region), which specify which courses will be accepted for credit if a student transfers between the institutions concerned, how much credit each will carry, and on what conditions it will be accepted (e.g. what standard of attainment will be required). The examples quoted in this section of the Report are thought, however, to typify the national scene.

A typical piece of guidance to a student at a 'technical' (i.e. community) college may read as follows:

'Many [college] alumni choose to continue their educations [sic] into a bachelor's program. In the past, this meant alumni needed to negotiate their own credits with the college or university they wished to attend. Thanks to the new '2+2' transfer of credit agreements with several area colleges and universities, there is no longer any guesswork in the transfer process. Graduates of certain [college] programs can now transfer to specific four-year colleges of universities with guaranteed junior-level standing. The '2+2' articulation agreements are formal signed contracts, so alumni no longer need to negotiate credit transfer on their own.'

There then follows a list of courses at the community college from which graduates will be accepted into the junior (third) year of a specific course at a specific 'college' of one of the four-year institutions with which an agreement to this effect has been negotiated. (Appendix 27). This modest one page or so is, perhaps, not typical of the literature on the subject (although it should be pointed out that it merely lists the articulation agreements which have been entered into). The detail of each such agreement is set out in guides published by each institution, and, in a large State, with a large number of both two-year and four-year institutions (e.g. New York), the number of such guides can run into the dozens. In addition, compendia of all such arrangements are published either for a specific State or for the country as a whole. (For examples, see the bibliography). As will be seen, it is all very labour-intensive.

There is also frequently a 'general education' requirement - namely a requirement that, in addition to having attained a certain level of performance in a specific field at a specific institution, students should be able to demonstrate that they have successfully followed courses in a range of subjects considered likely to have contributed to their 'general' education. These requirements can vary very widely between institutions and represent a major hurdle to be overcome by the aspiring transfer student.

In order to try and mitigate these difficulties, some states (such as Ohio, for example) have introduced the concept of the 'Transfer Module'

'Kwhich is a subset, or an entire set, of a college or university's general education program ... [and] ... consists of 36 to 40 semester hours ... of courses in ... English, mathematics, arts and humanities, social and behavioral sciences, natural and physical sciences, and interdisciplinary study. '

'A transfer module completed at one college or university [sc. within Ohio] will automatically meet the requirements of the Transfer Module at another college or university once the student is admitted. Students may be required, however, to meet additional general education requirements at the institution to which they transfer.' (Italics supplied).

'Since many degree programs require specific courses that may be taken as
a part of the general education or Transfer Module program ..., students
are encouraged to meet with an academic adviser at the institution to which they plan to transfer early in their academic career.' (See http://www.utoledo.edu).

In Indiana, state legislation requires that at least 30 semester hours of comparable general education courses fulfilling graduation requirements be available at, and transferable among, all state post-secondary institutions. (See bibliography (USA): Transferring General Education Credit ... etc.).

The willingness of institutions to recognise for credit purposes periods of study undertaken at other institutions varies widely from state to state. One of the factors influencing these variations seems to be the extent to which the State legislature interests itself in the question: in many states, articulation and transfer agreements have been established by legal mandate or as a result of state agency policy. In these states relatively robust arrangements exist for credit transfer between institutions, on which students can rely.

The Ohio State Board of Regents (see Appendix 28), for example, states that it is

'required by law to coordinate the Ohio institutions of higher education in the development and implementation of a statewide student credit-hour transfer policy to address the articulation problems associated with students transferring between institutions of higher education.'

It stresses that its policy

'preserves the college's or university's practice of making admission decisions on the basis of academic standards [amongst other things] ...'

and, whilst 'strongly urging' that priority in the admission of transfer students be given to those who have completed an Associate (i.e. two-year) degree, accepts that

'admission to a given institution does not guarantee admission to degree-granting [or any other specific] ... programs.'

A distinction is drawn between the 'acceptance' of credit (which is guaranteed to students who have successfully completed their two-year degree programme and obtained a GPA of 2.0 or better) and its 'application' (or not) towards the fulfilment of the requirements for any specific qualification (which remains at the discretion of the institution). Thus institutional autonomy is preserved within the context of a state-mandated policy on credit transfer - although it is mandatory only on institutions maintained by the state: for independent institutions the policy is merely 'recommended'.

In states which have no such centrally-mandated policy, transfer arrangements are more uncertain in their application.

Thus the University of Massachusetts states, under the heading of 'Transfer Admission':

'Admission is competitive. The primary criterion for transfer admission is the quality of the applicant's academic record. Other factors may include the number of transfer credits, entering class, programmatic limitations, prerequisite coursework, and consistency of academic performance. Applicants should have completed a broad range of academic coursework, including writing, math, and science, with above average grades.

Priority is given to Massachusetts community college graduates meeting the Commonwealth [sc. of Massachusetts] Transfer Compact (CTC) requirements; participants in the Community College Joint Admissions Program, and degree students at the University of Massachusetts campuses in Boston, Dartmouth, and Lowell. Out-of-state applicants generally must have more competitive grades'. (See http://www-saris.admin.umass.edu/ admissions/app_2.html).

So far as concerns the country as a whole, Creech (1995) emphasises the importance of well-written transfer and articulation agreements between two- and four-year institutions, stating that:

' ... the most frequent problem with these arrangements comes when one four-year institution grants credit for a particular course or programme at individual two-year institutions and another does not'

(although one would have thought that this would be a necessary consequence of preserving institutional autonomy, so far as admissions decisions were concerned, in a system characterised by variety in the content and prerequisites of different course offerings and variations in standards at different institutions).

Another problem seems to arise from what is felt by the two-year colleges to be the undue weight given to the interests of the four-year institutions in the design of the policies and procedures relating to the transfer of credit, at the expense of those of the two-year institutions. Where this is found, it is felt that this unequal balance of power has a number of negative consequences for the two-year (and particularly for the community college) institutions.

' ... freedom to set the curriculum is suppressed, since the community colleges must offer courses which are acceptable for transfer by a particular department at the university. Interdisciplinary courses �K. can not find an academic home and are not transferable' (See bibliography (USA): Prisoners of Elitism ... etc.)

A major concern seems therefore to be that, in allowing themselves to be persuaded (or obliged) to accommodate the needs of students aspiring to use their courses as jumping off points for entry into four-year institutions, two-year colleges are in danger of allowing their central mission to be distorted.

Possible Points of Interest for Hong Kong

  1. The possibility of preserving institutional autonomy, in respect of requirements for the admission of students to specific courses, and for the award of specific qualifications, within the context of state-wide legislation mandating the introduction of arrangements for credit transfer.
  2. The danger of distorting the central mission of junior, or community, colleges in order to enhance the acceptability of their graduates as candidates for admission to senior institutions.

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