OPINION

Why we're considering withdrawing UCT's LLB accreditation - CHE

HEQC notes with concern the insubstantial nature of law faculty's improvement plan

COUNCIL ON HIGHER EDUCATION

14 November 2017

Prof Daya Reddy
Acting Deputy Vice-Chancellor (Teaching and Learning) 
University of Cape Town 
Private Bag X3 
Rondebosch

Dear Professor Reddy

Revised Outcome: Bachelor of Laws (LLB) Programme

In the letter dated 7 April 2017, you were informed of the Higher Education Quality Committee’s (HEQC) decision to reaccredit the Bachelor of Laws (LLB) programme offered at the University of Cape Town (UCT) subject to meeting specified conditions. This letter called for the submission of an improvement plan (IP) and a progress report, with respect to the conditions stipulated in the HEQC review report, by 06 October 2017.

Your institution submitted an IP which also included progress made since the review panel site visit in 2016. The HEQC at its meeting of 09 November 2017 evaluated your IP. Although attempts have been made to address some of the issues raised in the review report, the HEQC considered that most of the critical issues had not been addressed. Given the nature and seriousness of the issues raised in your review report, and their impact on the quality of provision, the HEQC revised its accreditation decision from ‘re-accreditation subject to meeting specified conditions’ to ‘Notice of Withdrawal of Accreditation’. The reasons for the notice of withdrawal of accreditation are as outlined in the IP analysis report attached.

The HEQC requests that the University puts measures in place to address the reasons set out in the IP analysis report. The Improvement Plan (IP) must outline clear targets, resource allocations and milestones within specified timeframes. All improvement plans and progress reports received are subject to an evaluation. The HEQC may, at its discretion and for good reason; request a follow-up site visit if it is of the view that such would be an appropriate way of monitoring progress. The institution is expected to submit a detailed IP by 10 May 2018.

Furthermore, the institution is informed that the accreditation outcomes, not the improvement plan reports, will be published on the CHE website.

I would like to thank you and your colleagues for your co-operation in facilitating the LLB national review.

For further information kindly contact Dr Siyanda Makaula.

Yours sincerely,

__________________

Ms Olivia Mokgatle
Director: National Standards and Reviews

Cc Prof Penelope Andrews 
Dean Law

Ms Nikki Campbell 
LLB Institutional coordinator

Text of the report:

National Review of the Bachelor of Laws Programme

HIGHER EDUCATION QUALITY COMMITTEE REPORT

University of Cape Town

Improvement Plan Analysis Report 09 November 2017

Background

At its meeting of 09 November 2017, the HEQC evaluated your IP. Although some attempts have been made to address some of the issues raised in the review report, the HEQC considered that most of the critical issues had not been addressed. Given the nature and seriousness of the issues raised in your review report, and their impact on the quality of provision, the HEQC revised its accreditation decision from ‘re-accreditation subject to meeting specified conditions’ to ‘Notice of Withdrawal of Accreditation’

Reasons for HEQC decision

Comments

Adequately Addressed

(YES/NO)

Short-term

The Faculty must submit a report on the plan for curriculum review, in respect of curriculum design, how it represents the purpose of the qualification and graduate attributes as set out in the LLB Standard, and how the purpose and graduate attributes are reflected in the teaching methods, as referred to in Section 14.2D of, and elsewhere in, its Self-Evaluation Report.

1(iv),(vi)

-   No curriculum review plan in respect of curriculum design and alignment with LLB standard.

-   No rational provided for the strategies mentioned in the IP and how these will improve programme structure, content and delivery.

-  No clear evidence of planning and commitment.

-  No evidence of adequate resources available to accomplish improvement initiatives

Not addressed

Short-term

The Faculty must report on plans to enhance throughput and graduation rates (including race and gender equity).

17 (i), (ii) ; 19 (iii)

-  No rational provided for semesterisation and how this will improve throughput rate.

-  ‘Crowded curriculum’ Task team and Transformation Committee seem to have been established but no evidence provided of the existence of the task team/committee, no terms of reference, no task team/committee membership and no evidence of approval processes undertaken.

- No rational for development of the lecture attendance policy and plan to implement.

- It is not clear how the proposed initiatives will assist with improvement of throughput rate.

Not addressed

Short-term

A report is required on measures taken to 

enhance programme coordination, thereby ensuring integrated academic leadership and supervision across the entire programme, in the interests of coherence, progression and quality assurance. 10(i)

- It is not clear how the proposed initiative will assist in addressing the condition.

-  No clear evidence of planning and commitment.

Not addressed

Summary:

The HEQC notes with concern the insubstantial nature of the improvement plan. A number of the fundamental programme design related issues still remain unaddressed. There is no indication of proper and sound planning, no clear targets and timelines provided to convince the HEQC of the urgency and commitment to address the stipulated conditions.

Although the institution acknowledges the urgent need to address the issues raised in the curriculum, especially those pertaining to design and coordination, not much has been done to address them. The HEQC is concerned about the lack of urgency in addressing these critical concerns, without proper conceptualisation  of the programme design, coordination and assessment, the flaws in the programme will not be adequately addressed.

The communication of the LLB national review outcome of 07 April 2017 clearly stated that short-term conditions should be addressed within 3- 6 months of receipt of the report. It must be noted that these are short-term conditions which should have been addressed in 3-6 months. The 6-months period has since elapsed, yet very little has been achieved. In cases where the timelines for conditions to be met are not adhered to, or it becomes clear that the conditions are not being adequately addressed for whatever reason, the HEQC may alter a decision of ‘accreditation subject to conditions’ to a ‘notice of withdrawal’, or, where a programme is already on notice of withdrawal to confirmation of withdrawal.

The HEQC requests that the University puts measures in place to address the reasons set out in the IP analysis report. The Improvement Plan (IP) must outline clear targets, resource allocations and milestones within a specified timeframe. All improvement plans and progress reports received are subject  to  an evaluation. The HEQC may, at its discretion and for good reason; request a follow-up site visit if it is of the view that such would be an appropriate way of monitoring progress. The institution is expected to submit a detailed IP by 10 May 2018.

Some of the general weaknesses are as follows:

- A lack of clear timelines and firm commitments.

- Lack of consultation with key stakeholder groups, especially students.

- An understanding of what is required to improve in various areas is not demonstrated.

- It is not clear how the proposed strategies will improve the challenges raised.

- A lack of strategic thinking that realistically prioritises responses and links them to critical conditions that need to be met for accreditation.

- The institution simply provided a wish list of aspirations not supported by evidence of commitment, the submission is sketchy, no details provided.

- There is lack of clear evidence of careful, sound and viable planning with regard to issues stipulated in the review report.

- The IP lacks a sense of feasibility and completeness.

- There is no indication of the availability of adequate resources to accomplish improvement initiatives – e.g. evidence of budget adjustments and approvals or secured funding.

- It is not clear who was involved or consulted when the IP developed and approved.

- There are no clear performance indicators and targets for the interventions listed.

HEQC Accreditation decision for the University of Cape Town LLB Programme: ‘Notice of Withdrawal of Accreditation’

Reasons for ‘Notice of Withdrawal of Accreditation’:

1. Lack of a curriculum review plan in respect of curriculum design and alignment with LLB standard.

2. The Programme lacks formal structures that would enhance and enable programme coordination, thereby ensuring integrated academic leadership and supervision across the entire programme, in the interests of coherence, progression and quality assurance.

3. The programme fails to demonstrate evidence the diverse purpose of the qualification as set out in the LLB Standard to ensure achievement of the intended NQF exit level for educating a well-rounded law graduate, and how the purpose and graduate attributes are reflected in the teaching methods.

4. There is little evidence of formal tracking and monitoring of student performance with a view to improvement. The Faculty must report on plans to enhance throughput and graduation rates (including race and gender equity).

5. Timelines for conditions to be met are not adhered to, the institution has short-term conditions to address, and 6-months period has since lapsed yet very little has been achieved.

ENDS