ACC/A25/9.7.1.2
PART I: PREAMBLE
1.1 DETAILS OF VALIDATION EVENT
PROVIDER / Griffith College DublinDATE OF VISITATION / 13th March 2012
PROGRAMME(S)EVALUATED / Special Purpose Certificate in Advanced Taxation Planning and Advice
PROGRAMME RECOMMENDED FOR APPROVAL / Special Purpose Certificate in Advanced Taxation Planning and Advice
PANEL OF EXPERTS / Mr Ger Long, Head of Dept. of Accounting and
Economics, WIT (Chair)
Mr Jim Byrne, Revenue Commissioners
Ms Treasa Dempsey, Quality Assurance Officer,
Griffith College, (Rapporteur)
1.2 SUMMARY
The Expert Panel, having reviewed the documentation presented by Griffith College and considered the responses of the programme team during the course of the site visit, recommend approval of the above programme, without conditions and with four (4) recommendations.
PART II: REPORT OF PANEL OF EXPERTS
2.1 INTRODUCTION
Griffith College (GC) is an independent third-level institution providing a range of undergraduate and postgraduate programmes approved by the Higher Education and Training Awards Council (HETAC). A number of programmes are also delivered on the basis of joint award agreements with Nottingham Trent University (NTU). It also provides a wide range of programmes leading to the examinations of professional bodies in accountancy, law and other disciplines.
Established in 1974, the college currently has an annual student population in excess of 7,000. Its main campus is based in Dublin, with two other centres in Cork and Limerick. The College began development and provision of academic programmes in 1990, delivering degree programmes in Computer Science, Business Studies and Accounting and Finance. Awards were granted under the auspices of the University of Ulster (UU). In 1992, GCD became a designated institute of the National Council for Educational Awards (NCEA) and commenced the process of NCEA programme validation. This led to a migration of awards to the NCEA, an expansion in the range of provision from Higher Certificate through to Master degrees and an extension of the disciplines provided to include Media, Design, Law, Music and Education.
In October 2009, Griffith College was the subject of an institutional review, in accordance with the HETAC Policy on Institutional Review of Providers of Higher Education and Training, 2007. The overall conclusion of the Report of the Expert Panel found that:
1.The effectiveness of the Quality Assurance arrangements operated by GC were assessed and found to be effective and broadly in accordance with the seven elements of Part One of the European Standards and Guidelines for Quality Assurance, 2009 and the HETAC Guidelines and Criteria for Quality Assurance Procedures in Higher Education, 2004, and,
2.GC has implemented the National Framework of Qualifications (NFQ) and procedures for Access, Transfer and Progression, as determined by the National Qualifications Authority of Ireland.
The proposed programme was developed in consultation with the Institute of Certified Public Accountants in Ireland (CPAI). The programme has been informed by consultation with the Institute’s CPE committee, and by evaluation and analysis by members who formed an ad hoc committee for the purpose.
The programme provides advanced knowledge of the principles of the Irish taxation system and the current legislation relating to more complex issues affecting individuals and corporations. It aims to develop the learners’ ability to apply their in-depth knowledge and skills and to exercise professional judgement in providing taxation information and advice to individuals/corporations. Learners will extend their knowledge of the Irish tax system across a range of complex tax planning issues requiring interpretation and judgment.
The submission was made to HETAC in November 2011, and desk-reviewed by the Head of Framework Awards and Programme Validation in February 2012.
2.2 EXAMINATION OF PROGRAMME
The panel met with staff of GC and CPAI involved in the design of the programme, to examine the programme submission against the criteria for the validation of programmes as stipulated by the Council. In this regard, the HETAC’s Core Validation Policy and Criteria, 2010 was used by the panel. The programme was evaluated against the business standards for Level 8 awards.
2.2.1 DEVELOPMENT AND PUBLICATION OF EXPLICIT INTENDED LEARNING OUTCOMES
The programme submission, together with the outcome of detailed discussions with GC staff, articulated the target learners’ prerequisite learning and any other relevant assumptions about programme participants. The panel noted that the entry requirements stated that applicants are qualified members of the recognised accounting institutes. The panel recommended that this restriction be reviewed to also allow for the consideration of other suitably qualified or experienced candidates.
The discussion with the programme team also included an elaboration of the rationale for the minimum intended programme learning outcomes and any other educational objectives of the programme.
The minimum intended programme learning outcomes are consistent with the applicable awards standards and the relevant National Framework of Qualifications (NFQ) award-type descriptor.
2.2.2 PROGRAMME CONTENT AND LEARNING ENVIRONMENT
The panel was satisfied that the programme team is competent to enable learners to achieve the intended programme learning outcomes and to assess their achievements, in accordance with HETAC’s Assessment and Standards 2009. The panel reviewed the programme content including reading lists, teaching, and assessment methods to be used in the programme and considered them appropriate.
The panel commended the programme documentation, the rationale for the programme, and the cohesion and comprehensiveness of the component programme units.
The panel asked that consideration be given to inclusion of the treatment of company re-organisations in Unit 7., The panel suggested that it be explicitly included in the syllabus description for this unit.
The panel evaluated the depth and breadth of the programme, and the challenge and commitment it presented for learners. The panel felt strongly that the credit volume of 10 ECTS be re-considered and a higher rating proposed that would more accurately reflect the learner effort involved.
The panel was satisfied that the programme’s learning environment (including physical and social etc.) was consistent with the intended programme learning outcomes, and that the places at which, or virtual spaces within which, instruction is to be provided were suitable and fit for purpose.
Overall, the panel was satisfied that the programme content was appropriate, albeit demanding.
The panel also noted that the provider has a policy which provides for reasonable accommodation for people with disabilities (including access), in accordance with best practice and Policies, Actions and Procedures for Access, Transfer and Progression for Learners (NQAI) 2003.
2.2.3 ENABLING THE ACHIEVEMENT OF THE INTENDED PROGRAMME LEARNING OUTCOMES
The panel was satisfied that authentic learning opportunities existed which would enable the efficient and reliable attainment of the intended programme learning outcomes, subject to the learner making a reasonable effort and complying with the programme’s conditions. The programme’s strategy for enabling learners to move from the minimum access standard to the minimum intended programme learning outcomes is explicit, realistic and viable.
2.2.4 ACTIONS AND PROCEDURES FOR ACCESS, TRANSFER AND PROGRESSION FOR LEARNERS
The panel was satisfied that the procedures for access, transfer and progression are consistent with national policy. Furthermore, learners are advised appropriately regarding their entitlement to enter a particular profession or progress to another programme based on successful completion of the proposed programme.
The programme’s use of ECTS (credit) and provisions for Recognition of Prior Learning was deemed to be consistent with HETAC’s Assessment and Standards 2009 and with relevant national policy including:
i.NQAI’s Principles and Operational Guidelines for the Implementation of a
National Approach to Credit in Irish Higher Education and Training 2006 ii.NQAI’s Principles and Operational Guidelines for the Recognition of Prior Learning in Further and Higher Education and Training 2005
2.2.5 EDUCATION AND TRAINING NEEDS
The panel was satisfied with the evidence provided that the programme meets the target learners’ education and training needs and that this was informed by the views of appropriate stakeholders.
2.2.6 PROGRAMME VIABILITY
The panel was satisfied that the programme is consistent with the provider’s mission and strategy. The panel further noted that the provider presented a viable delivery/business-plan for the programme.
2.2.7 LEARNER PROTECTION
The Council will not validate any programme of education and training pursuant to Section 25 of the Act, where it is of a duration of three months or more, unless HETAC is satisfied that the provider concerned has arrangements in place, as specified under Section 43 of the Act, which make provision for learners where that provider ceases to provide the programme concerned.
Griffith College have an agreement in place (as per letter dated 8th October 2010 co-signed by Griffith College, Hibernia and Dublin Business School) to ensure continuity of provision in the event of it ceasing to provide validated programmes. Griffith College confirmed the applicability of this agreement to this application.
2.2.8 ASSESSMENT OF LEARNERS
The programme’s learner assessment methods are fully elaborated and the Panel was satisfied that these were consistent with HETAC’s Assessment and Standards 2009. The programme and module assessment strategies are both clear and appropriate and provide for the verification of the attainment of the intended learning outcomes. In relation to the examination process the module assessment strategy within the module descriptor does not make clear that examinations are open book, although it is mentioned in the programme assessment strategy. The panel felt that it is entirely appropriate that they should be open book exams and the documentation should be updated to make this clearer.
2.2.9 QUALITY ASSURANCE ARRANGEMENTS
The panel heard how the submission had been developed, including provision for on-going monitoring of the achievement of the programme’s objectives and were satisfied with the presentation of evidence in this regard.
2.2.10 ETHICS
It is expected that providers will have procedures in place to ensure that any teaching and learning or research activity at any level shall be conducted in a manner that is morally and professionally ethical. The panel was satisfied that this requirement has been met in respect of the proposed programme.
2.2.11 PROGRAMME TITLES AND AWARD TITLES
The panel is of the view that the programme title – Certificate in Advanced Taxation Planning and Advice – is appropriate, clear, accurate and fit for the purpose of informing prospective learners and other stakeholders and in accordance with the Council’s related named award title convention.
PART III: RECOMMENDATION/COMMENT
FOR THE ATTENTION OF THE ACADEMIC COMMITTEE
3.1 Recommendations:
The panel of experts recommend the validation of the programme:
NFQ Level / Level 8Programme
Title / Certificate in Advanced Taxation Planning and Advice
ECTS / 10 ECTS
for the purposes of the award of:
Level 8 Special Purpose Award
Subject to:
Council’s general conditions of approval
3.2 Conditions
The panel of experts have not attached any conditions to the recommendation
3.3 Recommendations
The panel of experts made the following recommendations:
R1. The programme team should re-consider the credit weighting of the programme. The amount of effort required from learners could justify the allocation of fifteen (15) ECTS;
R2. The entry requirement, that learners must be members of the recognised accountancy institutes appears quite restrictive. Other financial professionals would benefit from the programme and the team might consider changing, or removing, the accountancy requirement;
R3. Unit 7 might benefit from the inclusion of material in relation to Company Reorganisation and the team should consider this;
R4. The team should consider making it clearer in the documentation that the examinations are open book examinations;
APPENDIX
LIST OF INSTITUTE STAFF MET DURING THE COURSE OF SITE VISIT
Mr Tomás MacEochagáin, Director of Academic Programmes, Griffith College
Ms Madeleine Ford, Programme Director, Griffith College
Mr David Fitzgerald, Director Member Services, CPAI
Mr Joseph Aherne, Chairman of CPE Committee, CPAI
Ms Rosie Lawlor, Professional Services Executive, CPAI
Ms Audrey Crean, Tax Partner, O’Gorman, Brannigan, Purtill & Co
Mr Alan Lawlor, Partner, Wallace, O’Donoghue Accountants
Mr Darragh Kilbride, Director, Kilbride Consulting
Ms Ailish Finucane, Head of Central Administration, Griffith College
Ms Fiona O Riordan, Centre for Promoting Academic Excellence, Griffith College
Mr Robert McKenna, Head Librarian, Griffith College
VERSION FORACTION BY PROVIDER / PROVIDER / Griffith College
PROGRAMME / Special Purpose Certificate in Advanced Taxation Planning and Advice
DATE OF ISSUE / 15/03/2012 / PAGE / 1 of 14
Proposed Programme Schedule
VERSION FORACTION BY PROVIDER / PROVIDER / Griffith College
PROGRAMME / Special Purpose Certificate in Advanced Taxation Planning and Advice
DATE OF ISSUE / 15/03/2012 / PAGE / 8 of 11
Name of Provider / Griffith College
Programme Title / Certificate in Taxation Planning and Advice
Award Title / Special Purpose Award
Stage Exit Award Title / Certificate in Taxation Planning and Advice
Modes of Delivery (FT/PT): / FT/ACCS
Award Class / Award NFQ
level / Award EQ
level / F / Stage / Stage
NFQ
Level / Stage EQF Level / Stage Credits / Date Effective / ISCED
Subject Code
Special Purpose / 8 / 6 / 1 / 8 / 6 / 10 / Feb 2012 / 344
Module Title / Semester / Module / ECTS
Credits / Total Student Effort Module (hours) / Allocation of Marks (from the module assessment strategy)
Status / NFQ
Level / Total Hours / Contact Hours / Hours
Independent
Work / C.A.
% / Proj.
% / Prac.
% / Final.
%
Advanced Taxation Planning and Advice / n/a / M / 8 / 10 / 200 / 64 / 136 / 50 / 50
Certificate in Advanced Taxation Planning and Advice
Response to Experts’ Panel report
Submitted on behalf of Griffith College
March 2012
Introduction
Griffith College welcomes the report of the Expert Panel convened on March 13th, 2012 in respect of the College’s proposed Certificate in Advanced Taxation Planning and Advice
In line with the recommendations outlined in Part III of the report, the College has reviewed and revised its submission and now wishes to provide the following additional information. To facilitate consideration of the revisions, the report’s recommendations are considered in turn along with the College’s response.
Consideration is also given to the additional comments, suggestions and advice given within the body of the report.
Accompanying the report is a revised version of the College’s Programme Document incorporating the amendments referred to below.
Recommendations
The report suggested the following recommendations to the approval of the programme. These recommendations have been considered and the following revisions are proposed.
Recommendation 1
The programme team should re-consider the credit weighting of the programme. The amount of effort required from learners could justify the allocation of fifteen (15) ECTS;
Resolution:
The programme team have considered this recommendation and have agreed to implement this recommendation and revise the programme credits to 15 ECTS.
Recommendation 2:
The entry requirement, that learners must be members of the recognised accountancy institutes appears quite restrictive. Other financial professionals would benefit from the programme and the team might consider changing, or removing, the accountancy requirement;
Resolution:
The recommendation has been considered and the entry requirements have been reviewed by the programme team to make them less restrictive. The requirement for membership of a recognised accountancy institute has been removed and replaced with a requirement to have prior knowledge of taxation.
Recommendation 3:
Unit 7 might benefit from the inclusion of material in relation to Company Reorganisation and the team should consider this;
Resolution:
The team had planned to incorporate company reorganisations in their delivery of unit 7 although it is not explicit in the syllabus. The syllabus has been updated to reflect this.
Recommendation 4:
The team should consider making it clearer in the documentation that the examinations are open book examinations;
Resolution:
Whilst referred to in the programme assessment strategy the team agree that the module descriptor should also make reference to the fact that the examination element is open-book. The assessment strategy at the end of the module descriptor has been amended to reflect this.
Conclusion
The College wishes again to thank HETAC and the expert panel for reviewing and advancing the College’s submission and looks forward to the on-going development of the programme in the light of the recommendations suggested.