1. Policy and legal framework of NQF

Some provisions in Decision 1981/QD-TTg approving the structural framework of the national education system and Decision 1982/QD-TTg by the Prime Minister are different from current regulations of relevant laws and legal documents. Therefore, they will only be implemented after these relevant laws and legal documents are amended. This is clearly seen in the process of developing the Vietnam Qualifications Reference Report according to the AQRF. During this process, it is necessary to describe the educational system and map it out. Meanwhile, the NQF covers only higher education and vocational education. A diagram to unify and harmonize the Structural Framework of the National Education System and the NQF can be proposed as follows (Viet.NQ&Hung.QN, 2021):

Firstly, the Law on Higher Education 2018 officially stipulates some issues such as number of credits to be accumulated, standard training time for higher education levels, the training program (objectives, volume of knowledge, structure, content, methods and assessment forms for subjects, fields of study, training levels, output standards) in accordance with the VQF. When the Education Law takes effect from July 1, 2020, Decision 1982/QD-TTg needs to be replaced by another document. Some contents of this decision are no longer consistent with the implementation in reality and international practices. For example, it is impossible to separate higher education and vocational education with reference to the AQRF. According to the AQRF criteria and reference procedures, member countries must fully report on their national education systems with relevant levels of education and qualifications. It would be better if VQF is regulated as a part of a Decree and includes school education, qualification standards and specifically to be able to recognize learning outcomes of non-formal education. 

Secondly, according to the Law on Vocational Education, vocational education means a level of national education system which provides workers with elementary-level, intermediate-level, college-level vocational training and other vocational training programs in order to meet the demand of human resources in production, businesses and services, including formal training and continuing training. The issue is whether TVET is considered "a level of national education system" or not. Because other vocational training programs aimed at fostering, updating and improving knowledge and professional skills, technology transfer can achieve output goals, but they do not belong to the elementary, intermediate, and college levels. The development and evaluation of TVET output standards has not been officially identified, guided and implemented.

In order to synchronize all legislative documents which have already been issued by the National Assembly and the Government, the Education Law 2019 stipulates the educational levels and training levels of the national education system, including elementary level, intermediate level, college level and other vocational training programs. The Prime Minister stipulates the training time duration, standards for each training level, and the minimum learning volume for qualifications of vocational education and higher education. And most of all, the Law on Vocational Education currently has no official regulations on the National Qualifications Framework. Levels 1, 2, 3 corresponding to the certificates of elementary level I, elementary level II and elementary level III currently under VQF have not been codified, leading to documents under this Law when developing and implementing related regulations. It is very difficult to deal with elementary levels. The above issues can only be handled with amendments and supplements to the Law on Vocational Education.

 In addition, research shows that there is no concept of "knowledge volume" with the full meaning of this phrase but "learning volume" (learning volume or amount of learning). Meanwhile, the Education Law 2019 stipulates that the amount of knowledge includes knowledge, skills...? In Decision 1982/QD-TTg, the concept of “learning volume” was used to measure the average learning load, but not “knowledge volume”. In the past, the way of understanding and using "minimum amount of knowledge" has not guided actions consistently and explicitly in the practice of education and training.

2. Education and training category

 The ISCED International Classification of Education is a standard framework developed by UNESCO through the Institute of Statistics that is used to classify and report cross-country (national and international) comparative education statistics. When classifying educational programs according to ISCED, the transition points between the national program and the entry point to the labor market do not always coincide with the transition point between the ISCED ranks. There are programs that connect two or more ISCED tiers. Many others make up an ISCED tier together. Meanwhile, there are programs that do not clearly define any tier.

This is a point to keep in mind when referring to the ISCED classification framework to see that the purpose of promoting the collection and use of comparable educational data according to certain criteria is universal. It is also necessary to recognize that the different countries have different backgrounds. Therefore, we need to be flexible in terms of program tier timing. The main thing when comparing international classification is the content of the program.

However, the statistics and classification to build a list of training occupations according to the current Law on Statistics and the Law on Education can lead to inconsistencies in the development and assessment of output standards and programs, and the recognition of qualifications. There has not been a transferability mechanism for training professions; formal training, work-by-study, distance training, and self-guided study. The transferability between TVET and higher education is even more difficult when the List of training occupations level IV issued by the Ministry of Labour, Invalids and Social Affairs (Circular No. 04/2017/TT-BLDTBXH) still has a "disparity" with the list of education, training level IV undergraduate and master, doctoral degrees (Circular 24/2017/TT-BGDĐT and Circular 25/2017/TT-BGDĐT), not to mention the method of demarcation between majors - educational specializations/professions is also not really clear.

One of the contents of applying a universal NQF is the development of a demand-oriented new qualification with a process by which training institutions/organizations propose together with professional profiles and are validated at the national level. This process is often both rigorous and ensures timely updating of new qualifications according to the NQF. If there is no appropriate process and procedures to develop qualifications, it will partly hinder the autonomy of the school to be able to flexibly provide training to meet the rapidly changing labor market needs in the context of the digital economy and Industry 4.0. Therefore, it is necessary to innovate statistics, classify the category of education and training to ensure that it is appropriate to the context of integration, the mechanism for proposing and developing new qualifications according to the defined process and criteria. Transforming the list of education and training into a list of qualifications, together with the mechanism and process for putting a qualification on the list associated with the definite level of the NQF also means giving full autonomy to the training institution to flexibly adapt to the needs of the labor market.

3. Quality assurance of qualifications and transferability mechanism

Currently, output qualifications in general and its core, which is training program output, has not been reliably assessed by the Vocational Education and training and higher education Accreditation systems. The assessment is conducted on the surface. It should be carried out by specialized accreditation experts such as ABET. More broadly, Vietnam does not yet have a national quality assurance framework to establish a "Trust zone" among stakeholders in the recognition and recognition of qualifications, especially handling labor and employment relations.

Recognizing from the recent case that there are many conflicting opinions related to high school cultural knowledge in TVET institutions, it is necessary to clearly define the approach to be defined according to the following objectives: the amount of knowledge taught in VET institutions helps learners to gain foundational knowledge that meets the output standards of the intermediate level, or towards a degree (certificate or exam to graduate from high school) or both? If the goal is to "achieve 2 certificates", it will encounter limitations, difficulties and challenges such as "learning overload" for learners, as well as in the implementation stage. In order to have a foundation of knowledge to study in an intermediate program and at a college level, the form and volume of secondary and high educational knowledge must be suitable for the training profession, but not for the general education subject. If both of the above objectives are achieved, with the entrance level of secondary school graduates into vocational education, it could be feasible with a few special cases such as the Japanese KOSEN model.

Regardless of the point of view or goal, the most important thing is the design and implementation of the program. In terms of design, Vietnam is very short of experts in developing programs to integrate secondary and high education knowledge into VET or vice versa, vocational skills knowledge into general education (VET in school). In terms of implementation, the current contingent of teachers and administrators does not seem to have been trained or retrained in the implementation of integrated training (unlike intersubject, cross-subject and multi-subject integration within the scope of general education). The connectivity of the national qualification system represents the system's ability to allow learners to access and transfer between different training systems (programs, qualifications) and different systems; recognize learning results achieved in another training system or non-formal training system.

Therefore, in the future, it is necessary to conduct research on the following issues:

- First, a mechanism to connect secondary education, vocational education and higher education to ensure easy recognition of programs and learning outcomes based on output standards and corresponding number of credits. This mechanism should be built on the professional competency profile (the job position description clearly reflects the distinction associated with the qualifications in an occupation). The connection needs to be based on the NQF, which is the conditions for ensuring the quality of qualifications, the mechanism of mutual recognition and the conversion of diplomas and certificates. Therefore, it is necessary to take the NQF as a standard to review and redesign training programs in the direction of developing learners' capacity, ensuring opportunities for transferability. This study will provide a scientific basis for the Government to detail the connection between education levels and training levels in the national education system according to Clause 3, Article 10 - Transferability in education of the Law on Education. Education 2019. It is necessary to agree on methods and processes for designing, accrediting, accumulating and transferring credits including non-formal learning.

- Second, with the contents of the continuing education program specified in Point d, Clause 1, Article 43 of the Education Law 2019 (Educational program under the diploma program of the national education system) in order to achieve a degree in the structural framework of the national education system and the NQF of Vietnam, must satisfy the requirements for the contents of the educational program at the same level and the training level specified in Article 31 of this Law. provisions of the Law on Vocational Education and the Law on Higher Education. Clause 2, Article 43 stipulates the form of continuing education program implementation, including: a) Working while studying; b) Distance learning; c) Self-study, self-study with guidance; d) Other forms of learning according to learners' needs.

This problem poses the need to have research on the quality assurance system of qualifications in these forms, including testing and assessment, recognition of learning results that meet the output standards corresponding to the level as well as other specific regulations related to the above four forms of program implementation.

Third, develop a national quality assurance framework with a general quality assurance policy and mechanism for the "risk management" approach. International experience shows that “risk management” is the trend and approach of many countries with developed education with a modern governance model in the spirit of adaptive regulation, gentle intervention, and management, more favorable treatment for compliance and increasingly severe punishment for violations. At the same time, it is necessary to promote the accrediting of training programs according to the output standards of the NQF and specialized technical orientation.