The European University Association (EUA) submitted its Position Paper on the Commission's proposed amendments to the Professional Qualifications Directive (PQD).
EUA warmly welcomes the Commission’s proposals. They have emerged from a systematic process of consultation. They demonstrate the Commission’s awareness of the structural features of the European Higher Education Area (EHEA). They offer a gradualist approach to the reform of the Directive which is highly appropriate – in view of the progressive consolidation of qualifications frameworks, academic recognition practices and quality assurance procedures throughout Europe.
Continuing professional development (CPD): EUA applauds the Commission’s decision to set CPD clearly in the lifelong learning policy frame. This gives it a strong educational focus and a high strategic priority, encouraging higher education providers, professional and regulatory bodies, and consumer associations to work more closely together.
The amended Directive will pass through the new ‘ordinary legislative process’ and be supported eventually by new comitology procedures. This is the case, notably, of the Commission’s power to alter the manner in which the adequacy of knowledge, the sufficiency of understanding, and the adaptation of training courses to scientific progress are established in the seven sectoral professions. It is also true of the introduction of new medical and dental specialties. In the view of EUA, what is to be achieved in the new comitology is just as important as the content of the Commission’s proposals.
This raises the question of how the Committee Procedure will guarantee the full range of stakeholder involvement. How will the Expert Groups be constituted and what will be the status of their views? This issue is crucial. Recognition, mobility, transparency are aims common to the Directive and to the Bologna Process. EU institutions all agree that knowledge transfer, research, innovation in the services sector, professional training and mobility, university autonomy and quality assurance in higher education have to be considered holistically. This being so, it is clear that comitology cannot steer the Directive effectively without the contribution of the higher education sector.
Full Position Paper
© EUA - The European University Association
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