SETA complains and appeals for Training Providers

Through my experience working with the SETA’s since 2001 have I heard many complaints from Training Providers and a lack of resources to challenge or appeal their outcomes. It is however very important to understand the purposes of all the processes and bodies to determine the direction of the complaint. Below some of my personal experience and resources on this topic. Feel free to contribute on our public forum if you have any comments or additional resources in this regard.

An Employment Index survey conducted by the JSE-listed Adcorp human capital management group  found that “there are as many as 829 800 unfilled positions for high-skilled workers across a wide range of occupations in South Africa.”

To prevent this, government had signed in the Skills Development Act in 1998 (amended in 2013) to “provide an institutional framework” that would devise and implement “national, sector and workplace strategies to develop and improve the skills of the South African workforce.”

The success of the Act at addressing the skills’ shortage would hinge on the competency of the SETAs created to address the concerns of accredited training providers.


SETAs were established by an Act of Parliament to develop and administer sector skills’ plans to prioritize skills and their appropriate learnerships and apprenticeships. They play a crucial role in the implementation of the National Qualifications Framework (NQF). They ensure quality assurance by monitoring training provision; they also register assessors, collaborate with other education and training quality (ETQ) assurers and report to the South African Qualifications Authority on how they have fulfilled the ETQ role and disbursed levies. SETAs report to the Minister of Higher Education and Training and to the South African Qualifications Authority (SAQA).

While it’s impossible to exaggerate the importance of an empowered, high-quality training provider, it’s nearly as difficult to describe the trouble many have experienced trying to resolve problems that arise in their day-to-day relationship with their relevant SETAs. Some end up posting their complaints on Hellopeter! A Training Provider’s ability to meet operational needs and continue providing skills’ training is dependent on its SETA giving feedback, scheduling and performing external moderation visits, payments and providing resources in a reasonable and agreed-upon time frame. Training providers cannot afford for SETAs to experience administrative backlogs. When they do or when something else goes wrong, the Training Provider must know which entities exist around the SETAs, what each body does and the steps needed to address problems that may arise with the SETAs.


The South African Qualifications Authority (SAQA) exists to “create an integrated national framework for learning achievements; facilitate access to, and mobility and progression within education, training and career paths; enhance the quality of education and training; accelerate the redress of past unfair discrimination in education, training and employment opportunities; and thereby contribute to the full personal development of each learner and the social and economic development of the nation at large.”


The Quality Council for Trades and Occupations (QCTO) was created to “oversee the design, implementation, assessment and certification of occupational qualifications on the Occupational Qualifications Sub-Framework” and also to “offer guidance to service providers who must be accredited by the QCTO to offer occupational qualifications.” And of course, there’s the Department of Higher Education and Training that governs the SETAs.


In view of the ongoing impact of skills’ shortage on our economy, someone may wonder why there has been this multiplication of overseeing bodies but not a matching multiplication of results. One may also wonder whether there hasn’t been an overlap of roles and a duplication of efforts or, indeed, what QCTO and SAQA do that the DHET can’t and vice-versa.

In the wake of President Jacob Zuma’s ascension to the Office, there has not only been a division of the Education Department but also the creation of the SETAs and associated bodies. But far from making life easier, we hear of instances where Training Providers feel the need to lobby their complaints together and get heard as pressure groups.

It’s important for a Training Provider with a complaint to first determine the type of issue s/he is facing with the SETA. Operational queries related to a SETA should go to DHET. If the SETA has broken a policy, either their own or SAQAs (note how one trainer is responsible for interpreting, simplifying and harmonizing two bodies’ set of guidelines) or if the query is an appeal against an outcome or person, then it’s appropriate to contact the QCTO.

The Training Provider has to gather his or her evidence be it in the form of emails, documents and other pertinent communications. He must also get a copy of the SETA’s policy related to the issue, as well as a copy of the SAQA policies where they mention anything related to the issue. These can be found in their website’s documents’ tab.

Once these have been gathered, the Training Provider can send an email to with the below. The QCTO will not attend to the case if any of this information is missing or if it not in this format:

  1. Background
  2. Statement of the problem
  3. Source of the issue(s)
  • What happened, when and where
  • Who are the individuals involved?
  • Appeal issue
  • Attempt at resolution of the issues since the appeal
  • Timelines
  1. The Training Provider must also document the impact of this impasse on his ability to deliver services.


TRAINYOUCAN and the group members cannot guarantee the period for certification after submission of your final POE. (Portfolio of Evidence.)

Currently our average turn around time, (not guaranteed time) is between 4 to 8 weeks after submitting your final POE.

The process that is followed according to the ETDP Verification POLICY.

  1. Your POE is received by our helpdesk and the learner received instant SMS + Email confirmation of receipt.
  2. The Assessor assess the POE and provide feedback directly through our helpdesk to the learner.
  3. Once found competent, the learner is notified of all the processes to follow through our helpdesk again.
  4. Internal Moderation is scheduled every two week on the POE’s as part of the verification process.
  5. Every month (4 weeks) a request for verification is submitted to the ETDP SETA in JHB with a list of names of all the POE’s.
  6. The ETDP SETA in JHB will notify us of any available verification dates, that might be between 1 to 6 weeks in the future. (according to their availability. )
  7. Once the Verification visit was completed, the learner POE is uploaded in their DATA LINK. The PDF copy of the Statement of Results is normally generated 24 hours after uploading in the system and returned to us.
  8. Once TRAINYOUCAN received the PDF copy, are we allowed to generate the Certificate as per the ETDP Policy.
  9. Learner is notified by SMS and email on the same day we received notification back from the ETDP SETA.
  10. Learners will be able to respond to the ticket with instructions to either collect their POE or request for postal deliveries.


  1. Training Providers who offer POE building in the class is agents the ETDP SETA’s policy and procedure and must be report immediately to the the ETDP SETA in Johannesburg. (Learners who build their complete POE in the classroom while receiving the learning). There should be a clear break between delivery and workplace experience.
  2. Training Providers who guarantee the issue of the Certificate or Statement of Results on completion date of the course does not follow the ETDP SETA’s policies and could be de-registered. The ETDP SETA have a very strict policy regarding certification. No certificate may be generated by the Training Provider without the Statement of Results received to confirm the process was completed.
  3. Training Providers who offer courses and especially RPL Qualifications where no support or learning was offered should also be report to the ETDP SETA or the relevant SETA. Part of the any Training Providers accreditation process deal with the learner supporting structures. The relevant SETA will only be able to follow-up on this process if this was reported to the ETQA department.


Tel: (011) 372 3300 – Email:
TOLL Free No: 0800 ETDP 73
TIP OFF’S – 0800 204 937 or



Seta Mandatory & Discretionary grant regulations declared invalid 21st Aug. 2015

On 3 December 2012, the SETA Grant Regulations were gazetted (Government Gazette no. 35940). These come into effect on 1 April 2013. There were many major substantial changes in the new regulations and these may have serious implications for skills development in our country.

Some of the main changes were:

  1. That the mandatory grant to employers is reduced from 50% to 20%.
  2. Any unclaimed mandatory grants must be transferred by the 15 August each financial year into the discretionary fund.
  3. Discretionary grants will mainly be paid for programmes offered by public FET colleges and universities.

As a result‚ these funds could be spent on national skills initiatives that were not related to workplace training.

Labour Court has set aside certain aspects of the 2012 Seta Grant Regulations‚ declaring them invalid!

The Labour Court’s judgment on Friday 21st of August 2015 declared both regulations to be invalid‚ and it set them aside with effect from March 31 2016.

The court found that Mr Nzimande had failed to consult the National Skills Authority as required by law.

The court also ruled that the minister had acted irrationally by reducing the mandatory grant to employers as set out in the Skills Development Act. The minister had exceeded his powers by prescribing that surplus Seta funds be moved to the National Skills Fund.

The minister was ordered to pay all costs of the application, and Seta’s now have a period of about six months to prepare for the return to the previous skills-funding regime effective in March 2016.

Busa said on Monday it viewed the judgment as a significant decision that reinforced the rule of law and that reasserted the importance of workplace skills training programmes in SA.

Assessment Memo or Memorandum

Assessment Memo or Memorandum


This is the new monster on the block – we just don’t know who the daddy is.



We tried to research the topic. As of (date of research?) we found that none of these terms anywhere on the SAQA website or documentation, nor do they appear on any SETA website or documentation.


We cannot find any of these terms in the two official unit standards used by the ETDP SETA for OBE Programme Design, namely 123401 or 123394. We can’t find them on any of the ETDP SETA’s (The primary SETA of the Education Training and Development SETA) programme approval or evaluation documents.


This is of course the SETA that is responsible for the unit standard and the design of programmes. Never has this been requested or checked in the past during programme submission or previous verification.
Assessment Memo or Assessment Memorandum refers to a separate document needed during programme approval. When we checked the SETA’s requirements for programme approval or SETA verification, they only requested the following documents:

  1. a) Matrix/Programme application
  2. b) Learner Guide
  3. c) Workbook/Assessment Guide
  4. d) Assessment Guide and in some cases the
  5. e) Mentors Guide


Once again, there was no mention of the Assessment Memorandum again
We found a similar term on the unit standard 115755 used for “Assessment Design,” namely:

The guide includes all support material and/or references to support material, including observations sheets, checklists, possible or required sources of evidence and guidance on expected quality of evidence including exemplars, memoranda or rubrics as applicable.


I then went and looked the definitions of these two terms mentioned up. The first search result for memoranda read,


memoranda:noun, plural memorandums, memoranda. [mem-uh-ran-duh] /ˌmɛm əˈræn də/ ([reference to IPA]) a short note designating something to be remembered, especially something to be done or acted upon in the future; reminder. a record or written statement of something.

A note recording something for future use.


And also,


a written message in business or diplomacy.


As well as,


a document recording the terms of a contract or other legal details.


The other word pulled up these results –


rubrics:a heading on a document.


a set of instructions or rules.

We guess the Assessment Memo or Assessment Memorandum – terms that are not once used on any SETA or SAQA documents that relate to this process – must be this “memoranda or rubrics as applicable.”


This is a pity because there are no resources on the internet or any SETA reference that provide an explanation on this. It would eliminate a lot of confusion around this topic, especially for new Training Providers.



Some argue that this could form part of the model answers of your Assessment Guide. But why, then, is it required as a separate document pack during verification? At any rate, this is how we would recommend creating the document going forward:


–                      Create a separate document calling it the Assessment Memo Cover Page that makes reference to your Unit Standard

details, and maybe give it a “confidential” watermark, footnote or disclaimer of some sort.

–                      Include model answers for each activity/assessment activity in this guide – we’re not recommending any particular

format. You may also want to include the following, depending on the topic or structure of your activities:
*                      Support material and/or references that were provided to the learner – which he/she can use as resources (we mean

resources and references that were given to the learner during the induction or facilitation).

*                      Observations sheets – these should be in the Assessment Guide already if used previously

*                      Checklists – to check if the learner’s response is complete or that all required activities were handed in.

*                      Possible or required sources of evidence – or of course your model answers, or guidelines on how learners were asked

or could answer the question.
*                      Expected quality of evidence – maybe include the amount of pages, size of response, number of words, how many

points will be allocated to this activity and so forth.


In the meantime, we hope that this helps, clears some confusion and possibly gives a direction forward.


How do you charge for your Assessments completed.

How do you charge for your completed Assessments?

This difficult question has been asked by many. Some would suggest charging between R150 and R650.

Factors to take into consideration when determining what to charge:

    This is the number 1 factor that determine the assessment fees. Credits in short give an indication of the amount of work involved with the program, the duration of the learning process, the amount of workplace or practical experience required and also the duration of the assessment.

A generic formula:
5 Credits = 1 day of training and 1 week of practical experience in the workplace/previous experience.
I also think it’s fair to say that 1 day of training = 1 hour of assessment. Any rate above this should be questioned.

So there you go! Every 5 credits should be 1 hour of work in theory.

CALCULATION: If I charge R150 per hour of assessment and complete 8 assessments during the day, then my expected payment should be R1200. This also is roughly the average/recommended facilitator daily fee.

  1. NQF Level
    Theoretically, NQF level should not affect the cost of the assessment. While we could argue that higher education costs more than lower education levels, what matters more is the amount of work involved.

In practice we use more “assessment-type” instruments in lower NQF levels such as 1, 2 and 3. People on NQF 1–3 normally struggle with the language of instruction, may not have the needed computer skills and battle with assignment-type evidence; therefore, we make more use of instruments like written tests, observation and interviews. These instruments involve more labour on the part of the assessor.

When we talk about higher NQF levels such as NQF 4 to 6, the learners are more computer literate and able to complete assignment-type questions. The work is less labour-intensive for the assessor here than it is in lower NQF levels.

CALCULATION: Completing assessments for NQF 4, 5 and 6 is easier if it consists of assignments. Your work is ready and just waiting to be assessed. Working with lower NQF levels involve working with people and more written paperwork; this could cause a massive delay in the process.

    Now this can break or make you and all depends on how the material was developed. Questions you should ask include:
    -How many pages are there in the assessment guide?
    -How user friendly is the guide?
    -How much evidence is required by the instruments?
    -What type of instruments are used?
    -Can the learner complete the assessment electronically or must it be done in writing?
    Payment terms are also a major issue. When will you be paid? The amount of work should be in proportion to the final agreed amount.


  1. Calculate the amount of work involved.
  2. Calculate the amount of time it will take you to complete the assessments.
  3. Set your daily rate.
  4. Work out your budget.
  5. Agree on payment terms and numbers.

Can a Moderator Assess or Train the same learners

Can a Moderator Train and Assess the Same Learners?


SAQA policy has often been interpreted as saying that a Moderator cannot facilitate and evaluate his own students’ assessments (be the “same person”). Others, however, would argue that the trainer is doing formative assessments in the classroom with the learner and is therefore doubling as an evaluator.


To resolve this puzzle, we looked at the definition of Formative and Summative assessments. OBET (Outcomes Based Education and Training) makes use of formative and summative assessments.

  • Formative assessment refers to assessment that takes place during the process of learning and teaching.
  • Summative assessment is assessment for making a judgment about achievement. This is carried out when a learner is ready to be

assessed at the end of a program of learning.


We then compared the two types of assessment process as below:


A formative assessment
• Is designed to support the teaching and learning process.
• Assists in planning further learning.
• Diagnoses the learner’s strength and weaknesses.
• Provides feedback to the learner on his/her progress.
• Helps measure a learner’s readiness to do a summative (or final) assessment.

  • Is developmental in nature.
    • Is not for the purpose of awarding credits/certificates.


A summative assessment

  • Usually occurs at the end of a learning program and would result in a qualification, unit standard, or part-qualification.
    • Is used to determine whether the learner is competent or not yet competent.
    • Usually occurs after a specified period of study, e.g. one year in knowledge- and inputs-based systems.
  • Is carried out when the assessor and the learner agree that the learner is ready for assessment

    In OBET, learner-readiness determines when assessments will take place. All formative activities/assessments completed in the class are presented to the Qualified Assessor who will assess these activities as part of his role and as part of the Assessment Process.


From the statements above the following is clear:
• Formative assessment is part of a preparation process, not an actual assessment process.
• You cannot award credits/competency certificates on formative assessments. It’s completed by a facilitator, not an assessor as required by the SAQA policy.
• Formative assessments are part of a process of preparation of the learner for assessment. The evaluator cannot use the facilitator’s comments as part of his assessment decision. They are a recommendation on the readiness of the learner before the assessment process start. The assessor will have to re-assess the formative activities and reach his or her own findings.
• Summative assessment is then the process where the qualified assessor looks at all the evidence (even the formative evidence provided by the trainer) and reaches his own decision.
• As per the SAQA POLICY, a SETA can add to any policy in order to meet additional ETQA requirements. So the only way this rule that a Trainer cannot be the Moderator can be applied is if a SETA mentions in its Moderation Policy that a Trainer cannot be the same person as the Moderator. No SETA can implement this rule if they do not officially include it in their policy.


Therefore, according to us, a Moderator and the Trainer can be the same person. It’s fair, valid, reliable and practicable because an independent person assesses the learner. The Moderator only confirms the assessment process was followed and the outcome was correct.