The Federation of Malaysian Manufacturers (FMM) strongly objects to the microcredential fee being imposed on employers for all HRD Corp claimable programmes with effect from August 15, 2022 with the five exemption categories as outlined in Employers’ Circular 2/2022.
2. Firstly, FMM would like to state that we support and promote microcredential to the industry which is the way forwards to encourage employees towards a lifelong learning pathway. However, we are of the view that not all training programmes should be subjected to the microcredential requirement and do not agree with the microcredential fee that is being imposed on employers. It is important that only relevant training programmes be recognised with Accreditation of Prior Experiential Learning (APEL) from either MQA or JPK’s qualification framework so that it can be recognised by Higher Education Providers (HEP) as stackable microcredential courses to be accepted as credit transfer via APEL when enrolling into any HEPs tertiary programme.
3. Specifically on the Employers’ Circular No. 2/2022 on HRD Corp Microcredential (MC) Initiative Implementation issued on June 15, 2022, FMM member companies have expressed their concern over the following:
(i) MC as add value should be optional not compulsory. Therefore, not all courses registered by Training Providers (TPs) with HRD Corp must be converted to MC courses. Not all employees will be interested to collect MC to pursue with formal qualification. Example to achieve a diploma qualification, an employee must stack MC courses with MQF Level 4 (Bloom Taxonomy’s KSA domain > C3, P3, A3) and credit value of 3 (more than 5 days). Hence, any MC course with lesser days and below C3, P3 and A3 are meaningless.
(ii) There was no proper engagement whatsoever with employers as levy payers. It appears that HRD Corp is rushing to implement MC when the process of TPs to convert to MC is still ongoing and is very much debatable based on the MQF Level and Blooms Taxonomy. Consequently, the whole exercise of HRD Corp MC will be futile and likely to fail.
(iii) HRD Corp must explain the breakdown of RM300/trainee. This additional cost per pax is going to reduce the number of employees eligible for training which is against the spirit of the existence of HRD Corp and the levy contributions and all the other initiatives introduced by the Government to encourage greater levels of upskilling and reskilling. The additional fee of RM300/pax is almost 50% of course fee of RM700/day/pax for Remote Online Training (ROT). This is totally unacceptable especially to SME companies with small contribution levy for training. SME already take a longer period to accumulate sufficient funds for training given their lower number of employees and the standard training fee that applies across the board for all contributors.
(iv) There are few pertinent questions that must be answered by HRD Corp in the implementation of MC as below:
- Who are the panel of MQA or JPK experts that verify the MC course? The name of panel must appear in the approval with a validity date.
- Where is the list of Higher Education Provider (HEP) that accepts HRD Corp MC? The letter of acceptance by HEP must be published in the HRD Corp website. Are these HRD Corp MC courses also listed in the MQA MC portal recently launched on June 13, 2022?
- How can a MC course with 1 credit be charged a similar rate with a MC course with 3 credits?
4. In this regard, FMM is proposing that:
(i) HRD Corp MC courses must be regarded as optional and not compulsory. Meaning only selected courses accepted by HEP will be registered as HRD Corp MC courses and will be available for Employers to choose from the HRD Corp’s eTRIS system.
(ii) The process of registering HRD Corp MC course should be based on a standard practice and accepted by HEP. The approval of HRD Corp MC courses must done by MQA or JPK Panel with signatory and validity of MC course, example 3 years.
(iii) All HRD Corp MC courses must be available in the HRD Corp website similar to MQA Micro-Credentials “Senarai Micro-Credential” as shown in the link below:
(iv) HRD Corp’s role is to facilitate the implementation of MC but it does not have the authority to issue the MC certificate on behalf of the HEP and therefore, HRD Corp has no basis to charge a MC fee of RM300/trainee.
5. In this regard, we hope that HRD Corp will not hastily implement the MC for all the training programmes registered under HRD Corp Claimable Courses (SBLKhas) in the eTRIS system. FMM is willing to have further discussions with both HRD Corp and MQA to come up with the best framework and implementation model without burdening employers, especially the SMEs. Until then, HRD Corp should temporarily withdraw the Employers’ Circular No. 2/2022.
We hope that the above views and stance would be given due and appropriate consideration.
The letter was also copied to,
YBhg Datuk Seri Jamil Salleh, Chairman of the Board of Directors, HRD Corp
YBhg Dato’ Palaniappan Joseph, Board of Director, HRD Corp