The framework mainly addresses teaching, learning, assessment and related support activities such as networking, infrastructure, and leadership and governance. How this framework works with other frameworks and forms of assessment and evaluation in (a) organisational self-assessment and (b) policy design and implementation, as the two purposes of the framework, is not clear. This comes out later in the report where recognition of informal and non-formal learning is cited suggesting an assumed dependence of this recognition with digital education. But why this should be the case, why recognition of informal and non-formal learning is intrinsically digital, is not explained except as a link to open badges.
The Promoting Effective Digital-Age Learning report from the Joint Research Centre of the European Commission gives a competence framework for digitally competent educations organisations.
The report positions digital education as an important component of European economic competitiveness by boosting digital skills and promoting online and distance education and training to improve regional human capital and innovation capacities. Education and training organisations should both be effective in the use of digital technologies in teaching and in organisational processes as well as educating students in digital skills and literacies. Digital technologies are part of the wider European policy aims to enhance innovation in, and the modernisation of, education and training. Comparable work can be seen in the JISC programme on developing digital capabilities which clearly states “the economy is digital”
The document calls for greater mutual learning between organisations and education systems for greater cooperation swapping best practices and avoiding failures, consolidating progress and to deliver digital education at scale. The framework is designed for all education providers – primary, secondary, tertiary/ vocational and higher education as well as being a tool for policy-makers. So a first question on the framework is how useful it can be for the different needs, demands and aspirations of the different institutions and systems? Is is a valid claim that “a common conceptual framework approach at a European level, capable of supporting the development of digital capacity in education organisations, is both desirable and attainable”? Such a calling also fails to address the increasingly competitive nature of, especially, higher education as a marker of institutional and national prestige and comparative economic advantage in a knowledge-based economy.
The report presents a set of intended outcomes, for example, digital technologies should be used to extend the scope of formative assessment beyond the assessment of knowledge to include skills and competences (especially digital competences), or that educational organisations should have a code of practice for learning analytics. But if organisational digital competences are the “ability to apply knowledge and skills to achieve intended results” (ISO 17024) then only the intended results are addressed, the underpinning knowledge, assets or routines required are not identified. So rather than being a competence framework, I think this framework should be cast as a set of benchmark standards of a education or training organisation should have or be aware of to operate in the digital age.