A Legal Perspective on PLAR

YAO Laiyan   

School of Arts and Law, Open University of China, Beijing100039

Abstract: Prior Learning Assessment and Recognition (PLAR) is system that promotes lifelong learning by comprehensively assessing an applicant's study, work and life experience prior to enrollment in an educational institution and converting such experience into actual credits. The system was first developed in France and is widely used in the United States and Canada. At present, it is being studied and developed in many countries around the world. PLAR has also been implemented in China, led by the Open University of China (OUC). The university has made fine progress in both theoretical study and international collaboration. Based on the implementation experiences of certain developed countries, China's adoption of PLAR holds great practical significance, but operation will be highly challenging. PLAR has strict requirements when it comes to legal consciousness, equal treatment, individual respect, legislation and enforcement. It emphasizes laws and regulations, policy guidance, rules, process and transparency. PLAR in China must be implemented one step at a time, without rushing. It should begin with thorough study and involve government promotion, advance legislation and extensive experimental trials before rollout. 

Keywords: PLAR;Prior Learning Assessment & Recognition;Non-formal Learning;Informal Learning;Credit Recognition

As the saying goes, one is never too old to learn. People participate in all kinds of learning activities throughout their lives. The state, educational organizations and educators provide various continuing support with the same goal: to develop individual potential, to encourage the ceaseless acquisition of more knowledge and skills, to help people live happy lives full of confidence and creativity, and to promote self-improvement, all so as to develop human resources, to improve the overall quality of the people and to foster a learning-oriented society. Therefore, educators design various ways to encourage active study, and the state guarantees the citizens’ rights to education and learning through education legislation and policies promoting education. As far as learning recognition is concerned, researchers classify the different styles of learning as formal education, non-formal education and informal education[1].We adopt all kinds of certificate systems to assess and convert learning into actual, tangible achievements, and to promote further learning. Other countries have developed PLAR as a comprehensive assessment of an applicant's learning, work and life experience prior to enrollment in higher education. PLAR promotes learning by converting the assessment factors into real credits that can substitute for those in higher education institutions (HEIs). The system is of great value in promoting respect for learning, encouraging learning, conserving resources, cultivating integrity and upholding the rule of law. However, it is fairly new in China and this paper sets out to analyze and explain the system from a legal perspective.

Ⅰ. A Brief Introduction to PLAR

1. The concept of PLAR
 
"Prior Learning Assessment and Recognition", abbreviated PLAR, is also known by different names. In North America, PLAR is also PLA (Prior Learning Assessment) for short. In Europe and Oceania, it is abbreviated as APL (Assessment of Prior Learning), VINFL (Validation of Informal and Non-Formal Learning), RPL (Recognition of Prior Learning), RNFIL (Recognition of Non-Formal and Informal Learning), and APEL (Assessment of Prior Experiential Learning). Non-English speaking countries naturally have their own names for PLAR. In the field of natural science, PLAR can also stand for perceptual log area ratio, popularity and locality-based adaptive replication, etc. We hold that despite the differing aliases for PLAR, the basic concepts are the same, and the difference of terminology stems from the comparative newness and lack of international collaboration in the field. This paper chooses the term PLAR because it is comprehensive and yet concise. Furthermore, the term PLAR was previously adopted by Zhang Shaogang, Wang Ying and Yin Shuangxu in their paper "PLAR: a Positive Trial of Distance Higher Education", and maintaining consistent terminology can avoid confusion in research. PLAR is defined as a systematic process for appraising, recording, assessing and confirming skills and knowledge learned through formal or non-formal learning, including work and life experience, training, self-study, volunteer work, travel, hobby, family experience, and so on.[2] Dr. Christine Wihak, a famous Canadian PLAR scholar, holds that PLAR is the practice of assessing and recognizing knowledge and skills acquired by adults through experience and informal learning, and does not include that acquired through formal education. [3] [4] As a matter of fact, the two views are consistent. Though the former view mentions formal learning, examples given for the types of learning include only non-formal learning and informal learning. 
 
2. The functions of PLAR
 
What does PLAR do, and why should we study and adopt this system? In brief, PLAR aims to convert learners’ knowledge and skills into generally accepted credits. In summary, its major functions are as follows:
 
(1) Recording and certifying adult learning experiences. Work experience, knowledge and skills acquired through hobbies, participation in various training programmes, or simply the things learned through day-to-day life all contribute to a person's overall refinement. Without a cumulative record, learners do not have a clear view of their learning achievements, and their initiative to study would be dampened. With PLAR record certification, their learning achievements become solidified, measurable and convertible, and this promotes positive learning and lifelong learning. The keys to lifelong learning are promoting an inner transformation in individual learners and advocating lifelong continuous learning for citizens and active participation in meaningful learning activities.
 
2)Supplementing and promoting a credit transfer and credit bank system. With the increase of students' autonomy, mobility, and diversity, individualized education services have become the global trend. PLAR supplements the credit transfer system by summing and converting the applicants’ credits before enrollment with those after enrollment. Only when the credit transfer mechanism is operating smoothly can the credit bank with further credit exchange be of real significance. The credit bank system, which uses credits as its circulation currency, facilitates credit deposit and transfer and features a flexible and open system that combines enrollment, transfer, credit and study functions. It offers learning opportunities to all members of society and promotes coordination between schools, between schools and teachers, and between schools and students.
 
(3) Saving time and money. If the accumulated knowledge, skills, and experiences of adult learners cannot be counted up and verified, then they cannot be recognized by societal organizations. If individuals are required to master such content for work or other reasons, they would have to enroll in study or training programmes again, which is a waste of time and money for the individuals and for the organization. In fact, redundant study and training is a waste for society as a whole. Adopting PLAR and recognizing prior learning achievements gives people more opportunities for continuous learning, shortens the time needed for formal learning, saves money for individuals and organizations, and conserves societal resources.
 
(4) High value for receiving organizations. Applicants with PLAR assessments are a great asset to the HEIs that receive them. Their wealth of experience makes up for the lack of practical experience at the receiving institution or study programmes and contributes to the development of the discipline. PLAR assessment expands teachers’ professional knowledge and encourages professional development; it builds closer relations between HEIs and societal organizations, raises public awareness of what these universities or organizations do and what services they provide, and increases the visibility of participating organizations.
 
(5) Cultivating a society with integrity. Integrity is a fundamental requirement in any transaction; without it, no transaction could be conducted. Integrity needs to be cultivated in a society, for it is human nature to seek profit and avoid loss. PLAR affects every learner. Establishment of a PLAR system requires that first the organizing institutions act with integrity; once application rules are set, no changes can be made unless they benefit the learners. An honest, fair assessment of learning achievements gives learners a sense of accomplishment and pride. At the same time, it increases individuals' faith in society and leads to reasonable expectations.
 
3. Suitable target groups for PLAR
 
(1) Applicants for higher education who have acquired experience through work, volunteer activities, military service, or other specialized experiences. Their experience may measure up to part or even all of the knowledge learned at a university. Assessment and recognition may make up for the energy they spent on prior work, service or volunteer activities.
 
(2) Those who have worked for a period of time after completion of college education and would like to go for further study and professional enrichment. These applicants have accumulated a wealth of experience at the workplace and need theoretical reinforcement to take their work performance to a higher level. There is no use wasting time to restudy foundational knowledge.
 
(3) People who receive higher education later in life. These people receive higher education later than others in their age group. They may be socially disadvantaged or persons with special skills. They may not meet the qualifications for university admission, and need special consideration.
 
4. Forms of PLAR recognition
 
(1) Recognition of industry training certifications. Professional training is usually placed before university education since it is a faster way to renew knowledge. Examples include IT certifications and language proficiency certifications. With the recent proliferation of professional certifications, training institutions are taking into consideration long term development and placing greater emphasis on the quality of training certifications. For example, Microsoft training certifications may be directly recognized by university computer departments.
 
(2) Setting up knowledge and skill files (or portfolios). Students create portfolios according to specified rules, and experts in the field make an assessment as to whether each student meets the criteria to receive credits. The portfolios are usually electronic files. The list of courses for which students may submit portfolios for assessment is decided based on course features, strength of teaching faculty, etc., and then uniformly published by the school.
 
(3) Examinations. Students participate in unified national examinations, such as English qualification tests and accountant tests. If a student takes the examination according to regulations at a designated examination center and receives a passing score, this can be recognized and converted into credits.
 
(4) Challenge courses. These courses come with teaching syllabus and appraisal examination. If a student passes the appraisal examination, he or she can receive the corresponding credits. The appraisal method for a challenge course is established according to the features of the course. For example, for the Industrial Design course at the University of Maryland University College, the students present their designed works or give a speech instead of taking a conventional examination.
 
(5) Assessment by a specified educational institution. Take for example the University of Maryland University College. If the applicant completed a particular training programme, he or she can submit evidence of the knowledge acquired through training to the American Council on Education, a PLAR authority. Once the training is assessed by the PLAR authority, the applicant can receive a certain number of credits for the relevant major, and these credits are then recognized by the university.
 
(6) Agreements between institutions. For example, HEIs may recognize learning experience or credits through agreements with other HEIs, educational training organizations and other societal organizations. The agreements include necessary terms and clauses, such as the background of the parties involved, assessment criteria, mutual recognition and cost. Mutual recognition of credits between international organizations of higher education is also generally achieved through agreements. Some agreements cannot be signed unless approved by special administrative agencies. For example, Canada's “Committee for Foreign Credit Recognition” is tasked with recognizing credits of universities in different countries. If a school wants to establish mutual credit recognition with a certain Canadian university, approval of the organization is a prerequisite. However, not all schools have to apply for recognition; world-famous universities do not need explicit recognition. The duration of the agreements tends to be rather long, such as six years. The stability of the agreement is of great importance to students.
 
Ⅱ. Development and Implementation of PLAR Around the World
 
1. France
 
The earliest official use of PLAR was legislated in France. The French government successively issued three decrees relating to recognition of non-formal learning achievements. The contents include legislation regarding university organizations that perform recognition, the role of recognition committee members, decisions made by recognition committee members, the role of tutorial consultants, qualification of applicants, and preparation procedures for applicants. In 1934, France passed a law concerning prior profession recognition. Any citizen whose professional experience met the specified criteria and was certified by an authorized institution could obtain the qualification of senior engineer. The decree approved recognition for all or part of the certificates, diplomas and qualification certificates for professional training programmes. It specified that any self-taught technical professional, auditing student or active student meeting the qualifications (at least 35 years of age, minimum 5 years of practical work experience as an engineer, etc.) was eligible to obtain the national qualification for senior engineer by way of recognition.[5] Regulations for engineering qualifications were further improved in the 1950s, placing emphasis on recognizing the employees’ abilities instead of their record of formal schooling, and encouraging them to sharpen their professional skills at work. In 1985, "La Validation des Acquis Professionnels" (VAP) was issued in France, which set forth the process for prior profession recognition. This decree aimed to help all the adults who wanted to receive higher education but did not meet enrollment qualifications, and it opened a new and non-traditional learning channel for them. The decree specified that all adults aged above 20 years can apply for higher education. Individuals could receive assessment and recognition regardless of whether their prior experience and knowledge were acquired through paid work, volunteer work, or independent study. The purpose of the policy was to encourage people to start learning again. In January 2002, "Social Modernization Law" was issued in France, which further affirmed that knowledge can be acquired through manual labor and that qualifications equivalent to professional training could be acquired through manual labor. To this end, "La Validation des Acquis de l’Expérience" (VAE) was passed, changing professional acquisition into experiential acquisition and broadening the scope of professional qualification recognition. As such, the concept of “prior profession recognition” gradually evolved into “prior experience recognition”. Both VAP and VAE assess professional experience and schooling, and advocate learning from experience. France issued the National Professional Certification Registry (RVCP) to be specifically assessed by a jury or panel of experts. On February 15, 2007, a representative of the French minister together with 16 professional departments organized by several employer organizations jointly signed the National Agreement for the Development of Prior Experience Recognition. This agreement has established increasingly mature regulations for informal and non-formal learning recognition and educational training. [6] [7] [8]In sum, France has successfully used legislation to gradually establish a system for differentiating and assessing informal learning and experiential learning.
 
2. United States
 
In English-speaking countries, PLAR in the educational sector appeared in the United States after World War II. At that time, formal education posed a great challenge for veterans returning from the battlefield. It was this challenge that prompted a change from standardized examinations to more simplified college entrance examinations. At the suggestion of a research committee on non-traditional education, a few universities in the northeastern United States started working together to conduct pilot PLAR projects at the Educational Testing Service in Princeton, New Jersey, in 1971. By the end of 1970's, the nonprofit organization Council for Adult and Experiential Learning (CAEL) emerged as a leader in the recognition of experiential learning. It developed PLAR practices and published a great number of influential works on the subject. [9] Between 1968 and 1974, 13 HEIs focusing on adult education and offering PLAR were founded or expanded. Thus, PLAR gained momentum and became an important part of the movement for equal access to education. At present, over half of the universities in the United States implement a PLAR assessment system, but detailed regulations differ by state. Some states, such as Minnesota, Oklahoma, Pennsylvania and Vermont, have instituted a statewide PLAR system. [10]In some universities in New York, all of the credits required for graduation can be transferred from PLAR credits, meaning that PLAR applicants can apply for a degree directly. In Maryland, a maximum of 30 credits may be transferred through PLAR. For example, University of Maryland University College requires 120 credits for an undergraduate degree, of which up to 30 credits, or one fourth, may be PLAR credits.
 
3. Canada
 
PLAR has a history of over 20 years in Canada. Quebec was the first to implement PLAR policies in community colleges across the province. Then, British Columbia, Ontario, New Brunswick, Nova Scotia and Newfoundland began to follow suit. British Columbia has developed an excellent PLAR system which serves as a model for other provinces. One part of this system is the British Columbia Council on Admissions and Transfer (BCCAT). BCCAT is funded by the provincial government, but is operated semi-independently. Members of the Council include some well-known universities, such as Thompson Rivers University. Members arrange for an annual meeting to coordinate activities and to share experiences. The system commissioned universities to produce a credit transfer guide for British Columbia. [11]As education is managed at the provincial level in Canada, the federal government was initially reluctant to get involved with PLAR. [11]However, the federal government oversees employment insurance and immigration, and showed interest after it realized PLAR's potential for workforce training. Currently at the federal level, the Canadian Labour Force Development Board and Human Resources and Skills Development Canada are actively promoting PLAR and support PLAR research projects and publications.
 
4. Norway
 
Since the 1950's, adults in Norway have been allowed by law to sit for examinations based on practical work experience upon completion of an apprenticeship. In 1999, a national system was established to record and identify informal learning at the workplace and in the education field. [12]
 
5. Britain
 
Britain has close ties to the United States, and expands upon research conducted by American scholars. British scholars started to study prior experiential learning assessment around 1980. The government actively promotes PLAR development, and has established the Credit Accumulation and Transfer System (CATS) and National Vocational Qualification (NVQ) system. Before 1994, Britain’s recognition of prior learning achievement mainly applied to a single subject or study activity, and was a way for non-traditional students to enter HEIs. After 1994, the recognition of prior learning experience and corresponding credit conferment has become part of the process of getting a degree or diploma. In 2004, the Quality Assurance Agency for Higher Education issued "Guidelines on the Accreditation of Prior Learning". Though Scotland is a part of Britain, it has developed its own PLAR policies and practices. [13] [14]
 
6. Australia
 
Australia developed PLAR practices extensively in the late 1980's and early 1990's. In December 1993, the Australian Government Publishing Service published "Guidelines for Credit Transfer and Recognition of Prior Learning", requiring universities to develop and publish policies for prior learning recognition. In 1995, heads of various national departments convened and created the Australian Recognition Framework. In 2000, the learning achievement recognition system was formally implemented nationwide. Aboriginal students and those participating in national training reform projects began to benefit from universities' adoption of PLAR. Despite high enthusiasm early on, PLAR had little long-term effect on disadvantaged students, perhaps because PLAR is mainly used by private education providers to attract paying students. Traditional academic education is still predominant, and credits are only recognized for certain practical courses. In June 2004, the Australian Qualifications Framework Advisory Board(AQFAB)published "National Principles and Operational Guidelines for Recognition of Prior Learning". In May 2009, the government adopted the AQF's national guidelines on credit transfer and PLAR.[15]Just as in Canada, the federal government of Australia is also responsible for vocational education and training. Despite support from the federal government, application of PLAR remains limited in Australia.[16]
 
7. South Africa
 
PLAR was originally part of an effort to change the social and economic conditions of South Africa after the abolishment of apartheid. In 2002, the South African Qualification Authority (SAQA) released a policy document relating PLAR to the national framework of qualification recognition. This document set standards regarding assessment quality, system policy and environment, learner support, training and registration of appraisers and other key personnel, assessment methods and procedures, quality management systems, PLAR cost, etc. In 2003, SAQA released an executive guide to PLAR as a follow-on document. [17]
 
8. South Korea
 
South Korea's credit bank system was proposed by the Presidential Commission on Education Reform on January 13, 1997, approved by the South Korean government and officially rolled out in March 1998. As an open education system, the credit bank recognizes various kinds of learning experiences inside and outside schools. The system is mainly administered by the Ministry of Education, Science and Technology (MOEST), National Institute for Lifelong Education (NILE) and educational offices in each province. Recently, the system has focused on providing innovative, diversified and maximized educational opportunities for learners seeking education and training after finishing secondary school. In 1999, South Korea passed the Law on Lifelong Education. This law was originally submitted to parliament as the Law on Lifelong Learning on November 26, 1998. During the course of deliberation, members of parliament felt that the articles all related to education and approved the legislation as the "Law on Lifelong Education". As specified in Article 28, Section 2 of the law, South Korea recognizes the credits and schooling for the following persons in accordance with pertinent legal regulations: (1) Persons who have finished lifelong learning subjects as specified by law; (2) Persons who have completed compulsory subjects in schools of all levels or lifelong education institutions; (3) Persons who have received education at industrial entities and obtained qualification recognition at their workplace; (4) Persons who have obtained qualification recognition by passing proficiency tests held by the state, local autonomous organizations, schools of all levels or industrial entities; (5) Persons who have been professionally trained in accordance with the laws for preservation of cultural relics. (6) In line with the regulations on distance education, the credits, schooling and degrees acquired by learners in schools of all levels and lifelong education institutions at home and abroad are recognized. PLAR in South Korea focuses on non-formal education, including vocational education, extended university education, education in hi-tech training schools and distance education. [18]South Korea's legislation related to PLAR is quite comprehensive, but we are unable to comment on the state of practical implementation due to lack of data.
 
9. Japan
 
The Japanese government established the “Monbusho (Ministry of Education) Review System for Skill Recognition” specifically to encourage the recognition of learning achievements. Some private organizations appraise the knowledge and skills learned by youths and adults through various different channels. The Japanese government supports and recognizes these appraisals by issuing corresponding certificates. Schools also recognize credits acquired through this method. [19]
 
10. Taiwan
 
Since the 1980's, Taiwan has passed education laws and policies to steadily promote lifelong learning and learning achievement recognition. Article 16 of the Law on Lifelong Learning passed on June 26, 2002, specified that a system for recognizing learning achievements in non-formal educational activities should be established. Such recognition would provide motivation for lifelong learning and could serve as a reference for admission to schools or promotion assessment. The recognition system should include the recognition of courses, the acceptance of learning achievements, credit validity period, terms for admission acceptance and other items. By the end of 2003, Taiwan created and issued related measures such as "Implementation Rules for the Law on Lifelong Learning" and "Recognition Measures for Learning Achievements in Non-formal Education". The latter included detailed regulations on the recognition of non-formal learning and established a “recognition committee for non-formal education courses”. The actual recognition should be performed by universities, scholarly organizations and educational organizations in Taiwan. In February 2005, a “recognition center for non-formal education courses” was established in Taiwan. In July 2008, Recognition Measures for Learning Achievements in Non-formal Education was revised once again. [20] Unfortunately, these regulations on lifelong learning and credit recognition have not been fully implemented. For example, Taiwan offers course recognition but has not started informal learning recognition; recognition for non-formal learning courses is an individual, separate process lacking a complete framework and organic integration between organizations. [21]
 
11. International Organizations
 
In "Agenda for the Future", passed at the United Nations Fifth International Conference on Adult Education in 1997, states that “full acknowledgement of knowledge and skills acquired through non-formal education” shall be guaranteed. In 2004, the resolution at the 32nd General Assembly of UNESCO (United Nations Educational, Scientific and Cultural Organization) officially proposed that investigative research be done on the issue of recognition for non-formal, informal and experiential learning. [22]
 
In 1995, the European Union (EU) established a "personal skill card" system that allows for timely examination and recording of various skills acquired through channels besides formal schooling and diplomas. In 2001, the EU committee published "Making a European Area of Lifelong Learning a Reality". This document further emphasized the importance of non-formal and informal learning in adult education and the need to break down traditional concepts of the time period and locations for learning, relating “lifelong learning” with “lifewide learning”. In 2002, education ministers of EU countries passed the Copenhagen Declaration and formulated a series of common principles to recognize non-formal and informal learning. The declaration is a guide to action for each country for establishing a recognition system for learning achievements outside school. [23]
 
Between 1999 and 2004, the Organization for Economic Cooperation and Development wrote a report on major policies for adult learning based on research of adult learning in 17 member countries. The report emphasized the great significance of PLAR. In 2002, the TRANSFINE project was first launched by the European Universities Continuing Education Network (EUCEN), including 170 universities in 35 countries. The project focuses on the transfer of learning achievements between formal and non-formal education. In 2007, the report "Recognition System: A Bridge to Lifelong Learning" reiterated that a recognition system for learning achievements is the key issue in formulating and advancing lifelong learning policies.
 
12. China
 
In mainland China, the concept of PLAR is quite new. Currently, there is only a small pool of PLAR research by a few scholars. However, there is more research on the related subjects of credit banks, credit transfer and recognition for learning achievements. Though research has gotten a later start, there are nonetheless some PLAR practices in China. Examples include: universities having regulations about exemptions from courses or examinations, equivalent credit substitution between non-degree education and degree education for the "Quality-oriented Education for Capital Workers" project, Beijing Language and Culture University's credit recognition for non-degree students converting to degree students, etc. The above practices all relate to formal or non-formal learning, and do not include assessment and recognition of informal learning, or at least not explicitly. As for PLAR, there is likewise no corresponding assessment criteria. A literature review indicates that PLAR research began at the OUC. For example, Zhang Shaogang, Wang Ying and Yin Shuangxu of the OUC published the article "PLAR: a Positive Trial of Distance Higher Education" in the journal Higher Education in China. Wang Ying and Yin Shuanxu published the article "PLAR: Empirical Research of an Informal Learning Assessment Method" in the journal Open Education Research. Wang Ying published "Research and Practice on Recognition of Informal Learning" in China Educational Technology. More scholarly articles and papers are successively being published. The OUC has conducted joint research with Canada’s Thompson Rivers University, which has made outstanding achievements in PLAR. In November 2010, a joint research center was established and scholarly exchange visits were arranged. With the approval of the Ministry of Education at the beginning of 2012, the OUC arranged for scholars to go to Thompson Rivers University and the University of Maryland University College for PLAR training. Thus, the OUC is taking the lead in PLAR research in China. We must also admit that research is still at an early stage and there is a lack of consensus on some fundamental issues; our understanding of PLAR implementation remains superficial. China's study of PLAR, both in terms of domestic implementation or advocating recognition at the national level, will be a long and gradual process.
 
Ⅲ. Analysis of international PLAR development from a legal perspective
 
  After an examination of international PLAR development, it is not difficult to draw the following conclusions:
 
1. Laws and regulations are the prerequisite to PLAR development. In some countries, the establishment of PLAR began with the formulation of laws, regulations, guidelines or manuals. PLAR implementation generally begins at the local level, followed by gradual acceptance and positive promotion at the federal or national level. For example, France issued a total of three decrees and also signed some agreements. Education departments of some US states also drafted PLAR regulations relating to their own state. Certain universities, because of their autonomy and law-based administration, also pass their own regulations. South Korea's credit bank system, plan, courses and standards are all published and implemented by way of law. Laws and regulations ensure that the development of PLAR has a legal basis and has rules to follow. Thanks to the stability and continuity of law, the system will continue to develop, and learners will trust the system and be motivated to continue learning.
 
2. PLAR development must be guided by education policies formulated by the government. Since laws and regulations are by nature stable and continuous, the contents of the regulations should remain broad and general, as PLAR is a new system in the trial stage of assessing all kinds of individual learning activities. While the system is a challenge to operate, it is also of great value in promoting lifelong learning and contributing to the betterment of society. As such, government support and promotion is crucial. When governments recognize the value of PLAR, they actively promote it through their education policies.
 
3. PLAR development is driven by the pursuit for equality and fair treatment for all. After studying a subject at one educational institution, one should not need to study it again at another educational institution. If one already possesses some knowledge or skill, it is not necessary to re-study it; institutions should treat all applicants fairly. When explaining the reasons for PLAR development, each country usually includes a demographic analysis, a focus on diversity and equality, development of new technology, and sustainable globalization. The early development of PLAR in the United States was aimed at improving education for veterans, while in Canada, Australia and South Africa, the goal was to improve the educational levels of aboriginals, to help the disabled and to train the labor force. Arthur L. Wilson, a scholar from Cornell University, says in his co-authored work Handbook of Adult and Continuing Education that the PLAR campaign is a “quiet revolution”. He believes that in addition to the development of PLAR procedures, PLAR development is driven by society, economy and politics. [24]
 
4. Regulations are the core of PLAR. PLAR is the assessment and recognition of  prior learning, which facilitates the direct transfer of credits after getting enrolled in school. What kinds of learning can be recognized and transferred into credits? What kinds of experience and learning cannot be transferred into credits? How many credits can be transferred from experiential learning? How are they calculated? How can the appraisers’ assessment results be recognized by the applicants? What procedures are involved in learning assessment? What qualifications must appraisers meet? What preparation is necessary before applying for assessment? How to set up financial aid? PLAR regulations must be designed to address these core issues and others. The complexity of regulating PLAR is obvious when one starts to think about the issues. Professions and interests are almost infinitely diverse; certain restrictions must be applied when making assessment. For example, when assessing work experience, the goal is not to establish how many years the applicant worked but to demonstrate that the applicant's acquisition of theoretical knowledge improved and guided his or her work performance. Let us take a policeman in service for 30 years as an example. If he wants to apply for a degree in criminology, he needs to demonstrate that his work performance was guided by his learning of criminology theory.
 
5. Emphasize procedure and transparency. Procedure is critical for many reasons. It results in democratic and scientific policy making, and feasible and fair enforcement of specific regulations. It contributes to authenticity, objectivity, rationality, equality, fairness and efficiency. In addition to the rationality and fairness of the procedure itself, it is the means by which we achieve good implementation results. Transparency requires that all regulation procedures must be publicized and open and that no arbitrary changes or inconsistent interpretations may be applied. The purpose is to ensure stability and predictability, so as to win over the students’ trust in the school and its regulations. PLAR research practitioners place great emphasis on PLAR procedure. It is no exaggeration to say that PLAR handbooks are all about procedure regulations. For example, the PLAR operation manual of Thompson Rivers University tells applicants what to do and clearly states the responsibilities of staff at the same time. For example, it specifies that an applicant’s question shall be answered within one business day, and that all staff must observe this regulation. Assessment of students is also conducted strictly by procedure regulations. All procedure regulations are published openly so that the public can access the information and play a supervisory role.
 
6. PLAR is closely tied to jurisdictional area. PLAR regulations may be valid nationally or locally, in multiple institutions of higher education or just one. Within a certain jurisdiction, PLAR develops with its own local characteristics. Internationally, the development of PLAR has always surpassed the planned institution and legislation of each jurisdiction. Through legislation, each nation or region can learn from others and see which PLAR procedures are suited for local adoption.[25] It is understandable that each different jurisdiction creates and applies its own set of PLAR regulations, , but this hampers mutual exchange and communication, causing difficulty in credit transfer across a wider area. Thus, the jurisdictional area makes PLAR development possible, but is also a barrier to further PLAR development. International and interregional communication is necessary to establish agreements to overcome this barrier.
 
Ⅳ. Major challenges in developing PLAR in China
 
PLAR development in China faces many difficulties.
 
First, respect for the law is not as deeply ingrained, staff and appraisers may lack a sense of professional responsibility, and there is the utilitarian tendency to rush to achieve results. These problems may lead to China's PLAR practices becoming superficial and formalistic.
 
Second, unilateral national education policies and laws are implemented across the country; with China's great regional variation, high volume of students, and diverse experiences, it becomes difficult to make choices. If we choose to implement PLAR on a national scale, it is difficult to calculate the workload and cost involved and to spur initiative for the work; cost could outweigh benefit. If PLAR is implemented locally, the work will be much simpler, but again, credits will not be transferred to other places and its practical significance will be lost. 
 
Third, it is difficult to ensure the quality of PLAR with the current state of education. However, the advantages of PLAR outweigh the disadvantages, and we should research how to avoid or overcome these unfavorable factors. We believe that the following problems should be taken into serious consideration.

1. Education laws and regulations. PLAR legislation must precede PLAR development. At present, the main laws pertinent to higher education include Education Law, Higher Education Law, Vocational Education Law, Regulation of Academic Degrees and other administrative and local regulations. Though "Regulations for the Promotion of Lifelong Education" has been formulated in Fujian and Shanghai, there are no national-levels laws like the Law on Lifelong Learning that clearly regulate adult education, lifelong education and lifelong learning. The overall state of education law enforcement is less than satisfactory. To advance PLAR in China, a high-level law like the Law on Lifelong Learning must first be passed. Second, the Ministry of Education needs to formulate regulations or measures to promote lifelong learning, including credit transfer and PLAR. Lastly, all provincial education departments can formulate corresponding implementation measures or flexible regulations suited to local conditions. In this way, a complete legislative system for PLAR comes into being. Given the difficulty in issuing the Law on Lifelong Learning, we suggest that the Ministry of Education departments in charge of adult education and vocational education arrange for experts to research and draft credit transfer regulations and provisional PLAR regulations. These regulations should specify the definition and boundary of PLAR in the light of international and domestic circumstances, assessment scope, assessment organizations, assessment personnel, assessment procedure, credit recognition and financial aid, etc.

2. Education policy. As laws are closely related to policies, the government usually publishes an education policy aside from legislation to guide the educational development of the nation. Chapter 8 ("Continuing Education") of the National Outline for Medium and Long-Term Education Reform and Development (2010-2020) calls for the construction of a flexible and open lifelong education system to build an "overpass" to lifelong learning. The system promotes horizontal and vertical ties between various forms of education at different levels, and provides more opportunity and choice to satisfy people's diverse needs for learning and development. The system should also facilitate the accumulation and transfer of continuing education credits, and implement mutual linking and recognition of various types of learning achievements. This shows that China has clear policy support for PLAR and that we should proceed with work on details and practical implementation.

3. Design of detailed regulations. Before formulating PLAR regulations, we must first thoroughly learn from existing achievements and experiences to avoid pitfalls. For example, the international Council for Adult and Experiential Learning headquartered in Chicago is dedicated to establishing standards related to PLAR, and higher education institutions refer to those standards to formulate their own regulations. The following fundamental guiding principles should be encapsulated in the design of detailed regulations: recognition of prior learning; fair treatment for all students; member organizations acknowledge and respect the procedures of each school; clear, open and transparent assessment procedures; transferability of PLAR credits; etc. The scope, procedure and requirements for assessment must be spelled out in detail. For example, the PLAR operation manual of Canada’s Thompson Rivers University clearly specifies the school's methods for PLAR assessment, and includes specific procedures for portfolios and examples. The manual covers the entire process from how students make information inquiries to how to obtain results and how to appeal unsatisfactory results.
 
4. PLAR implementation. Legislation and law enforcement complement each other. Good laws with poor implementation will lead to PLAR remaining a formality. After the PLAR measures and regulations have been formulated, they must be implemented by educational institutions or industries. How can PLAR overcome existing maladies, such as arbitrary handling of agreements, cheating in exams, plagiarism, sitting for examinations in place of others, backdoor relationships, and lax control?  Since PLAR is an assessment system which includes prior learning, societal experience, individual preferences and other factors, subjectivity in assessment is unavoidable. If the enforcers lack a strong sense of responsibility, a low quality system may result in which credits are granted once payment and materials are received. Alternatively, if students are not interested in participating in challenging experiences, or they feel it is too cumbersome, students may ignore PLAR. Therefore, how to enforce PLAR and how to prevent academic misconduct and student dishonesty are all important topics.
 
5. Prior research to design a feature-rich PLAR system. PLAR in China is now mainly in the research phase, and our development path is basically similar to those of countries with good PLAR development. Through the publication of papers and books and the convening of academic conferences, education administrators are gradually realizing the importance of PLAR, and educational management departments are beginning to promote it. The definition of PLAR terminology must take into consideration existing international achievements and common knowledge, as well as the characteristics of China. One of the suggestions made by Dr. Christine Wihak to the OUC trainees is that terminology interpretations may not be the same, such as the term "credit bank". Challenging examinations may be a practical way to deal with the great number of students, and institutions dedicated to the organization of such examinations could be established. For example, the United States has a similar institution called the College Level Examination Program (CLEP), sponsored by the College Board and run by the Educational Testing Service (ETS). CLEP is the largest national examination programme that grants university credits, and it offers examinations for 5 general subjects and 29 specialized foundation subjects. When those who study university-level courses outside of regular universities pass CLEP examinations, they can acquire credits for the corresponding subjects recognized by universities. At present, there are about 1300 examination sites all over the United States. CLEP examination participants usually fall into one of three groups: (1) university students aged between l8 and 22; (2) in-service adults (company employees); (3) part-time students. CLEP is an effective and reliable channel for acquiring credits via examination, and CLEP credits are recognized and accepted by over 2900 universities and colleges. [26]
 
Ⅴ. Conclusion
 
The benefits of PLAR are obvious on paper, but it is difficult to operate and requires a lot of work. There have always been opposing voices, and some scholars and institutions ignore PLAR procedures. In some countries, years of development have failed to produce meaningful implementation. Coordination between course assessment experts and PLAR experts also remains a challenge. We can take Thompson Rivers University as an example. When PLAR staff ask professional instructors of a university department to assess students' materials using PLAR procedures, they will sometimes say it is too difficult to do. PLAR regulations must be developed and implemented gradually. PLAR is a system that started in the 1930's, but did not experience significant development until about 30 years later, and it is still under development today. Dr. Huang Fushun, president of Taiwan Adult and Lifelong Education Society says, “The recognition of non-formal learning achievements is an international trend, and a necessary task in promoting lifelong learning. However, as recognition of these achievements involves the conference of credits, degrees and other related documents of certification, it must be implemented with great care and forethought, and meet high standards of fairness, openness and quality control. Only then will it be accepted and supported by society. Otherwise, it may become a useless or ineffective system, or at worst, even risk destroying the existing education system. A good policy improperly executed becomes harmful to societal institutions. Therefore, prudence in implementation is most appropriate.” [27] Dr. Huang's words summarize our viewpoint on the subject. In sum, PLAR development in China should begin with research and involve advance legislation, government promotion and extensive experimental trials. It should be implemented steadily in phases, without rushing to achieve quick results.
 
*There are no references for some of the information and commentary views in this paper. The source for this information is the “PLAR Delegation to Canada and America” headed by Dr. Wang Ying and Dr. Huang Danqing in early 2012. The information was gathered from presentations by related experts at Thompson Rivers University (TRU) and the University of Maryland University College (UMUC), as well as from analysis and discussions among the delegation members. Acknowledgement is hereby made to all of them.
 
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About the author: Yao Laiyan, doctor of law science, associate professor, School of Arts and Law at the Open University of China (100039)