Scotland has incorporated further education colleges. And there the similarity with England and Wales more or less ends. No FE Funding Council, no sixth-form colleges and no Office for Standards in Education. There is only one body - the Scottish Vocational Education Council (Scotvec) - which validates courses and examines them. And, despite recurring criticisms about fragmented learning, non-advanced further education remains staunchly modular.
This centralised model does not, however, extend to the "quality" industry. The inspectorate inspects, Scotvec's quality audit attempts to guarantee the standards of its awards, the Scottish Quality Management System (SQMS) tries to bring all the standards together in one framework, the colleges have their own Total Quality Management (TQM) club, and the 22 local enterprise companies (LECs) subject the colleges to quality control as well.
The colleges confuse the picture further by choosing their own routes to high quality. Lauder in Fife has won the right to a British Standards 5750 imprimatur, Perth flies the Investors in People flag, while Aberdeen proudly boasts Mr Major's Charter Mark.
These, of course, are measures of different things. BS 5750 aims to ensure consistent standards, Investors in People is a staff development tool, and the Charter Mark is intended as applause for excellence in public service.
John McDonald, HM chief inspector in charge of post-16 education at the Scottish Office Education Department, sees a wondrous symmetry in it all, involving a partnership between the colleges, the central agencies and the SOED.
He identifies three "complementary strands" necessary to create that agenda - developing techniques and approaches which ensure high standards such as those represented in SQMS, the colleges which put these into practice through self-evaluation and, bestriding it all, external quality assessment by HMI.
Mr McDonald is keen to differentiate between different aspects of "quality". "Responsibility for quality assurance and quality control resides clearly with the colleges and with Scotvec; quality audit is a responsibility which is shared by colleges and by HMI, but one which is tackled from different perspectives; responsibility for quality assessment lies clearly with HM inspectorate."
SQMS is the quality Bible of Scottish FE. The SOED sees it essentially as "a self-evaluation tool" based on agreed standards. But it has an even more crucial role in that all the LECs are or intend using it to check up on the colleges before awarding any contracts. It concentrates minds.
The SOED is moving very slowly towards funding colleges on "quality" criteria. This year some 90 per cent of college budgets is based on the allocations inherited from their former education authorities and only one per cent - around 2.5 million - is reserved for activities devoted to improving the quality of their operations. A new performance-related funding formula is being gradually phased in but will not be fully implemented until Scottish Office ministers are content that colleges will not lose out too heavily - or gain too much.
The other weapon at the SOED's disposal is its power to approve college development plans. Mr McDonald has strongly urged colleges to involve staff in drawing these up.
But, as he stressed last year, "we have to remember that whatever approach is used for the management of quality, the effects must penetrate to the classroom, laboratory and workshop." The research on pupil achievement in schools, he reminded his audience, shows that real improvements are effected in class, not at the more general school level.
Mr McDonald's view last year was that "we are still a considerable way off having a fully effective operational system (of quality assurance)." His view remains that "penetration" varies from college to college. The inspectorate is currently taking stock of just how much progress is being made in ensuring that standards that are said to be in place are actually percolating down to the classroom.
Scottish inspectors like to see themselves as harbingers of the sensible middle way. As far as quality in FE is concerned, they do not favour autonomy with colleges left to do their own thing. But the inspectorate has no illusions either that it can be achieved by external inspections or rhetorical declarations. "You've got to have people committed to the process," Mr McDonald acknowledges.
The Scottish system will remain one which he described in his speech last year as "a combination of the traditional French grand design approach and English pragmatism."