International Journal of Language Education, Vol. 3 No. 2, October 2019 pp. 20-26

NEGOTIATING CONFLICTS OF NEEDS IN DESIGNING TEACHING ENGLISH FOR
MIDWIFERY STUDENTS
I Made Sujana
University of Mataram, Lombok, West Nusa Tenggara Province, Indonesia
Email: madesujana@unram.ac.id
Nurachman Hanafi
University of Mataram, Lombok, West Nusa Tenggara Province, Indonesia
Email: nurachmanhanafi@yahoo.com
Sudirman Wilian
University of Mataram, Lombok, West Nusa Tenggara Province, Indonesia
Email: sudirman_wilian@unram.ac.id
Edy Syahrial
University of Mataram, Lombok, West Nusa Tenggara Province, Indonesia
Email: edysyahrial@unram.ac.id
Eka Fitriana
University of Mataram, Lombok, West Nusa Tenggara Province, Indonesia
Email: ekafitriana@unram.ac.id

Abstract
As an international lingua franca, English plays an important role for students of health for both academic and career success;
however, it is often neglected in its planning and implementation. The present study aims at redesigning the teaching of English
for midwifery students using an ESP approach by analyzing present situations (PSA), target situations (TSA), and learning
situations (LSA) as the basis for designing English programs. The research was conducted at Midwifery Department, Polytechnic
of Health (Politeknik Kesehatan henceforth POLTEKES) Mataram, Indonesia involving students, English lecturers, subject
specialists, and management. Data were collected using triangulation techniques -- ECSCS Test, questionnaires, interviews, Focus
Group Discussion (FGD), and documentation – and were analyzed qualitatively and quantitatively based on the characteristics of
data. The research found that (i) the students’ level of English was still low (84.6% in Basic); (ii) the target needs (necessities) are
to be able to communicate both spoken and written in carrying out the duties in workplaces and professional development; (iii)
from those results mentioned above, there were conflicts among aspects of needs in designing courses, that is, the high target does
not correspond to entry behavior, the number of credits allocated, and facilities. Considering the results of NA, it is suggested that
the English programs can be designed using Necessities (TSA)-based Approach, PSA-based Approach, or Mixed Approach with
its own advantages and disadvantages.
Keywords: ESP, midwifery, need analysis, English, SKBI, syllabus, PSA, TSA, LSA
opinions on the meaning of needs. Needs can be translated
into target needs consisting of necessities, lacks, and wants
(personal aims) and learning needs (Hutchinson and Waters,
1993), subjective and objective needs (Brindley, 1989),
perceived and felt needs (Berwick, 1989). Dudley-Evans &
St. John (1998) translate needs in a more elaborate way of the
needs analysis by finding out 8 kinds of needs. Some
translated it into PSA, TSA, and LSA. Chambers (1980)
coined the terms of Target Situation Analysis (TSA) to refer
to communication needed in the target situation while
Richterich and Chancerel (1980 cited in Songhori, 2008)
proposed the term Present Situation Analysis (PSA) to refer
to what learners are like at the beginning of a course. The
results of PSA and LSA become the basis to design Learning
Needs or Learning Situation Analysis (LSA). LSA relates to
what learners need to do and how to do it in order to enable
them to reach the target needs from the present situations
(Dudley-Evans & St. John, 1998; Hutchinson & Water, 1993).

INTRODUCTION
Needs Analysis (NA) has become a fundamental
principle in designing the teaching of English using an ESP
approach (Basturkmen, 2010; Dudley-Evans & St. John,
1998; Hutchinson and Waters, 1993; Iwai, et al,1999;). Even
Brown (2016) claims that NA as primordial to ESP --- there
is no ESP if there is no NA. Many studies all over the world
have been devoted to conducting NA prior to designing ESP
programs in various fields (Araminta & Halimi, 2015;
Munby, 1978; Poedjiastuti & Oliver, 2017; Brown, 2016;
Ulum, 2015; Sujana, Fitriana, & Syahrial, 2016). NA is
defined as “a systematic and on-going process of gathering
information about learners’ needs and preferences,
interpreting the information, and making course decisions
based on learners’ needs” (Graves, 2000:98). However,
interpreting information and making course decisions from
the results of NA is not a simple task due to the complexity of
the meanings of needs. Different experts have different

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I Made Sujana, Nurachman Hanafi, Sudirman Wilian, Edy Syahrial, & Eka Fitriana. Negotiating…
Of various meanings of needs, following Hutchinson
and Waters’ (1993) supposition in that designing courses is
likened planning traveling comprising ‘starting point’,
‘destination’, and ‘route’, the needs in this context are
grouped into these three categories. Dudley Evans & St. John
(1998) group them into PSA, TSA, and LSA. The concept, at
the same time as a framework for this research, is proposed as
follows:

students of POLTEKES Mataram, West Nusa Tenggara; (2)
to analyze target situation (TSA) and (3) to provide
recommendations for teaching of English for the midwifery
students of POLTEKES Mataram.
METHODS
Research Protocol
The needs analysis employed the protocol adapted from
Hutchinson and Waters (1993) and Dudley-Evans & St. John
(1998) by analyzing three areas of needs: Present Situation
(PSA), Target Situation (TSA), and Learning Situation
(LSA). The PSA covers students’ entry levels, perceptions of
students, management and subject specialist, and English
lecturers. The TSA covers necessities of learning English.
These two aspects above -- PSA and TSA – becomes the basis
for course recommendation of English programs at
Department of Midwifery POLTEKES Mataram.
Respondents
The research was conducted at the Department of
Midwifery of POLTEKES Mataram (D3 and D4 programs )
involving 98 students out of the total 240, three management
staff who are also subject specialists, and 3 English lecturers.
Data Collection and Data Analysis
Data were collected by triangulation techniques in the
form of ECSCS Test (English Communication Skills for Civil
Service) developed by ODA-LAN-BC Project (1996),
questionnaires, interviews, Focus Group Discussion (FGD),
and documentation (SKBI – Competency Standard of
Indonesian Midwifery). The collected data were then
analyzed qualitatively and quantitatively.

Diagram 1: Designing an ESP Course
Comprehensive NA involves finding students’ present
situation (PSA) and target situation (TSA) before designing
curriculum and syllabi (learning needs or LSA). The ultimate
goal of designing an English program is to bring learners from
the present situation (level) to the target needs. From the
theoretical point of view, NA looks simple; however, at the
application level, NA often causes conflicts due to the
complexity of aspects involved in the design (see for example
Sujana, Fitriana, & Syahrial, 2016 for higher education
contexts in Indonesia).
The present research aims at redesigning the teaching of
English programs for students of midwifery at Mataram
Polytechnic of Health Lombok, Indonesia by employing an
ESP approach. For students in the field of health (medicine,
midwifery, nursing, etc.), English is urgently needed since it
has ‘strong position’ in their study in the sense that they will
be in trouble when they do not have adequate English
proficiency (Sujana, Fitriana, Syahrial, 2016). It is due to the
fact that the development of technology and science in
medicine and health is very fast and massive and they are
mostly written in English. In addition, for students of
medicine and health in Lombok Indonesia, English plays
more and more important roles along with the development of
business and tourism and the opening of international
hospitals. With the global competition in the coming age,
English proficiency also opens opportunities for Indonesian
medical personnel to work abroad. Therefore, preparing
students to improve their English proficiency becomes added
values in global competition. Accordingly, a thorough study
needs to be conducted so that teaching and learning English
can make a positive contribution to the students. It seems that
the learning objectives of almost all courses, i.e. to provide
students with the ability to understand textbooks in English
and to prepare graduates to compete in their future careers are
still very far from achievement.
This study, as a series of ESP (English for Specific
Purposes) studies in state and private universities, is
conducted in the framework of re-design of English teaching
for students of midwifery in Mataram Lombok, Indonesia
using an ESP approach. Thus, the purposes of this study are
(1) to analyze the present situations (PSA) of midwifery

FINDINGS AND DISCUSSION
Analysis of Present Situation (PSA)
The data on PSA cover students’ English entry
behavior, students’ perception of English needs, management,
and subject specialists, and English lecturers.
English Level of Midwifery Students
The English level of Midwifery students of Poltekes
Mataram is measured using ECSCS Test (English
Communication for Civil Service) published by LAN-ODABC Project (1996). This is a placement test comprising of 15
sections with each section consisting of 10 cloze procedure
types to be completed by the test-takers. The following is the
result of the test from 98 students.
Table 1. Results of Placement Test of Midwifery
Student (N = 98)
Ecscs
Score
Freque
%
Level
level
ncy
6 (+)
135-150
Post-Intermediate
5
111-134
Upper-Intermediate
4
87-110
2
2.0
Intermediate
3
63-86
2
2.0
Pre Intermediate
2
37-62
14
14.3 Elementary
1
00-36
80
81.6 Foundation
The table above shows that the English language ability
of midwifery students in POLTEKES Mataram is still low.
The scores range from 5 to 81 out of 150 questions given. In
general, the average ability of students is at the
Basic/Foundation level. It is found that 80 students (81.6%)

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International Journal of Language Education, Vol. 3 No. 2, October 2019 pp. 20-26
of the 98 respondents are in Basic/Foundation level; Fourteen
students (14.3%) are in Elementary Level, and 2 students each
(2.0%) are at a Pre-Intermediate and Intermediate Levels.
Given the fact of students’ English entry behavior
above, it is difficult to design effective language programs
using an ESP approach. Three aspects need to be considered
in designing language or other education programs are ‘where
to go’ (goals), ‘where to start from (entry/starting points), and
‘which way to take’ (process/route). With such current levels
of English, is it possible to achieve the expected goals?

for D4 program), the management emphasizes on improving
grammar mastery in English 1 and on improving
communication skills in English 2. The institution expects that
English in the future is directed to the improvement on
students’ communication ability (both oral and written) such
as an ability to understand simple communication on
obstetrical topics and to read journals written in English to
anticipate various global issues and development of tourism
in Lombok, Indonesia. To meet these demands, the institution
plan to extend to an extra English program on English journal
analysis in the 7th semester.
In terms of curriculum issues, the problems are the
Midwifery Department of POLTEKES Mataram has no
course description as a guide for developing Semester Lesson
Plan which leads to different interpretation among lecturers of
English [interview with the secretary of the department and
the Program Coordinator of D3 POLTEKES Mataram]. This
statement is supported by English lecturers [interviews and
questionnaires].
From the interview above, it can be concluded that the
management and subject specialists expect that students have
active mastery on English both oral and written language to
cope with their study (reading textbooks) and with their jobs
(oral communication).
Putting together, the management, subject specialists, and
students have the same directions and language proficiency.
All expect that students have functional ability to be able to
use English for written and spoken communication for their
future career (job) and academic life (as students). However,
various obstacles hinder the goals.

Needs Perceived by Students
The purposes of learning English. From the
questionnaires distributed to 49 midwifery students of
Poltekes Mataram, it is found that 42.8% of the students
wanted to improve communication skills (Speaking); 26.5%
wanted to increase the ability of reading textbooks; 12.2%
expected to increase their translation capability; and only
6.1% of students intend to prepare themselves for future
career.
From the analysis of the top three options of the
students, the finding is quite the same as the results mentioned
above. The main goal is to increase the ability to speak
(24.0%), followed by the goal to increase reading
comprehension ability (22.1%) and the ability to translate
(13.9%) and prepare for the future career (13.9%).
Accordingly, the English training program should be
designed and directed to improve the ability to speak and read.
In other words, since the institutional purpose of learning
English is to improve students’ ability to read textbooks, the
materials must involve activities in which students have the
opportunities to express themselves in English.
Skills to be Developed. The objective above is in line
with the midwifery students‘ responses to the question of what
skills they want to develop in learning English.
From data on preferences of skills to be learned, it is
revealed 46.9% of respondents focused more on Speaking,
and 30.6% on Reading. In terms of English sub-skills,
increasing vocabulary is favored by 35 respondents (71.4%)
followed by the development of pronunciation (7 students, or
14.2 %) and grammar mastery (7 students or 14.2 %)

Needs Perceived by English Lecturers
From the results of questionnaires, interviews, and
discussions with the English lecturers and subject coordinator,
it is found that the direction of English learning is different
from one lecturer to another. This difference in purpose leads
to the difference in teaching materials and methods. In parallel
classes of the same subject and credits, the emphasis of each
class is different: one class is geared to reading
comprehension while another emphasizes on communication
skills; meanwhile, the management, as admitted above,
suggest on the improvement of English Grammar in English
1, and on the improvement of communication skills in English
2.
To overcome these differences, the teaching team and the
program management need to determine the direction together
so that the parallel classes will have the same learning
objectives and materials. They need to agree on the learning
outcomes of the courses, the expected competency, and the
materials coverage

Preferences in English Learning Activities
Of the three priorities of the preference on learning
activities by the Midwifery students in POLTEKES Mataram,
no trend of preference is reflected: students’ choice among
nine preferred learning activities ranged between 12.2% to
13.0%. This indicates students’ preferences vary widely.
It is also found that the students favor activities that
involve others in learning: small-group activities (46, 9%) and
pair work activities (32.6%). Large group activities and
individual activities are favored respectively by 8.1% and
12.2%. Thus, it is necessary to design activities that allow
students to interact in pairs and small groups.

Analysis of Target Situation (TSA)
Analysis of Duties and Responsibilities of Midwives as
Professionals. As explained in the methodology section, the
English language needs analysis for midwifery students was
performed through analyzing the responsibilities/tasks
usually performed by professional midwives. In this study, the
responsibility of a professional midwife is analyzed from the
documents containing competencies and responsibilities of
the midwife with the reference of Indonesian Midwives
Competency Standards (Standar Kompetensi Bidan Indonesia
– SKBI, DIKTI, 2012). According to the SKBI, the

Needs Perceived by Management and Subject Specialists
The management and subject specialists (lecturers) of
Midwifery
Department
of
POLTEKES
Mataram
acknowledged the needs for improvement of English learning
to produce students who are able to use English to
communicate about obstetrical topics. However, with the
limitation of credits allotted (i.e. only 2 for D3 program and 4

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I Made Sujana, Nurachman Hanafi, Sudirman Wilian, Edy Syahrial, & Eka Fitriana. Negotiating…
as students' and providing skills for future career and
professional development. However, from data collected
above, the design of the teaching English program will be
difficult due to the conflicts among aspects of needs
(necessities, lacks, and wants).

competence of Indonesian midwives covers seven areas of
competence: (1) legal conduct and patient safety, (2) effective
communication,
(3)
personal
development
and
professionalism, (4) the scientific base of midwifery practice,
(5 ) clinical skills in midwifery practice, (6) health promotion
and counseling, and (7) leadership and entrepreneurship
management. In the analysis of midwifery students’ needs of
the English language, what is required is the breakdown of
sub-competencies related to the purpose of the use of
language (English).
From the SKBI documents, the required tasks and
responsibilities (competencies) associated with language can
be summarized as follows:
a. Capable of exchanging information verbally or nonverbally with the patient/female, the family, female
environment, obstetrics professionals, other health
professionals, and stakeholders.
b. Capable of developing themselves by following the
developments of science and the latest technology, as well
as self-awareness of the limitations associated with the
practice of obstetrics, and uphold the commitment to the
profession of the midwife.
c. Having knowledge and skills on obstetrics, neonatology,
social sciences, public health sciences, ethics, culture, and
proper care for women, newborns, childbearing women,
and families.
d. Conducting health promotion and counseling about public
health in general and women's health in accordance with
the development stage of the reproductive cycle.
e. Planning and managing resources with the aid of science
and technology to produce strategic steps of
organizational development.
From descriptions of the language-associated
competencies mention above, midwives and students of
midwifery are demanded to have high levels of English
proficiency. They are required to have (a) ability of oral
communication (speaking and listening) in the field of
obstetrics and health with various levels of difficulty; (b)
ability to read English texts with varying complexity (simple
to complex); (c) ability to write simple texts up to writing
reports and scientific journals; (d) the ability of vocabulary,
pronunciation and grammar with varying complexity which is
presented in an integrated and contextual way; and (e) the
mastery of cross-cultural understanding in midwifery-patient
communication.
Based on the data obtained from various sources, the
ideal English learning for midwifery students can be
categorized into two major parts, namely preparing ‘students

Justification of the design of ELT
Referring to the theoretical framework used in the
design of the ESP approach, namely the design of the
curriculum should be based on the entry behavior and the
goals to be achieved (the target needs). Both of these concepts
will show the gap to be filled with the curriculum (learning
needs).
The data collected from various sources (students,
faculty subject areas, management of institution) involving
various data collection techniques (test of English,
questionnaires, interviews, and FGD) illustrate that the
English proficiency of midwifery students in Mataram city is
averagely still at the 'basic' level (81.6%). Furthermore, the
analysis of the tasks and responsibilities of midwives
indicates that midwives are required to have high levels of
language skills to carry out the duties and functions as a
midwife and a student of midwifery. It means that the teaching
English should be directed to the achievement of all aspects
of language proficiency at high levels in their own field. A
midwife (and midwife students) is required to have the
followings:
a. Verbal communication skills (speaking and listening)
from simple activities (welcoming and patient
registration, patient history record, etc.) to complex ones
(discussion, presentation of the findings in the field of
health).
b. Ability to read English from simple manual/information
to reading journals and scientific publications.
c. Ability to write simple memos, announcements, etc., to
writing reports and scientific articles.
d. The mastery of related vocabulary, pronunciation, and
grammar presented in an integrated and contextual way.
e. Mastery of cross-cultural understanding (CCU)
underlying communication in English.
Of the two data described above --- students’ English
levels and the target needs (necessities) --- it is clear that the
gap between target needs and the English entry behavior of
midwifery students is very large. According to Dudley-Evans
& St. John (1998), the ESP program can be implemented to
students at the minimum level of Intermediate. The
hierarchical arrangements in the context of the ESP can be
described as follows:

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International Journal of Language Education, Vol. 3 No. 2, October 2019 pp. 20-26

ESP:
Academic
Reading

ESP:
English for Jobs

Interm
ediate
Pre-Intermediate

Elementary
Basic
Figure 3. Levels of English Courses
Recommendations for English Programs at Midwifery
Department
Recommendations of ELT programs for students of
midwifery are based on theories or concepts of Needs
Analysis proposed by Hutchinson and Waters (1993) and
Dudley-Evans and St. John (1998) and on the results of NA
conducted at Poltekes Mataram. As seen in Diagram 1 above,
three main areas in syllabus designs are the analyses of target
situations (TSA), of present situations (PSA), and learning
situations (LSA). The LSA will be based on the gap between
TSA and LSA.
Based on the findings mentioned above -- students’ low
level of English (entry behavior), high demand, limited
number of credits, big number of students in one class, and
other factors, it is difficult to design ELT programs for
midwifery students, which is ideally based on the necessities
(TSA) as the main target of learning English. From various
analyses of needs mentioned above, the target needs are
categorized into short-term targets (to be able to read
academic publication) and long-term targets (to use English
for jobs). With present situations, both of them are hard to
achieve. Therefore, it is difficult to redesign the ELT program,
whether it is based on the necessities (TSA) or on current
situations (PSA). In such complicated situations, this research
recommends some alternatives or choices.

In the design of English learning, proficiency is acquired
gradually. According to Krashen (1982), learning will run
smoothly if the objectives are at one level above the current
capabilities; this is known as an i+1 concept (i is the current
capability, 1 is the ability acquired one level above the current
capability). It is also in line with Vygotsky’s (1978) Zone of
Proximal Development (ZPD). The picture above shows that
the gap is too high between the students’ current level of
English and the goals to be achieved. The situation is
worsened by the number of credits allocated to achieve the
goals (2 credits for the D3 program and 4 credits for the D4
program). As seen in the picture above, it is required to go
through, at least, 4 levels to accomplish learning Academic
Reading (reading scientific journal). If one level takes 60
hours (± 4 credits), it takes quite a long time (240 hours / ± 16
credits) to achieve the desired goals. That required time for
class meetings can be made shorter by providing a selflearning program, the participation of lecturers to encourage
students to use English or by requiring certain certificates for
graduation. These will be able to motivate students to study
harder.
In addition to the problems mentioned above, teaching
English becomes more difficult due to other obstacles such as
the big class size, the absence of clear and standardized
program/syllabi/materials, and the weak teamwork among
teachers.
From the analysis of information related to English
language learning targets (target needs), the direction of
teaching and learning English can be grouped into short-term
goals and long-term goals. In the short term, the goal of
learning English in the Department of Midwifery Poltekes
Mataram is to prepare ‘students’ to become ‘students’.
English is needed as a means to study (that is, reading
textbooks/journals in the own field). In the long term, English
is needed to prepare students as ‘job seekers’ who need
English to carry out jobs as midwives. Again, it needs to be
reminded that to be able to achieve those goals requires high
levels of English. Given the data above, is it possible to
achieve those goals? If not, what are the strategies or actions
need to be taken by the Department to equip their students
and/or graduates with adequate levels of English for global
competitions?

Recommendation #1. Necessity (TSA)-Based Program Design
Since the purpose of teaching English in an ESP context
is to be able to use the language professionally in the targeted
contexts, the ESP programs are ideally designed based on the
necessities (i.e. where the language will be used). Therefore,
the ideal learning outcomes of teaching English at the
Midwifery Department are to be able to read academic
publications to support their study and to able to use English
for employment (job). Thus, the language programs are
English for Academic Purposes (EAP) and English for
Occupational Purposes (EOP) in midwifery. It means that the
ELT programs will contain high levels of English. In EAP, the
teaching will be directed to the achievement of reading
academic publications written in English. Academic reading
requires learners to be effective, active, and critical readers
(Kocukoglu, 2011). In EOP the teaching will be directed to
the use of English for communication (spoken and written) in
a workplace.

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I Made Sujana, Nurachman Hanafi, Sudirman Wilian, Edy Syahrial, & Eka Fitriana. Negotiating…
However, the problem with EAP and EOP programs is that
both need an adequate level of English to start. Dudley-Evans
& St. John (1998) suggest that ESP programs ideally start at
least from an intermediate level. With the current level of
English (81.6% at the basic level), the program will need a lot
of credits and support (such as facilities, human resources,
students’ readiness, etc.). [see leveling in Figure 3 - Levels of
English Courses above].

and has the ability to professional development; (d) limited
number of credits, and (e) class size.
Based on the data given above, the course designer can
choose Necessities (TSA)-Based Design, PSA-Based Design,
or Negotiated English Program with their own strengths and
weaknesses in the application.
Considering the conditions mentioned above. it is
necessary for the policymakers at the Department to consider
other supporting programs to support class meetings.

Recommendation #2. PSA-Based Program Design
The design recommended above will raise a number of
problems especially related to the number of credits allocated
to English subjects. The second alternative of program design
for teaching English for Midwifery students is based on the
current level of English, considering Krashen’s
comprehensible input (Krashen, 1982). Since most of the
students are at the Basic level (81.6%), the ELT program must
be designed to achieve one level above (Elementary level).
The advantage of the PSA-based program design is that the
program seems realistic and comprehensible to students;
however, they will never achieve the demand for English
proficiency needed for academic and occupation contexts. In
this case, English will not give added value and it tends to be
‘formality’ in midwifery curriculum (Sujana, Fitriana, &
Syahrial, 2016; Sujana, 2016).

Acknowledgment:
o Researchers would like to extend their gratitude to
Graduate Program, the University of Mataram, Lombok,
Indonesia for funding this research.
o Researchers would also like to extend their gratitude to
students, lecturers (English and subject specialist), and
management of Mataram Polytechnic of Health
(POLTEKES Mataram) Lombok Indonesia for their
participation in this research.
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Recommendation #3. Negotiated English Program design
The third possibility of program design is by applying a
‘win-win’ solution or negotiated program design. When the
Academic English hard to be achieved and the PSA-based
program design is ‘less’ meaningful for higher education
students, the program can be designed ‘in-between’. This
design is commonly used in ESP at Higher Education in
Indonesia, called General Academic Reading, that is, the
materials are taken from contents of the subject matter
(midwifery) but the levels of difficulty of the texts and tasks
are simplified to minimize the gaps between lacks and
necessities. It is expected that by giving them exposures on
general academic English the students will develop their
English ability outside the class.
It is the job of policymakers to decide which design will
be taken from the three options given above by considering
advantages and disadvantages of each suggestion from
various aspects of designs (English entry behavior,
necessities, class size, time allocation, facilities, teachers,
etc.). In addition to the formal class, the policymakers also
need to consider supporting programs such as Self Access
Language Learning (SALL) Program, Language Rich
Environment, English requirements for graduation, Blended
Learning, and so on to motivate students to study on their own
initiatives.
CONCLUSION
The designing of English programs for students of the
Midwifery Department at Poltekes Mataram is complicated
due to the conflicts among aspects of needs: (a) students’ low
level of English (81.6% at Basic level); (b) different
perceptions of needs among management and subject
specialists, midwife students, and English lecturers; (c)
requirement of high levels of English in SKBI requiring
students and graduates to have adequate communication
competence both spoken and written in carrying out its duties

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