More on CHED’s Outcomes- and Typology-Based Quality Assurance

Comments re: POLICY STANDARD TO ENHANCE QUALITY ASSURANCE (QA) IN PHILIPPINE HIGHER EDUCATIONAL THROUGH AN OUTCOMES-BASED AND TYPOLOGY BASED QA

To the Distinguished Members of the Task Force on Quality Assurance of the Commission on Higher Education:

Thank you once again for this opportunity to express thoughts on the Proposed Outcomes- and Typology-Based Quality Assurance (OTBQA) Program for CHED. I have participated in this discussion before not only in my capacity as President of the Ateneo de Davao University but also in representation of the Catholic Educational Association of the Philippines (CEAP) and of the Coordinating Council for Private Educational Associations. Meanwhile I have assumed responsibilities as President of the Philippine Accrediting Association of Schools, Colleges and Universities (PAASCU).

I acknowledge with gratitude the “movement” in positions from the first draft to the current draft of the proposed Policy – much of which was a result of a dialogue between CHED and its stakeholders. In this matter I appreciate especially CHED’s willingness to listen to voices “on the ground”.

In this light, I wish respectfully to reiterate the problem in principle of the un-level playing field between the private higher educational institutions and the State Universities and Colleges and Local Colleges and Universities. While I admire the manner in which the current CHED administration under its Chair, Dr. Patricia Licuanan, has sought to hold off the proliferation of SUCs and LCUs in negotiating with congressional leaders, and has worked to get the current administrators of SUCs and LCUs to agree to quality standards, on the one hand, and administrative measures coordinating the offerings of private HEIs vs those of SUCs and LCUs on the other hand, there is for us still no assurance that under an new CHED Chair or under a different administration, these administrative covenants shall endure. Issues pertinent to leveling playing field between private and State HEIs will have to be resolved through a new law on tertiary-level education, and not through a CHED MO under RA 7722. The new law would need to spell out the manner in which private HEIs are “partners” of State HEIs in general, but also specifically in matters of QA. The level-playing field is best addressed prior to the implementation of the proposed OTBQA Program, lest the OTBQA Program exacerbate the unlevel playing field.

Concerning the OTBQA Program itself, I wish again to register for the consideration of CHED that the implementation of the OTBQA Program parallel to the implementation of the K-12 Educational Reform is considered onerous. Even in an atmosphere of good-will and general support for the K-12 program, there is still much uncertainty and anxiety related to this reform.

• First, while the Aquino administration has already called for its implementation,K-12 still does not enjoy supportive legislation. This makes it extremely difficult for private HEIs to plan for the ramifications of this reform. For many private HEIs, at stake is not only adherence to quality standards, but the prospects of survival.

• Second, the prospect of no freshmen students in 2016 and 2017, is an administrative nightmare deeply affecting institutional finances and viability, as well as the careers of a significant number of tertiary-level teachers.

• Third, the K-12 reform has ushered in many curricular changes affecting not only universal kindergarten, the old Grades 1-10, the new 11 and 12; it will also affect tertiary-level curricula.

• While the CHED has come out with College Readiness Standards, and while the proposals relative to Tertiary-Level General Education are now under consultation, the effect of K-12 on the tertiary-level programs will be both significant and destabilizing, as both the regulated and the regulators try to find their way through unchartered territory again.

• Clearly, K-12 shall thrust private HEIs into an unwanted transitional upheaval – which for some may mean significant loss of personnel in order to survive, or, if possible, transfer of personnel according to the demands of the K-12 roll out. How institutions will have to manage this, considering existing permanent appointments is no small challenge. Private institutions have, nevertheless, for the good of our educational system, deliberately chosen to bite the bullet to accommodate this necessary reform, even though the actual consequences for many are uncertain.

In this context, I am constrained to recommend that CHED en banc hold off the approval of this OTBQA Program at least until there is more tranquility in the K-12 field. My recommendation would be that in lieu of this, CHED help the private HEIs in their transition to K-12.

Since in our estimation Quality Assurance is in fact no different in objectives from accreditation, I would like to respectfully suggest that for this transition period CHED focus on the monumental yet necessary task of settling minimum standards especially for the academic programs in the light to the K-12 reform, even while the need for a more authentic realization of tertiary-level standards in instruction, research and outreach is acknowledged.

During the transition period I suggest that the existing, functioning and experienced accreditation bodies not only continue in, but expand, their accreditation activities, as a genuine exercise in the service of quality assurance. Unto this end, support and incentives coming from CHED, especially for schools entering into the culture of accreditation, would be useful.

I would like to argue, however, that for continuing improvement of the HEIs, what must be weighed and evaluated are not only outcomes but appropriate inputs. While it is legitimate to stress the need to give due attention to the “success” of our educational services in outcomes, it is unreasonable and contrary-to-tested-experience to expect quality outcomes without insisting on quality inputs. This includes inputs in the teacher qualifications, standards of competent instruction, adequate libraries, laboratories, classrooms, playing fields and the like. A fundamental part of the quality assurance framework is also a well-disseminated and well-understood National Qualifications Framework not only for TESDA-related disciplines (as recently announced on 20 August 2012) but also for tertiary-level, general- and professional academic disciplines. This may need to be informed by the ASEAN Quality Assurance Framework in Higher Education which will be presented in a forum being held in Kuala Lumpur, Malaysia on October 10-11, 2012. The ASEAN Plus Three Forum includes China, Korea and Japan. Indonesia passed their Qualifications Framework into law early January 2012. Malaysia and Thailand have their Qualifications Framework in place.

In a letter dated 22 August 2012 to the Hon. Patricia Licuanan, Chair of the Commission on Higher Education, Fr. Antonio Samson, S.J., Chair of the Federation of Accrediting Agencies of the Philippines (FAAP) suggests that the proposed horizontal typology be reduced to only two, namely the University and the College. Since I was provided a copy as PAASCU President, I quote the pertinent passage of the FAAP President here:

“Regarding the ‘horizontal typology’ of higher education institutions for QA, now proposed to be three types of HEIs [ a) Professional Institutions; b) Colleges; and c) Universities], I suggest that the ‘horizontal typology” of HEIs be further reduced to only two: [ a) Colleges and b) Universities], for the following reasons:

“a. As proposed the main distinction or difference between ‘Professional Institutions’ and ‘Colleges’ rests in that Professional Institutions offer degree programs ‘which lead to professional practice’ (Sect. 23.1 and Sect 25) while Colleges offer degree programs not in areas or disciplines which are for ‘professional practice.’ Careful reading of Sect. 23.1 on Professional Institutions and of Sect. 23.2 on Colleges would confirm this.

“b. Similarly, except for the areas or the academic degree program offerings, the operational criteria for Professional Institutions (Sect. 27.1) and Colleges (Sect. 27.2) are basically the same. True, for colleges there is mention that ‘At least 70% of undergraduate programs have a core-curriculum that develops thinking, problem solving, decision making, communication, technical and social skills” (Sect 27.2.1). But these objectives are clearly also desiderata and requirements for Professional Institutions.

“c. Thirdly, inasmuch as Philippine HEIs /colleges in general offer a variety of courses and insofar as there seem to be very few stand-alone ‘Professional Institutions’ which offer only degree programs for professional practice, I wish to ask whether this distinction between ‘Professional Institutions’ and ‘Colleges’ is helpful and whether this distinction can work out in actual practice.”

Fr. Samson has much more to say on OTBQA in his letter, which I append for the appreciation of the members of the Technical Panel on Quality Assurance and whomever might be reading this document.

In addition to Fr. Samson’s remarks, however, where the mandate of the Professional Institution is one “of developing technical knowledge and skills that lead to professional practice,” I wish to add two remarks: First, the aim of developing technical knowledge and skills requires research that would allow the educational facility not only to keep up with industry and to be innovative for industry. It is contrary to the finality of the Professional Institution as conceived not to have a research requirement that must be essential to all tertiary-level institutions. While the current formulation, “Professional Institutions should have – Full-time faculty members with relevant degrees, as well as professional licenses and/or professional experience in the subject areas they handle” (Sec. 23.1), is appropriately stringent (i.e. an MS, following the MORFHE), the actual requirement for professional institutes is a core of faculty members with at least 50% of the them having the relevant degrees and professional licenses. “All other faculty should have the relevant degrees, professional licenses (for licensed programs), and/or professional experience in the same subject areas they handle” (Sec 27.1.3. italics. mine). While I recognize that those with professional experience may have much to teach, the criteria of how to judge the adequateness of this or that type of teaching for instruction must be professionally determined and overseen. Otherwise this provision (and similar provisions, e.g. Sec. 27.2.2) will be a gateway for unqualified instruction. Those who have much experience in being professionally unsuccessful will find their bread and butter teaching future professionals how to succeed.

Now, if Outcomes-Based Quality Assurance, prescinding from fashionable discourse, can be successful only through strong assurances of quality input, including a critical framework of an internationally-acceptable Qualifications Framework (yet outstanding for us!), and if what has been argued concerning the closeness of the College and the Professional Institution is acceptable, then the importance of approving the OBTQA at least for this time of transition to K-12 might be denied.

Then CHED might focus more on assuring the success of the transition to K-12 from the viewpoint of higher education.

Meanwhile, I reiterate my comments of April 24, 2012: Concerning the issue of institutional accreditation (or institutional sustainability), a reincarnation of IQUAME (as Engr. Rey Vea disclosed during the recent CEAP National Convention), I believe that this might be left to the private accreditation agencies. PAASCU has institutional accreditation in place. The focus in any case ought be on program accreditation in the light of K-12.

On Quality, Norm, and Quality Assurance (Accreditation)

Finally, allow me some critical comments on the definition of quality as it appears in Section 6:

CHED defines quality as the alignment and consistency of the learning environment with the institution’s vision, mission, and goals demonstrated by exceptional learning and service outcomes and the development of a culture of quality:
Quality as fitness for purpose…
Quality as exceptional…
Quality as ‘developing a culture of quality’…

I think, however, helped by Merriam-Webster: “quality” is a standard of something as measured against other things of a similar kind.

The trouble with the CHED stipulated definition of Quality is that is undertakes to define “quality” in general, in the abstract, without reference to the reality which is the bearer of quality. It seems to be referring to an institution, while quality can be said of the learning process or of the teaching process, etc..

Relative to a norm, quality is of various types: poor, good, excellent, etc.

From other perspectives, but always with reference to the norm, quality is adequate or inadequate, passing or failing, functioning, malfunctioning, fatally flawed.

Quality is determined by human evaluative judgment based on a norm or standard of goodness.

The standard may apply ideally – as informing reality that falls short of the ideal.
The standard may apply really – as informing efforts to achieve the ideal in reality.

The former is peremptory and the “stick” of regulators.
The latter is historical, perceived and applied by practitioners.

So back to Section 6:
“CHED defines quality…” This is a stipulative definition of quality in the abstract.
But it fails to identify the bearer in being of “quality.’

Instead it seeks to determine quality through peremptorily stipulating as an aspect of goodness: “alignment and consistency of the learning environment with the institution’s vision, mission and goals…”

CHED however fails to state that it is talking about the quality of a particular being like an HEI, educational program, teacher, student, etc.

And jumps to the relationship between a learning environment…and an institution’s VMG.

But based on what is supposed to be the bearer of quality and possible real demands being made on it, alignment of the learning environment with the VMG may or may not be really important. [e.g., Real research of great social relevance may be being undertaken in a grade school.]

Then it stipulatively defines that “alignment and consistency of the learning environment with the institution’s VMG” is “demonstrated by exceptional learning and service outcomes and the development of a culture of quality.”

Unclear is the necessary relationship between the actual learning environment, the VMG, and actual outcomes in learning and service. But the definition forces the relationship, stating that good outcomes “demonstrate” the alignment of learning environment with VMG.

In my view, articulating the norm on the basis of which quality is determined for higher education belongs to CHED. Regulation is based on the norm.

Assessing quality, however, belongs to accreditation. Above the norm, it is a function of excellence. This is why the accreditation process should be voluntary and is best kept in the private sector.

Philip Altbach in the Report Prepared for the UNESCO 2009 World Conference on Higher Education entitled, Trends in Global Higher Education: Tracking an Academic Revolution, states that “in practice, the issue of quality is addressed more usefully as a process than an idea… Even without a concise definition of quality in higher education, a pattern for evaluating higher education has been established in most of the world. In a break from the past, this new pattern tends to rely on peers rather than government authorities to conduct the evaluation process “.

(Sgd) Fr. Joel Tabora, S.J.
Davao, 3 September 2012

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About Joel Tabora, S.J.

Jesuit. Educator
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