[PAASCU’s Request of CHED to Postpone CMO on OTBQA. 30 November 2012]
The Honorable Commissioners on Higher Education (CHED):
The as-of-yet unnumbered CHED Memorandum Order entitled “Policy Standard to Enhance Quality Assurance (QA) in Philippine Higher Education Through an Outcomes-Based and Typology-Based QA” is purportedly slated for formal consideration by the honorable members of the Commission on Higher Education.
Although this proposed policy has been subject to multiple-rounds of consultations, and although its contents have changed appreciably from its initial formulations as a result of these consultations, allow me to respectfully inform you that the General Assembly of the Philippine Accrediting Association of Schools Colleges and Universities (PAASCU) meeting in Manila last November 23rd, 2012, unanimously:
“Resolved, that the member institutions of PAASCU focus their energies on the implementation of K-12 and that the Commission on Higher Education be requested to defer approval and implementation of the Outcomes-Based and Typology-Based Quality Assurance scheme (OBTQA) and
“Resolved, furthermore that the President and the Board of PAASCU work with other educational institutions and relevant government officials or institutions for the postponement of the latter.”
While our members are not rejecting outright the aims and goals of the OBTQA, they embrace K-12 as the urgent educational reform which they must implement. K-12 is an academic revolution that affects all our schools, especially our tertiary-level institutions that must look forward beginning 2016 to severely lessened enrollments, that for some may cause their closure. Should they survive, K-12 involves shifts in curricula with the introduction of the new Grades 11 and 12, as well as shifts, displacement, and loss of tertiary-level faculty. How to manage the displacement is a major challenge which they believe CHED should be concerned about. The announcement of the Department of Education on the hiring of some 48,000 new public school teachers with a starting compensation of PhP 18,000 may decimate the faculty ranks, especially of our smaller private schools. How the schools and the Department of Labor will handle this necessary shift for some teachers from tertiary to senior secondary high school, or the number of possible terminations in many tertiary-level schools is a cause of concern.
Beyond K-12, our members feel many issues pertinent to OTBQA are still unresolved. Therefore it would not be wise for the Commission en banc to approve the proposed memo without the issues being resolved. Among these are the following:
Questions related to Typology-Based QA
There has been movement in the proposed policy from five horizontal types to three. But the question still remains unanswered as to whether there really must be the professional institute and the college, when their structures as defined by Sec. 23.1 and 23.2 are so similar, and the provisions of Sec. 26 allow them to be even more similar. As Fr. Antonio Samson, S.J., Chairman of the Federation of Accrediting Agencies of the Philippines, has said, it would be sufficient to have colleges and universities. Working with college and universities, it would still be possible to do quality assurance beginning with the HEI’s self-identity and mission. That is in fact how it is done today.
While it is appreciated that CHED is looking to a QA mechanism based on vertical type, there are concerns with regard to the “level playing field” or equal protection before the laws between private and state universities. CHED is able to exercise status sanctions on private universities but it cannot do so legally with chartered public state universities. A private university may stand to lose its university status granted by CHED, while a state university is immune to status sanctions of CHED.
Questions related to Outcomes-Based QA
There are many unresolved questions related to Outcomes-Based QA which the draft OBTQA has attempted to deal with, but which we still find unsatisfactory. Earlier drafts spoke of Outcomes-Based QA in capital letters and outcomes-based QA in small letters. Sec. 13 states: “CHED is committed to developing competency-based learning standards that comply with existing international standards….” This is a laudable commitment which the document then exemplifies in parenthesis, “(e.g. Outcomes-based education for fields like engineering and maritime education).” It should be noted, however, that outcomes- based education is a different concept from outcomes- based QA. There is a need for a clear conceptual definition of what outcomes-based QA is.
Sec. 14 speaks of learning outcomes “as intended, implemented and achieved”. Then in Sec. 15, it actually explains what this means, “While CHED adopts an outcomes-based approach to monitoring and evaluation, specific inputs (e.g. qualified teachers, laboratories for relevant disciplines) and processes remain important, as they create the environment and shape the learning experience that is made available to students.” Why not say that inputs are as essential as the outputs?
Indeed, if in Sec. 7 it is stated, “Quality Assurance (QA) for CHED does not mean merely specifying the standards of specifications against which to measure or control quality. Rather, QA is about ensuring that there are mechanisms, procedures and processes in place to ensure that the desired quality, however defined and measured, is delivered.” Mechanisms, procedures and processes are inputs. In Sec. 8 and in the Annex, the Deming cycle of plan-do-check-act is described and illustrated. But if this is what QA is about, then it is not merely Outcomes-based QA. It is simply QA. That is what PAASCU has been doing in the past 55 years as an external QA body, ensuring quality while working collaboratively with educational institutions across the country.
Questions related to QA in itself
PAASCU wishes respectfully to express a conviction that for private education, QA is best left in the hands of HEIs and private accrediting agencies. This is because global practice of quality assurance focuses on two main elements: Internal QA which is undertaken by the institution itself in accordance with its own vision, mission and goals and External QA which is conducted by the accrediting agency. Does CHED see itself as an external QA body?
For PAASCU, QA is based on a fundamental commitment of our member institutions to academic freedom and the pursuit of a culture of quality through goals embedded in our respective visions and missions.
We trust that CHED understands this. In the Declaration of Policy of RA 7722 creating CHED it states,
“…The State…shall ensure and protect academic freedom and shall promote its exercise and observance for the continuing intellectual growth, the advancement of learning and research, the development of responsible and effective leadership, the edu0cation of high-level and middle-level professionals, and the enrichment of our cultural and historical heritage.
“State-supported institutions of higher learning shall gear their programs to national, regional and local development plans. Finally, all institutions of higher learning shall exemplify through their physical and natural surroundings the dignity and beauty of, as well as their pride in, the intellectual and scholarly life” (Sec. 2).
Here the separation from regulation and quality assurance is crucial. Regulation is a government right and duty that must be exercised consistently and impartially; it is based on enforcing minimum standards. But quality assurance beyond regulation is a matter of academic freedom which recognizes excellence not as a result of regulatory demand but of a wisdom in governance that knows how to “protect academic freedom” and “promote its exercise and observance…” (Sec. 2).
Sec. 9 of the proposed CMO states that “QA can be carried out with the help of external agencies like CHED and the accrediting bodies”. The use of “can” makes it sound optional. CHED accords no necessary role to private accrediting agencies.
However, in PAASCU’s exposure to accreditation systems of many countries, including ASEAN QA, the independence of the accrediting agency from the university being accredited, from the market, and from government is a sine qua non for an effective quality assurance system.
Sec.10 states that “the overall CHED approach to QA is “developmental”. May we know the specifics of this developmental approach? What are the presuppositions of the trajectory of development?
In the hearings leading up to this version of OTBQA, it has repeatedly been stated that CHED is not trying in this policy to “take over” private education. But when CHED declares in Sec.16 that its approaches to “outcome-based evaluation of programs and of institutions” are:
“A direct assessment of educational outcomes, with evaluation of the individual program that lead to these outcomes…
“An audit of the quality systems of an institution…” (Sec 16). it certainly gives the impression that it is.
PAASCU is not against QA. It lives and breathes QA – in academic freedom. It knows that voluntary accreditation as QA works. For over half a century, it has served as a partner of government in its pursuit of quality and excellence in Philippine education. And therefore, for the reasons we have explained here, beginning with the grave concerns our members have with implementation of K-12, but pertinent directly to QA itself, it respectfully asks CHED to postpone its approval of OTBQA at least until the implementation of K-12 is complete and to consider the points made in this letter. Perhaps, if we give ourselves more time to think and achieve consensus, what we could end up with is a CHED Policy Standard On Enhancing QA.
Sincerely in Our Lord,
(Sgd.) Fr. Joel Tabora, S.J.