January 9, 2012
Hon. Patricia B. Licuanan
Commission on Higher Education
C.P. Garcia Ave.
UP Diliman, Q.C.
Dear Dr. Licuanan:
Thank you for your letter of December 12, 2012.
Here you explain your stance regarding the request of the PAASCU General Assembly to the Commission en banc to postpone its approval of what was then the proposed Policy Standard on Outcomes-Based and Typology-Based Quality Assurance (OTQBA).
We would have wanted to further discuss the serious problems we have with OTBQA, and its implementation at this time of disquiet due to the implementation of K-12. Unfortunately, we never got this chance because on December 11, 2012, CMO 46, s. 2012, “Policy Standard to Enhance Quality Assurance (QA) in Philippine Higher Education through an Outcomes and Typology Based QA,” had been passed.
Now, after having consulted trusted lawyers and colleagues in Philippine education and upon unanimous resolution of the PAASCU Board of Directors in an extraordinary meeting held on January 8, 2012, we wish to inform you of our continuing objections to CMO 46, s. 2012.
We are convinced that in its mandate to Philippine higher education to contribute to “building a quality nation” (Art. I. Sec. 1), however laudable that may seem, it violates the academic freedom that RA 7722, Sec 2 mandates CHED to “ensure and protect.” It commands CHED to promote the “exercise and observance…” of academic freedom (Sec. 2). In fact, it issues an explicit “Guarantee of Academic Freedom” in Sec. 13: “Nothing in this act shall be construed as limiting the academic freedom of universities and colleges.”
RA 7722 guarantees academic freedom in implementation of a Philippine Constitutional guarantee: “Academic freedom shall be enjoyed in all institutions of higher learning” [Art. XIV, Sec. 5(2)].
This is not enjoyed in the same way by schools offering basic education. It may be appropriate for the Department of Education to prescribe curricular content in all levels of basic education. This is not appropriate in higher education precisely because of the Guarantee of Academic Freedom.
Beyond this issue in fundamental principle, the PAASCU Board also noted certain issues in CMO 46, s. 2012 and the Implementing Guidelines which will harm the work of quality assurance and accreditation in the Philippines – a service PAASCU has been engaged in with international recognition for 55 years.
Some of the issues are:
On Article II: Quality Assurance Framework
1. There seems to be a flaw in the perspectives of quality adopted by CHED in Sections 6 and 7. These perspectives are not linked to a typology of HEIs. To a great extent, these perspectives are shared or have equivalents in the systems used by private accrediting agencies. The plan-do-check-act or PDCA quality cycle is used by HEIs as the framework as they implement an internal QA system in preparation for the accreditation visit.
2. In Section 9, CHED suddenly offers itself as an external agency that can help carry out QA and assumes the role “to oversee a rational and cohesive system that promotes quality according to the typology of HEIs.”
However, the agencies and ministries represented in the ASEAN Quality Assurance Network (AQAN) have already produced the Principle Statements of Quality Assurance Framework in Higher Education with the following components:
i. External Quality Assurance Agency
ii. Quality Assurance Processes
iii. Institutional Quality Assurance
iv. National Qualifications Framework
While many provisions of Article II are in consonance with the principle statements, key portions are not. In particular, an external quality assurance agency must have “autonomous responsibility for its operations” while for quality assurance processes, “appropriate mechanisms are in place to ensure reviewers are free from conflict of interest”. Clearly, CHED has no autonomous responsibility for its operations and as a government regulatory agency, it immediately has conflict of interest issues, even with a QA pursued under a developmental approach.
This situation is ironic considering that CHED cited “the acceptance of internationally-agreed-upon frameworks and mechanisms” as among the considerations that underscored its focus on quality and quality assurance. On the other hand, the private accrediting agencies in the Philippines such as PAASCU are consistently operating in harmony with the AQAN principle statements. CHED should not assume a new role for itself, especially one that is already being done extremely well by external QA agencies.
On Article III: Rationale for Adopting Competency-Based Standards and Outcomes-Based Monitoring and Evaluation
3. In Section 16, CHED makes it known that it is adopting two approaches to outcomes-based evaluation of programs and institutions, which later in the Implementing Guidelines become the definitions of outcomes-based quality assurance (OBQA) for the program level and institutional level, respectively. Lost in the translation is the quick shift from evaluation to QA, which are two different but related matters.
Also, Section 16 is essentially quoted verbatim from the summary of the hotly-contested 2004 Technical Report of John Randall on Quality Assurance of Higher Education in the Philippines.
4. IQuAME has been the centerpiece of CHED’s Quality Assurance System since 2005. Has there been an evaluation done on IQuAME, its impact on Philippine higher education and the HEIs that have been visited over the years?
5. Dr. Rey Vea, QA Task Force member, in his presentation on OBTQA during the 2012 General Assembly of the Catholic Educational Association of the Philippines (CEAP) admitted that the origin of the Institutional Sustainability Assessment (ISA) could be traced to IQuAME. Consequently, the many complaints and criticisms on IQuAME vis-à-vis voluntary program and institutional accreditation become relevant again.
6. It should be recalled that EO 705 already clarified that “colleges and universities’ accreditation by PAASCU shall be automatically recognized as accredited by IQuAME.” In changing the name from IQuAME to ISA, is CHED trying to circumvent EO 705? This question is particularly important since in the vertical typology of HEIs, lower points are awarded to local institutional accreditation compared to IQuAME.
7. An inventory of CHED CMOs on Policies, Standards and Guidelines (PSGs) of the different programs dating back from 1996 reveals that Competency Standards are either integrated as program competencies/outcomes or are given a separate Section in the CMOs. If we have been focusing on Competency Standards for the last 17 years (over 100 CMOs), why are HEIs now being asked to shift to learning competency-based standards? Is CHED not aware of its issuances pertaining to prescribed learning competencies or outcomes?
The accrediting agencies always refer to existing CMOs. These Policies, Standards and Guidelines serve as valuable references for accreditors as they assess the quality of programs/institutions. In the Philippine context, however, accreditation goes beyond the minimum requirements. This is the reason we have argued time and again that PAASCU has always dealt with Learning Outcomes.
On Articles IV and V: Rationale for a Typology-Based QA and Adoption of Horizontal Typology of HEIs for QA
8. CHED has cited the “lack of focused support for important research in the country’s universities” as a consequence of the “one-size-fits-all” QA system. This situation is basically a function of funding and capacity building and will not be effectively addressed with an HEI typology.
9. In a country where the private sector is still the dominant player in higher education, a differentiation among types of HEIs will not necessarily rationalize their number and distribution. Across all HEIs, programs are offered in response to demand. Even assuming that HEI typology is necessary for QA, the present proposal of three categories still needs to be reviewed. In this regard, the comments and position of Fr. Antonio Samson, S.J. in his letter addressed to the CHED Chairperson dated August 22, 2012 are reiterated.
On Article VI: Vertical Typology of HEIs
10. There is a need to revisit CHED’s definition of local and international accreditation. The definition should not be based on where the accrediting agency is located but on the scope and reach of the concerned agencies. Under the current definition, the accreditation which PAASCU gives is considered “local accreditation”, even while it is already accrediting programs in other countries, e.g. Medical Education in Samoa and Graduate Education in Bangladesh.
PAASCU is recognized both regionally and internationally. Medical education accreditation conducted by PAASCU has been recognized by the US Department of Education as having standards comparable to those of the United States. Why should it be relegated as granting only “local accreditation”? Incidentally, only 23 countries in the world have been accorded such recognition by the US Department of Education.
11. Since the definition of basic terms is essential, CHED needs to revisit the definitions provided in the implementing guidelines to make them current vis-à-vis recent literature on QA to capture the nuances or contexts of usage. It has been noted that CMO 46, s. 2012, the Implementing Guidelines and Annexes use references which go back to 1939, 1986, 1988 and 1993. The universe of Quality Assurance and Accreditation has been constantly evolving and many lapses were noted in the definitions which could cause confusion among HEIs who will need to struggle through the voluminous documents.
12. We regret that the CMO 46, s. 2012 and its voluminous Implementing Guidelines were passed without the benefit of actual dry runs among our schools and without consultation from the Coordinating Council on Accreditation (CCA) created under EO 705-A.
Section 1 of EO No. 705-A clearly states that “Higher education institutions with programs accredited by the five existing agencies, namely: the PAASCU, the PACU-COA, the ACSCU-AA, the AACUP, and the ALCU-COA, shall not be subjected by the CHED under the process of IQuAME, provided that these accrediting agencies conform with a set of common standards formulated by a Coordinating Council on Accreditation (CCA), hereafter to be established by the CHED”.
On 11 January 2010, Fr. Joaquin G. Bernas, SJ in his article about Dialoguing with CHED commented that ‘whoever formulated EO 705-A worded it very carefully that the standards would be formulated not by CHED but by the CCA consisting of representatives of private accrediting associations’ (Sec. 1, EO No. 705-A). Further, he stated that ‘the standards, in other words, would be a form of self-regulation by the accrediting associations, i.e., if they freely agree to do it. CHED would then serve merely as a conduit for the standards. Thus EO 705-A itself in effect recognizes that CHED has no authority over private accrediting associations’.
13. A review of Outcomes-Based Education in the Internet revealed the following information:
In Western Australia, implementation of OBE was widely criticized by parents and teachers and was mostly dropped in January 2007.
OBE was introduced to South Africa in the late 1990s by the post-apartheid government as part of its Curriculum 2005 programme, but it was widely viewed as a failure, and was eventually scrapped in 2010. On a smaller scale, some OBE practices, such as not passing a student who does not know the required material, have been used by individual teachers around the world for centuries.
OBE was a popular term in the United States during the 1980s and early 1990s. It is also called mastery education, performance-based education, and other names. Standards are an evolution of the earlier OBE (outcomes-based education) which was largely rejected in the United States as unworkable in the 1990s
In Papua New Guinea, news reports dated October 2012 show that the OBE reform has come to a deadlock. Results gathered nationwide reveal there is a big problem with the implementation process. Therefore, the government of PNG has decided to scrap OBE.
· An Overview of OBE posted in the website of the Association for Supervision and Curriculum Development (ASCD) comprising 140,000 members—superintendents, principals, teachers, and advocates from more than 134 countries including 56 affiliate organizations states that:
“OBE has been the topic of acrimonious debates in many states and school systems. The furor surprised some educators who, after years of hearing calls for “results” from political and business leaders, assumed that most parents and citizens would support a move to more definite outcomes and means of assessing them. Perhaps the majority of people do agree with the principles of OBE—or would if they understood them—but highly vocal critics have now raised enough questions about how OBE might work in practice to create doubts among informed members of the public about its desirability.
Should education be outcome-based? Some might argue that it already is, to some extent. Nearly all education institutions have goals that supposedly guide their work. When educators plan curriculums or teachers plan lessons for their classes, they usually start by clarifying the purposes.”
Why then should CHED embark so emphatically on OBE for higher education institutions in the Philippines when some countries across the globe have already scrapped it?
Though PAASCU was already involved in the service of quality assurance through accreditation long before the creation of CHED by RA 7722, we have always wished to work with CHED in this essentially voluntary service. It would like to continue this collaboration.
However, the PAASCU Board has decided it cannot implement CMO No. 46, s. 2012 until the issues and concerns raised in this letter have been satisfactorily resolved. It hopes they can be resolved.
Sincerely in Our Lord,
(Sgd) Fr. Joel Tabora, S.J.
[Approved unanimously and signed by all the members of the PAASCU Board of Trustees.]