Disqualifying CMO 46 s. 2012 For Genuine Quality Assurance

[Text of CEAP Ad in PDI, May 6, pg A14]

Disqualifying CMO 46 For Genuine Quality Assurance:
CEAP Position on CHED”s Outcomes- and Typology-Based Quality Assurance

The Commission on Higher Education’s (CHED) Memorandum Order No. 46, s. 2012 (CMO 46) entitled Policy-Standard to enhance Quality Assurance (QA) in Philippine Higher Education through an Outcomes-based and Typology-based QA issued on 11 December 2012 intends to help Philippine Higher Education. It doesn’t. It messes things up. Quite horribly.

The CHED decries the large number of unqualified Higher Education Institutions (HEIs) operating in the country. Instead of just closing substandard HEIs for non-compliance with minimum standards, it has approved a Quality Assurance Mechanism that cannot be equitably implemented, if it can be meaningfully implemented at all. Higher education will not improve through CMO 46. It will only get more confused.

CMO 46 is issued in a higher educational context where CHED’s regulations for private schools (recognized by CHED) cannot apply to state universities and colleges (created by law) and local colleges and universities (created by local ordinance). Accordingly under CMO 46, there is no equal protection before the law. On the basis of CMO 46, CHED can close private universities for substandard performance. It cannot close State Universities and nor Local Universities and Colleges. That’s unfair.

The approval of CMO 46 with its myriad infirmities by the Commission on Higher Education en banc was rushed, despite our pleas to the contrary, allegedly because of international pressure coming from the ASEAN, APEC and the like. But as approved, it cannot be implemented, because essential pre-requisites are not in place: e.g. a legislated Philippine Qualifications Framework (as already accomplished in other countries) and minimum Policies, Standards and Guidelines for all academic programs.

We do not accept that bad policy will eventually improve through serendipity.

CMO 46 moves counter current to the international quality assurance mechanisms now being put in place in the ASEAN. Where ASEAN insists on quality assurance agencies being independent (1) of government, (2) of the universities being monitored, and (3) of the market, CMO 46 offers the government agency CHED as an external quality assurance agency that would subject higher education to the needs of the market.

Where the Constitution and RA 7722 guarantee Philippine Higher Education Institutions academic freedom, i.e., the freedom to determine who teaches, whom to teach, what to teach, how to teach, CMO 46 arrogates to itself the power to state: “Philippine higher education is mandated to contribute to building a quality nation…” Where it gets the power to mandate what is properly left to the HEIs, esp. the private HEIs, to determine in academic freedom, is unknown. This is a violation of the academic freedom to determine WHAT to teach.

That CHED articulates this mandate as a fundamental premise of a CMO on Quality Assurance implies that quality will be co-determined by the manner in which an HEI contributes or does not contribute to the “quality nation,” itself undefined by the CMO. But: HEIs may determine in academic freedom to teach content that CHED may not consider “contributory to the quality nation,” especially if critical of government. The HEI would then be evaluated negatively. CMO 46‘s mandate to contribute to a quality nation, therefore, violates the academic freedom to determine WHAT and HOW to teach.

As part of this Quality Assurance mechanism it has approved the creation of Professional Institutes alongside current Universities and Colleges. The rationale of the professional institutes, however, is seriously questioned, since there is no substantial distinction from the college.

Initially, the impression given was that adherence to CMO 46 is mandatory for all HEIs in the Philippines. The language of the CMO and the set of deadlines in the Implementing Rules attest to this. Now they are saying that CMO 46 is not mandatory. But a reading of the CMO gives the opposite impression.

The good intentions of the CHED commissioners are irrelevant when they are not expressed appropriately in the CMO’s text.

CMO46 doesn’t help Philippine higher education. The CHED should abrogate it. Or, at least, suspend it until its myriad infirmities are cured.

We call on the President of the Philippines and the legislators to read CMO 46 for themselves, consider the issues we have raised, and help return order and rationality to our CHED in pursuit of quality higher education.


About Joel Tabora, S.J.

Jesuit. Educator
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