COCOPEA to Sen. Bam Aquino on Free Private Higher Education

22 January 2017.

Hon. Paulo Benigno Aquino IV
Senate Committee on Education, Culture and the Arts
Senate of the Philippines

Dear Senator Aquino:

In the context of the discussion of your draft legislation on free tuition in State Universities and Colleges (SUCs), the Philippine Association of State Universities and Colleges (PASUC) and the Coordinating Council of Private Educational Associations (COCOPEA) have come together twice.  In their last meeting at the Ateneo de Davao University from Jan. 12-13, both associations jointly issue the resolutions I am happy to share with you today [Resolutions of PASUC and COCOPEA].

Resolution 4 and 8 are historic resolutions.  They articulate the resolve of both associations to “work together in complementarity to improve the quality of higher education in both public and private HEIs” and their commitment in self-governance “to a shared mission of providing quality higher education to the Filipino People.”

Resolutions 1 to 3 emerged out of both associations’ concern that the Philippine System of Education provide not only access to higher education but access to quality higher education, and that both public and private HEIs be involved in this provision.

Resolution 1.  That the Philippine System of Education provide access to quality higher education to all qualified Filipino students.  

While higher education must in principle be accessible to all, in fact Filipinos must be properly prepared for higher education and able to meet its requirements.  This is an urgent issue of quality.

Resolution 2.  That government scholarships be provided in quality higher education institutions, both public and private.   

That scholarships (or government assistance or free tuition) be provided in quality HEIs, both public and private.  At issue is not only access to higher education but access to quality higher education.  Where conditions of quality (appropriate classrooms, libraries, laboratories, etc.) suffer in HEIs due to lack of funding, these must be met as a condition to their receiving government-funded scholars.  Otherwise precious funds are squandered and lives of scholars compromised.  From the very beginning the resources of both quality public and private should be tapped towards providing universal access to private higher education.

Resolution 3.  That qualified Filipino students able to pay for their higher education pay for it; that qualified Filipino students unable to pay for their higher education be fully supported in their higher education by government through scholarships and allowances as needed, especially in programs or courses consistent with the National Development Plan and contributory to the realization of Ambisyon Natin 2040.  

That Philippine Education System, heeding the constitutional mandate to provide universal access to education on all levels for all, on the higher educational level respect the ability of many to pay for their own higher education as their socio-economic conditions may allow or as their basic education may have empowered them to, especially if assisted by loans.  Therefore, this resolution, “That qualified Filipino students able to pay for their higher education pay for it.”  Precious government educational resources needed to improve the quality of higher education in the Philippines should not be wasted on students able to pay for their own education.  However, qualified Filipino students unable to pay for their higher education should be fully supported by government through free tuition, educational expenses, allowances, etc. as required, in SUCs and private HEIs of documented quality.  Priority should be placed on courses identified as consistent with the NDP.

These resolutions considered, it is respectfully submitted that:


On your invitation we have drafted the latter and submit it respectfully to you for your sponsorship and support.  


That Sec. 1. State:  “This Act shall be knows as the “Free Higher Education Act for SUCs.”  This is consistent with its fuller title and resonant with the bill providing for free higher education in private HEIs.

That Sec 4, “Exceptions to the Full Tuition subsidy: include among those ineligible:

  • Must not be capable of paying for higher education
  • Must not be a foreign student

That Sec 6 on Administration of the Fund be amended as follows:

The Fund shall be administered by the Commission on Higher education, in consultation with PASUC and COCOPEA, shall have the following powers…

Under Sec 7.  Requirements for SUCS. Add the following:

That the SUCs apply for availment of the fund in academic freedom and responsibility declaring its level of quality preparedness.

In the PASUC-COCOPEA discussion, the SUCs were fearing that the Free Tuition Act would swell their studentries beyond quality capacity, especially where quality is already suffering because of lack of budgetary support for their desires to improve quality.  The SUCs already need more funding to provide quality higher education to the student populations they already serve.  This funding essential for minimum quality should be attended to before swelling their student ranks with new students.

Respectfully in Our Lord,

Fr. Joel Tabora, S.J.


Appendix to Letter, COCOPEA to Sen. Aquino
of January 22, 2017

COCOPEA Internal Brief Re Free Tuition Bill
Objectives for any tuition-support (aka Free Tuition) policy:

  • quality must not be compromised
  • complementarity between public and private, as enshrined in the constitution, must not be weakened
  • students must have full diversity of choice of institutions and degrees in their access to higher education
  • the growth of total enrollment in higher education should be a policy target (since this is correlated with improved economies)
  • Academic freedom, as enshrined in the Constitution, must continue to be respected.

Private Higher Education

  • Private higher education serves the majority — at approximately 55% — of the 4,104,841 higher education students enrolled in colleges and universities across the country.  Approximately 2,219,857 students study at private HEIs.
  • Private higher education contains most of the top universities and colleges in the Philippines, and exclusively occupies 100% of the list of autonomous and deregulated institutions as identified by the CHEd. It contains the oldest institutions in the Philippines. Private universities and colleges reflect the broad diversity of educational missions, reflected in the missions of religious and non-sectarian institutions.
  • Private higher education employs over 114,000 full-time and part-time faculty and non-teaching employees, and reflects the single largest pool of professionals with advanced degrees in the country.
  • COCOPEA is composed of five national educational associations, and has been the “unifying voice of private education” in the country since 1961.  The five associations are the Catholic Educational Association (CEAP), the Association of Christian Schools, Colleges and Universities (ASCU), the Philippine Association of Colleges and Universities (PACU), the Philippine Association of Schools, Colleges and Universities (PAPSCU) and the Technical Vocational Schools Association (TVSA).
  • COCOPEA numbers 1,920 educational and learning institutions among its member institutions (excluding tech-voc), with an employment base of roughly 146,938 (67,380 in higher ed), servicing a combined enrollment of 2,401,272 students (1,096,303 in higher education).
  • Clearly, the role of the private sector in providing higher education is as important, if not more important than that of the public sector.  Given this, any legislation or educational policy must balance the health of both the public and private sectors, to avoid the “unintended consequences” that can occur toward quality, complementarity, student choice, private sector employment and institutional survival..

Our Comments on the Free Tuition Bill: the Unintended Consequences We Wish to Avoid

  • Unintended consequence: funding poor-quality institutions.  A policy that rewards all SUCs regardless of their institutional performance does not reward quality.
  • Unintended consequence: enrollment movement toward SUCs, away from private schools.  COCOPEA supports market competition (with reasonable regulation) as the key driver to improving higher education and a main factor for balancing complementarity.  If the main reason students shift to the public away from the private is an artificially introduced lower price, then this goes against such concepts, and damage complementarity.  A free tuition policy, all things equal, will attract more students into SUCs compared to private schools..  This is not just wishful thinking.  This has been the position of educational experts, such as the CHEd, the PIDS, and through our discussions with SUC university presidents.  This was also the experience of secondary education over the past 20 years, which saw a drop in the participation of the private sector, from 40% in 1985-86 (before the 1987 Constitution that mandated free basic education) to 9% in 2011-12.
  • Unintended consequence: chasing enrollment in SUCs to the detriment of quality.  The increase in students, if unmonitored will be problematic for SUCs, as they unlikely not have the resources to handle the increase.  More specifically, what happens if more students enroll than forecasted and budgeted, a likely scenario?  The way to safeguard against a reduction in quality in such situations is through a strict strict enrollment cap or ceiling for each institution, thus maintaining the resource allocation levels per student, based on their budgets and forecasts.  To this end, the consolidated bill makes an effort to limit the temptation of SUCs to just accept more students, but it has loopholes.  We ask the body to strengthen these provisions to mitigate unintended consequences for the sector, and can suggest language if requested.
  • Unintended consequence: damage to the private sector, and inefficient investments.  As the secondary education experience suggests, such a student exodus means a negative economic impact to the private sector, in terms of employment and investments in education.  We do not want to see empty classrooms and in the private schools, accompanied by expansion in SUCs for the same investments, nearby. This would be an inefficient use of resources from a national standpoint, and a reasons why the government decided on vouchers for SHS.
  • Unintended consequences: reduced access by the poor.  We will not repeat the concerns voiced by PIDS educational economists and CHEd here, and their advocacy for a more focused targeting toward the poorer students.  We do note, however, the estimate of PIDS that approximately 220,000 more “poor” students can benefit from a more focused targeting (a 67% increase from the current comparable population).  The potential exclusion of this group is a concern that the bill should address.  Additionally, we do want to raise a concern over the data provided by SUCs in determining the income profile of their students, which in turn may influence the interpretations on the bill with regard to being pro-poor. We have examined a sample instrument from Ifugao State and have seen it is a single-question self-reported student assessment of income, with a narrow range of income options.  This means, among others, a likely underreporting of income (a research bias in self-reporting income) among others.  We suggest looking the data provided by the Philippine Statistical Agency (PSA) through its Annual Poverty Indicator Survey (APIS), which also includes more detailed and validated questions on household income and attendance in public or private institutions.
  • Unintended consequence: Inconsistency with international experience.  We have argued how this policy will reduce the role of the private sector in higher education.  Yet globally, private institutions are growing faster than public institutions and gaining share.  Private education enrollment growth rates are higher in East Africa, Latin America, the Middle East and North Africa, Southeast Asia, the US and France, among others.  It is not difficult to see why such trends exist: the private sector has several traits to complement public sector provision, including being typically more attuned to industry needs than the public sector (85% vs 60% employment rates are estimated)
  • Unintended consequence: a bias against the student enrolled in private education.  We do not see the argument why a student in a private institution cannot avail of the same benefits as a student in a state college.  This is not a case of a “rich family” choosing a private school. This is a case of a hardworking family making a choice on how to educate its kids, and saving its money to send its child to a private institution. Yet he or she is penalized (in terms of foregone Tuition support) depending on the kind of institution he or she selects.  In the end, the contributions to the economy of a private college graduate versus a public college graduate are the same at the very least. It is in the national interest to support both equally.

Our proposals
We have proposed an alternative bill, that, among others: (1) focuses on/prioritizes the poor; and (2) provides a voucher, wherein the student has free choice in his or her selection of institution, whether public or private.

On these points, we note that we are simply replicating funding models that exist in the Philippines:  ESC for junior high school, the SHS voucher for SHS, and Philhealth (wherein the amount a person is eligible to receive from Philhealth has the same economic effect as a voucher).

We hope our proposed alternative bill will be given consideration.

About Joel Tabora, S.J.

Jesuit. Educator
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