21 November 2005

Quality Assurance

The Randall Scandal (The Philippine Star, 3 March 2005)

Once upon a time, a false god rose in the British isles. His name was John Randall.

He started the Quality Assurance Agency for Higher Education (QAA), an accrediting body established in 1997 whose mission, according to its website, is “to safeguard the public interest in sound standards of higher education qualifications and to encourage continuous improvement in the management of the quality of higher education.” As the first teacher to raise the alarm against the Randall idolatry put it, however, “the QAA is part of the UK government’s bureaucracy for controlling education.”

Randall had a gospel that he tried to ram down the throats of all British academics. He had a very strange idea that he did not want to sell to the academics, probably because he knew deep inside him that intelligent people would never buy it. Instead, he wanted everyone merely to follow blindly what he said just because he said it. He did not want consultations. He did not want to listen to anyone; he wanted everyone to listen to him. To his disciples at QAA, he was an angel sent from above, a god walking among mere academic mortals.

He thought that government should control – not support nor encourage – higher education. He wanted government inspectors to enter university classrooms, to check on teachers and students, to look at textbooks. He wanted all universities to document every department meeting and every class session, to follow standardized curricula, to adopt only one method of teaching – that sort of thing. In a country that prides itself on its academic freedom, this was, of course, anathema. Randall knew that nobody would agree with him, but using his position to full advantage, he was able to fool some of the people some of the time, but not most.

Being bright, most of the British were not fooled by Randall’s bull-headedness. The Association of University Teachers (AUT), the academic trade union and professional association of almost fifty thousand British teachers, launched a revolt against the dictatorship of Randall. The revolt was led by the heads of Oxford and Cambridge, the top universities not just in the UK, but probably even in the world.

The revolt spread not just like wildfire, but like fish and chips (or in these days, like Big Macs). Before anyone knew it, Parliament got into the act. On Jan. 17, 2001, Randall was summoned by the Select Committee on Education and Employment of the House of Commons. At the investigation, he was confronted by comments such as this: “You are part of the problem. University teachers are so worried about the time and expense and disruption caused by the QAA that they have hardly got time to provide quality education for their first year students.” He was warned about the QAA becoming “the great prescriptor.” (You can read the minutes of the entire interrogation at parliament.co.uk.)

The problem was really quite simple. Randall was no god, and his ideas were far from divine. In fact, he was dead wrong on many, if not most, issues. When the teachers demanded that they be consulted on his ideas before he did anything, Randall decided to resign. Consultation was the last thing he wanted. He did not want anyone questioning his ideas, for the simple reason that he had no answers to any questions, except to say that he felt he was right.

Upon his resignation on Aug. 21, 2001, he said to the press: “The Agency is moving to a new phase of its development, with consultation on the way in which the framework we have built will be used in external reviews and by institutions themselves. It is an appropriate time for me to consider the future direction of my career. There are challenges and opportunities that I would like to pursue outside the Agency.”

Randall, nevertheless, was unrepentant to the end. His last public comment was to compare universities to meat factories (Daily Telegraph, Aug. 22, 2001). Clearly, his desire to control universities was based on a deep disrespect and even disdain for teachers and students.

The AUT immediately released a statement: “John Randall’s resignation marks the end of an era of overly-bureaucratic and prescriptive regulation in higher education. The last five years have seen a hugely unsuccessful and morale-sapping experiment in higher education. The QAA failed to deliver a sensible balance between bureaucracy and accountability. The development of overly-bureaucratic regulation has antagonised those who work in the sector but has plainly failed to deliver a quality assurance regime that has the confidence of staff, students and the wider public.”

For intelligent teachers, students, and parents in the UK, Randall was dead. The false god had been unmasked and ridiculed out of office.

What opportunities did Randall pursue after his disastrous career in the UK? Lo and behold, Randall resurrected in the Philippines and became, in the eyes of our own Commission on Higher Education (CHED), the white god of education. CHED recently ordered all Philippine schools to follow the gospel according to Randall. Heaven help us!

The Randall Proposal (The Philippine Star, 6 October 2005)

This is a long-delayed sequel to “The Randall Scandal.”

On June 18, 2004, John Randall submitted to the Commission on Higher Education a proposal entitled “Quality Assurance of Higher Education in the Philippines.” Although CHED’s Commissioners have assured me that they are not going to implement the proposal in full but will remove impractical and inapplicable components, Randall’s final report to CHED (and to ADB and the British Council, which brought him to the country) remains the key document being used today to compel universities to toe his line.

As in any other government or consultant’s report, there are good and bad points in Randall’s proposal.

The best point in the proposal is Randall’s insistence on an “outcomes-based” assessment of universities. The jargon may be confusing, but Randall’s point may be illustrated by an example he does not use. When teachers apply for employment in a university, they are usually asked what their degrees are, how many years they have been teaching, and what research they have undertaken. In Randall’s terms, these data would be “inputs.”

“There is an assumption,” says Randall, “that, if adequate resources are present, quality will be guaranteed. This, of course, is not true, as much will depend on the effectiveness with which resources are deployed.” In our example, degrees, years of teaching experience, and publications may be irrelevant to teachers that face, let us say, a class of basketball players accepted primarily on the basis of their height.

Randall points out that universities are also evaluated in terms of their “processes (particularly the processes of teaching and learning).” In our example, teachers are usually judged by what their syllabi contain, what teaching strategies they use, how they fare in student evaluations, how they look to other teachers that observe their classes. Randall argues that evaluating inputs and processes is an immature act.

“Mature evaluation systems,” he writes, “are based upon outcomes, and in particular the learning outcomes that it is intended that students should achieve.” In our example, teachers applying for employment should be asked what percentage of their former students passed board examinations or found jobs. I myself often provoke literature teachers by telling them that they are bad teachers if their students do not, after high school or college, go on their own to a bookstore or library to read a new novel. As that often-misquoted Biblical verse puts it, by their fruits you shall know them. (Of course, during the Sermon on the Mount, Jesus was referring only to false prophets and not necessarily to everyone else; see Matthew 5:15-20.)

The problem occurs when Randall tries to apply the principle of outcomes-based assessment to the Philippine situation. Although he admits that “CHED, as the regulator of higher education, should be less prescriptive,” he actually ends up urging CHED to be more prescriptive. Randall submits, together with his general statements about the Philippine educational system, a very detailed “Operating Handbook” that is about as prescriptive as you can get. An example: “Formal meetings should always involve at least two members of the [visiting] team.”

In fact, it is not just the prescriptive portions, but the whole Randall proposal that is wrong, because it falls into the trap of self-contradiction. He starts off by saying, in effect, that Filipinos are doing the wrong thing when it comes to quality assessment. Then, when asked what we should be doing instead, he ends up saying that we should be doing exactly what we have been doing all along.

Since I belong to PAASCU, as well as to a CHED Technical Panel, I may be accused of bias when it comes to the Randall proposal. But I still have to find in his proposal anything that either PAASCU or CHED is not yet doing. In simpler terms, what Randall is saying is this: you are doing everything wrong, but everything you are doing is right.

In more intellectual terms, what Randall has done is to assume that he has a monopoly of wisdom. When asked what wisdom that is, he has done nothing else but to point to the wisdom that we already had decades before he arrived in the Philippines.

I am reminded of a similar argument I used to have with Americans not too long ago. They would tease me about always having a cellphone, saying that in the United States, since everybody had a landline at home and there was a pay phone everywhere you looked, Americans would never buy cellphones. Today, there are affluent homes in the United States without landlines and practically everybody there now has a cellphone. In short, we were (and still are) much more advanced than Americans when it comes to telecommunications. (If you don’t believe that we are more advanced than them, go to any cellphone shop in New York and see how primitive their units there are.) No American can teach us anything when it comes to cellphones.

Randall came into our country thinking that he knew better than we did about higher education. When he realized that we knew a lot more than he did, he had no choice but to recommend back to us everything that we had already been doing. In effect, he was a false prophet, and the fruit of his labor – his proposal – proves that that both the ADB and the British Council wasted their money on him.

Hello Again, Randall (The Philippine Star, 6 October 2005)

Once again, the Randall Scandal rears its ugly head.

First, a flashback. Since it was established in 1994, the Commission on Higher Education (CHED) has been quietly and effectively fulfilling its mandate to promote quality assurance among the 1,605 (as of latest count) higher education institutions (HEIs) in the country.

Soon after its establishment, CHED created regional Quality Assurance Teams (RQATs, called NQAT in NCR), which included volunteer experts in every discipline. These experts usually belonged to the CHED Technical Panels, which were the private sector’s contribution to the governance of higher education in the country. Among the projects of the Technical Panels was the selection of Centers of Excellence (COEs) and Centers of Development (CODs), which were then given funds by CHED to help develop teaching and research in the Philippines.

On Sept. 25, 2001, CHED granted autonomy to 30 private colleges and universities and deregulated status to 22 others. The criteria for selecting these HEIs were explicit: They were “established as Centers of Excellence or Centers of Development and or private higher education institutions with FAAP Level III Accredited programs; [they showed] outstanding overall performance of graduates in the licensure examinations under the Professional Regulation Commission; [and they had a] long tradition of integrity and untarnished reputation” (CMO 32, s. 2001).

The reference to accredited programs is important. The Philippines has a long tradition of accreditation, which is another name for quality assurance. Accreditation was first proposed by Congress in 1949, first implemented in 1951, and repeatedly endorsed in laws and memos relating to education (such as the Educational Development Decree of 1972, the Education Act of 1982, and CMO 1, s. 2005).

This commendable tradition of quality assurance or accreditation was radically disturbed when a certain John Randall came into the country and claimed that the Philippines had never heard of the term “quality assurance.” For some strange reason, CHED forgot that it had been using the term for years and agreed with Randall!

When I first wrote about what I called the Randall Scandal, I was asked by then CHED Chair Rolando de la Rosa, O.P., and then CHED Commissioner Cristina Padolina to meet with them. They told me that they were not taking Randall hook, line, and sinker, and that they would definitely take a second look at the so-called Quality Assurance Program that he had proposed. I wrote a second column giving fair time to the two commissioners.

Strange as it may seem, although I head the CHED Technical Panel on Humanities, Social Sciences, and Communication and am an ex-officio member of the CHED University Status team, I was not told that Randall had been resurrected in a memo entitled “Institutional Monitoring and Evaluation for Quality Assurance of All Higher Education Institutions in the Philippines,” shortened to IQuAME (CMO 15, s. 2005) and in a subsequent memo entitled “Evaluation of Higher Education Institutions Granted Autonomous and Deregulated Status in 2001” (CMO 18, s. 2005). Since I do not regard myself as someone that important in CHED, I kept quiet when I found out that autonomous and deregulated universities were beside themselves trying to figure out how to prove that they had quality when they had already been pronounced to have quality.

Last Aug. 3, 26 of the 30 autonomous and 17 of the 22 deregulated HEIs wrote a strong letter to the CHED Commissioners questioning CMO 18. Here are excerpts from the long letter:

“We join the many who have expressed reservations about IQuAME as given in CMO No. 15, s. 2005, and the consultancy work on quality assurance done for CHED by Dr. John Randall. We feel that Dr. Randall’s experience and background in the British educational system are very different from our Philippine educational system and situation. As everyone knows, eighty percent of tertiary education in our country is provided by the private sector without any government assistance. We join many who have questioned Dr. Randall’s basic contention that private voluntary accreditation in the Philippines today which is ‘program-based’ does not cover ‘institutional’ concerns and looks mainly on ‘inputs’ rather than ‘outcomes.’

“We feel that more time and consultation should have been spent validating Dr. Randall’s recommendations and the instrument to be used for IQuAME visits.

“We strongly feel that making use of a new and untested IQuAME instrument is not the best way to monitor and evaluate the HEIs granted special status.

“We feel that for the review of HEIs with these special status, CHED should use the same criteria [as in CMO 32, s. 2001].”

Guess what CHED did to respond to the letter? On Sept. 28, CHED called the heads of all the autonomous and deregulated HEIs to a meeting at Richville Hotel in Mandaluyong and, wonder of wonders, distributed to all the participants a “Primer on the Quality Assurance, Monitoring, and Evaluation of Higher Education Institutions,” with this explicit note at the end of it: “This primer is based on materials prepared by Dr. John Randall, Quality Assurance Consultant, CHED Organizational Development, Asian Development Bank (ADB) Philippines 2004.”

Why CHED is allowing itself to look silly when it already looked good is something only we Filipinos living in our self-destabilizing world can understand.

Quality Assurance and CHED (The Philippine Star, 3 November 2005)

What is the difference between quality assurance and accreditation?

Nothing, if we are to listen to the vast majority of accrediting associations around the world. Here are three examples:

The Council for Higher Education Accreditation of the United States, with more than sixty American national, regional, and specialized accrediting organizations as members, uses the two terms interchangeably.

The German Akkreditierungs-, Certifizierungs- und Qualitätssicherungs-Instituts (Accreditation, Certification and Quality Assurance Institute) does the same thing.

So does the Swiss L’Organe d’accréditation et d’assurance qualité des hautes écoles suisses (Center of Accreditation and Quality Assurance of the Swiss Universities).

Of course, a few countries make a distinction between the two.

The Australian Universities Quality Agency (AUQA), for example, looks at accreditation as something universities do themselves and to themselves; quality assurance is what an outside agency does.

By and large, however, universities and governments around the world treat the two terms as synonyms, whether what they are talking about is program accreditation (meaning that only certain programs, and not whole institutions, are accredited) or institutional accreditation (which means that a whole institution is accredited, even if its programs are not all on the same level of quality).

There are only two groups that still are in the dark about the two terms – students in Europe and our CHED commissioners.

The National Unions of Students in Europe (ESIB) bewailed in 2000 that “at the moment there is no common frame in which actors of higher education can discuss quality assurance and accreditation. There are quality assurance systems actually doing accreditation and the other way around. Furthermore the aims and methods of quality assurance and accreditation differ from country to country and there are obscurities in the terms being used.”

Behaving more like students than the professionals they are supposed to be, our CHED commissioners are equally confused.

In 1995, CHED recognized that Philippine accrediting associations were already doing quality assurance or accreditation, both institutional and program. It did this through CMO 31, s. 1995 (“Policies on Voluntary Accreditation in Aid of Quality and Excellence in Higher Education”), which used the terms accreditation and quality in the same breath. CHED at that time also recognized that voluntary accreditation included both programs and institutions. CHED used the term Institutions/Programs even for Level I or the starting level of accreditation.

CHED actually had no choice in 1995 but to recognize voluntary accreditation, which was first proposed by a Joint Congressional Committee in 1949. The first Philippine accrediting association was formed in 1951, and the first actual accreditations were conducted in 1957.

By the way, the initial delay was due to something very similar to what is happening to CHED today.

Francisco Dalupan and several other educators formed the Philippine Accrediting Association of Universities and Colleges (PAAUC) in 1951, preparing for voluntary accreditation done by private schools themselves, based on the objectives of each institution to be accredited. Then Education Secretary Manuel Carreon, however, following advice from a consultant named Pius Barth, wanted compulsory accreditation done by the government, based on so-called objective standards. It was only in 1957, when the Philippine Accrediting Association of Schools, Colleges, and Universities (PAASCU) started actual accreditation, that the impasse was broken. PAASCU’s efforts were officially recognized and endorsed by then Education Secretary Carlos P. Romulo in 1967. Since then, accreditation in the country has been private and voluntary.

Early this year, CHED issued CMO 1, s. 2005 (“Revised Policies and Guidelines on Voluntary Accreditation in Aid of Quality and Excellence in Higher Education”), which removed the word institutional from the different levels, but still recognized that quality assurance or accreditation itself was being done and should be done by the already existing accrediting associations.

CHED then famously imposed the so-called IQuAME, based on an expensive, but silly study by its consultant John Randall, in two infamous memos, “Institutional Monitoring and Evaluation for Quality Assurance of All Higher Education Institutions in the Philippines” (CMO 15, s. 2005) and “Evaluation of Higher Education Institutions Granted Autonomous and Deregulated Status in 2001” (CMO 18, s. 2005). Suddenly, despite having said that quality assurance, in the worldwide sense of program and institutional accreditation, existed in the Philippines, CHED said that there was a need for quality assurance!

How can the present CHED claim that schools should undergo quality assurance when many of them (though admittedly not all of them) have already been accredited and, especially in the case of autonomous and deregulated institutions, been recognized as having quality?

I have only two foreign words: ignorantia, as in “Ignorantia judicis est calamitas innocentis (The ignorance of a judge is the misfortune of the innocent), and hubris, as in Oedipus and Macbeth. I could say that what we now have in CHED is pure tragedy, but if you know your Aristotle, there are no tragic figures in that otherwise rational government agency, just comic ones.

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Anonymous said...

Dear Mr. Cruz,

Good day. We are currently preparing for our first IQuAME accreditors visit and are in a panic preparing all the documents that they may ask us to present. I came to realize and I hope that this initiative will do us more good than harm. Wish us luck please.

Thanks so much for this very comprehensive view on the IQuAME. I dont know but now I am less worried about facing the accreditors when they come to our school. Knowing about it's source/background.

More power and kind regards,
April

Anonymous said...

Good day, Mr. Cruz,

What you wrote on IQuAME is very enlightening. Our school, which is fairly new is taking measures to get ready for accreditation. Would you happen to know who specifically champions IQuAME from CHED? Thank you for your time.

prettynurz said...

Dear Mr. Cruz,

I am a student in the graduate school taking up nursing administration and IQUAME was given to me as an assignment to be reported. I was really enlightened by your insights on the issues about IQUAME. I believe that our educational standards are tested to have produced a number of professionals which are being used as I may say by other countries. I am also a professor in a university and I would say that in order to be accredited by ched, we sometimes have to sacrifice our clsses esp. when the accreditation day is very near. Is it justified when we do such things wherein the time of learning is being sacrificed just to complete all the paperworks that needs to be available for the accreditors. If Mr. Randall has been proven to have committed errors in his own country then why are we listening to his proposals. We dont really learn from our mistakes. I hope that CHED will be awakened by the flaws of IQUAME. God bless! Thanks sir.

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