No, accreditation is not the answer

The game is afoot in Punjab. The Punjab Higher Education Commission (PHEC) is the provincial cousin of the Higher Education Commission (HEC) in Islamabad. Established in 2014 by the Punjab Higher Education Act of 2014, it came about as a result of the devolution of authority to provinces under the 18th Amendment.

The PHEC makes fewer headlines than its federal counterpart, but its purview extends to regulating 90 of the country’s approximately 240+ universities in a province home to roughly half of its population. The relationship between the PHEC and HEC and their respective purview and authority is still a matter of conflict and confusion but that is a topic for a future piece.

The PHEC functions alongside the Higher Education Department (HED) that is part of the regular provincial bureaucratic machinery. The PHEC’s relationship with the HED is somewhat akin to the HEC’s relationship with the Ministry of Federal Education and Professional Training (MoFEPT) in Islamabad. The relationship between the HEC and MoFEPT has been in the news for the last two years and could be described as tense. The MoFEPT has made repeated attempts to rush through a series of amendments to the Higher Education Ordinance of 2002 that would bring the HEC under the direct control of the ministry.

Now, an attempt echoing the changing dynamics between the HEC and MoFEPT in the capital is underway in Punjab. On February 15, 2022 the HED sent letter No SO(Univ)PHEC-2/2021 to the PHEC. It informed the PHEC about the cabinet’s decision to introduce the Punjab Higher Education Commission (Amendment) Bill 2021 which had already been drafted.

The officially stated purpose of this amendment is to address a genuine, long-standing issue. Universities launch departments/ faculties and programmes that fail to receive accreditation before the first cohort of students graduates (for any of a number of reasons) but continue to enroll students and offer these programs anyway. In time, students graduate from those non-accredited programs often at a substantial cost and, especially in the private sector. In the local economy, graduates of non-accredited programmes remain ineligible for government jobs, scholarships and admission to graduate programmes at other universities.

For graduates who want to move to another country on a work or study visa, the first step in that process is having their degree(s) attested, first by the HEC, followed by a number of other offices (Ministry of Foreign Affairs, embassy of host country, etc.). If a programme is unaccredited, the HEC cannot and does not attest degrees, blocking them from working or further study abroad. The only option that remains for such graduates is to either find a job in the private sector with an employer that is not too particular about the degree or venture out on their own.

This is a real issue that continues to affect hundreds of students every year because non-accredited programmes are not made to close down, and students are not sufficiently informed to verify the accreditation status of programmes before enrolling. The question now is: how does the proposed amendment to the PHEC Act 2014 seek to address it?

Technically, it would introduce seven changes to the existing PHEC Act of 2014, amounting to two major changes:

First, it makes several amendments to section 12 of the PHEC Act. This section pertains to the structure and functioning of the PHEC’s Accreditation Committee which is at the core of the PHEC’s power. It makes recommendations to the commission to grant university charters, add new faculties, open sub-campuses, grant affiliation, monitor, inspect and visit private sector institutions. The new amendment changes the constitution of the Accreditation Committee by reducing commission representation from three to “at least one”, opening it to outside (HED) influence.

However, the most significant change comes as addition of new subsections which empower the Accreditation Committee(s) to “make recommendations to the Commission for regularization as a one-time dispensation to those institutions that started faculties, departments and disciplines without the approval of competent authority.”

Translation: This is an amnesty scheme for private universities to get their programmes accredited.

On paper, the amendment specifies that the new Accreditation Committee(s) can recommend regularization only after universities have met all necessary standards. If that was possible, there would be no need for an amnesty of this kind in the first place.

The second change will make the PHEC subordinate to the HED and mirrors what is happening between the HEC and MoFEPT at the federal level. This means the HED, a department of the government of Punjab (staffed by bureaucrats), will be inserted into more decision loops, delaying decision-making and slowing down operations even more. Even now, the HED (reportedly) usually takes many months to respond to issues.

It also gives the HED a stick by empowering it to conduct ‘performance audits’ of the PHEC. This can be a handy instrument if the PHEC refuses to play ball on the regularization / amnesty agenda. Transparency and accountability in government should, in principle, be welcomed. In that respect, the PHEC is already accountable to the chief minister, while leaving it autonomous of the wider bureaucracy.

No surprise then that the PHEC (Amendment) Bill 2021 described above has been written and is being driven by the HED without consulting the PHEC.

On the surface, this amnesty scheme for private universities is being justified as a rescue mission for graduates of non-accredited programmes. However, in my opinion this is a rescue mission for a different stakeholder – students are just the ones treading water, grabbing onto the edge of the lifeboat that is there for someone else and are hitching a ride to shore.

In the US, gambling permits are tightly controlled, much sought after and a regulatory requirement for casino establishments. It is a statistical fact that the odds are always (slightly) in favour of the house which is why, in the long run, the house always wins. In other words, a gambling permit is a licence to print money In many ways, the closest thing we have to such a permit is the combination of a university charter and program accreditations.

The former (grant of university charter) begins with a technical review with positive recommendations from the PHEC and HED. That is followed by a recommendation from the CM office and followed by passage of an act in the Punjab Assembly. One might say that the current Punjab Assembly has perfected the swift grant of university charters into an art form. Since 2019, it has largely dispensed with the role of the HED and the PHEC and resorted to passing bills and granting charters on its own. Historically, this last hurdle used to be notoriously difficult to clear and required political connections, a sympathetic ear and a sizable ‘donation’ to the right cause (rumors put the going size of such donations in the Rs18-20 crore range).

The latter (programme accreditation) requires adherence to objective, technical benchmarks (eg: adherence to curriculum requirements, campus infrastructure capacity, full-time faculty, etc) and is in the purview of professional bodies (PEC, PDC / PMDC, etc) or the HEC / PHEC.

After shunting the PHEC and HED’s role in the charter granting process, some parliamentarians in Punjab now seem bent on overriding PHEC objections to programme accreditations.

As if this is not bad enough, in addition to the PHEC (Amendment) bill 2021 being pushed through by the HED, there is a private member bill, called the PHEC (Amendment) Bill 2022. This second bill seeks to restrict the PHEC’s authority to only “new” universities from here on out, thus giving all existing universities a pass.

Both, the PHEC amendment Bill 2021 (pushed by the HED) and 2022 (pushed by MPAs) to the original PHEC act might help graduates from non-accredited programmes by recognizing their qualifications in Punjab (I am qualifying this statement with “in Punjab” because the HEC Islamabad is under no compulsion to recognize and attest degrees of such programmes). It will not improve the skills they obtained from non-accredited programmes and magically make them employable. In reality, these amendments are the answer to prayers of proprietors of private universities that are unable or unwilling to do the work needed to have their programmes accredited.

Whither higher education in Punjab?

The writer (she/her) has a PhD in Education.