Quality assurance agencies should place the interests of students in tertiary institutions and those that are still coming front and centre of what they do. In this second and last installment of a two-part series, TITUS MBUYA* argues that so long as there are no consequences for failure to comply with the standards set by regulatory agencies, unscrupulous education and training providers will continue to cheat the system at the expense of the future of students while they laugh all the way to the bank.
The challenge for Botswana over the last 17 or so years has been how to reconcile the rapid increase in the number of students accessing tertiary education with good quality education which is globally competitive and nationally relevant. This is something that higher education authorities elsewhere in the world are also grappling with because the general trend in many countries has been that when there is a rapid growth in the number of students in higher education the quality of higher education drops substantially.
With the rapid increase in the number of eligible students graduating from secondary school, the demand for institutions of higher learning increased, and hence, private tertiary institutions proliferated. Again, this was a continental phenomenon not only unique to Botswana. In some countries, like Kenya, it happened much earlier than here. By the 1980s seven new universities in Kenya were added to the already existing three, which had been there since independence in the 1960s. Since there were no robust mechanisms in place to regulate higher education institutions the quality of education in many countries suffered. So, the growing diversity of private institutions, in particular, raised the issue of standards.
With respect to Botswana there is a policy framework in place, albeit evolving. It provides for a quality assurance and regulatory regime that governs higher education. The old Tertiary Education Act of 1999 covered issues of accreditation, quality assurance and accountability following the need to regulate, and coordinate higher education as a result of growth and expansion of the tertiary education sector in Botswana.
The Tertiary Education Policy was also passed by Parliament in 2008. And in 2013 two acts establishing Botswana Quality Authority (BQA), and the Human Resource Development Council (HRDC), were passed by Parliament, to ensure an orderly development of the higher education sector and how it feeds into the human resource requirements of the country.
Under the subheading “Strategic Change Agenda”, the Tertiary Education Policy states that there will be an “increased focus on quality, accountability and performance development of formal quality assurance systems and increased oversight, monitoring and evaluation of performance of tertiary education institutions to ensure both improvement and accountability”. That is the process that was started by the former Tertiary Education Council (TEC) until it morphed into HRDC in 2013.
According to its mission statement, “BQA ensures all learners to acquire quality assured awards through implementation of a national quality assurance system”. The BQA Act states that the objectives of the Authority “shall be to provide for and maintain national credit and qualifications framework and coordinate the education, training and skills development quality assurance systems”.
The Authority would also set teaching and learning standards for education and training providers; develop and review quality standards, and ensure compliance through monitoring and evaluation systems. BQA is the de facto regulator of tertiary institutions as it is also there to “set criteria for the development of national education and training quality and inspection standards.”
The HRDC’s function in relation to higher education is with regard to promoting the “establishment, coordination and approval of institutional plans for public and private tertiary education institutions, and post implementation monitoring and evaluation with respect to human resource development, research innovation, and institutional capacity building”.
According to the HRDC Act, the Council’s objectives are to promote human resource development in line with national economic and social objectives; stimulate a culture of training and lifelong learning at the individual, organisational and national levels for employability and increasing productivity; and, provide the necessary human resource thrust for successful transformation of the economy of the country into a knowledge economy.
There is no doubt that in terms of the blueprint of the regulatory framework the provisions of the BQA Act and its National Credit and Qualifications Framework (NCAF) substantially conform to best international practice. The NCAF sets quality standards (threshold standards) in the provision of education and training in Botswana, as well as moderation across fields of learning and levels of qualification. The Act also empowers the Authority to set criteria for the development of national education and training quality and inspection standards.
Responding to University of Botswana’s Professor Thapelo Otlogetswe’s recent intervention on the subject regarding regulation and quality assurance, the chief executive officer of BQA, Abel Modungwa, stated that among the criteria that are looked into when considering an institution’s application for accreditation were, facilities, course content, strategy direction and plans, entry requirements, assessment criteria, student support services and teacher qualifications. He explained that the approval process ensures that necessary checks and balances are in place.
Perhaps the biggest flaw of the domestic regulatory regime is its failure to place the student at the front and centre of their strategies to ensure that tertiary institutions comply to the “threshold standards” that they have set. Because the main trigger for the establishment of quality assurance agencies in Botswana may have been the emergence of the private tertiary institutions, their main focus has been regulation of the development of the sector rather than to enhance accountability and quality improvement for the benefit of the student.
To his credit, in his response to Otlogetswe, the BQA boss, Modungwa, had said, “A key function of the Authority is learner protection. BQA has developed a Learner Protection Policy that would be cascaded to Education and Training Providers (ETPs) once the BQA Regulations are implemented. BQA works closely with Student Representative Councils and is designing a structured approach to this partnership. This will ensure that learners’ rights are upheld and protected. These envisaged measures are meant to enhance existing quality assurance mechanisms”.
Unfortunately, up to now that has not happened. Quality assurance agencies should understand that the student is their customer and not the institutions. It is not enough for the BQA Act to state as one of the agencies responsibilities, the fact that it “designs procedures and rules for the protection of enrolled learners”. The role of quality assurance agencies should be to safeguard the interests of all students including “future” students studying within Botswana’s higher education system. The agencies’ principal concern should be to ensure that every student studying at an institution registered locally receives quality higher education and thus, the standing of the sector is upheld.
It is also the responsibility of the quality assurance agencies to ensure that students at a tertiary institution have access to learning resources. In its definition of quality assurance, the BQA states that it encompasses “the systematic review of institutional capacity, infrastructure and human resources to ensure that agreed and acceptable level of quality exists in the education provided by Education and Training Providers”.
By that one assumes that the BQA would ensure that ETPs provide a wholesome learning environment for students. And this includes, among others, electronic or physical library and information resources that students need to achieve the outcome of their studies.
The agencies should also ensure that ETPs give students support services in the form of orientation courses, tutorials etc. And they should ensure that students enjoy a safe and secure learning environment in the form of facilities, e.g. laboratories, workshops, and other infrastructure anywhere a provider delivers education. This must happen before giving the ETP accreditation.
Fact of the matter is that by accrediting an ETP it is being legitimised and qualifies them to enroll students sponsored by government. Some of these schools, as soon as they get accredited, it becomes business as usual. They take advantage of the loopholes in the system and continue to siphon money from government for sub-standard tuition.
BQA rightly views the ETP’s as the main custodians of quality within their institutions. In their website they state: “Much as it is the responsibility of the BQA to safeguard the public interest in sound standards of education qualifications, ETPs have the primary responsibility for the quality of their programmes and their assurance”.
Indeed, a quality assurance agency like BQA should place strong emphasis on promoting and facilitating a culture of effective self-assurance by providers. It usually takes time for a provider to be able to assure quality to an acceptable level when they would have reached a certain level of stability and resilience to market pressures and changes of personnel. Most private institutions do not have any track record in terms of producing high quality student outcomes. They are not engaged in academic networks, nationally or internationally through which they could peer-review and benchmark their courses, assessment methods and review student outcomes.
It is no wonder that lack of compliance is so prevalent among tertiary institutions in Botswana. Most of them do not have corporate as well as academic governance and controls to manage risk to quality. In his response to Otlogetswe, the BQA chief said, “The levels of compliance within accredited institutions has improved. There are a few isolated cases where some ETPs employ trainers who are not accredited and this is attributed to the high mobility if trainers in the system. These cases are appropriately dealt with as and when they arise. BQA will continue to closely monitor and audit ETPs to ensure compliance”.
Regulatory agencies play a double role regarding enforcement of quality assurance in ETPs, namely guiding and helping the providers, but also imposing sanction or punitive action upon transgressors. For instance, the Act states that the Authority shall revoke accreditation and learning programmes for non-complying ETPs. The BQA Regulations, which form part of the Act, state that in the event that the agency takes such action the offenders shall be named and shamed in the press.
I have, personally, not seen any such notices in the press regarding non-complying ETPs in Botswana. This is done all the time in other jurisdictions. For instance, the Commission for University Education (CUE) (equivalent of BQA) in Kenya, occasionally closes both public and private university campuses and colleges for lack of compliance. In 2016 the CUE closed 34 percent of the institutions that it audited that year. The institutions were disqualified for reasons ranging from locating campuses in environments not compatible with learning such as near bars, casinos, markets etc, to irregular student admissions. The CUE is a government agency mandated to regulate university
This brings me to the next weakness in the regulatory framework for higher education in Botswana. In the past the Vice Chancellor of the University of Botswana, Professor Thabo Fako alluded to the need to preserve the “sanctity” of the university as an institution of higher learning. He was reported to have said, ”To me a university is a prestigious institution, and the name ‘university’ should be protected. What we are doing is giving children the hope that they are something which they are not”. Although the Professor may have sounded condescending, to the extent that the appellation “university” should be held to a certain standard of academic excellence, which includes research and innovation, he was on-point.
Regarding the example of Kenya, cited above, the CUE was established in 2012 to replace the former Kenya Commission for Higher Education (KCHE), which was similar to the TEC. The KCHE was established in 1985 in response to a need to regulate, coordinate and assure the quality of the growing university sub-sector in the 1980s in that country.
The mandate of CUE is very clear. Kenya’s Universities Act states that the Commission is there to “promote, set standards and assure relevance in the quality of university education”. The CUE advises government on university education policy, undertakes accreditation inspections, monitors and evaluates the state of university education and ensures compliance with set standards.
The Commission works closely with the Directorate of Higher Education, which is within the Ministry of Higher Education, Science and Technology. The Directorate coordinates policy formulation and implementation of university education and also oversees matters of university education for both public and private universities.
The point that one is making here is that, in the case of Kenya there is a clear delineation with regard to the governance structure for higher education that is guiding the development of university education as well as the maintenance of standard, quality and relevance in all aspects of university education, training and research. Of course it does not make it a perfect system as Kenya continues to grapple with problems regarding bogus universities and non-compliance by registered institutions. The only reason I am using Kenya as an example is because, according to the latest Global Competitiveness Report, among emerging and developing countries, Kenya, Rwanda, China, Brazil and Colombia are examples of countries with education systems that will experience an improvement in the future skill-set of their workforce.
Granted, the population of Botswana is relatively small compared to many countries, and there is no need for the establishment of a cumbersome governance structure for higher education. However, there is still need to streamline the governance structures of our higher education system to avoid a duplication and conflation of roles. In that regard, it made sense to collapse Botswana Training Authority (BOTA) and TEC in 2013 into the HRDC to oversee the relevance of programmes offered by tertiary institutions, and to establish BQA to ensure adherence to set quality standards.
From the point of view of regulation there has to be a separation between university, on the one hand, and vocational and technical training, on the other. The repealed Tertiary Education Act of 1999 lumped all the higher education (tertiary) sub-sectors together and gave TEC wide-ranging powers to regulate them. Colleges offering programmes for certificate to diploma qualification should not be lumped with universities because the academic programmes of the two sets of institutions cannot be similar. Although the decision to collapse TEC and BOTA into HRDC, was meant to rationalise the governance structure of higher education and make it more effective the problem of “conflation” has not been resolved.
The absence of a “university act” of Parliament is problematic in this regard. It is not enough just to have the acts regarding University of Botswana, Botswana International University of Science and Technology (BIUST), and Botswana University of Agriculture and Natural Resources (BUAN), which are public institutions. It would assist to have a “university act” with clearly spelt out provisions and regulations as well as policy, which set out the parameters regarding the development of university education; the establishment, accreditation and governance of universities in Botswana as a sub sector of higher education. Such a law would go a long way in standardisation in terms of public and private universities alike. For instance, there would be expectation for them to have uniform management structures including university council, the senate, and vice and deputy vice chancellors.
The mandate of BQA, which is now the regulator, straddles early childhood to primary, through secondary to tertiary. This may create lack of focus and results in all these sectors of education suffering. Higher education in particular, has been neglected because until the creation of the Ministry of Tertiary Education, Research, Science and Technology, there was virtually no department of higher education in the former Ministry of Education and Skills Development (MOESD), which played a coordinating role regarding the development of university education. If it was there, it was dysfunctional. Primary, secondary and vocational training did have such departments in the ministry and they were relatively well resourced and functional.
The other omission that is glaring in our regulatory regime is to “exempt” public institutions from regulation and external quality assurance. As stated above when the quality assurance agencies were first established locally in the 1990s, it was in response to the need to regulate, coordinate and assure quality in higher education. The main goal of establishing BOTA and TEC was for them to variously coordinate the two elements of the tertiary sub-sector – tertiary education and vocational and technical programmes, to provide policy advice to government and plan for sub-sector development and provide for quality assurance and accreditation processes.
This process was triggered off by the emergence and proliferation of tertiary private institutions. There was concern that with the rapid growth standards and quality would be compromised. As a result the focus of local quality assurance agencies has been concentrated on private education and training providers. Government-owned (or public schools) have been left to their own devices. This has actually earned these agencies the ire of private institutions who accuse them of applying double standards in their application of the Act.
To assume that public institutions do not have to undergo accreditation processes and that they would take responsibility for their own quality control may have contributed to the decline in standards at these institutions. Public ETPs should equally be subject to the accreditation and quality assurance procedures of the BQA. This would ensure fairness and possibly enhance quality assurance in all schools, both public and private.
This act of omission may have contributed to the low standards experienced in public schools as evident from their graduates who are half-baked, to say the least. Some of these institutions do not even have an arrangement for “external examiners” which in the absence of an external quality assurance mechanism could assist in improving standards because the institution subjects itself to regular outside “peer review”.
It is therefore, encouraging to learn from Modungwa’s statement in response to Otlogetswe that, “To further improve quality of education and training, BQA will register and accredit all ETPs across the entire education and training sector, both public and private, to ensure a common quality assurance system that promotes clear articulation and progression across levels. This will be an improvement on the old system that required all (public and private) Technical and Vocational Education and Training Providers (TVETP) to register and accredit with the then Botswana Training Authority (BOTA) whereas the Tertiary Education Act required public tertiary institutions to register, but exempted them from accreditation, while private providers were required to register and accredit”.
Quality improvement for higher education globally is a continuous process of adjustments, reflections and reform and one can never say they have absolutely realised it. However, our quality assurance agencies can do better to enforce standards and accountability in tertiary institutions. Some of the transgressions are not only glaring but appalling. For instance, how does one explain accreditation of a college of technology without workshops and laboratories for practicals? How does a student become an engineer without mathematics? How does someone with a diploma teach a student studying towards attaining a diploma? This could only be the machinations of unscrupulous businessmen taking advantage of loopholes in gate-keeping and quality assurance to maximise income. And they are able to do this because there are no consequences.
This blatant disregard of the “threshold standards” by ETPs is detrimental to the country not only in terms of money that government pays to these institutions, but to the future of the students themselves and most importantly, the country’s competitiveness. According to the 2015 Global Competitiveness Index (GCI), in general, (higher) education - as a critical component of a country’s human capital - increases the efficiency of each individual worker and helps economies to move up the value chain beyond manual tasks or simple production processes. Human capital is considered the “most distinctive feature of the economic system,” and further work has proven the impact of (higher) education on productivity growth empirically.
The GCI identifies three channels through which education affects a country’s productivity. First, it increases the collective ability of the workforce to carry out existing tasks more quickly. Second, tertiary education, in particular, facilitates the transfer of knowledge about new information, products, and technologies created by others. Finally, by increasing creativity higher education boosts a country’s own capacity to create new knowledge, products, and technologies.
So long as our higher education system is not aligned to such outcomes Botswana will always be somewhere at the end of the bottom half of the annual global competitiveness table. Yes, there will always be isolated cases of individual brilliance and excellence as it has always been the case, with one or two of our compatriots doing very well internationally, but as a country, zilch!
*Titus Mbuya is a former teacher and founding member of the Botswana Federation of Secondary School Teachers (BOFESETE), which now goes by the name Botswana Sectors of Educators Trade Union (BOSETU).