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A VALUE FOR MONEY AUDIT REPORT ON THE REGULATION OF UNIVERSITIES BY THE NATIONAL COUNCIL OF HIGHER EDUCATION (NCHE)

A REPORT BY THE AUDITOR GENERAL

DECEMBER, 2018 THE REPUBLIC OF UGANDA

A Value For Money Audit Report on the Regulation of Universities by the National Council of Higher Education (NCHE)

A Report by the Auditor General

December, 2018 AUDITOR GENERAL’S MESSAGE

24th December 2018

The Rt. Hon. Speaker of Parliament Parliament of Uganda .

VALUE FOR MONEY AUDIT REPORT ON THE REGULATION OF UNIVERSITIES BY THE NATIONAL COUNCIL OF HIGHER EDUCATION (NCHE)

In accordance with Article 163(3) of the Constitution, I hereby submit my report on the audit undertaken on the Regulation of Universities by the National Council of Higher Education (NCHE).

My office intends to carry out a follow-up at an appropriate time regarding actions taken in relation to the recommendations in this report.

I would like to thank my staff who undertook this audit and the staff of the National Council of Higher Education (NCHE) for the assistance offered to my staff during the period of the audit.

John F.S. Muwanga AUDITOR GENERAL

TABLE OF CONTENTS

LIST OF TABLES...... II LIST OF FIGURES...... II ABBREVIATIONS...... III

EXECUTIVE SUMMARY...... IV

CHAPTER ONE...... 1 INTRODUCTION...... 2 1.1 Motivation...... 2 1.2 Description of the Audit Area...... 2 1.3 Audit Objectives...... 4 1.4 Audit Objectives...... 4 1.5 Audit Scope...... 4

CHAPTER TWO...... 5 AUDIT METHODOLOGY...... 6 2.1 Sampling...... 6 2.2 Data Collection...... 6 2.3 Data Analysis...... 6

CHAPTER THREE...... 7 SYSTEMS AND PROCESS DESCRIPTION...... 8 3.1 Roles and Responsibilities of Key Players...... 8 3.2 Process Description...... 9

CHAPTER FOUR...... 12 FINDINGS, CONCLUSIONS AND RECOMMENDATIONS...... 13 4.1 Monitoring and institutional audits...... 14 4.2 Human Capital Assessment...... 22 4.3 Minimum standards for courses of study...... 23

APPENDICES...... 26 Appendix I: Organizational Structure...... 26 Appendix II: Data collection methodology...... 27 Appendix III: Documents reviewed...... 28 Appendix IV: Interviews held...... 28 Appendix V: Quality Assurance Framework Indicators...... 29 Appendix VI: University adherence to capacity indicators...... 32

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General I LIST OF TABLES

Table 1: Funding...... 4 Table 2: Programmes assessed...... 13 Table 3: Licenses and authorisations granted...... 14 Table 4: Universities with monitoring reports...... 15 Table 5: Planned, budgeted and actual allocations...... 15 Table 6: Allocation of students’ fees collections to monitoring activities...... 16 Table 7: Quality assurance and accreditation department staffing levels...... 17 Table 8: Status of University programme accreditation...... 18 Table 9: University with un-reviewed charters...... 18 Table 10: Universities with more than 3 years of holding provisional licenses...... 19 Table 11: Analysis of budget and actual expenditure for minimum standards...... 24

LIST OF FIGURES

Figure 1: Comparison of applications and assessments of programmes...... 13 Figure 2: Analysis of planned and actual unit cost monitoring activities...... 16

II The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General ABBREVIATIONS

DQAA Department of Quality Assurance and Accreditation ED Executive Director GoU Government of Uganda HEO Higher Education Officer NCHE National Council of Higher Education NDP National Development Plan NPA National Planning Authority NTR Non Tax Revenue SDG Sustainable Development Goal UBOS Uganda Bureau of statistics UGX Uganda Shillings UOTIA Universities and Other Tertiary Institutions Act

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General III EXECUTIVE SUMMARY

The National Council of Higher Education (NCHE) was established as the regulator of higher education to implement the Universities and Other Tertiary Institutions Act of Parliament (UOTIA, 2001 as amended). By the provisions of the Act, NCHE is mandated to guide the establishment of institutions of higher learning as well as ensure delivery of quality and relevant education to all qualified persons.

NCHE has strived to achieve its mandate to ensure that sustainable quality higher education is provided at all Higher Educational Institutions in Uganda. However, there are chronic problems of staffing and inadequate research in universities1 that impede the achievement of quality education. This is coupled with the increase in number of universities. To date, the country has 9 public and 43 private universities.

The overall objective of the study was to assess the extent to which NCHE has ensured that universities comply with the operational and quality standards necessary for the delivery of quality higher .

KEY AUDIT FINDINGS During the three year period ending 30th June 2018, NCHE received 4,237 applications, of which 3,523, representing 83.1% were assessed for accreditation. It also granted 13 provisional licenses, 10 letters of interim authority to private universities and granted permission to universities to establish 9 branches and campuses. Despite these achievements, the following inadequacies were noted.

a) Monitoring and institutional audits NCHE inadequately conducted monitoring and institutional audits during the period despite UGX 331,954,999 being provided. In the period 2015/16 to 2017/18 NCHE planned to undertake 60 monitoring visits of universities. Although reported that they had conducted 30 monitoring visits, audit could only confirm eleven (11) monitoring visits, of which, three (3) were discussed by Council in the period. In addition, NCHE neither organised peer institutional audits nor undertook external institutional audits. This was due to inadequate allocation and utilisation of activity funds and low staffing to conduct the activity. This has led to universities continuing to run unaccredited/unrevised programmes, unreviewed charters and provisional licences, admitting students without equating their foreign study qualification, and universities providing poor physical facilities. This affects the quality of higher education in the country.

b) Conducting of tracer studies by NCHE and universities NCHE conducted two tracer studies in 2011 and 2015 for cohorts of 2001 and 2011 respectively, contrary to the good practice of having studies conducted for cohorts of within 2-3 years. Moreover the studies were limited to an average of 6 universities and 16 programmes and 2000 graduates. Instead of at least 26 universities, 1000 programmes and 20,000 graduates. The expected 2018 tracer study was not conducted despite UGX 90 million being budgeted in the period. The universities were also noted not to have conducted tracer studies. This was attributed to the universities not being compelled to undertake the studies. There is no information system in place to enable NCHE to track all graduates in the country. This contributes to the continuous mismatch between the needed graduate programmes and content with the labour market requirements.

1 NCHE 2018 annual performance report

IV The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General c) Minimum standards of courses of study I also noted that NCHE had established minimum standards for only 43 (2%) of the 2,104 courses of study. By April 2016, 38 of the 43 courses had since expired and were neither reviewed nor published. This led to programmes being accredited without a check to up to date standards which may compromise the quality of programmes taught. As a result, NCHE has accredited 2,100 programmes without checking them against up to date minimum standards for courses of study.

KEY AUDIT RECOMMENDATIONS The NCHE management should; a) Plan adequately, prioritize and allocate its resources, including the mandatory students’ fees collections, to conduct its statutory obligations of monitoring and institutional audits, Tracer studies and minimum standards of courses of study, b) Enforce compliance by ensuring that all Universities offering un-accredited and/or courses whose accreditations are unrevised submit them for review leading to accreditation and/or re- accreditation or else have their licenses revoked, c) Enforce the conducting of tracer studies by the universities and consider developing guidelines and simpler templates for use by universities when undertaking tracer studies, and d) Government should build and empower the capacity of NCHE to undertake its mandate adequately, through a renewed policy with punitive measures for non-compliance.

OVERALL AUDIT CONCLUSION Whereas the National Council of Higher Education has undertaken specific interventions aimed at increasing the quality of higher education in universities, inadequate monitoring and conducting of institutional audits and tracer studies and non-establishment of minimum standards of courses of study have resulted in universities mounting unaccredited and outdated programmes, operating below the required quality assurance and capacity indicators, which has an effect on the quality of higher education.

It is hoped that with the appropriate stakeholder engagement and policy review, the inadequacies in the higher education sector will be reduced to enable the country to benefit from improved quality of higher education, increase in employment prospects and more competent service delivery.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General V 01

CHAPTER ONE The Regulation of Universities by the National Council of Higher Education (NCHE) | (NCHE) | by the National Council of Higher Education The Regulation of Universities General A Report by the Auditor CHAPTER ONE

INTRODUCTION

1.1 BACKGROUND Higher education plays a key role in the development of any nation. For Uganda, it is a pillar in the attainment of Sustainable Development Goal (SDG) No 4 - ensuring, inclusive, equitable, and quality education for all by 2040. The National Development Plan (NDP) II prioritised human capital development and gave prominence to the role of higher education towards attainment of the middle-income status.

The liberalisation of higher education in Uganda opened the education space, allowing both public and private sector players to participate, and hence an increase in the number of higher education institutions. To date, the country has 9 public and 43 private universities registered and regulated by National Council of Higher Education (NCHE), with over 270,070 students enrolled in the higher institutions of learning by 20152.

1.2 MOTIVATION To date, universities have continued to train and produce graduates every year in some fields that are neither relevant on the labour market nor in high demand, which has worsened graduate unemployment3.

The NDP II notes that Uganda’s labour market continues to face a shortage of requisite skills, with only few people being in possession of some form of higher education qualification. There is a mismatch between the curriculum at the higher education institutions and the labour market requirements, which explains the high graduate unemployment rates on Uganda’s labour market4.

In addition, the National Planning Authority (NPA) noted that the physical facilities in many universities were not commensurate to the increasing enrolment numbers in the higher education institutions. This therefore calls for proper regulation of Universities by National Council of Higher Education (NCHE).

The Auditor General’s report of 2017, also highlighted inadequate implementation of NCHE activities like audit inspections, existence of unaccredited programmes being offered in the public universities and some universities operating without valid licenses.

It is against this background that the Office of the Auditor General undertook an independent review of the extent of regulation of higher education by NCHE.

1.3 DESCRIPTION OF THE AUDIT AREA 1.3.1 General description The NCHE is a semi-autonomous and self-accounting body with a Secretariat headed by the Executive Director (ED). The day-to-day management of the Council affairs is vested in the Secretariat, headed by an ED appointed by the Minister of Education. The ED, who reports to the Council, is also the Accounting Officer and Secretary to Council.

2 UBOS statistics on higher education census 3 “The places of universities in National Human Resource Planning for Vision 2040”, paper by NPA, October 2017. 4 NDP II

2 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General The audit focussed on the activities of the the Department of Quality Assurance and Accreditation (DQAA) which is responsible for regulating the operations of the private and public universities in Uganda. These activities included; setting of minimum standards of course of study, monitoring and inspections of higher education institutions and institutional audits.

1.3.2 Legal Framework The Universities and Other Tertiary Institutions Act (UOTIA), 2001 (as amended), established the NCHE as a statutory agency to regulate higher education, guide the establishment of institutions of higher learning and to ensure quality and relevant higher education5. Section 7 of the Act, provides for the establishment of the NCHE Council, as the supreme governing body. The Council has 20 members, headed by a Chairperson, deputised by a Vice Chairperson and then other stakeholders who represent various interest groups. The day-to-day management of the Council affairs is vested in the Secretariat, headed by an Executive Director (ED) appointed by the Minister of Education. He is also the Accounting Officer and Secretary to Council.

1.3.3 Vision and Mission Vision: The NCHE vision is; “A Uganda with Accessible, equitable, relevant, and sustainable quality higher education”.

Mission: Its Mission is; “To ensure provision of relevant and sustainable quality higher education for development and transformation of society”.

1.3.4 NCHE Objective The overall objective of NCHE6 is to ensure improved standards of higher education institutions that are able to provide relevant quality world-class education to all qualifying Ugandans.

Specific Objectives NCHE’s specific objectives include:- a) Ensuring adherence to minimum operational and quality standards for provision of higher education in the country; b) To gather and avail evidence-based data and information to inform effective planning and delivery of quality higher education in Uganda; and c) To regulate delivery of quality higher education in Uganda in a sustainable manner.

1.3.5 NCHE Activities The activities7 undertaken by NCHE include:- a) Conducting human capital assessment of the country; b) Setting minimum standards for courses of study; c) Accrediting higher institutions and programmes of study; and d) Monitoring, evaluating, inspecting, and auditing of institutions of Higher Education.

5 NCHE strategic plan 2012-2017. 6 NCHE strategic plan -16/17 7 Section 5 of the UOTIA Act

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 3 1.3.6 Organisational Structure The ED heads the Secretariat, which undertakes the day-to-day operations of NCHE. The Deputy ED assists the ED. In the execution of the policies of the NCHE, the Heads of Departments, who constitute the management team, assist the ED. NCHE has five Directors responsible for Legal; Research, Documentation and Development; Finance; Management Support Services; and Quality Assurance and Accreditation. For details, Appendix 1 refers.

1.3.7 NCHE Funding The NCHE is financed by Government of Uganda (GoU) and the development partners. NCHE also collects Non Tax Revenue (NTR) through students’ fees contributions and application fees for licensing and accreditation. The funding for NCHE over a three-year period is shown below:

Table 1: Funding Source 2015/16 2016/2017 2017/2018 Budgeted Actual Budgeted Actual Budgeted Actual (UGX bn) (UGX bn) (UGX bn) (UGX bn) (UGX bn) (UGX bn) GoU 2.00 1.93 2.00 1.72 2.00 1.66 NTR 7.30 3.82 6.81 4.10 5.85 5.13 Donor 0.90 0.06 1.00 0.07 0.50 0.46 Total 10.2 5.81 9.81 5.89 8.35 7.25

Source: NCHE Annual approved budgets and audited financial statements for 2015/16 – 2017/2018

1.4 AUDIT OBJECTIVES The overall objective of the audit was to assess the extent to which NCHE has ensured that universities comply with the operational and quality standards necessary for the delivery of quality higher education in Uganda.

The specific audit objectives were to:- a) Ascertain the extent to which NCHE conducts monitoring and institutional audits of selected universities; b) Establish whether NCHE has conducted human capital assessments of the country; c) Evaluate the extent to which NCHE has established minimum standards for courses of study in Uganda.

1.5 AUDIT SCOPE The study was undertaken at NCHE Headquarters at the Department of Quality Assurance and Accreditation, focusing on the extent to which universities adhered to the quality assurance and capacity indicators. The study also evaluated the extent to which NCHE undertook monitoring, carried out institutional audits, established minimum standards of courses of study and carried out human capacity assessment. In addition, the study involved visiting main campuses of the selected private and public universities. The audit covered three financial years from 2015/16 to 2017/18.

4 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 02

CHAPTER TWO The Regulation of Universities by the National Council of Higher Education (NCHE) | (NCHE) | by the National Council of Higher Education The Regulation of Universities General A Report by the Auditor CHAPTER TWO

AUDIT METHODOLOGY

The audit was conducted in accordance with the a) Document Review International Organization of Supreme Audit The team reviewed monitoring reports and annual Institutions Auditing Standards and guidelines in performance reports by NCHE, the quality assurance the Office of the Auditor General’s Value for Money framework, the UOTIA, and university documentation manual. The standards require that the audit be relating to governance, infrastructure, publication, planned in a manner that ensures that an audit of research, student enrolment, staffing gaps, among high quality is carried out in an economic, efficient others. The documentation was to provide criteria for and effective way. the compliance with the required capacity indicators, in addition to answering the audit questions. 2.1 SAMPLING Appendix 3 sets out the details. The audit team accessed and reviewed documents for all 52 universities to assess their accreditation b) Interviews status. For inspection, all the public universities The team conducted interview with NCHE top were considered for the sampling. Out of the 9 management, the staff of the Quality Assurance public universities in Uganda, two universities, and Accreditation Department, and selected quality namely and were eliminated from assurance officers in universities, directors and, in the sample because the former had previously been some instances, the university Vice Chancellors, assessed on compliance while the latter was yet to Appendix 4 refers. In addition, the team administered open to the public. an assessment questionnaire to capture data on compliance by universities to the capacity indicator 5 public universities were then randomly sampled benchmarks. Appendix 5 sets out the details. to be inspected from the remaining 7, these being , , c) Inspection University of and , The team visited the fourteen selected universities, and University. where physical infrastructure was inspected, to ascertain the extent to which they complied with the In addition, out of the 43 private universities in capacity indicator benchmarks set by NCHE. Uganda, 9 private universities were randomly selected for inspection. These included ISBAT 2.3 DATA ANALYSIS University, University, International The data collected from the universities was analysed University of East Africa, Stafford University, Clarke using a statistical package for Social International University, , St. (SPSS) software to provide descriptive statistics Lawrence University, , and Team of the findings, to the extent of establishing which University. In total therefore, 14 universities were universities had complied with the ideal capacity identified for inspection. indicator levels. Audit used Excel Microsoft to analyse the data collected from document review. 2.2 DATA COLLECTION The audit team collected data using the methods Furthermore, audit compared the programmes below, for which details are contained in Appendix offered by universities with the NCHE 2017/18 2:- database for accredited university programmes to ascertain the universities running un-accredited programmes.

6 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 03

CHAPTER THREE The Regulation of Universities by the National Council of Higher Education (NCHE) | (NCHE) | by the National Council of Higher Education The Regulation of Universities General A Report by the Auditor CHAPTER THREE

SYSTEMS AND PROCESS DESCRIPTION

3.1 ROLES AND RESPONSIBILITIES OF b) Principal Higher Education Officer - KEY PLAYERS Monitoring This section presents the key stakeholders involved in The HEO responsible for monitoring carries out the the activities of the provision of university education, day-to-day activities of monitoring of the universities; their roles, and responsibilities. undertakes inspections of universities; development of minimum standards of courses of study for 3.1.1 National Council of Higher Education universities and engages in the preparation of the This is the legal body mandated to regulate disseminative reports (for instance on minimum Universities in Uganda. The role of Council includes standards development), for the attention of the quality assurance and accreditation, establishing Director Quality Assurance and Accreditation. minimum standards of courses of study, human capital assessment, monitoring among other roles c) Principal Higher Education Officer - as stipulated by the Universities and Other Tertiary Certification, Verification and Equating of Institutions Act (UOTIA). The Council undertakes Qualifications its duties through the NCHE secretariat, headed by The HEO responsible for Certification, Verification the ED. The secretariat is made of 5 departments, and Equating of Qualifications is responsible for however for this study the focus was on the the applications for certification and equating Department of Quality Assurance and Accreditation. of qualifications from foreign institutions before admissions into universities and organising Department of Quality Assurance and Accreditation awareness workshops to inform the general public The Department of Quality Assurance and and relevant stakeholders on the emerging issues Accreditation (DQAA) reports to the Executive regarding certification and equating of Qualifications Director through the Deputy ED who is in charge of of Higher Education institutions. Quality Assurance. The DQAA Plans and budgets for its activities in liason with the finance department. Department of Research, Development and The Department’s mandate includes setting quality Documentation assurance and capacity indicators for univiersities, The Director is the head of Research, Development reviewing and developing minimum standards for and Documentation and reports to the ED through courses of study, monitoring, conducting instituional the Deputy ED; advises and reports on all matters of audits and constantly updates acceptable quality Research, Development and Documentation within indicators for the universities. The other offices NCHE; collects, evaluates and publishes information that are critical in fulfilling the mandate of this relating to students institutions of Higher Education; department are discussed below: and ensures regular quality checks in the Higher Education information dissemination services, a) Principal Higher Education Officer - conducts human capital assessments, for instance Licensing and Accreditation producing tracer studies. The Higher Education Officer (HEO) responsible for licensing and accreditation is in charge of applications for the establishment of universities; and accreditation of programmes taught in Universities.

8 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Department of Finance and Administration The minimum standards form the pillars of The Department is headed by the Finance Director programme development at the training institutions. and reports to the Executive Director; prepares The Universities are then expected to develop their documents and presents annual budgets for NCHE programmes while building on the existing minimum after consolidating individual department budgets; standards. At the point of submission of programmes reconciles and ensures that student contributory for accreditation to NCHE, individual universities funds are collected and allocated to support council are expected to comply with the requirements of mandate activities. minimum standards of courses of study with regard to the programmes they submit for accreditation. 3.1.2 Higher Education Institutions The Higher Education Institutions are charged with Accreditation of Higher Institutions governing and managing their institutional affairs a) Issuance of Letter of Interim Authority for a and abiding by the regulations and quality assurance proposed private university framework standards. They are also required to An applicant applies to NCHE8, by filling and submitting carry out quality assurance activities, including NCHE form 7. The application is accompanied by the internal quality assurance reviews (institutional information required under section 95a (2) of the audits), and peer reviews. In addition, they ensure UOTIA which contains information such as the name that students have paid the mandatory fees to NCHE of the proposed university, proposed location, the before registering with the respective institution. name or names of the promoters of the universities, and proposed governance structure. The payment of 3.2 PROCESS DESCRIPTION the required fees and verification (desk and physical), The NCHE activities are implemented as described if successful, leads to the award of a letter of interim below:- authority, that would be valid for three years.

3.2.1 Minimum standards for courses of b) Provisional Licensing study After the three years have unrevised, an application is The NCHE under the Department of Quality Assurance made to the NCHE for a provisional license to establish and Accreditation derives concepts on programmatic and operate a private university by individuals themes in order to develop minimum standards of wanting to set up the institution. The persons obtain courses of study, which is done in conjunction with and fill application forms from the NCHE, attach an assessment of the human capital of the country the required supporting documentation, and make (tracer studies). A hybrid document is then developed payments, depending on the type of application. in conjunction with the expert(s) in the subject specific area, which is then discussed with a large NCHE, on receipt of the application organizes a audience involving representatives from professional meeting or series of meetings with the applicant bodies, practitioners, industry and students, among to verify the resources and information submitted others. with the application. The verification team assesses the institution against the capacity indicators in the The reviewed hybrid document is then circulated quality assurance framework for compliance on to training institutions and other stakeholders for physical infrastructure, quality of teaching staff, validation. On completion, the edited document is library and other requirements. processed through the internal organs of NCHE for endorsement.

8 Quality assurance Framework for universities and the licensing process for higher Education Institutions, 2014

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 9 NCHE, on receipt of the application organizes a meeting or series of meetings with the applicant to verify the resources and information submitted with the application. The verification team assesses the institution against the capacity indicators in the quality assurance framework for compliance on physical infrastructure, quality of teaching staff, library and other requirements.

A verification report is prepared and submitted by the appointed team to the QA/AD, who then reviews and submits the same to the top management of the NCHE. The NCHE equally reviews and submits to the quality assurance and accreditation committee of the board through the ED. A provisional license is then issued to a private university and will be valid for at least three years from the date of publication in the Gazette.

c) Issue of Charter A university operating under a provisional licence for a period of not less than three years is eligible to apply for a Charter. The applicant is provided with a copy of the requirements as contained in section 100(2) of the Act by the NCHE Secretariat.

If the Council is satisfied with the evaluation report on the activities of the applicant under the provisional license in conducting its operations as envisaged in its earlier applications, an inspection committee is appointed by the NCHE. The inspection committee makes an inquiry and ascertains the reliability of the information submitted by the applicant, submits to the national council a report on the private university for consideration. The President, through the minister, grants a charter. The NCHE Council evaluates charters after every five years.

3.2.2 Accreditation of Programmes All programme applications for accreditation are forwarded to the Director Quality Assurance and Accreditation who passes them to the officer in-charge of programmes through the Head of University Unit. The officer in-charge of programmes is expected to verify that the submitted programmes meet the NCHE assessment criteria (minimum standards for course of study). He is required to collate the salient facts about an institution that include the list of staff (as per the Capacity Indicators in the QA Framework) to support the programmes and the validity of their academic qualifications among others. The programmes that fail are brought to the attention of the Head of University Unit and are subsequently returned to the institutions for further improvements.

The officer in-charge of programmes on completing the above, enlists all programmes which are ready for assessment and in consultation with the Head of University Unit, identify assessors for endorsement by the Director Quality Assurance and Accreditation. Programmes are assessed in four (4) cycles in line with the Accreditation and Quality Assurance Committee and Council schedules. For instance, the programmes that are received in January are assessed within January to mid-February. All programme assessments are done at location/center and do not last for more than five (5) days. Assessment reports are processed and forwarded through the internal organs that include QA department, Top Management, Quality Assurance Committee and Council for endorsement. The accredited programmes are valid for five years. Besides accreditation, the department also equates qualifications attained outside Uganda.

10 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 3.2.3 Monitoring Monitoring is a core function of NCHE. A checklist (Quality and assessment indicators) is used to ascertain compliance. Monitoring is based on prior reports from inspectors to assess whether the recommendations and standards set by NCHE are adhered to. Monitoring exercises can also be planned as a result of complaints over a training institution, or where it is deemed a training institution is performing well so best practices may be emulated. The monitoring activities are planned prior to commencement, and are conducted by respective resource persons, namely experts, technical officers and supervisors.

On completion of the monitoring activity, a report is provided to NCHE by the appointed team. A copy of the said report is also availed to institution monitored for their notice and areas of action, where necessary. The NCHE Council is informed of the monitoring outcome.

3.2.4 Institutional Quality Audit This is a requirement under Section 99 of the UOTIA, 2001 (as amended), for universities with provisional license, Section 15 of the Statutory Instrument No. 34 of 2008 for universities holding a Charter and the provisions of the Quality Assurance Framework (2014) for public universities. The university is required to conduct an independent self-assessment (Internal institutional audit) of its operations in all categories of the quality assurance framework. This self-review is expected to be completed in two (2) years and thereafter the self-assessment report is submitted to NCHE for review.

The NCHE then appoints and trains peer reviewers to cross check the information submitted by the institutions in a process referred to as peer assessment (External Audit). Peer-assessment can be done on the institutional facilities/infrastructure or the on the academic programmes. This process also takes two years, implying the two audits take four years. The fifth year is used to address any identified challenges in external and internal audits. The NCHE reviews (external institutional audit) the courses accredited but not taught in the universities, unaccredited programmes taught and any issues reported by peer reviewers in the fifth year.

3.2.5 Compliance with payment of student fees Statutory Instrument No 17 of 2017 requires all registering students to remit UGX.20,000 to the accounts of NCHE annually. The Secretariat of the NCHE reviews the status of compliance of the mandatory contribution per student before they register at the university. The university administration registers annually only those students who have made the payment to the NCHE bank account. The finance department and top management allocate student annual fees to contribute to council activities, such as, monitoring, tracer studies, reviewing and developing minimum standards for courses of study, human capital assessments, among other core activities.

3.2.6 Research and information dissemination The Department of Research periodically evaluates the overall national manpower requirement together with other national organisations, for instance Uganda Bureau of statistics and National Planning Authority. The Department is supposed to conduct tracer studies for year cohort graduates who will have graduated between 2-3 years before the year of the study.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 11 04

CHAPTER FOUR The Regulation of Universities by the National Council of Higher Education (NCHE) | (NCHE) | by the National Council of Higher Education The Regulation of Universities General A Report by the Auditor CHAPTER FOUR

FINDINGS, CONCLUSIONS AND RECOMMENDATIONS

This chapter presents notable achievements of NCHE. In addition, it presents findings, conclusions and recommendations on areas where the entity needs to improve to ensure that universities supply the labour market with labour force of required calibre.

Notable Achievements Between 2015/16 and 2017/18, NCHE received 4,237 applications, of which 3,523, representing 83.1% were assessed for accreditation. This achievement was attributed to NCHE co-opting university staff to undertake the assessment of the applications. Figure 1 refers.

Figure 1: Comparison of applications and assessments of programmes

1800

1600

1400

1200

1000 Applications submitted

800 Programmes Assessed

600

400

200

0 2015/16 2016/17 2017/18

Source: analysed data from state of higher education reports 2015-2018

Of the assessed applications, an average of 39.5 % were accredited in the period under review. The highest percentage of accredited courses was 44.5% in the FY 2016/17. See Table 2 below: Table 2: Programmes assessed Period Programmes Assessed Programmes Accredited % of applications accredited 2015/16 1432 473 33.0% 2016/17 944 420 44.5% 2017/18 1,147 471 41.1% Total 3,523 1,364 Source: analysis of data from NCHE Reports

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 13 Besides the accreditation of programmes, NCHE in the FYs 2015/16 to 2017/18 also granted 13 provisional licenses, 10 letters of interim authority to private universities and granted permission to universities to establish 9 branches and campuses. Refer to Table 3 below:

Table 3: Licenses and authorisations granted Period Provisional license Letter of Interim Authority Branches and campuses 2015/16 8 1 2 2016/17 2 2 1 2017/18 3 7 6 Total 13 10 9 Source: NCHE Annual performance reports

In the same period, management, revoked two licenses of , and Stafford University; and issued three intentions to revoke licenses: St. Lawrence University, Kayiwa International University, and Nsaka University.

Areas of Improvement Regulation is enforced through institutional and programme compliance with legislative requirements for registration; availability of governance and management structures conducive to delivery of quality education and a commitment to the promotion of an environment conducive to pursuit of academic excellence. Despite the notable achievements of NCHE, field inspections, document reviews and interviews with various stakeholders revealed instances of inadequacy in the implementation of key activities cardinal to the attainment of the Council’s mandate as discussed below:

4.1 MONITORING AND INSTITUTIONAL AUDITS According to Section 5(g) of the UOTIA, the NCHE is expected to monitor the operations of universities. In addition, Section 3 of the Quality Assurance Framework requires NCHE to conduct external institutional audits in the Universities in a sequence of five years, after peer and self-reviews have been conducted.

Furthermore, section 1.3.2 of the principles and guidelines for quality assurance in higher education, requires NCHE to engage in external quality assurance activities, which include accrediting universities on the basis of pre-determined minimum standards, monitoring and evaluating quality assurance aspects in universities and auditing universities for continuous enhancement of quality.

However, audit noted the following inadequacies in monitoring and institutional audit;

4.1.1 Monitoring of universities NCHE in the period 2015/16 to 2017/18 planned to undertake 60 monitoring visits of universities. Although management reported that they had conducted 30 monitoring visits at a cost of UGX.331.954,999, it was observed that only 11 were supported with monitoring reports, and only 3 had been discussed by Council and Top Management. Refer to Table 4.

14 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Table 4: Universities with monitoring reports Year University Date of Report 2015/16 Busoga University (Draft report) Dec 2015 Feb 2016 UTAMU Kampala Feb 2016 St. Lawrence University Nov 2015 International Health Science University Dec 2015 Muteesa 1 Royal University Dec 2015 2016/17 Uganda Sept 2016 Ibanda University Nov 2016 All Saints University Uganda Dec 2017 2017/18 Cavendish University April 2018 Kayiwa International University April 2018 Source: analysed reports submitted by NCHE

4.1.2 Institutional audits NCHE is supposed to organise peer institutional audits and conduct external audits. Through interviews with management, it was revealed that NCHE neither organised peer institutional audits nor undertook external institutional audits. The institutional audit activities were actually not planned in the period under review - 2015/16 to 2017/18.

The inadequate monitoring and the failure to undertake institutional audits by NCHE were caused by a number of factors, but mainly the following:

Inadequate allocation of funds for monitoring A review of the annual performance reports for the financial years 2015/16 to 2017/18, budgets and financial statements, revealed that NCHE budgeted to undertake 60 university monitoring visits in the three years at a cost UGX.524,999,000 but only allocated UGX.331,954,999. Refer to Table 5.

Table 5: Planned, budgeted and actual allocations FY Planned Actual Budget (UGX) Outputs (Units) Expenditure (UGX) Outputs (Units) 2015/16 149,999,000 20 143,954,999 10 2016/17 175,000,000 20 88,000,000 10 2017/18 200,000,000 20 100,000,000 10 Total 524,999,000 60 331,954,999 30 Source: Budget, performance reports and financial statements from NCHE

Scrutiny of the expenditure vis-à-vis the actual outputs (monitoring visits) revealed that for the FYs 2016/17 and 2017/18, the outputs were more or less commensurate to the funds spent, in view of the unit costs. However, in the FY 2015/16 NCHE was inefficient in utilising the funds. Instead of undertaking a monitoring visit at the planned unit cost of UGX.7,499,950, the entity instead spent UGX.14,395,500, resulting in fewer visits undertaken.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 15 Instead of the possible 19, NCHE only carried out 10 monitoring visits, given the funding available of UGX.143,954,999. Refer to the Graph below.

Figure 2: Analysis of planned and actual unit cost monitoring activities

16,000,000

14,000,000

12,000,000

10,000,000 Planned (Unit Cost) 8,000,000 Actual (Unit cost) 6,000,000

4,000,000

2,000,000

0 2015/16 2016/17 2017/18

Source: OAG analysis of NCHE data

Analysis of the fund allocations, revealed that funds allocation for monitoring activities were meagre, considering the student fees of UGX.20,000 charged on all higher education institution students annually. These funds are meant to fund mainly monitoring activities, which is at the core of NCHEs mandate. In the years under review, NCHE collected a total of UGX.9,259,034,392. Refer to the Table 6.

Table 6: Allocation of students’ fees collections to monitoring activities FY Total Students fees collection Monitoring Expenditure Monitoring to Total NCHE Expenditure (UGX) (UGX) %age 2015/16 2,978,337,336 143,954,999 4.8 2016/17 2,884,304,902 88,000,000 3.1 2017/18 3,396,392,154 100,000,000 2.9 Total 9,259,034,392 331,954,999

Source: OAG analysis of NCHE data on expenditure and revenue

Analysis of allocation of funds collected from students revealed that whereas funds generally increased, the allocation for monitoring reduced. In the FY 2015/16, NCHE allocated 4.8% of the total students’ fees collection. This situation worsened in the FY 2016/17 and 2017/18 with allocations of 3.1% and 2.9% despite having fund balances of UGX.175,558,573 and UGX.188,528,827 respectively on the student’s collection account.

16 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Inadequate staffing The quality assurance and accreditation department has 9 staff as opposed to 23 provided for in the organisation structure, to handle monitoring and compliance, and accrediting institutions and programmes. Table 7 below refers. Unlike the assessment activities, where university staffs are co-opted, the monitoring is undertaken by strictly staff of NCHE.

It is evident that with 52 universities, and 250 other higher education institutions, a fully staffed quality assurance and accreditation department cannot adequately undertake monitoring activities in these institutions. In comparison with Rwanda’s Council of Higher Education, the body charged with regulating higher education institutions has a staff strength of 7 in the department of quality assurance and is responsible for 16 public and private universities.

Table 7: Quality assurance and accreditation department staffing levels Position Establishment Actual Variance 1 Director Quality assurance 1 1 0 2 Principal Higher education Officer 4 2 2 3 Senior Higher education Officer (M&C) 9 3 6 4 Higher education officer (technical) 9 3 6 Total 23 9 14 Source: OAG analysis of data from NCHE

Inadequate punitive regulation In regulating higher education, NCHE is required to establish regulations and guidelines under which universities are to operate. However, it was noted that the existing statutory obligations in the higher education sector do not arm the Council to institute punitive measures against the non-compliance actions of the universities. This inadequacy leads to complacent behaviour by certain universities towards the quality requirements.

Consequences of inadequate monitoring and failure to undertake institutional audits The consequences of the inadequate monitoring of the universities and the failure to undertake peer and external institutional audits by NCHE include; a) Unaccredited programmes being offered by universities The inadequate monitoring resulted in universities offering unaccredited programmes or programmes whose accreditations had unrevised, contrary to section 3 of the quality assurance framework. It was noted that on average, only 43.5% of courses offered by 15 selected universities, were accredited. The universities of Busitema, Lira and ISBAT had fairly all their courses accredited and up-to-date (within five years after accreditations)9. Table 8 below refers.

9 NCHE Database of Accredited courses as at May 2018

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 17 Table 8: Status of University programme accreditation Number of Unrevised Unaccredited Total No. of % of accredited courses courses Programmes on accredited courses (b) (c) Database as of courses (a) June 2018 (a/(c+d)) (d) 1 Lira University 10 0 0 10 100.0% 2 ISBAT University 18 3 0 21 85.7% 3 Busitema University 54 15 0 69 78.3% 4 MUST 53 24 0 77 68.8% 5 Muni University 3 3 0 6 50.0% 6 St. Lawrence University 24 26 0 50 48.0% 7 Clarke International 9 12 0 21 42.9% University/ IHSU 8 Team University 7 8 2 15 41.2% 9 75 112 0 187 40.1% 10 Nkumba University 74 115 0 189 39.2% 11 International University of 7 31 0 38 18.4% East Africa 12 12 77 0 89 13.5% 13 Kampala International 25 124 56 149 12.2% University 14 Stafford University 2 0 22 2 8.3% 15 Kampala University 6 95 0 101 5.9% Average 43.5%

* NCHE Accreditation Database, NCHE data in responses to draft ML ** Brochures, websites & Graduation books

Un-reviewed charter and provisional licenses Another challenge posed by the above inadequacies was universities operating under un-reviewed charters. Out of the 4 private and chartered universities that were inspected, 3 had not been reviewed by the 5th year of operation, contrary to regulation 15(3) of the Statutory Instrument No.34 2008 of the Universities and Other Tertiary Institutions (Quality assurance) regulations. By the time of audit (June 2018), the Universities of Nkumba, Kampala International University, and Ndejje University had taken 6, 4 and 4 years respectively, from the year of the expected review. Refer to Table 9 below.

Table 9: Universities with un-reviewed charters University Charter license year Expected year of review Years after expected review Kampala International University 2009 2014 4 Nkumba University 2007 2012 6 Ndejje University 2009 2014 4 Kampala University 2016 N/A

18 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General In addition, section 97(3) of the UOTIA, 2001 (as amended), requires provisional licenses to be held for three years from the date of publication of the university in the gazette. It was noted that 20 universities holding provisional licenses were not assessed for progression to charter staus, after 3 years of holding provisional licenses. Table 10 refers.

Table 10: Universities with more than 3 years of holding provisional licenses University Provisional University Provisional license year license year 1 2001 11 Cavendish University 2008 2 2004 12 International University of East Africa 2010 3 African Bible University 2005 13 Victoria University 2010 4 Mountains of the Moon University 2005 14 St. Augustine International University 2011 5 Uganda Pentecostal University 2005 15 Virtual University of Uganda 2011 6 St. Lawrence University 2007 16 2011 7 Muteesa I Royal University 2007 17 Livingstone International University 2011 8 Cavendish University 2008 18 Uganda Technology and Management 2013 University (UTAMU) 9 All Saints University, Lango 2008 19 Africa Renewal University 2013 10 Clarke International University 2008 20 Nsaka University 2013 b) Equating of qualifications for minimum entry requirement A review of ten randomly selected student files from universities that were inspected revealed that the universities of St. Lawrence, Team, Ndejje and Clarke International admitted foreign students without NCHE equating their admission qualifications in accordance with section 3 (b) and 5 (j) of the UOTIA. This implies that such students may not satisfy the minimum criteria for admission to the under-graduate and/or higher degree programmes in Uganda and thus their qualifications may be brought to question in future. c) Non-compliance with quality assurance and capacity standards Regulations 4 and 7 of the statutory instrument No.85 (2005) institutional standards and 80 B – quality assurance and capacity indicators, set quality standards and capacity indicators that universities are supposed to adhere to. Document review and field inspections of 14 universities revealed non-adherence with set indicator parameters. For instance, in terms of infrastructure, only 4 universities had the required computer laboratory space; 5 had the required science laboratory space and 7 had the required Library space. In terms of the Education facilities indicator, only 29% of the universities had the recommended student to library book (hard copy) ratio. Appendix 6 refers.

The inadequacy in these critical capacity indicators affects the ability of staff and students to research, publish and innovate. For instance, only had more than one research project winning sponsorship every academic year, while St. Lawrence University, Stafford and Team University never had any publications by staff in the period of review. The importance of research cannot be over emphasised, since in the developed world, knowledge-based economies, research and innovation powers long-term economic growth.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 19 Although the Universities decried limited number of PhD staff, the inability to collect adequate student fees and attract external funding, particularly in high priority areas, the universities should first demonstrate initiative and drive to offer research based courses as opposed to duplicating courses and programmes to attract students. By conducting research-based courses, universities may attract funding from both Government and private sector besides being able to attract students who are capable of paying the standard unit charges recommended by NCHE.

Box 1: Fees charged in Universities in Uganda

Universities in Uganda charge lower than the standard unit charge recommended by NCHE standard and the ideal standard. Weighted unit cost of university education is UGX.3,519,918 yet NCHE standard is UGX.4,528,747, while the ideal rate is UGX.5,592,932.

This is made worse with the high inter university competition of students leading to exorbitantly low fees structure in a bid to attract students. The tuition charged by private universities is lower than that of the public universities.

The implication of this cost structure is the inability of universities to provide adequate facilities to enable effective learning and quality education.

Courtesy: NPA publication, 2017

Management Responses i) The 30 monitoring visits were conducted as planned. Notably, some of the institutions were monitored more than once due to the complexity of their compliance issues such as All Saints University, Muteesa I Royal University, and Busoga University

ii) Institutional audits were conducted for the period 2015/16 to 2017/18 in collaboration with the Inter University Council of East Africa.

iii) The process of re-accreditation is underway at most of the Universities. Some programmes have been reviewed and feedback given to the respective Universities such as Kampala International University and Kampala University. However, they have compliance issues that must be addressed before accreditation is done.

iv) The challenge of some HEIs admitting foreign students without equating their qualifications shall be addressed by the Integrated Management Information System since all HEIs shall be required to submit lists of all admitted students and the criteria used as a basis for admission. In addition, NCHE has drafted a concept for having a central admission system for all Universities so that students admitted match the available facilities. This is going to be considered by relevant governance organs.

v) NCHE has prioritised the compliance to standards in the current strategic plan, by setting up a unit and this unit will ensure that institutions adhere to set minimum standards.

20 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Audit Comments i) Audit only reviewed eleven monitoring reports. According the Council minutes provided, audit could only ascertain the monitoring visit reports of Kayiwa University (47th Council meeting May 2018), university (46th Council meeting February 2018), Busoga university (39th Council meeting March 2016). The latter minutes noted that the report of Mutesa 1 University was yet to be received. ii) No reports were provided for institutional audits undertaken by NCHE as per the regulations. There were no copies availed for review of any institutional audits undertaken in collaboration with the Inter University Council of East Africa. iii) Management did not provide evidence of correspondence and applications to indicate that re- accreditation of the programmes was being undertaken. Audit notes that certain courses in the universities had elapsed for over a year without starting the re-accreditation process. iv) The central admission system and integrated Management Information system is a welcome initiative to combat irregular admissions in the private universities.

Conclusion Although NCHE has a clear mandate and regulatory framework to regulate the quality of higher education through monitoring of the universities and to undertake peer and external institutional audits of higher institutions of learning, it lacked the required capacity to adequately do so. Consequently, some universities are undertaking unaccredited courses, admitting foreign students whose qualifications are not equated, while some have failed to meet the minimum standards as provided by the NCHE, which compromises the quality of university education. Universities are not placing emphasis on research to generate and/or adapt knowledge, innovate, to integrate into the global knowledge networks10 and thus solve societal problems.

The contribution by higher institutions of learning to social transformation of the country through providing adequate skills that match the required labor market demand may not be achieved, as envisaged by the NPA.

Recommendations NCHE should; i) Adequately plan, properly allocate and utilise the students’ fees collections to conduct its statutory obligations of monitoring and institutional audits. ii) Advocate and liaise with relevant government bodies with a view of recruiting adequate staff to ensure effective monitoring of universities in the country. iii) Government should build and empower the capacity of NCHE to adequately undertake its mandate and enforce punitive measures in order to compel compliance to the standards. iv) Enforce compliance by ensuring that all Universities offering un-accredited and/or courses whose accreditations are unrevised submit them for review leading to accreditation and/or re-accreditation.

10 NPA paper, the place of universities in National Human resource Planning Vision, 2040, October 2017

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 21 4.2 HUMAN CAPITAL ASSESSMENT

4.2.1 Failure to undertake Tracer Studies According to Sections 5(h, and P) of the UOTIA, 2001 (as amended); NCHE is required; to evaluate the overall national manpower requirements and recommend appropriate solutions, and to generally advise the government on policy and other matters relating to institutions of Higher Education. To do so, NCHE is required to conduct tracer studies, for graduates who would have graduated between 2-3 years, to establish whether the knowledge and skills acquired by graduates are adequate in the job market. Tracer surveys involve both graduates and employers and the findings there in are a basis for curriculum review of academic programmes11.

Through document review and interviews, it was noted that NCHE has so far conducted two tracer studies in 2011 and 2015. The tracer study of 2015 was for graduates of 2011, involved six universities and five other tertiary institutions (OTIs), involving 16 degree and 10 diploma programmes. The expected 2018 tracer study for cohorts of 2015 was not conducted despite UGX 90 million being budgeted in the period. In addition, there was no follow up of the implementation of the recommendations of the two tracer studies conducted by NHCE.

Besides NCHE, universities are also required to undertake tracer studies, as stipulated by section 3.2.6 of the Quality Assurance framework. In this regard, only Clarke International University out of the sampled 14 conducted a tracer study. It was established that NCHE just encouraged universities to undertake the studies rather than compelling them to do so.

It is evident that NCHE lacks a mechanism to continuously monitor, assess and track graduates wherever they may be working to ascertain the relevance of the programmes offered by the various higher education institutions. NCHE stated that the conduct of tracer studies was a costly process. It was noted that there were no standard guidelines and templates to undertake and report on tracer studies by the universities. As a result, NCHE, universities, government and other stakeholders lack information on the relevant courses, course content and marketable programmes that could meet the needs of the labour market. In addition, curricula and academic programmes may not match the labour requirements. According to the NPA, the non-responsive education curriculum to the needs of the country is one of the factors affecting the supply of un-employable workforce.

Box 2: The Keynes argument on employment equilibrium

Keynes argues that the volume of employment in equilibrium depends on the aggregate supply function, the propensity to consume, and the volume of investment. This theoretical perspective provides grounds for development of the macro model for projecting imbalances on a country’s labour market.

Courtesy: NPA paper, the place of universities in National Human resource Planning Vision, 2040, October 2017

11 NCHE Tracer Study Report, 2005

22 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Management Response NCHE conducts tracer studies to inform the country’s needs for human resources and review of curricula. Higher Education Institutions graduate approximately 40,000(Forty thousand students every year), due to the limited resources NCHE usually covers a sample of about 2,000 students. The desirable is to engage at least 50% of the graduates biannually at an average cost of 500m.

Audit Comment The cohorts traced are beyond the expected time frame and the sample of 16 university programmes is limited in relation to the 2000 number of courses conducted in the country and the 40,000 number of graduates per annum. There was no evidence that the 2018 tracer study was being undertaken, since it was an output expected in the 2017/18 financial year.

Conclusion The delay to conduct the 2018 tracer study implies that there is lack of up-to-date information about the adequate of graduates in the job market. Due to the inefficiencies of universities aligning their curricula to the labour needs, there is need to pursue deliberate and comprehensive approach to human capital assessment by NCHE and all other stakeholders so as to produce graduates who will play a positive role in the social economic transformation of the country.

Recommendations NCHE is advised to; a) Allocate adequate funds from the students’ fees collection to conduct the core functions of human capital assessment and tracer studies in a timely manner. b) Consider developing guidelines and simpler templates for use by universities when undertaking tracer studies. The templates, if incorporated in the NCHE management information system would render tracer research less expensive. c) NCHE should enforce the conduct of tracer studies by the universities rather than encouraging.

4.3 MINIMUM STANDARDS FOR COURSES OF STUDY According to Section 5(i) of the UOTIA, 2001 (as amended), NCHE is required to establish minimum standards for courses of study. In addition, the NCHE guidelines on preparing/reviewing of minimum standards12 require the universities to submit their courses and programmes for accreditation based on the established minimum standards of courses of study. Furthermore, the council guided13 that the minimum standards should be reviewed after every five (5) years.

Through document review and interviews, audit noted that NCHE had established minimum standards for only 43 (2%) of the 2,104 courses of study. By April 2016, 38 of the 43 courses had since expired and had either not been reviewed or published.

12 The NCHE guidelines on preparing/reviewing of minimum standards 13 NCHE council minute of its sitting deciding that the minimum standards will be revised after five years.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 23 Through interviews, it was noted that no minimum standards for courses of study were developed, although management planned for 100 courses in the period under review. In addition, the planned review of 15 minimum standards for courses of study in the same period was not undertaken, despite UGX 118.45 million being availed for the activity. Refer to Table 11.

Table 11: analysis of budget and actual expenditure for minimum standards Activities 2015/16 2016/17 2017/18 Budget Actual Budget Actual Budget Actual millions millions millions millions millions millions

Developing minimum standards 0 0 40 0 60 0 Reviewing minimum standards 88 88 30 30 50 0 Source: analysis of NCHE financial statements and budgets

Management is not prioritizing these activities, by not properly budgeting and allocating adequate funds despite increase in the students’ fee collections. As a result, NCHE has accredited 2,100 (99.9%) programmes without checking against up to date minimum standards for courses of study.

Management Response The standards were reviewed as evidenced by the soft copies in the folder. Council approved and reviewed during its sitting of 38th Council meeting held on 21st December 2015. Every programme is assessed by subject experts who are selected for the exercise on the basis of expertise and experience. Other Standards have also been developed in the areas of Engineering Facilities at Institutions, Nursing Programmmes and requisite facilities benchmarks for Postgraduate Training.

Audit Comment A review of the minutes of the 38th council meeting held on 21st December 2015, minute 184/38/2015/ 5, shows that the Council approved nine minimum standards of courses of study and approved six newly developed minimum standards of courses of study. However, five of these courses were published in January 2014 prior to council approval. These were B.Sc. in Computer Engineering, B.Sc. Information Systems, Information Technology, Library and Information Science, and BSc in Software Engineering. These courses will have expired in January 2019.

There were no published standards in either hard copy or the council website for the other ten courses. The regulation expects courses to be accredited on the basis of an approved minimum standards and not expert knowledge at the time of reviewing courses for accreditation.

Conclusion NCHE did not conduct and publish the fifteen budgeted minimum standards in the period of study. Audit could not establish on which activity the released UGX 118.45 million for minimum standards was spent. Minimum standards ensure that the course content in the programmes conducted is relevant to the needs of the country. By not developing, and reviewing the minimum standards in a timely manner, the skills and knowledge imparted to the students may not be in tandem with the evolving challenges of the global village.

24 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Recommendation Management should allocate adequate funds to ensure that minimum standards for courses of study for all programmes are set.

OVERALL AUDIT CONCLUSION NCHE has a mandate to regulate the quality of higher education through monitoring of the universities and to undertake peer and external institutional audits of higher institutions of learning. Failure to undertake this mandate adequately has led to, some universities running unaccredited courses, admitting foreign students whose qualifications are not equated, while some have failed to meet the minimum standards as provided by the NCHE, which compromises the quality of university education. Universities are not placing emphasis on research to generate and/or adapt knowledge, innovate, to integrate into the global knowledge networks14 and thus solve societal problems. NCHE is also not enforcing the compliance with these standards by the Universities, but only encouraging them to comply.

The delay to conduct the 2018 tracer study by NCHE implies that there is lack of up-to-date information about the adequacy of graduates in the job market. Universities are not conducting tracer studies are required. This has led to the inefficiencies of universities aligning their curricula to the labour market requirements.

NCHE did not conduct and publish the fifteen budgeted minimum standards in the period of study. Audit could not establish on which activity the released UGX 118.45 million for minimum standards was spent. Minimum standards ensure that the course content in the programmes conducted is relevant to the needs of the country.

14 NPA paper, the place of universities in National Human Resource Planning, Vision 2040, October 2017

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 25 APPENDICES Appendix I: Organizational Structure

National Council of Higher Education

COUNCIL COMMITTEES - QA and Accreditation - RDD - Audit and RIsk - Finance

Executive Director

Director QA and Management Support Director Legal Director RDD Director Finance Accreditation Services

Research and Audit, Monitoring and Human Resource and Planning Compliance Administration Internal Audit

Institutional and ICT, Library and Programme Documentation Accreditation

Standards, Recognition and Equating Qualifications

26 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Appendix II: Data collection methodology

Audit Question Methodology 1 To what extent has NCHE estab- Audit carried out document reviews and interviews (as shown in Appendix lished minimum standards for II and III respectively) with the director quality assurance, Principle higher course of study in Uganda? education officer / Head Universities, the heads of quality assurance in various universities to gain an understanding of how minimum standards for courses of study are established, the extent of establishment, the consequences due to inadequacies in establishing minimum standards and also corroborate information gathered from documents reviewed relating to minimum standards for courses of study.

2 To what extent have higher educa- A semi structured questionnaire was also administered to the heads of quality tional institutions complied with the assurance / estate managers of the various universities to establish the extent institutional standards set by NCHE? to which the universities faired against the quality assurance and capacity indicator checklist established by NCHE. In addition, corroborating information was gathered from documents reviewed as shown in Appendix 3.

Audit also physically inspected various facilities and infrastructure in the selected universities to establish the existence and fairing with the indicators.

3 To what extent has NCHE conducted Audit reviewed the strategic plan, annual work plans, budgets, Annual monitoring in an effective and timely performance reports, Audited financial statements for the three years 2015/16 manner? – 2017/18, to establish; the planned and Actual M&E activities, the budgeted and Actual amounts for the M&E activities and the extent to which NCHE has conducted monitoring.

The team interviewed Director Quality assurance, Principle higher education officer / Head Universities, senior higher education officer, to obtain an understanding on the extent to which NCHE conducts M&E, inspections, and institutional audits.

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 27 Appendix III: Documents reviewed No. Document reviewed Purpose 1 Quality assurance framework for universities and the To obtain an understanding of the Quality assurance licensing process for higher education institutions, operations governing the higher education system in 2014 Uganda. 2 Universities and other tertiary institutions Act To obtain an understanding of the regulations governing higher education systems. 3 NCHE Human resource manual To obtain an understanding of the organisation structure and job descriptions of the different stake holders. 4 NCHE strategic plan 2016-2020 To obtain an understanding of the mission, vision and activities of the council. 5 Documentation as per NCHE website To obtain an understanding of the operations and function- alities of the council. 6 National Development Plan II To obtain an understanding of the national objectives in regard to higher education in Uganda. 7 Programme brochures, timetables and • To obtain a listing of academic programmes university websites. Other university conducted by the universities. materials; Graduation books, Time tables for courses of study, strategic plans, financial statements, • To verify whether universities are in compliance with the certificates of accreditations, senate and council quality assurance framework checklist. minutes, research publications by staff, lists of students, staff list with their qualifications, land titles. 8 NCHE accreditation database To obtain a listing of the accredited courses as at May 2018. 9 NCHE Annual performance reports To obtain an understanding of the performance of NCHE over the period under review. 10 Financial statements 2015/16 – 2017/18 11 NCHE work plans and budgets

Appendix IV: Interviews held No. Interviewee Purpose 1 Quality assurance and accreditation • To obtain an understanding of the Quality assurance operations governing director the higher education system in Uganda

• To obtain an understanding of the processes involved in the accreditation of both programmes and higher education institutions.

2 Human resource personnel To obtain an understanding of the Organisation structure and job descriptions of the different stake holders. 3 Senior Higher Education Officer- To obtain an understanding of the processes involved in the accreditation of Universities both programmes and higher education institutions. 4 University Secretary - To obtain an understanding of the processes involving the university and university NCHE. 5 Vice chancellor –Team university To obtain understanding on the limitation of compliance with the quality as- surance standards 6 Vice chancellor Ndejje University To obtain understanding on the limitation of compliance with the quality as- surance standards. 7 NCHE top management (Executive To discuss the preliminary findings of the inadequacies in the universities and Director NCHE, department heads obtain an understanding of the shortcomings of the council. of finance and quality assurance)

28 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General Appendix V: Quality Assurance Framework Indicators

ASSESSMENT TOOL FOR UNIVERSITIES AND PROGRAMMES Name of Institution: Interviewees: Tick where appropriate

S/N Item Ideal Good Acceptable Can be Unacceptable Remark improved 1. Land for campus/ 10-30 acres 5-10 acres 3-5 acres 3 acres Less than 3 urban acres 2. Land: Rural 50 acres or 30-50 acres 20-30 acres 10 acres Less than 10 over acres 3 Governance (i) Council In control of operational In place To be Does not meet policy elected (ii) Senate Supervises Meets often In place Meets when Administration to all academic need arises make decisions policy (iii) Administration Appointed Respects Consults with Meets with Insensitive to legally by administrative staff and staff staff concerns council structures students (iv) Staff and Staff and Staff and Staff and Staff and Staff and student Student unions student union student unions student unions unions unions absent involved fully consulted exist present 4 Infrastructure (i) Classroom space 2.5m2 per one 2 m2 per one 1 m per 1 1 m2 per 4 1 m2 per over 5 student student student students students (ii) Library space 2.5 m2 per one 2 m2 per one 1 m2 per 1 1 m per 4 1 m2 per over 5 student student student students students (iii) Science 3 m2 per one 2.5 m2 per one 1 m2 per 1 1 m2 per 4 1 m2 per over 5 laboratories student student student students students (iv) Computer 3 m2 per one 2.5 m2 per one 1 m2 per 1 1 m2 per 4 1 m2 per over 5 laboratory student student student students students (v) Administrative 5 m2 per one 4 m2 per staff 3 m2 per one 2 m2 per 1 or less m2 per staff offices staff staff staff staff (Vi) Academic staff 5 m2 per one 4 m2 per staff 3 m2 per one 2 m2 per 1 or less m2 per offices staff staff staff staff (vii) Sports fields 1 field for 500 1 field for 1000 1 field for 1500 1 field for 1 field for 2500 or registered students students 2000 more students students (viii) Facilities for dis- All buildings All classrooms Only on a few Planning to No plan at all abled have (ix) Tennis court, 1 field for each 1 of each field 1 of each for 1 of each for 1 of each field for swimming pool, sport for 1000 for each 1500 2000 students 2500 stu- over 2500 volleyball, students students dents students hockey and crick- et

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 29 S/N Item Ideal Good Acceptable Can be Unacceptable Remark improved (x) Conference hall One for 500 One for 750 One for 1000 One for 1500 One for over 2000 registered registered stu- registered stu- registered registered stu- students dents dents students dents (xi) Student union 20 m2 for 300 20 m2 for 500 20 m2 for 1000 20 m2 for 20 m2 for over offices registered stu- students students 1200 stu- 1500 registered dents dents 5 Academic staff a) Staff/student ratio: General 1:15 1:20 1:25 1:40 1:50 or more Arts/Social 1:15 1:25 1:30 1:50 1:60 or more sciences Medicine, Veter- 1:8 1:15 1:20 1:25 1:26 or more inary, pharmacy Dentist Science based 1:10 1:15 1:20 1:25 1:26 or more profession Agriculture. For- estry, technology Other professions 1:15 1:20 1:25 1:30 1:30 or more - , education, statistics b) Qualifications (staff develop- ment) PhD Holders 60% of staff 50% of staff 15-50% of staff 10% of staff Less than 10% of staff Masters Holders 70% or more of 60% of staff 50% of staff 40% of staff Less than 30% staff Contact hours for 10hrs/week 15hrs/week 20hrs/week 30hrs/week 30hrs or more a academic staff week Percentage of 20% of staff 30% 35% 40% Over 50% part-timers 6 Education facil- ities Student: Library 1:40 1:30 1:20 1:10 Less than 1:10 book ratio (rel- evant and diver- sity) Computer: stu- 1 computer : 5 1:10 1:20 1:25 More than 1:30 dent ratio students Access to inter- 1: 20 hrs. ac- 1:10hrs 1:5 hrs. 1:3hrs None at all net; 1 student:hrs cess 7 Financial health Percentage of 100% 80% 75% 70% Less than 50% budget received Percentage of NIL Less than 10% Less than 20% Less than Over 35% deficit over ex- 25% penditure 30 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General S/N Item Ideal Good Acceptable Can be Unacceptable Remark improved Proportion of 50% 60% 65% 70% Over 75% budget spent on salaries Percentage of 25-35% of bud- 40% 45% 50% Over 75% income derived get from fees 8 Facilities for the All facilities Most of the fa- Facilities are Council has Nothing is in disabled available cilities in place being put in endorsed place or being place their con- planned struction 9 Gender sensitivity Comprehen- 75% of the Council has Council Nothing is being sive affirma- needed rules approved a committee planned tive action and regula- comprehen- has drafted regulation to tions in place sive list of rules and increase ac- them regulations cess for wom- en and other disadvantaged groups in place 10 Strategic plan Being imple- Has been ap- Is before sen- Being draft- None is being mented proved by uni- ate or council ed worked on versity council 11 Publications by Over 10 books 5-10 books a 1-5 books a One book a No publication staff a year year year year at all 12 Research proj- Over 10 proj- 5-10 projects 1-5 projects One project No research go- ects won by staff ects won won won won a year ing on 13 Percentage if 100% 80% 40-60% 40% 0-40% inst. Graduates employed in year of graduation

The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 31 Appendix VI: University adherence to capacity indicators

Quality assurance Specific indicator universities with ac- universities with un- Percetange with un- and capacity indica- ceptable measures acceptable measures acceptbale measures tor 1 Land 11 3 33% 2 Governance University council 13 1 7% Staff union 13 1 7% Student union 13 1 7% 3 Infrastructure Computer lab. space 4 10 71% Laboratory space 5 9 64% Library space 7 7 50% Conference facilities 7 7 50% Sports facilities 8 6 43% Staff office space 9 5 36% Classroom space 11 3 21% 4 Academic staff Percentage of part 5 9 64% timers PhD holding staff 6 8 57% General staff to stu- 9 5 36% dent ratio Masters holding staff 13 1 7% 5 Education facilities Student: library book 4 10 71% ratio Computer: student 12 2 14% ratio Access to internet 13 1 7% 6 Financial health Income derived from 6 8 57% fees 7 Publications by staff Books published by 7 7 50% staff 8 Research projects 1 13 93% won by staff 9 Tracer studies Tracer study Reports 1 13 93% Average 8 6 43%

Source: Analysis of data collected from field inspection and university document review.

32 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General 33 34 The Regulation of Universities by the National Council of Higher Education (NCHE) | A Report by the Auditor General

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