Comments on New Policy on Distance Learning in Higher Education as proposed by the MHRD

Points as given in the proposed policy

S No. Points as given in the Observations proposed policy Background 1. Reference should be made of establishment of the Distance Education Council as a statutory body created by the Indira Gandhi National Open University in 1991 for the promotion, coordination and maintenance of standard in the Open and Distance Learning System in the country. 2. The background note does not reflect on the current scenario of ODL system. 3. Instead of a standing committee on Open and Distance Education under the National Commission for Higher Education and Research (NCHER), there should be an autonomous statutory regulatory apex body for Open and Distance Education in the country under the NCHER. (i) Only those programmes, 1. Programmes and extensive which do not involve practical work need to be extensive practical course specified. work, shall be 2. If it means programmes in permissible through the Science and Technology, this distance mode. point is not justified. Many distance education institutions including open universities, have been offering programmes in these areas for the last few decades, and more recently programmes in dietetics and health education and vocational education involving skill- based/competency based practicals and hands-on training. 3.It is pertinent to mention that the entire practical component is delivered in a face-to-face mode at the designated education institutions specifically identified for the purpose that are well- equipped with specialised laboratories/ skill development centres/ work centres etc., where the practical component is being transacted. Further, face-to- face sessions are also conducted for theory courses. 4.For example, health science programmes offered by IGNOU are meant for in- service medical and nursing professionals for upgrading their knowledge and skills. In these programmes, about 50 % credit is devoted to hands- on skill training at specially selected programme study centres under the supervision of qualified and experienced faculty. The teacher-student ratio is maintained at 1:5. Further 50 % is the minimum pass mark for both theory and practical components. However, a range of practices to ensure hands-on practical sessions is being followed by different ODL providers in the country. There is therefore a need to develop standardised norms for practical based programmes and closer monitoring of the same. 5. The graduates are well accepted in the country and even abroad. They are getting admission through open competition in Masters and Research degree programmes in universities and IITs, and are also getting accepted in the job market, which are considered the benchmarks of quality in the country. 6. Many Open Universities all over the world are offering Science and Technology programmes through distance mode. To cite a few, The Open University of U.K.; The Athabasca University, Canada; Israel Open University; German Open University; Korean Open University; S.T. Open University, Thailand; Hong Kong Open University; CRTV University of Science, Malaysia; Wawasan Open University, Malaysia; and the Sri Lanka Open University are all offering programmes in Science and Technology. Even in our country, AMIE, which is pursued through distance mode only, is recognised equivalent to B,E./B. Tech. 7. Distance education has tremendous potential in providing an opportunity to a large number of working professionals to improve their knowledge and skills, and enhance their qualifications for career advancement. 8. The ODL system is supposed to cater to the needs of those in-service and disadvantaged, who need to upskill/upgrade/ retrain themselves and acquire the competencies and skills required in the world of work. By excluding all practical based programmes, how would we fulfil this mandate? 9.Therefore, if an institution has human resources and puts in place infrastructure and processes to ensure hands-on practical training, there is no reason why practical- based programmes through distance mode cannot be allowed.

(ii) Universities / institutions Universities/ institutions shall shall frame ordinances / frame ordinances / regulations / regulations/ rules, as the rules, as the case may be, case may be, spelling out spelling out the outline of the the outline of the programmes to be offered programmes to be offered through the distance mode through the distance indicating the number of required mode, indicating the credits, list of courses with number of required assigned credits, reading credits, list of courses references in addition to self with assigned credits, learning material, hours of study, reading references in contact classes at study centres, addition to self learning assignments, material, hours of study, examination and evaluation contact classes at study process, grading etc. which centres, assignments, should be as per norms examination and prescribed by the Distance evaluation process, Education Council (DEC). grading etc.

(iii) DEC of IGNOU shall 1. Word ‘only’ has to be deleted. only assess the Also It is not clear whether the competence of assessment is to be done university/institute in programme-wise or institution- respect of conducting wise. distance education 2. DEC should be made a programmes by a team of statutory body for open and experts, whose report distance education in the country, shall be placed before the and not merely a body to access Council of DEC for the competence of consideration. university/institutions. (iv) The approval shall be The phrase “…. and not by the given only after Chairperson DEC” should be consideration by the deleted. Council of DEC and not by Chairperson, DEC. For the purpose, a minimum number of mandatory meetings of DEC may be prescribed. (v) AICTE would be directed The accreditation should be done under section 20 (1) of by the DEC and not AICTE the AICTE Act 1987 to alone. DEC may devise policy ensure accreditation of guidelines and do accreditation the programmes in of ODL providers by involving Computer Sciences, members drawn from respective Information Technology Councils as per requirement of and Management the programmes on offer. AICTE proposed to be offered by as a body should not supersede an institute/university DEC as DEC is the agency through the distance mandated to develop and mode, by National Board maintain standards for ODL. of Accreditation (NBA). (vi) UGC and AICTE would The norms for various technical/ be directed under section other programmes have already 20 (1) of their respective been developed by DEC in Acts to frame detailed consultation with the respective regulations prescribing councils. In case the norms are to standards for various be revisited, then it can only be programmes/ courses, done with active involvement of under their mandate, DEC. offered through the In any case NBA can only distance mode. accredit technical programmes. This situation would thus result in an applicant institution to run between different approval and accreditation committees/bodies for different programmes. What about accreditation of general programmes. Why has this policy overlooked NAAC at all places? (vii) No university/institute, 1. What is the basis for the cut except the universities off date? established by or under Rather it should be framed as “... an Act of No university/ institute shall Parliament/State offer programmes through Legislature before 1985, distance education mode, shall offer any henceforth without prior programme through the approval of the DEC.” distance mode, 2. The restriction put on henceforth, without universities/ institutions approval from DEC and established after 1985 is accreditation by NBA. absolutely arbitrary. This clause However, the is discriminatory to the universities/ institutions universities established after already offering 1985. It also discriminates programmes in against the universities that offer Humanities, Commerce / certain programmes. Business / Social Sciences / Computer Sciences and Information Technology and Management, may be allowed to continue, subject to the condition to obtain fresh approval from DEC and accreditation from NBA within one year, failing which they shall have to discontinue the programme and the entire onus with respect to the academic career and financial losses of the students enrolled with them, shall be on such institutions / universities. (viii) In light of observation of 1. Looking at the hardship Apex Court, ex post facto imposed on the students who approval granted by any have acquired degrees through authority for distance the distance mode, the DEC has education shall not be put in place a mechanism for post honoured and granted facto approval. A definite cut off henceforth. However, the date be fixed for institutions to universities established apply to DEC for the same. by or under an Act of 2. This clause is discriminatory Parliament or State to the Universities established Legislature before the after 1985. It also discriminates year 1985 and offering against the Universities that offer distance education programmes other than programmes in the humanities/ commerce/sciences”. streams of Humanities / Commerce / Social Sciences before the year 1991 shall be excluded from this policy. (ix) The students who have It is not clear who the examining been awarded degrees agencies will be, when and where through distance mode by would be examination conducted, the universities without whether it would be a single taking prior approval of examination applicable to all, or DEC and other statutory would different exams be bodies, shall be given one conducted for different chance, provided they institutions. fulfil the requirement of Further, there are lacs of students minimum standards as who have acquired their degrees/ prescribed by the UGC, diplomas/ certificates through AICTE or any other distance mode. How practical relevant statutory will it be to examine the authority through competence of all these students? regulation, to appear in Is there a similar procedure to examinations in such examine the students who have papers as decided by the acquired their degrees/ diplomas/ university designated to certificates from conventional conduct the examination. universities/ institutions? If these students qualify in this examination, the university concerned shall issue a certificate. The degree, along with the said qualifying certificate, may be recognised for the purpose of employment/ promotion under the Central Government (x) A clarification shall be 1. In the light of points raised issued with reference to above, it will further complicate Gazette Notification No. the situation. There is no need for 44 dated 1.3.1995 that it a clarification. Rather the new shall not be applicable to policy on distance education will the degrees/ diplomas help to clarify things. awarded by the 2. A highly discriminatory universities established clause; it seems this document by or under an Act of has been prepared to let a few Parliament or State universities and courses out of Legislature before 1985, the scrutiny of the assessing in the streams of authorities. Humanities / Commerce and Social Sciences. (xi)(a) The policy initiatives spelt out in succeeding paragraphs shall be equally applicable to institutions offering distance education/intending to offer distance education. (b) All universities and This point is in contradiction to institutions offering point (vii) above programmes through the distance mode shall need to have prior recognition/approval for offering such programmes and accreditation from the designated competent authority, mandatory in respect of the programmes offered by them. The violators of this shall be liable for appropriate penalty as prescribed by law. The universities/ institutions offering education through distance mode, and found involved in cheating of students/ people by giving wrong/false information or wilfully suppressing information shall also be dealt with strictly under the penal provisions of law. ( c) The universities / The term own study centre needs institutes shall have their careful definition. own study centres for face-to-face counselling and removal of difficulties, as also to seek other academic and administrative assistance. Franchising of distance education by any university/ institutions whether public or private shall not be allowed. (d) The universities/ What about open universities, institutions shall only which are single-mode offer such programmes universities? through distance mode, which are on offer on their campuses through conventional mode. In case of open universities, they shall necessarily have the required departments and faculties prior to offering relevant programmes through distance mode. (e) It would be mandatory This is a good initiative reflected for all universities and in the policy. education institutions The word mandatory should be offering distance replaced by ‘desirable’ in the education to use light of the ICT penetration and Information and access, especially among rural Communication and disadvantaged population. Technology (ICT) in the Technology should facilitate and delivery of their not become a barrier to access for programmes, such population. management of the student and university affairs through a web portal or any other such platform. The said platform shall invariably display in the public domain, the information about the statutory and other approvals, along with other necessary information about the programmes on offer through distance mode, their accreditation and students enrolled, year- wise, etc. This may be linked to a national database, as and when created, to facilitate the stakeholders to take a view on the recognition of the degrees for the purpose of academic pursuit or employment with/under them. (f) All universities/ This is a good initiative in the education institutions policy shall make optimal use of Who will do it? And how will it e-learning contents for be done? delivery/ offering their programmes through distance mode. They shall also be encouraged / required to adopt e-surveillance technology for conduct of clean, fair and transparent examinations. (g) The focus of distance This is a good initiative in the education shall be to policy provide opportunity of Who will do it? And how will it education to people in be done? educationally disadvantaged situations such as living in remote and rural areas, adults with no or limited access to education of their choice etc. (h) In order to promote This is a good initiative in the flexible and need- based policy. learning, a choice-based Who will do it? And how will it credit system shall be be done? promoted. All ODE institutions shall be encouraged to adopt this system, and evolve a mechanism for acceptance and transfer of credits of the courses successfully completed by students in the face-to- face or distance mode. For the purpose, establishment of a credit bank may be considered. Similarly, conventional universities offering face- to-face mode programmes shall be encouraged to accept the credits earned by the students through distance mode. A switch over from annual to semester system shall be essential. (i) Convergence of the face-to-face This is a good initiative in the mode teaching departments of conventional universities with policy. their distance education directorates / correspondence course wings, as also with open universities/ institutions offering distance education, shall be impressed upon to bridge the gap in distance and conventional face-to- face mode of education. (j) Reputed foreign i) The policy should give more education providers, well emphasis on the guidelines to established, recognised evaluate/ recognise/ accredit/ and accredited by manage the affairs of foreign competent authority in education providers. their country and willing ii) Foreign providers seeking to offer their education entry into Indian markets should programmes in India, be required to go through the shall be allowed, subject same domestic approval/ to the fulfilment of the accreditation process as the local legal requirement of the providers to ensure a level country. playing field. (k) A National Information How? Who will do it? and Communication Technology infrastructure for networking of ODE institutions shall be created under the National Mission on Education through Information and Communication Technology. (l) Efforts would be made to Who will make the efforts? create a favourable MHRD/ UGC/ AICTE/ DEC? environment for research And how? in ther Open and Distance Education (ODE) system by setting up infrastructure like e- libraries, digital database, online journals, holding regular workshops, seminars etc. (m) Training and orientation Who will do it? And how will it programmes for be done? Simply listing here educators and won’t work. administrators in the ODE system with focus on use of ICT and self- learning practice, shall be encouraged. (n) ODE institutions shall be Who will do it? And how will it encouraged to take care be done? Simply listing here of the educational needs won’t work. of learners with disabilities and senior citizens. (o) An official notification Who will do it? clarifying the issue of recognition of academic qualifications earned through distance model for the purpose of employment shall be issued. (p) A mechanism shall be set Who will do it? And how will it up for evaluation of be done? degrees of foreign universities for the purpose of academic pursuit as well as for employment under the Central Government. This may include t assessment of the credentials of the university concerned as also to test the competence of the degree holder, if needed.

The policy document has not included the following important and evolving requirement in the present day ODL environment:

 Recognition of prior learning and assessment of due credits to such experiences for academic study programmes.  Recognition of work-based skills/learning and their translation into equivalent credits for higher academic study.  Recognition process – institution-wise/ programme-wise  Types of institutions which can offer programmes.  Programmes that can be offered through distance mode.  Assessment and accreditation process, no mention of accreditation of programmes other than professional programmes.  Assessment and evaluation of students.  Networking and resource sharing.  Jurisdiction of Institutions.  Funding of ODL system.  Coordination and maintenance of standards of ODL – who will do it.  Quality assurance mechanisms.