Only those programmes, which do not involve extensive ...



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 proposed policy |Observations |

| |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, which do not involve |Programmes and extensive practical work need to be specified. |

| |extensive practical course work, shall be |If it means programmes in Science and Technology, this point is |

| |permissible through the distance mode. |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. |

| | |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. |

| | |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. |

| | |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. |

| | |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. |

| | |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. |

| | |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? |

| | |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 shall frame ordinances /|Universities/ institutions shall frame ordinances / regulations / |

| |regulations/ rules, as the case may be, spelling out|rules, as the case may be, spelling out the outline of the |

| |the outline of the programmes to be offered through |programmes to be offered through the distance mode indicating the |

| |the distance mode, indicating the number of required|number of required credits, list of courses with assigned credits,|

| |credits, list of courses with assigned credits, |reading references in addition to self learning material, hours of|

| |reading references in addition to self learning |study, contact classes at study centres, assignments, |

| |material, hours of study, contact classes at study |examination and evaluation process, grading etc. which should be |

| |centres, assignments, |as per norms prescribed by the Distance Education Council (DEC). |

| |examination and evaluation process, grading etc. | |

|(iii) |DEC of IGNOU shall only assess the competence of |1. Word ‘only’ has to be deleted. Also It is not clear whether the|

| |university/institute in |assessment is to be done programme-wise or institution-wise. |

| |respect of conducting distance education programmes |2. DEC should be made a statutory body for open and distance |

| |by a team of experts, whose report shall be placed |education in the country, and not merely a body to access the |

| |before the Council of DEC for consideration. |competence of university/institutions. |

|(iv) |The approval shall be given only after consideration|The phrase “…. and not by the Chairperson DEC” should be deleted. |

| |by the 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 under section 20 (1) of the|The accreditation should be done by the DEC and not AICTE alone. |

| |AICTE Act 1987 to ensure accreditation of the |DEC may devise policy guidelines and do accreditation of ODL |

| |programmes in Computer Sciences, Information |providers by involving members drawn from respective Councils as |

| |Technology and Management proposed to be offered by |per requirement of the programmes on offer. AICTE as a body should|

| |an institute/university through the distance mode, |not supersede DEC as DEC is the agency mandated to develop and |

| |by National Board of Accreditation (NBA). |maintain standards for ODL. |

|(vi) |UGC and AICTE would be directed under section 20 (1)|The norms for various technical/ other programmes have already |

| |of their respective Acts to frame detailed |been developed by DEC in consultation with the respective |

| |regulations prescribing standards for various |councils. In case the norms are to be revisited, then it can only |

| |programmes/ courses, under their mandate, offered |be done with active involvement of DEC. |

| |through the distance mode. |In any case NBA can only 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, except the universities |1. What is the basis for the cut off date? |

| |established by or under an Act of Parliament/State |Rather it should be framed as “... No university/ institute shall|

| |Legislature before 1985, shall offer any programme |offer programmes through distance education mode, henceforth |

| |through the distance mode, henceforth, without |without prior approval of the DEC.” |

| |approval from DEC and accreditation by NBA. However,|2. The restriction put on universities/ institutions established |

| |the universities/ institutions already offering |after 1985 is absolutely arbitrary. This clause is discriminatory |

| |programmes in Humanities, Commerce / Business / |to the universities established after 1985. It also discriminates |

| |Social Sciences / Computer Sciences and Information |against the universities that offer certain programmes. |

| |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 Apex Court, ex post facto|1. Looking at the hardship imposed on the students who have |

| |approval granted by any authority for distance |acquired degrees through the distance mode, the DEC has put in |

| |education shall not be honoured and granted |place a mechanism for post facto approval. A definite cut off date|

| |henceforth. However, the universities established by|be fixed for institutions to apply to DEC for the same. |

| |or under an Act of Parliament or State Legislature |2. This clause is discriminatory to the Universities established |

| |before the year 1985 and offering distance education|after 1985. It also discriminates against the Universities that |

| |programmes in the streams of Humanities / Commerce /|offer programmes other than humanities/ commerce/sciences”. |

| |Social Sciences before the year 1991 shall be | |

| |excluded from this policy. | |

|(ix) |The students who have been awarded degrees through |It is not clear who the examining agencies will be, when and where|

| |distance mode by the universities without taking |would be examination conducted, whether it would be a single |

| |prior approval of DEC and other statutory bodies, |examination applicable to all, or would different exams be |

| |shall be given one chance, provided they fulfil the |conducted for different institutions. |

| |requirement of minimum standards as prescribed by |Further, there are lacs of students who have acquired their |

| |the UGC, AICTE or any other relevant statutory |degrees/ diplomas/ certificates through distance mode. How |

| |authority through regulation, to appear in |practical will it be to examine the competence of all these |

| |examinations in such papers as decided by the |students? |

| |university designated to conduct the examination. If|Is there a similar procedure to examine the students who have |

| |these students qualify in this examination, the |acquired their degrees/ diplomas/ certificates from conventional |

| |university concerned shall issue a certificate. The |universities/ institutions? |

| |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 issued with reference to |1. In the light of points raised above, it will further complicate|

| |Gazette Notification No. 44 dated 1.3.1995 that it |the situation. There is no need for a clarification. Rather the |

| |shall not be applicable to the degrees/ diplomas |new policy on distance education will help to clarify things. |

| |awarded by the universities established by or under |2. A highly discriminatory clause; it seems this document has been|

| |an Act of Parliament or State Legislature before |prepared to let a few universities and courses out of the scrutiny|

| |1985, in the streams of Humanities / Commerce and |of the assessing authorities. |

| |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 institutions offering |This point is in contradiction to 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 / institutes shall have their own |The term own study centre needs careful definition. |

| |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/ institutions shall only offer such|What about open universities, which are single-mode universities? |

| |programmes 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 for all universities and |This is a good initiative reflected in the policy. |

| |education institutions offering distance education |The word mandatory should be replaced by ‘desirable’ in the light |

| |to use Information and Communication Technology |of the ICT penetration and access, especially among rural and |

| |(ICT) in the delivery of their |disadvantaged population. Technology should facilitate and not |

| |programmes, management of the student and university|become a barrier to access for such population. |

| |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/ education institutions shall make |This is a good initiative in the policy |

| |optimal use of e-learning contents for delivery/ |Who will do it? And how will it be done? |

| |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 education shall be to provide |This is a good initiative in the policy |

| |opportunity of education to people in educationally |Who will do it? And how will it be done? |

| |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 flexible and need- based |This is a good initiative in the policy. |

| |learning, a choice-based credit system shall be |Who will do it? And how will it 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 mode teaching |This is a good initiative in the policy. |

| |departments of conventional universities with 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 education providers, well |i) The policy should give more emphasis on the guidelines to |

| |established, recognised and accredited by competent |evaluate/ recognise/ accredit/ manage the affairs of foreign |

| |authority in their country and willing to offer |education providers. |

| |their education programmes in India, shall be |ii) Foreign providers seeking entry into Indian markets should be |

| |allowed, subject to the fulfilment of the legal |required to go through the same domestic approval/ accreditation |

| |requirement of the country. |process as the local providers to ensure a level playing field. |

|(k) |A National Information and Communication Technology |How? Who will do it? |

| |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 create a favourable |Who will make the efforts? |

| |environment for research in ther Open and Distance |MHRD/ UGC/ AICTE/ DEC? And how? |

| |Education (ODE) system by setting up infrastructure | |

| |like e-libraries, digital database, online journals,| |

| |holding regular workshops, seminars etc. | |

|(m) |Training and orientation programmes for educators |Who will do it? And how will it be done? Simply listing here won’t|

| |and administrators in the ODE system with focus on |work. |

| |use of ICT and self-learning practice, shall be | |

| |encouraged. | |

|(n) |ODE institutions shall be encouraged to take care of|Who will do it? And how will it be done? Simply listing here won’t|

| |the educational needs of learners with disabilities |work. |

| |and senior citizens. | |

|(o) |An official notification clarifying the issue of |Who will do it? |

| |recognition of academic qualifications earned through| |

| |distance model for the purpose of employment shall be| |

| |issued. | |

|(p) |A mechanism shall be set up for evaluation of degrees|Who will do it? And how will it be done? |

| |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.

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