Tuesday, January 7, 2014

My reply to UGC on its request for suggestion on draft regulation on distance education

Dear Friends,

I came to know about UGC's planning to establish an independent body to regulate distance education after DEC and DEB.They are pllaning to establish Distance Education Council of India (DECI) and I found the effort as half hearted. You may refer the entire draft on following weblink:


The effort is poor and disappointing. I have replied them as follows. My reply is also message for those people who feel that I am against distance education which is not true. Please respond with your comment on my reply

January 06, 2014

Shri Vikram Sahay
Director (Administration)
University Grants Commission
New Delhi- 110002

Through email: vikramsahay.edu@nic.in

Subject: Suggestion on regulation regarding draft of “regulation regarding open and distance learning institution and programmes of study, 2013”

Dear Sir,
I read UGC’s notification on its website ugc.ac.in and came to know that you have asked for suggestion by January 03, 2014. I sincerely apologize for sending this after your specified deadline but if you are really want to take people’s feedback then I hope this will be useful to you.

Before starting to write on the above mentioned subject, I have few questions to UGC through you as a medium/ source.
1.       What has UGC done in all these years to provide assistance to distance learner and other students? In most of the cases, you even did not bother to reply to RTI query carefully and in last 12+ years, I never got a single reply on any mail sent to UGC including to its directors, secretaries and chairman. Should we still believe in your intention to reform education?
2.       The quality of education is not at par all across the country. There is no uniform syllabus, no uniform evaluation system. A 75+ % scorer in a particular state even cannot perform more than 50% score in another university.
3.       You talk about similarity of a full time degree and a distance learning degree, have you seen the reality? Bar Council of India does not allow a graduate through Open University System to pursue LLB full time (95+% law graduates are low in quality and most of them are from formal schooling system with 10+2+3 degree). A deemed university like NMIMS does not accept distance learner for its Ph.D programme. IBPS does not allow a distance MBA holder even to compete (and I can bet with such useless policy makers that a distance learner MBA with work experience in the corporate world are much better manager than those who are graduated through C grade B school who do not have knowledge of practicality of the business).
4.       UGC, DEC, AICTE have done nothing more than framing policies. You give excuse of lack of manpower but such excuses are useless. Let me tell you, I am a full time working professional and work for world’s one of the best MNC full time. I head its HR and Administration department. Still, I have time to write blog exposing these universities involved in degree scams and selling degrees at a price. Then, how come you simply cannot monitor? Forget about monitoring, you even did not bother to reply on such mail exposing these degree selling universities.  Everyday, more than 5000 people read my blog and many ask queires. Isn’t it your responsibility to do this? How much manpower it requires? Even if you keep 5 full time such employees as an executive, it does not cost more than 5 lakhs per month including all expenses. Do not you have budget to spend this much to save student’s future?
5.       How DEC and UGC allowed a non university to offer distance learning courses (SCDL, Welingkar, IMT etc.) out of these, Welingkar and SCDL like institutes spending money like water in advertisement and misleading students by saying that their paper print diplomas are management programme. You publish advertisement saying IIPM is a fake institute and I do not doubt it then how you forget SCDL, Welingkar, ITM Kharghar (who offered executive MBA for years without any approval in distance mode). There are many such institutes.
6.       Many distance learner students do not get job opportunities in teaching as indirectly, they are turned down by colleges. What have you done to protect their interest other than just publishing a notice/ circular?
7.       Private universities like CMJ, MGU Shillong, EIILM, Manav Bharti, Monad, Shridhar, Manav Bharti, Jaipur National, Jodhpur National, Venkateshwara Open University, Swami Vivekanand University, C V Raman are openly selling degrees (there are many more) and private universities like Sikkim Manipal, ICFAI, LPU are openly violating and offering degrees through franchisee, what monitoring are you doing to maintain the quality? You even did not bother to take strict action against KSOU, PTU and other errant state universities. I sent a mail few months back to Dr. Nalini Lele about how University of Madras’s Mumbai centre was offering mass copying and sure success in a degree for 50,000/ - Neither you nor Madras University to contact me back or to respond and such private centre with the approval of university still running.
8.       You talk about non- acceptance of distance learners by corporate so before drafting this, have you contacted corporate people including human resources professionals? Well, its not true that corporate do not accept distance learning degrees. We do but we are careful about it. CA, CS, ICWA, CPA, CFA all are offered in distance mode and widely accepted. I have handled recruitment for many years and in my previous organization which is a healthcare MNC, I was incharge for overall recruitment process. I preferred a B.Sc. graduate from IGNOU and YCMOU over a regular full time of Mumbai University. This is because I am aware about rigorous process of awarding degree. Yes, I never accept qualifications from the universities involve in degree scam. You need to look into these aspects first.

You really need to think about it instead of bringing a law every 2-3 years after.

Now, let me provide feedback on your so proposed regulation.

Point no 2.1.a.II is a welcome move. However I suggest that only those institutes who got A status from NAAC after completing 10 years of conventional education should be only allowed to offer courses in distance mode.

Point no 2.1.a.III: Please add that alongwith the parent state government approval, approval of the state government as well as open university/ conventional university of that particular area is also mandatory. Opening of such study centre should be allowed only if no other alternative is available on those area. For instances, Mumbai University offers BA, B.Com, MCA etc. in distance mode but does not offer B.Sc. in life sciences and natural sciences. So approval must be granted for those programmes not available only.

Point no 2.5
You have missed an important point here. Many universities in open mode (IGNOU, YCMOU, KSOU, MANUU, TNOU, Andhra University, SNDT University to name few) where someone completed 18 years of age, who can read and write but does not have 10+2 or any previous qualification can pursue various degree like BA, BBA, B.Com, BTS etc. Bar Council of India does not accept such degree although the exam, evaluation is same as of the conventional mode. Even few other universities do not accept such qualification. You must frame a guideline on this. My suggestion is: There should be bridge course of 3 years which can go concurrently with the degree programme. It should be stringent and should be same as secondary and senior secondary syllabi based on NIOS (National Institute of Open Schooling) methodology. Just sending circular to universities requesting to accept distance education degree does not help. You must set up a cell to receive grievances from the students and you must reply to every mail, every complaint sent to UGC. Otherwise shut down this money making machinery, a centre house of corruption in higher education.

Point no. 2.6
Please illustrate and mention it clearly what do you mean by self learning materials? Printed, video, multimedia, ICT? In that case please explain ratio also. If I copy paste from internet and print, publish it with some pictures, will it be a self instructional material? 90% of the universities are doing this way only. There should be condition that the syllabus need to be updated within a specified period. There should be compulsory internship for every programme.  There must be provision that the SLM (self learning materials) must be approved by UGC and the agency (DEB)

Point no. 2.9.2:
When you say franchisee of higher education not allowed, then why are you specifying that learner centre cannot admit students. Every state or private universities have appointed these franchisee. They accept DD in the name of the university only but they distribute study materials, they distribute hall tickets, they conduct examination. These lead to malpractices and selling of degree. There should be following conditions:
1.       Every university should have its own regional and study centre and all staff should be on roll employee of the university. The examinations must be conducted, supervised by the university staff only. However, the university may take help of the conventional/ open state or central (no private and deemed) university in the region.
2.       All the ODL institute must send list of students enrolled with name, course, their address to UGC. UGC must have an online system where after entering a specific no say PNR (permanent registration no) anybody can verify authenticity of the degree and the institute. This will save students. This system should be managed and controlled by UGC or proposed DECI.

Point no 2.10
Please add that no private person / body/ company/ institute/ partnership firm . It must be run by a college and university department  All the staff in learner’s support centre should be on roll employee of the university offering distance education.

Point no. 2.11
You have missed important point here. For dual mode universities (those offering distance as well as conventional degree) the question paper, evaluation of the distance learning programme should be same as of the conventional. For instances, University of Mumbai has 20 marks internal assessment for each subject and 80 marks main exam however for distance learners it is 100 marks theoretical question. Further, 1st and 2nd year degree exams are conducted by colleges deciding quarter portion of the book for each trimester however for distance learner, they have to read full books and appear for exam at end.

2.13  About pursuing M.Phil and Ph.D through distance mode
The condition you have put is not sufficient and may lead to producing junk and fake Ph.D degree. It should have following conditions:
1.       Over and above than the UGC specified minimum qualification for Ph.D and the regulation for Ph.D, one must have minimum 5 years work experience post the post graduation qualification.
2.       The institute/ organization where someone is working must provide certificate saying they have enough facility to conduct the said research.
3.       UGC must approve the research topic and the DECI must issue eligibility of pursuing Ph.D from that particular university and both UGC and DECI must have data of all people pursuing research degree.
4.       A student staying beyond the area of 200 Kms of the university from where he/she is applying for Ph.D should not be allowed. This will help to prevent Ph.D scam run by EIILM, CMJ, Bhagwant, Swami Vivekanand, Monad and many such other private universities. Once UGC and DECI issue the eligibility certificate to pursue the Ph.D then in any case, it should be acceptable and valid in future also. The eligibility certificate must mention name of the Ph.D research topic and name of the university. UGC and DECI must certify that the Ph.D coursework and research topic is original (and if UGC cannot do it, what the hell you are doing to produce quality research and quality research scholars). Wherever required joint approval of AICTE/ NCTE / NCI / Ayush etc. will also be required.

You have missed out point like which programme cannot be offered in distance mode. You must clarify on this too.
I hope you are sincerely committed to produce quality institute.  Also, you should make provision that a new institute will be allowed to offer only vocational and job oriented courses and the courses which are not available with existing universities.

Govind Sharma

MA, MBA, M.Phil, CRTI, PGDHRO, LLB (Pursuing)
Manager- Human Resources and Administration in a leading US MNC
Enthusiastic blogger, educationist, career counselor, die heard researcher on ODL and a common citizen

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