India's National Education Policy 2020 - a critique

National Education Policy 2020 - Higher Education Critique

Ajay Shukla

Author Note

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Abstract

The overall diagnosis of what ails higher education in India in this policy document is quite rational and realistic. Fragmentation, poor learning outcomes, early specialization leading to rigidity, institutional autonomy, lack of ‘real’ research, poor governance and management. It however misses the commercialization and politicization of higher education as a ‘root cause’. Some of the recommendations are the culmination of the National Knowledge Commission report (during the NPA regime) and the Kothari Commission report. The standout features are - emphasis on large multidisciplinary universities with one in or near every district, moving undergraduate to a more ‘liberal’ multi-subject curriculum, revamp of outdated curriculum, pedagogy and assessment, merit based faculty appointments, establishment of the National Research Foundation, independence of the institutional boards with qualified appointees, rationalize regulation and increase access including through open and distance learning with IT tools.

Keywords: liberal, governance, regulation, independence, access, multidisciplinary, revamp 

National Education Policy 2020 - Higher Education critique

Prognosis

The decay in the Indian higher education system was precipitated by the previous education policy that put the onus of expansion and access in the hands of private players with little intervention on quality assurance, regulation and protection of the interests of the students, faculty and researchers. It led to a much higher Gross Enrolment Rate (GER) -a number that was an obsession with the government at that time. However, that gave an opportunity for private ‘diploma’ mill colleges to proliferate where the educational and research outcomes were ‘doctored’. This profiteering was aided and abetted by a corrupt UGC and AICTE bureaucracy that handed out educational licenses to private players for a suitable ‘consideration’. The rot was further deepened by a lax and bureaucratic National Academic Accreditation Council (NAAC) that gave approvals for dubious programs with no employability or research relevance. 

How deep is the crisis - through a reliable survey of private sector employers less than 20% of engineering graduates have the basic knowledge and skills to be absorbed by the industry and fit for re-training. Only 0.4% of the engineering graduates are directly employable by industry. Just a few years ago, 2013/14 - before the consolidation and shakeout in the engineering colleges due to poor employability happened - India was churning out 1 million engineering graduates - more than 3 times that of the USA! The quality of the graduates of the top 5% was less than the comparable graduates from the bottom 5% of the USA. I hope this shocks you all to take the enormity of the reform needed. 

India ranks quite high in the overall research output - 5th in the world as per some reports. However, under 16% of the research is published in global standard publications. Comparatively, this is less than half of the UK, USA and China. Therein lies the issue - due to reckless privatization of higher education, poor quality control of the research undertaken we have a self-fulfilling prophecy - poor academics guiding and assessing poorer quality research. A circular spiral to the bottom.

Analysis of NEP 2020 by theme

Institutional restructuring and consolidation

Consolidation of sub-scale colleges and universities into multi-disciplinary universities with a scale of 3,000 or more students. This is a brilliant idea and proposal to a) build a larger community of students, scholars and faculty which in turn promotes intellectual exchange and cross-disciplinary osmosis b) builds economies of scale - shared resources like labs, technology infrastructure, facilities both curricular and extra-curricular.  

This is not an easy endeavor to pull off through the stroke of a pen. It requires a careful, data driven analysis of the the geographies, current and future education disciplines envisioned, surgical decisions on closing facilities while expanding others, physical distance challenges due to consolidation and avoiding diminishing access and increasing inequity. There is of course the issue of power struggle on who will win the consolidation race will inevitably lead to concentration of power in the hands of few with a high likelihood of corruption, favoritism and crony capitalism -  “One reform leads to a palace of corruption” syndrome. How this will be avoided or minimised is left to imagination. The policy document does not elaborate or even offer any guidance.

The next recommendation is an evolution of universities into research intensive, teaching universities and autonomous degree awarding colleges. The university classification requires careful mapping and must include the university on the path they wish to take. This should be properly assessed through a neutral AND autonomous assessment body. The institutional mission and strategic plan will have to be recast and must have a democratic process of consensus with institutional leadership, governance and even students, faculty and scholars.

The move to allow colleges with autonomy to award degrees has the potential to be the ‘achilles heels’ of the proposed reform. One, a vast majority of nearly 50,000 colleges are simply ‘unfit’ to do so. In my opinion before embarking on this exercise the bottom 25% of the colleges - scientifically assessed on the appropriate past outcomes - should simply be closed or put on probation i.e no new intake till the quality measures up. Once this ‘cutting the gangrenous limb’ is done we can focus better on the gradation of colleges that are ready for autonomy, those that are on the margin and are better controlled through a university affiliation process and as they evidence readiness for autonomy they can be given the choice of degree awarding powers. This could even be by programs - ie. Those that have achieved maturity and outcomes could be fast tracked for degree awarding and those that are lagging could be controlled by the affiliated university. The best model for this is the University of London and how it devolved the degree awarding to the individual colleges - e.g. King’s College, London, London School of Economics, London Business School and School of African Studies (SOAS).

The other idea - HEIs to engage with the community although stated is under-emphasized. This is a must. If we look at the world’s most reputed universities, the standout feature is how they engage with the immediate community. For example - developing and supporting local industry through innovation and research, opportunities for scholarship to gifted and talented youth, establishing innovation centers actively supported by local and industry, curriculum inputs and academic collaboration with employers, job-internships and work-study projects, visits/tours/talks for school children to foster inspiration and aspiration for higher education are some outcomes that could galvanize an entire ecosystem around the host HEI. As always, the devil is in the detail and often a product of the HEI’s leadership and vision. That is why the complex challenge of the proposed reform must take into account the multiple factors that lead to the realization of the vision. 

Enhancing the gross-enrollment-rate (GER)

The policy now recognized the ill-conceived ideas of the previous policies - e.g. creation of categories within universities - e.g. ‘deemed to be university’, ‘affiliating university’ etc. There is only one universal definition of university - one that is multi-disciplinary and is a home to students, scholars, researchers and faculty for high quality teaching and research. Simple. This was the reason for the fragmentation and poor quality GER. With the consolidation proposed above the policy aims to correct this. But it will be a decade before we see the real impact considering the low point we have reached. 

The other mistake that is being corrected, and has to be read as a subtext in the policy document, is expansion of public HEIs (existing and new) and expansion of ‘scale’ HEIs after consolidation. This idea must be pursued with vigor and determination. Public universities in a diverse country like India with serious challenges on access, affordability and inequality must leverage HEIs to lift the weaker sections of society over the ‘education opportunity discrimination’ that has led to concentration of power, resources in the hands of the creamly layer elite. A recent survey says that if you have a household income of >35,000 Rupees a month you are in the top 10% of India’s income bracket. How shameful is that. We cannot lift the 90% to an acceptable level of income without at least one member of the family with a higher education qualification. 

The policy direction of Open Distance Learning and Online Programs is also an idea whose time has come. In addition to providing access, lower cost Online and Distance Learning provides a) power of knowledge and skills building in the hands of the learner b) Promotes lifelong learning especially in rapidly changing and emerging areas c) Transparency and competition leading to a superior program - no longer can HEIs offer substandard programs away from the gaze of the public and have to compete on a global landscape and not benefit from monopoly over students within the geographic catchment. The quality of the online programs and degrees are expected to be of the standard and quality of the classroom programs and hence will be a ‘quality’ signal to the students.

Inclusion of professional education within the HEI framework is also a good move as a) Removes the multiplicity of professional bodies like MCI, Bar Council and b) forces HEIs to remain relevant to the workplace and community c) constant updation of the knowledge resources on the basis of current trends and needs and supply requirements e.g. India’s doctor/population ratio is currently below that of much poorer sub-saharan African countries.

Holistic education

As expected, this aspect of the policy is full of rhetoric in its opening section but devoid of that there are some excellent policy directions. Some notable ones that struck the author are:

1. Emphasis on building capacity through departments to provide options to pursue arts, literature, philosophy, Indology, dance, music, performing arts, public service
2. Curricular structure to allow for ‘liberal’ and holistic education with multiple entry and exits eg. 1 year diploma, 3 and 4 year degree (4 year preferred) and creation of a digital Academic Credits Bank to help students even transfer to another university or have the option of the extra year to pursue liberal subjects and even research.
3. The elimination of the M Phil program is a good direction on paper but can only work if the masters programs have a mandatory curriculum component of research based credits. This research should be assessed with the similar rigor as that of a PhD candidate to create, nurture and build research methods, technique and process at an early age thereby creating the competency pool for academic research.
4. Building of innovation/incubation/tech development centers within the consolidated HEIs is again an excellent direction. These should involve co-optive resources, mentoring and support from the industry. I have seen many innovation centers with ero footfalls because they thought: “build it and they will come”. 

Learning Environment

The key aspects are independence and innovation in pedagogy, building capacity within student support through sports, fitness, psycho-social wellness. This has been absent and I foresee that while this will take roots after the consolidation but will be a frontline department within universities. 

Choice Based Credit System to encourage criteria based learning outcome and grading system and move away from high stakes summative assessments. This is an excellent direction and if implemented well could reduce exam pressure/anxiety and place the emphasis, rightly, on consistency of the knowledge and skill building in a formative way instead of ‘cram-exams’.

Online learning to supplement classroom i.e. blended learning or even offered as an independent ‘100% online’ program will also lend flexibility, This should be welcomed. The readiness of instructors to build high quality online programs is a serious gap and this requires professional development, provision of technology tools and partnerships with local and global technology companies to jump start.

Internationalization

Beyond the rhetoric of India being a ‘Vishwa Guru’ - a quite unnecessary and rather political insertion into this section should instead have spoken about our tradition of cross border scholarship e.g. Nalanda, Takshshila  and the success of IITs and IIMs that were built on a vision of academic collaborations with the best universities in the world. 

Unfortunately, this aspect of the policy is hastily or ignorantly conceived. This is perhaps due to the ‘babus’ themselves not knowing enough about transnational education (TNE) or even seeking expert input from outside. In all, it was very disappointing especially after the scrapping of the Foreign Education Provider (FEP) Bill from the UPA regime time.

What is right about this specific area - 

High performing universities setting up campuses abroad. This must include the likes of IITs and IIMs and other government controlled universities who are currently not allowed or encouraged. Remember, the IIT Delhi director was forced to resign by the ‘Yale Graduate’ MHRD Minister for a simple collaboration with Maldives to help set up an engineering program. What an abominable crime! 

International Branch Campuses (IBCs) of top 100 universities. If we look at TNE destinations like UAE, Malaysia, China - they have evolved different models and approaches but through transparent and clear rules and laws on ownership, governance, academic autonomy, local university collaborations and quality assurance. This should be the guidance from the policy and not setting the stake on the ground with a motherhood ‘top 100 universities’ only. Top 40-50 universities are highly unlikely to set up international campuses and often universities have flagship programs that would rank in top 100 but not the university as a whole. Let us do a reality check, counting the tenured IITs, IIMs and select top public universities in India - the next tier of universities do not even compare with the top 500 or even top 1000 universities in the world. We need to evolve a more realistic and sensible policy that balances the need to grow local HEIs but welcoming international universities.

Overall the aspect of internationalization is poorly conceived including the student mobility and research collaborations that are mentioned only in passing. The right approach would be to set-up Academic Free Zones in important skill clusters, encourage JVs with local investors, mandatory local license and accreditation and ensure fees, quality, sustainability are regulated through a clear and consistent set of rules. Also, there should be no ‘top 100’ type limitation. Any university in the top 500 should have a fast-track process and any university beyond that should be on a case by case basis. A branch campus specific executive department should be set up to attract and regulate international universities of repute.

Financial support for students

This objective is certainly laudable in its vision of not denying access to higher education due to financial inability to any student. I believe some directive for institutions to reserve a certain % of fee revenue towards, means-tested, deserving students would have made the intent more explicit. A transparent scholarship portal is also an excellent proposal.

Faculty development

Faculty initiatives include a) flexibility in designing the curriculum and pedagogical delivery within the overall course framework b) Set standards for faculty qualifications and achievements for recruitment c) Dedicated faculty to ensure commitment and engagement d) Defined student to teacher ratio ie between 20:1 and 10:1 e) Merit based rewards and promotions f) University leadership should be accomplished and administratively adept.

All these ideas are not new but to be explicit is a step forward. I however feel that university leadership often follows the ‘Peter Principle’ where people rise to their level of incompetence. To be blunt - university administrative leaders are often highly tenured professors who haven’t taught for a while or published original research but are articulate and politically savvy. This must stop and mechanisms must be in place to deter political appointees as we have seen recently in top public universities like JNU. Also, university leadership should not be an exclusive preserve of academics - there should be lateral talent from the broader educators community who have served the education sector in non-academic capacities. 

Equity and inclusion

The policy has very explicit prescriptions including half of the government budget allocated to special economically deprived groups and setting up of clear goals for increasing GER within this segment. There is also guidance to HEIs to include SEDG goals within their strategic plan and making provisions for bridge courses. All these proposals are excellent but as always the implementation without political and corruption considerations is key.

Teacher Education

These directives recognize the problem of commercialization, proliferation and quality. Justice J S Verma Commission report of 2012 concluded that most of the 10,000 teacher training colleges are diploma mills exchanging fees for degrees to have teachers secure a job in a public school. The proposal to have teacher education qualification, a4 year integrated B Ed with subject proficiency as a core component, as a minimal qualification by 2030 is laudable and directionally good. Another provision is for a national test of eligibility for teachers is again an excellent provision. Inputs and support from global agencies proficient and proven assessment of teachers must be sought to ensure consistency and scientific proven assessment should be actively sought.

Use of technology platforms for continuing professional development through a portal is also an excellent provision.

Vocational education

Vocational education - having worked in this sector for over a decade - requires addressing:

1. Removing the stigma associated with vocational training
2. Equivalence of skills with a degree program
3. Careful and constantly revamped alignment with labor market demands
4. Regionalization of vocational training to serve the local labor market and diminish migration that breaks families and urbanization 
5. Introduction of mandatory vocational programs as part of K-12 and HE course offerings
6. Validation of curriculum and employment mandates from industry e.g. no plumber, surveyor, brick-layer shall be employed by real-estate companies unless they possess professional qualifications related to their jobs
7. Practice based and knowledge based rigorous skills assessment by independent agencies
8. Rewarding learners for success and subsidizing the vocational training on outcomes (qualifications) and not process (attending classes)

To my mind a significant number of these issues have been recognized and addressed by the policy but a clear demarcation of the rule setting, outcome and quality assurance by the government but having a free market for everything else should have been encouraged in the policy.

Professional education

This area has been besieged with multiple agencies like MCI, Bar Council and an outdated curriculum and quality guidelines. To bring these rapidly with the technological and knowhow enhancement is badly needed. In healthcare and allied healthcare education there is a serious gap in supply as well as quality - this is fundamental to a healthy and productive society. The policy is strangely silent on this area. 

Further professional education should recognize the digital age and to compete globally as a talent source the best way would be to strengthen IIITs or create mandatory departments within multi-disciplinary universities for Digital Sciences and Technology and Bio-technology and Sciences. This would have been more specific and recognize the urgency and need.

Research

The formation of the National Research Foundation (NRF) is an excellent proposal and much needed since our research spending is amongst the lowest in the large economies - 0.7% vs South Korea (4.2%). While the recommendations are in the NEP 2020 but a further recognition of the need should also involve large corporates. For example, all companies above INR 1000 crore of turnover should be able to spend up to 2% of revenue for R&D including by way of contribution to NRF and claim a tax rebate on such contributions. Let us hope something similar emerges as the charter for NRF is defined. The outcomes of NRF are well defined eg. peer-reviewed publishing, industry and government engagement and recognition and rewards.

Leadership and governance

Institutional autonomy, a defined system of governance, transparent and merit based appointment of governors and institutional leadership are critical to success. Fortunately, the policy recognizes these aspects but how will political appointments be avoided is a moot point. We have seen degeneration of reputed universities like JNU due to the politicization of leadership and governance.

The constitution of a single authority National Higher Education Regulatory Authority (NHERA) has been the crying recommendation for the past 20 years from various education policy review proposals and finally it is being addressed. I will say no more other than - lets wait to see the charter of NHERA.

HE sector transformation 

 The policy recognizes, again, the ills like the tough requirements for setting up HEIs leading to corruption and input-centric requirements eg. land, building, facilities, books leading to license raj. Some of the best universities in the world like LBS or LSE would probably fail the Indian HEI requirements!

NHERA is mandated to review and change these requirements and make them more outcome focused. Let us see the provisions - but the fact that the policy is directing this change is more than welcome.

UGC again has been corrupt, full of favoritism and inspector raj driven. A simple reconstitution as Higher Education Grants Commission (HEGC) will not serve the purpose. There has to be an overhaul and ‘rewriting the book’ for HEGC. As I once said after my numerous visits to Shastri Bhavan - “The only way to build a vibrant education sector is to raze the building (proverbially) to the ground, get rid of all the dead-wood bureaucrats starting at the top and then re-imagine education as we did when the country became independent”. 

The other ill is treating private individuals and education leaders from the private sector as adversaries. This rot is deep especially with the bureaucracy. In the end we are all citizens of India and the well-being of the nation, nation building is a common goal. As long as the expertise is welcomed and does not lead to promotion of private interest such a participatory process should be welcomed and institutionalized. Sadly, this is unlikely to happen due to power grab and insecurities at all levels - political and bureaucracy. 

In summary - the Higher Education policy gets a resounding thumbs up from me with the proviso that the implementation would be a challenge. However, so long as the rules, regulations and the compliance mechanism is ‘light but tight’ the market forces will ensure capacity, quality, access and excellence. Unshackle Higher Education and make it corruption and political influence free and we will see a transformation within 10 years. The country has the talent, vigor of youth and an aspiration to be a global leader - we can realize it.

References

Bridge Labs Solutions LLP - Employability Survey 2019

Aspiring Minds Employability Report 2019

J S Verma Commission Report 2012

National Knowledge Commission Report 

Kothari Commission Report