Regulatory Issues in the School Accreditation and Standard Setting Mechanism Under the National Education Policy 2020

This essay attempts to analyse the major regulatory concerns arising from the newly proposed systems for school accreditation and standard setting under the National Education Policy (NEP) 2020. The highlighting of these concerns shall be complemented by policy proposals to address them.

Before beginning the analytical section of the essay, it is necessary to clarify the meaning of “accreditation” and the mechanisms that having an accreditation system entails. This is because it is often conflated with affiliation. Affiliation is when a school is formally affiliated to a particular board of education whose curriculum and other educational practises the school subscribes to. While affiliation does involve some degree of standard setting, its purpose is inherently different from that of accreditation. One should think of it as a license to operate. However, in India school board affiliation is often considered a marker of credibility primarily because certain school boards have a better reputation when it comes to quality. On the other hand, accreditation means getting a certificate of credibility from an authorised body stating that the institution in question follows the standards that have been set by the accrediting body. Such certification is ideally given after an external assessment by a review team, which examines whether the school is following the standards and processes as claimed. The point of this exercise is that such certification would boost the credibility claims of the school and increase the parents and students’ confidence in the school.

At present in India, there are two institutions carrying out accreditations. The first is the National Accreditation Board for Education and Training (NABET), which is a constituent body of the Quality Council of India, and the second is the CBSE. Both of these institutions have differing approaches, use different standards and examine different aspects of a school in their accreditation process. NABET carries out accreditation for all kinds of schools, regardless of board affiliation while CBSE does it only for schools affiliated to it. NABET evaluates schools on three extremely broad parameters: school governance, education and support processes, and performance measurement and improvement. The CBSE evaluates schools on seven specific parameters: scholastic process, co-scholastic process, infrastructure, human resources, management and administration, leadership and beneficiary satisfaction.

By and large the culture of accreditation does not exist in India beyond the urban centres, and there too it is mainly a phenomenon with schools catering to the upper middle class and upper class. In the present context, it is most likely that parents would have to rely on general public opinion and hearsay while choosing a school. Before proceeding with the analysis, it is important to state that school accreditation and standard setting remain an under researched topic in India. As a result, one has to rely on publicly available commentary from sectoral experts and stakeholders to carry out this analysis.

Under the prevailing education system, the task of ensuring minimum standards and school regulations is under the departments of school education of various states and UTs. These bodies use a command-and-control approach when regulations are not followed wherein, they utilize their regulatory authority to either take away the school’s state board affiliation and recognition or by suspending the school’s license to operate. This approach has been condemned on account of rampant, often whimsical, overregulation where political issues and equations are the driving factor rather than issues in the schooling sector. Such overregulation has acted as a major roadblock to innovation and transformative service delivery by education entrepreneurs and has hampered the flow of private capital into the sector. Moreover, the departments of school education are also tasked with a range of other tasks, including framing policies and running the state government’ schools, and this generates criticism on account of potential institutional conflict of interest. The NEP document also claims that the existing framework failed to control commercialism and was a roadblock for philanthropic schooling initiatives.

The State’s response via the NEP to the aforementioned issues is to decentralize the departments’ regulatory authority and, in their stead, envisioning new standards authorities for each state – the State School Standards Authorities (SSSAs). These new authorities are supposed to frame minimum standards on a range of key issues like student safety, infrastructure, school fees, etc. and ensure adherence to these standards through a system of self-disclosure by the schools. The precise parameters that shall be used to gauge these issues are to be created after thorough negotiations with “all stakeholders”. The proposed system is to be a form of accreditation given by the SSSAs, on the basis of the schools’ regular self-disclosures on the online and offline domains. The SSSAs are also responsible for dealing with stakeholder complaints arising from the public disclosures. The stated aim of the NEP here is to accord legitimacy and reward schools for seeking to achieve accountability in the public domain. Besides these aforementioned minimum standards, the monitoring and assessment of the academic standards to be maintained by schools is to be done in accordance with a “School Quality Assessment and Accreditation Framework” (SQAAF), whose parameters are to be developed by the state’s SCERT in coordination with the NCERT and after consultation with “all relevant stakeholders”. It is important to take note of the fact that the NEP does not clearly demarcate the “stakeholders” to be taken into confidence for all the aforementioned consultations. 

While the NEP’s suggestions on accreditation and standard setting have been commended for attempting to introduce a progressive culture of accreditation into the Indian schooling sector, there are certain concerns that are yet to be addressed. The biggest issue lies with the NEP’s proposed system of periodic self-disclosures, where there seems to be no scope for any kind of external evaluation to claims that shall be made by schools. This raises the concern of how the proposed system of disclosures shall match up in terms of credibility and validity against a system that includes external evaluations. Moreover, in relation to the proposed system, there is no clarity on what the “dispute resolution” process would entail when stakeholders question the validity of the schools’ claims in the disclosures. As a result of these concerns, one believes that in order to improve stakeholder confidence in the standards framework, the proposed system ought to have an in-built mechanism for external evaluations, which could be annual, biennial or even wholly randomized.

Another issue relating to the accreditation framework concerns the specific challenge posed by low cost/low budget schools. While it is well known that the proliferation of such schools has driven private school enrollments to reach almost 50% of all enrollments, the proposed framework does not pay specific attention to serious quality issues with such schools. While the NEP has promised to look at issues like student safety and focus on learning outcomes in its standard setting approach, it is necessary that the specific limitations faced by low budget private schools be incorporated into standards frameworks in order to make it practically implementable on ground.

While the state has through the NEP, quite admirably, stuck to the idea of federalism by proposing a decentralized standard setting and accreditation regime under the aegis of the state level SSSAs, the lack of any kind of uniformity in minimum standards across states is a concern. Having looked at the stark differences between the two existing NABET and CBSE accreditation frameworks, one can rationally argue that the frameworks to be followed by the proposed SSSAs in their accreditation mechanism are likely to have similar differences which shall be determined by the states’ contexts. Furthermore, leaving the specific parameters open to being influenced by stakeholders, including those having vested commercial interests, raises a host of related concerns. Looking at these issues from the lens of private interest theory, one can anticipate situations where stakeholders like parents and teachers are not organized and hence their interests could go unrepresented. Thus, their legitimate interest could suffer as profit seeking commercial interests in the sector influence the parameters of the standard setting framework in order to gain regulatory rents. Such an event would invariably lead to lower minimum standards in states where the aforementioned circumstance of poor stakeholder organization persists. To avert such an undesirable situation from occurring, a national uniform common minimum framework should be set up. Such a framework should focus on the aspects of school education that are absolutely necessary for a child to gain minimal outcomes from school education. SSSAs should be encouraged and incentivized to set standards above and beyond this minimum framework.

The enormity of the task can only be understood when one realizes that since education is a subject under the concurrent list, therefore the setting up of SSSAs would need a complete re-imagining of the existing systems of school education in the various states. This promises to be a protracted process due to the differing levels of complexity in state laws that match the particular socio-economic context of the state – with states like West Bengal, Odisha and Jharkhand having the most sizeable yet least restrictive laws while states like Karnataka have laws that are as voluminous but far more restrictive. Lastly, while education is generally not seen as a hot button issue, there is always the aspect of political conflict between the states ruled by opposition parties and the narrative setting competition between the ruling party that formulated the NEP and the opposition.

In conclusion, one has to acknowledge that the decentralization of standard setting authority, and the linking of standard setting for schools with an accreditation mechanism are very progressive measures for the school sector. However, with these proposals we are entering wholly uncharted territory as a decentralized accreditation mechanism of this scale has never previously been attempted in India in the education sector. Therefore, as was seen over the course of the essay, the key concerns are related to the issues of implementation and feasibility. The key challenge for the whole exercise continues to be one of ensuring accountability while preventing regulatory capture by vested interests. Finally, due to the unpredictable nature of Indian politics and the lack of political capital arising out of these proposals, it remains to be seen when standard setting based on accreditation systems for schools shall become implementable in all parts of the country.

About Archit Bhat

Archit is currently pursuing his Master's in Public Policy from National Law School of India University, Bengaluru. He is interested in governance and social justice-related issues. You can reach out to him at architbhat@nls.ac.in

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The views expressed in this article are the author's own.

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