Papers Presented at the 1st National NADEOSA Conference
Held 11-13 August 1999

Author: Andrew, M. G

Title: Quality Assurance and the Private Distance Education Colleges

About the Author:
President of the Association of Distance Education Colleges of South Africa (ADEC)

Since there are many misconceptions about the private education and training sector, let me start by giving an outline of the sector. There has not been much research on this sector. In 1996 the National Business Initiative (NBI) was commissioned by the National Training Board (NTB) "…to estimate the level of expenditure by individuals on training in the private college sector, outside of the academic curriculum of schools …". EDUPOL, a unit within the NBI, submitted "NTB Study 1 (c) Expenditure on Training in the Private College Sector" to the NEDLAC Counterpart Group on the Financing of Training in June 1996. Among the key findings were these (ii-iii):

wThe sector is substantial.

wThe study revealed a high level of spending by individuals on training in the private sector.

wThe private college sector is growing rapidly.

wTraining is predominantly in the commercial field, through distance learning courses lasting one year or more.

wMost students in training courses are employed.

wThe private college sector is flexible and provides access to under-represented groups.

wThe associated colleges display a high concern about quality.

As far as I am aware, this is the only independent research on the private college sector that has been undertaken. The reference to "associated colleges" above is to colleges associated with the Association of Distance Education Colleges (ADEC), the Association of Private Colleges of Southern Africa (APCSA), and the colleges registered with the Correspondence College Council (CCC). A finding of the study not mentioned above is "The extent of the wider universe of non-associated colleges is limited" (NTB Study (c), 1996, ii). The study indicated a headcount enrolment of 223 102 students in Associated Private Colleges in 1995, making the private education and training sector "the largest single sector in the training system" and "larger than the headcounts at technikons (190 000), technical colleges (112 000), or teacher colleges (81 000)" (ii). The study refers to " a growth rate of 94% over 4 years (1993-1997)" (ii).

When one considers that this study confined itself to training and therefore excluded a large area of the operations of the private education and training sector, the numbers mentioned in the study should be increased considerably for a proper perspective of this sector.

There have been impressive changes in educational policy in South Africa, and these are due largely to the South African Qualifications Authority (SAQA) with the National Qualifications Framework (NQF). But credit should also be given to the private education and training sector, which was the forerunner in opening up general, further, and higher education in this country.

As early as 1965 the private distance education colleges in the form of the Association of Correspondence Colleges of South Africa (ACCOSA) – now the Association of Distance Education Colleges (ADEC) - prepared a private bill, which was put before parliament and became law. The purpose of the Correspondence Colleges Act of 1965 was to regulate private distance education, to provide quality assurance, and to safeguard the interests of distance learners. The statutory body, the Correspondence College Council, has functioned ever since

was the ombudsman for the private distance learner,

was the registration body for private distance education colleges,

was the agent for inspections of private distance education colleges, and

was the custodian of the Fidelity Fund that guarantees that no private distance learner will suffer from a "fly-by-night" or insolvent private distance education college.

In thirty-four years there has been no need for the Fidelity Fund to be used to "bale out" a "fly-by-night" or insolvent college. The composition of the Correspondence College Council is:

wfour members elected by registered colleges, with four alternates also elected by registered colleges,

wtwo members appointed by the Minister of Education, with two alternates appointed by the Minister, and

wthe Registrar of the Council, appointed by the Minister on the recommendation of the Council.

What is the secret of the success of the Correspondence College Council? Because its membership included representatives from the registered colleges, who understood the sector, the Council has always been aware of the needs of the private distance education learners and providers, who have respected its knowledge of the private education and training sector. The Correspondence Colleges Act was the first attempt at quality assurance in South Africa and preceded the Certification Council for Technikon Education (SERTEC) and SAQA by decades. For all the perceived shortcomings of the Council, there were aspects of its representivity, its form of funding, and its role as an ombudsman that should have been incorporated into the plans for the registration and quality assurance of private providers by the Department of Education and SAQA respectively.

It is true (and regrettable) that there has not been a similar statutory body regulating private face-to-face education and training. This was an omission on the part of the private providers and on the part of the Ministry of Education. There have, it is true, been ‘fly-by-night’ and insolvent colleges in this subsector of the private education and training sector. And students have suffered from lack of regulation and lack of quality assurance. But the Association of Private Colleges of Southern Africa (APCSA) has to a large extent regulated its members, and no APCSA member has been guilty of ‘flying by night’ or of going insolvent. APCSA conducts regular inspections of its members and requires them to observe ethical practices.

Private distance education colleges have one primary motive: customer service. And from that primary motive come two secondary motives: quality and profitability. Many critics of private distance education say that because profitability is the primary motive of private distance education colleges, their delivery is suspect and they "rip off" their customers. There may be some truth in this for face-to-face private college provision, but it is obviously not a good business strategy to make " a fast buck" and move on. And it is not true of private distance education colleges: private distance education colleges have not made a "fast buck" and have not moved on. They have stayed with amazing tenacity, despite many trials and tribulations! The relationship between quality and profitability is an important one: if you overemphasise quality to the detriment of profitability, you go out of business; if you overemphasise profitability to the detriment of quality, you do not satisfy the customer, you lose market share, and you go out of business. The right balance between quality and profitability means cost effectiveness and customer service – neither of which are very notable characteristics of public distance education provision. Cost effectiveness and customer service mean quality and profitability. This is why for the past two decades at least ADEC has been advocating that the control of market forces with the regulation of the private distance education industry through the Correspondence College Council is the only quality assurance mechanism needed. Nevertheless we welcome SAQA and the NQF and wish to co-operate in the improvement of quality assurance in South Africa.

In 1994 the Education Department of the African National Congress (ANC) through the South African Institute for Distance Education (SAIDE) constituted an international commission consisting of, among others, Raj Dhanarajan, our Keynote Speaker at this conference. The Report published in 1995 was entitled "Open Learning and Distance Education in South Africa". The Report admitted that the work of the Commission had been "unavoidably selective" and had " concentrated on the four publicly funded national distance institutions engaged in further or higher education" (Report page 59). Nevertheless the Commission commented "on private colleges and non-governmental organisations, usually with adverse and negative connotations in respect of the former, and in glowing and exaggerated terms when referring to the latter" (Andrew (1995) page 13). The Report made this comment on the private distance education colleges: "Student support is usually rather limited. Performance indicators are not available, but it is usual for colleges to have a very low success rate for academic studies, and a somewhat higher rate for vocational and professional studies." (Report (1995) page 172) How the Commission could make these sweeping generalisations when it had not investigated the private distance education colleges in any acceptable way is very puzzling and suggests bias on its part. In September 1994 ADEC asked the late Professor Don Swift to open its Conference and to comment on the work of the Commission, of which he was a member. He referred to the private colleges as being "in the field of, as it were, preying on the inadequacies of ordinary people" (Andrew (1995) page 15). Both the Report of the Commission and the words of Professor Swift were not well received by the private distance education colleges, and such ill-advised statements cast doubt on the validity of the whole research exercise. ADEC responded as follows:

ADEC colleges are aware that there are many ways in which distance education can be improved in South Africa and they welcome change and improvement. They do not, however, wish to be chastised unjustly by a watchdog that has no informed evidence and that acts in a vindictive, partisan way. ADEC colleges wish to participate in the reconstruction and development of South Africa and, because of their large constituencies of students and their experiences of open learning support and high success rates, they feel that they deserve better recognition than the Report gives. (Andrew (1995) page 18)

Before NADEOSA was formed in 1996, the Association of Distance Education Colleges (ADEC), which started as an association of a few of the larger private distance education colleges, broadened its membership to include not only smaller private colleges but also public institutions and SAIDE. As such it was the only voice of distance education in South Africa until NADEOSA was formed. ADEC organised a number of distance education conferences to which participants from public and private distance education organisations contributed. The private distance education colleges welcomed the formation of NADEOSA and were involved in the planning stages from the beginning. The private colleges have been represented on the executive of NADEOSA and in some of the key positions on the executive. At one stage ADEC thought of disbanding because NADEOSA was established, but on consideration it found that there was still a role for an association that focused on the private distance education sector and its needs, which are often different from those of the public distance education institutions. ADEC has for a long time expected its member colleges to subscribe to its Code of Ethics, and it was significant that the NADEOSA Code of Ethics has drawn considerably on the ADEC Code of Ethics. Such is the spirit of co-operation that not only ADEC but also many of the private distance education colleges are active members of NADEOSA.

Until the Higher Education Act of 1997 the private sector in education and training was prohibited from offering technikon and university courses. It therefore turned to the professional institute courses, and many learners who were unable to study at universities and technikons - because of the restricted access policies of technikons and universities in those days - turned to professional institute diploma studies. This developed into a thriving institute education and training industry in which many innovations were implemented:

wrecognition of experiential learning,

wnon-discriminatory access policies,

wcontinuous registration opportunities,

wself-paced study,

wexternal examinations leading to internationally recognised qualifications,

wmultiple examination opportunities in a calendar year,

warticulation opportunities, and

wlifelong learning opportunities.

The professional institutes organised themselves into the South African Association of Management Institutes (SAAMI), later to be called the Association of Management Institutes (AMI), which co-operated closely with the Association of Private Colleges (APCSA) and the Association of Distance Education Colleges (ADEC).

The private education and training sector welcomed the SAQA Act and its implications for education and training in South Africa. As can be seen from the short outline of the sector above, it had anticipated many of the principles of the Act. The National Qualifications Framework (NQF) is welcomed by our sector as a long overdue attempt to bring about recognition, articulation, and portability of a large range of qualifications and to engender a culture of lifelong learning.

As Professor M C Mehl has observed (Mehl in SAQA Bulletin, November/December 997, 32): "Some of the guiding principles (of the NQF) appear to be:

wTo establish a learning environment which enables people to realize their full social and economic potential in the modern world.

wTo produce educated people who are independent problem solvers and reflective learners and who have learned how to learn.

wTo provide a learning environment with the proper integration of academic abilities and workplace skills, in order to produce qualifications which not only meet needs, but have appropriate intellectual content – thus removing the artificial distinctions between academic and vocational training.

wTo establish an enabling framework for the many who have been marginalised from formal education and/or workplace opportunities.

wTo remove the existing artificial learning ceilings and to provide the pathways of continuous learning toward meaningful qualifications.

wIn essence, to establish the framework for a nation of life-long learners who are able to realise their full potential through flexible curricula and opportunity structures which enable movement between various levels of achievement."

The private education and training sector has espoused these principles for many years.

Private distance education colleges greeted SAQA and the NQF with enthusiasm. It was a very large sector already committed to Outcomes-Based Education and Training. It was, therefore, a great disappointment to the sector that our nomination for a position on SAQA went unheeded by the Minister of Education, whereas nominations from smaller sectors such as technikons, technical colleges, and teacher colleges were accepted. This experience of rejection has been experienced by our sector with reference to appointments on other bodies such as the Council on Higher Education (CHE). It leaves the private education and training sector feeling that not much has changed in terms of real representivity. Whereas our sector appreciates the needs for representivity on the grounds of race and gender, we think that to exclude a large sector from participating in such important areas of education and training policy is foolhardy in the extreme. It makes us feel that, in education and training terms, not much has changed from the apartheid distinctions between formal and non-formal education with an obvious favouring of formal education.

It is true to say that two professional institutes were represented on the South African Qualifications Authority: the Institute of Personnel (now People) Management (IPM) and the South African Institute of Chartered Accountantants. (The Executive Director of IPM, who was appointed onto SAQA, has since resigned, and the vacancy has not been filled.) The nomination from the Association of Management Institutes was, however, rejected.

Then came the appointment of the National Standards Bodies (NSBs). By this time the private education and training sector had realized that there was little hope of its nominees being appointed from the private education and training sector, but a few individuals from the sector were nominated by the College Sector Coalition (CSC) and were appointed. This is ironical because to all intents and purposes the CSC is not very active, whereas the private education and training sector, represented by the Alliance of Private Providers of Education, Training and Development (APPETD), continues to flourish.

On the National Standards Body 3 (Business, Commerce and Management Studies) there is very active participation from the professional institutes, and this has no doubt contributed to this NSB being one of the most active of the NSBs.

A disquieting comment made by SAQA on a number of occasions is that in the present South African education and training environment there is no longer a role for examining bodies such as the professional institutes have been in the past. This is connected with the stipulation of the NQF that all qualifications will have to be called Certificates, Diplomas, Higher Diplomas, or Degrees, and branding of qualifications, which has been important to both professional institute and private institution qualifications, will disappear. One of the criticisms of competency-based education and training has been that it favours mediocrity, and perhaps this criticism could be levelled at this aspect of the NQF as well. Uniformity should not be what the NQF is about.

Nevertheless the Alliance of Private Providers of Education, Training and Development (APPETD), an alliance of all private providers, including ADEC, continues its discussions with SAQA in the hope that SAQA will recognise that the sector has an important role to play.

In terms of the Higher Education Act of 1997 a Registrar of Private and Foreign higher Education Institutions, Dr Paul Beezhold, was appointed. All private and foreign higher education institutions have to register with the Registrar and to be accredited by SAQA. This process has caused great confusion and consternation in the private education and training sector. The reason for this is largely an ignorance of the sector on the part of the Ministry of Education represented by Dr Beezhold and on the part of SAQA. And the reason for the ignorance is the lack of representation on SAQA and on the CHE of people involved in the sector.

Dr Beezhold published a Manual that went through frequent revisions. In one of the many versions, he stated (Manual, 20 January 1999, iii),

The key challenge for Government lies in expanding the role of educationally sound and sustainable private higher education institutions in terms of the applicable South African legislation, and to root out poor quality, unsustainable, "fly-by-night" operators in the higher education band....

Dr Beezhold saw his role "as a watchdog over private higher education institutions operating in South Africa" (Ibid., 3). The harsh mixed metaphors of "rooting out", "flying by night", and "watchdog" would be laughable if they did not indicate what the private education and training sector sees as a possibly sinister intention. The NBI research mentioned earlier and the records of the Correspondence College Council show that there are no "unsustainable, fly-by-night operators" among the "associated colleges". Some of us in the sector fear that these remarks are a deliberate attempt to "root out" the small providers who have played an important part in the sector in the past. Unfortunately it appears that certain large private operators in the higher education band may support this attempt and may even benefit from it. There has been little or no attempt to make use of the knowledge and experience of the private education and training sector through the involvement of the Associations that are the true representatives of the sector, ADEC, APCSA, the association of professional institutes, and the Alliance (APPETD).

A condition of registering with Dr Beezhold was that the institution had to be accredited with SAQA. To do this, the institution had to complete a sixty-eight-page application document. This so-called "Blue Book" was prepared for SAQA and the Department of Education by Dr J A Brink, the Director of the Quality Promotion Unit of the South African Universities’ Vice Chancellors’ Association, and Dr D J Jacobs, the Director of the Certification Council for Technikon Education, without any input from the private education and training sector. The cost of evaluation for preliminary accreditation was "by bank guaranteed cheque" (Procedures , May 1998, p. 10)

R2 000 per institutional audit (institutional quality assurance review) and R2 000 per programme quality evaluation.

These costs have proved prohibitive to many private institutions.

The Alliance of Private Providers of Education, Training and Development (APPETD) in a position paper presented to the Department of Education and SAQA in May 1999 stated that ... private providers ... found the administrative work required for registering and applying for accreditation prohibitive and the cost exorbitant.
The ... document that private providers must complete when applying for accreditation is not suited for this purpose. It is not feasible to expect private providers of education and training to have the same facilities and structures in place as state subsidised institutions. The quality of education and training in private institutions should be subject to accreditation and not whether there are sports facilities, student representative councils, elaborate media centres and community involvement.
... it was proposed that an entirely new document be drawn up.
This document should be developed by APPETD and other stakeholders.
Small and emerging businesses are not considered and should be given specific attention by having discussions with the executive committee of the Forum for Independent Providers (INPROV), the SMME leg of APPETD.
Private providers are not happy with the way government makes decisions which affect their very livelihood without any consultation. They would like the Department and SAQA to include representatives from APPETD in their decision making.
There is a strong feeling among private providers that they need to have an ETQA for private providers in the education sector.

This strong feeling of unhappiness came not from SAQA or NQF policy but from its implementation. The main reason for the unhappiness is that the private education and training sector considers that neither the Department of Education nor SAQA has an understanding of what the sector does or thinks because the sector is not represented on any of the crucial policy-making bodies. (There is, however, some likelihood that this will change with the implementation of the Further Education and Training Act of 1998, and our sector is always hopeful and always prepared to participate.) Despite the recognition "that private provision plays an important role in expanding access to higher education by responding to labour market opportunities and student demand" (Manual, 1), the way that SAQA is implementing perfectly acceptable policy is (at the time of writing this paper) unacceptable to the private education and training sector. There is, however, always the opportunity for SAQA to become aware of how the sector thinks; and then representatives of the sector will be only too pleased to work together with SAQA to implement the NQF more satisfactorily – and (dare we say it?) more speedily and effectively.

REFERENCES

Andrew, M G: ‘A Review and Assessment of Open Learning and Distance Education in South Africa’ in The OLiSA Review Number One, December 1995, Open Learning Association of Southern Africa, Cape Town.

Beezhold, Paul: Manual for the Registration of Private Higher Education Institutions, 20 January 1999, Registrar of Private Higher Education Institutions, Pretoria

Buckland, Peter, Ros Jaff, Kate Reid: NTB Study 1 (c) Expenditure on Training in the Private College Sector, June 1996, National Business Initiative, Johannesburg

Mehl, M C: ‘SAQA and the NQF: An Outsider’s View’ in South African Qualifications Authority Bulletin, Vol. Two Number Two, Novemeber/December 1997, SAQA, Pretoria

Procedures for preliminary accreditation: Private Higher Education Institutions, May 1998, SAQA, Pretoria

Report of the International Commission: Open Learning and Distance Education in South Africa, Macmillan, 1995

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