Certifications and accreditations are no substitute for governance

I have been a sceptic of the efficacy of the increasingly common use of certifications and accreditations as a means to assure service quality of public services. Such certifications are done by both the government directly or through arms-length agencies and by the industry themselves. I'll argue that such certifications cannot be a substitute for governance, and in the absence of good governance even the best certifications are ineffective. Worse still, band-aid solutions like these induce false confidence and detract from serious engagement from the problem itself thereby worsening things. 

Indian Express has in recent days carried two investigations highlighting the problems faced by the industry certification of the forest produce, and government certification of universities and colleges in India. 

The first concerns certification of the forest produce not being linked to afforestation or illegal activities

Forest certification is a sunrise industry, driven by a growing preference to avoid any product that can be linked to deforestation or illegal logging. In India, the forest certification industry is growing at 8 to 10 per cent every year, mainly catering to exporters wanting to tap the US and European markets that have strict regulations to ensure the legality of wood products coming in. Only processed wood is allowed to be exported from India, not raw wood... The investigation revealed that certifications in India were mainly a tool to bypass regulatory requirements in Europe and the US, where India’s forest-based products have an export market worth Rs 4,000 to Rs 5,000 crore every year. “It is easy to obtain forest certifications in India, if you are willing to pay the fees. There are several unscrupulous operators who are willing to make a quick buck. In fact, because of the intense competition amongst certification bodies, it is largely a buyers’ market. If you negotiate hard enough, you can drive down the costs of certification considerably,” said an executive of the India-based office of a foreign certification body... 

The main seekers of certifications have been exporters of wood products and other forest-based goods... Forty per cent of all certificates issued in India by two of the largest global certification systems – FSC or Forest Stewardship Council, and PEFC or Programme for Endorsement of Forest Certifications – have not been renewed... FSC and PEFC, and others like them, are developers and owners of certification standards, much like the International Organisation of Standardisation (ISO) or the Bureau of Indian Standards (BIS). The actual work of evaluation, recommendation of certifications, and monitoring of compliance is carried out by certification bodies and their subcontracted auditors.

The forest certification system has spawned an industry in green-washing.  

The second concerns a recent report of a panel appointed by the National Assessment and Accreditation Council (NAAC), which grades India's 43,796 colleges and 1113 universities, into its own functioning has thrown up several alarming signals,

According to the review panel’s report... the process of selection of experts who comprise peer teams that are sent to assess applications for accreditation is “neither random nor sequential”. It points out that nearly 70 per cent of experts from the pool of assessors do not appear to have received any opportunity to conduct site visits while some others have had multiple such visits. According to an NAAC official, there are 4,000 experts, who are mostly academics attached with higher educational institutions, serving as members of peer teams in NAAC. Sources involved in the process said only about 30 per cent of these experts are involved in the accreditation process, which was a “clear indicator” of the “extent of rot” due to “allotment through manual interventions without valid reasons”. Sources said the other “glaring” gaps highlighted in the report include the presence of multiple “super admins” who have full access to the NAAC’s internal system and the power to allot experts; and, “non-maintenance of logs which may have adverse fall outs”... Under NAAC’s accreditation process, the first step involves an applicant institution submitting a self-study report (SSR) based on quantitative and qualitative metrics. The data is subjected to validation by expert teams of NAAC, with quality reviewed during site visits by peer teams.

The Chairman of NAAC Mr Bhushan Patwardhan who has resigned in frustration has alleged "vested interests, malpractices, and nexus among the persons concerned". In simple terms, as governance of the colleges and universities themselves and that of state and central higher education regulatory authorities have weakened, the certification process which provided the fig leaf of credibility appears to have been completely captured. 

In India from the days of ISO certifications of all kinds of government facilities from Tahsildar offices to citizen service centres to electricity sub-stations, in recent times certifications have been used to declare villages open defecation free (ODF), rank cities for their cleanliness, and accredit skilling centres. This has been a questionable strategy. Worse still, they have detracted attention from the real painstaking and long-drawn struggles required to bring about sustainable change. In sum, the recent mindless expansion of certifications in both scope and scale does much more harm to the cause than good. 

The underlying belief that a one-time certification process can, like with outcomes-based financing (see this, this, this, and this), discipline a weak and unruly system into complying with processes and generating outputs is deeply questionable. This comes from the ideological belief in the efficacy of new public management approaches to public systems. 

The results are always the same - the innovation (certification or outcomes-based financing) gets captured and slowly discredited. There is also the difficulty of creating the supply-side (trained auditors/certifiers, monitoring systems etc) to rapidly expand such activities to serious scale and across activities or sectors. They are no substitute for the hard task of efforts at governance and capability improvements.

Update 1 (17.03.2023)

Two points about the NAAC accreditation process. One, if you set impossibly ambitious goals, failure is inevitable. To get a sense of the gap between the scale of ambition and reality,

The National Education Policy (2020) has set an ambitious target of getting all higher educational institutes to obtain the highest level of accreditation over the next 15 years. However, according to information shared by the Centre in Lok Sabha in February, out of the 1,113 universities and 43,796 colleges in the All India Survey on Higher Education Report 2020-21, only 418 universities and 9,062 colleges were NAAC-accredited as on January 31, 2023... According to current and former officials of the NAAC, the fear of obtaining poor grades holds institutes back from applying... Its parameters include curriculum, faculty, infrastructure, research and financial well-being. The grades issued by NAAC range from A++ to C. If an institution is graded D, it means it is not accredited.

Two, it's difficult to maintain the fidelity of any process which involves evaluating institutions on a number of parameters through physical visits assigned to individuals and that too at a nation-wide scale and involving a high-stakes decision which determines the fate of the institution.

Under NAAC’s accreditation process, the first step involves an applicant institution submitting a self-study report (SSR) based on 137 quantitative and qualitative metrics covering seven broad areas. The data is subjected to validation by DVV partners, which is followed up by site visits by peer teams drawn up from a panel of over 4000 assessors. The Joorel panel, which submitted its report last September, also flagged that the NAAC’s internal system has several super admin users (who enjoy full rights in terms of access and bringing changes) who are “no more employees” of the council... In its report, the committee flagged 13 cases, where grades between A++ and A+ were issued, having “anomalies” “which may be tip of the iceberg”, the source quoted the report as having observed. In one such case, the committee found, one university was graded A+ despite “over 50% of metric values entered by it in its SSR found to be wrong”.