Draft
Paper of Sub Group III
To
Define the Procedure for Accreditation and to Identify Possible Mechanisms of
Grading of Voluntary Organizations
Sumedh Gurjar
Representative
of CRISIL
Shri Alok
Misra/Shri Swetan Sagar, M-CRIL
______________________________________________________________________
(Note:
This paper assumes that the norms / standards of accreditation have been
defined by Sub Group I, and the structure and functions of the National
Accreditation Council have been defined by Sub Group II, broadly on the lines
of discussions during the first meeting of the Task Force. This paper,
therefore, tries to provide a link between the conceptual norms of
accreditation and the actual function of accreditation through suggesting a
procedure of accreditation to be adopted by the National Accreditation
Council.)
1. Broad
Principles and Premises
The procedure of
accreditation is the most sensitive and delicate segment of the entire
accreditation process. It is possible to define very good accreditation norms;
it is also possible to conceptualize a comprehensive accreditation process.
However, it is quite a challenge to translate them into a practical regime of
accreditation procedure. When tested on the ground, even the best designed
accreditation procedures turn vulnerable to human biases and errors, diversity
and multiplicity of contexts, limitations of time-resources-logistics, etc. The
magnanimity of intent behind accreditation finds itself caught in the narrow
procedural issues and debates. This is where accreditation often gets diluted
and even defeated.
It is therefore necessary to
design an accreditation procedure that has the following basic characteristics:
i)
Simple, clear and practical;
ii)
Easy to be taught, learnt and applied on ground;
iii)
Sufficiently generic to fit into a variety of contexts;
iv)
Flexible but not arbitrary or loosely framed;
v)
Empirical as against judgmental;
vi)
Amenable to verification by any body at any point of time;
vii)
Transparent and participative;
viii)
Feasible in terms of time-resource-logistic requirements.
These characteristics lead
us to certain broad principles of a good accreditation procedure:
i)
Accreditation procedure should consists of carefully designed
assessment tools (inventories, questionnaires, assessment schedules, etc.) that
facilitate a concrete and evidence-based verification of compliance with each
norm / standard of accreditation. This makes the assessment procedure
unambiguous, empirical and verifiable thus minimizing the biases and judgmental
errors on part of the assessor;
ii)
Assessment tools
should be accompanied by a comprehensive training / learning kit consisting of
detailed and self-explanatory guidelines for the assessor / assessee, which
makes the accreditation procedure easy to teach-learn-apply;
iii)
Accreditation procedure should offer progressive levels of
complexity of assessment. As an example, tiny organizations like SHGs / CBOs
may be asked to merely undergo a registration procedure, larger NGOs may be
subjected to compliance assessment against the minimum / desirable norms,
whereas more specialized professional / technical organizations may be offered
rigorous procedures of rating / grading. Accreditation procedure should offer
the flexibility of choosing the appropriate level of assessment corresponding
to the nature and context of the assessee organization. However, at each level
a standard assessment procedure should be followed, which would make the
accreditation procedure flexible yet well guarded against arbitrariness;
iv)
The time-resource-logistic requirements should also be
defined differently at each level of assessment as discussed above. This will
make the accreditation procedure practical and feasible for each category of
assessee organizations. As an example, the simple requirement of registration
may go well with the astronomical numbers of tiny SHGs / CBOs whereas those few
specialized professional / technical organizations would not mind undergoing a
much tedious and lengthier procedure of rating / grading and would also have
the financial resources to pay up the costs of such a procedure.
v)
Accreditation procedure should lay down a clear matrix of
roles and responsibilities of both assessor and assessee. The assessee should
have an equally active role as the assessor thus making the accreditation
procedure transparent and participative.
2. Alternative
Procedures of Accreditation
A review of various
strategies of accreditation practiced across the world shows that there are
three broad choices available in this regard:
i) Self-accreditation: This strategy involves a self-assessment by voluntary organizations using a set of accreditation norms. Public disclosure of accreditation information forms the key element of this strategy, which makes the organizations accountable to the public at large for the information they have disclosed. The organizations automatically stand liable to consequences in case the information is found to be incorrect or deliberately misleading. This strategy is useful where the number of organizations to be accredited is rather astronomical and it is not feasible for any external agency to carry out accreditation procedures.
ii) Accreditation through peer review: This involves the assessment of a voluntary organization by peer organizations from the same sector. This strategy provides greater autonomy to the voluntary sector and minimizes the scope of an external regulation as the accreditation mechanism is entirely contained within the voluntary sector.
iii) Accreditation by an external accreditation agency: This involves accreditation by third party in the form of an accreditation agency authorized by the State. This strategy involves the risk of too much external regulation on the voluntary sector at the same time it also opens up the possibilities of making accreditation more rigorous and scientific through pooling together different kinds of expertise, which may not always be available within the voluntary sector.
In the present context, it
is felt that the voluntary sector in
3. Institutional
Setup for Accreditation Procedure
Having chosen the strategy
of accreditation by an external accreditation agency, some basic institutional
arrangements necessary to support the accreditation are as follows:
i)
Regional Accreditation Committees: The regional offices of NAC
(as suggested by Sub Group II) should constitute Regional Accreditation Committees
to screen the assessment reports and to make recommendations to NAC regarding
granting or denial of accreditation to the assessee organizations. The Regional
Accreditation Committees may have the following composition:
a.
Eminent personalities from the voluntary sector;
b.
Experts in accreditation - those who have served in NAAC,
School Accreditation Board and such other accreditation bodies;
c.
Legal, financial, management experts;
d.
Retired senior officers from judiciary (ex-Judges);
e.
Retired senior officers from the academics (ex-Vice
Chancellors);
f.
Any other persons with established reputation and
credibility.
The recommendations of the
Regional Accreditation Committee should be forwarded to the apex body of NAC
for the final award of accreditation. Alternatively, this function may be
decentralized to the State offices of NAC if Sub Group II deems this fit.
ii)
Network of Certified Assessors: The regional offices of NAC
will screen and select assessors to carry out the actual accreditation
procedure. The assessors may be selected through a transparent competitive
procedure involving an open advertisement, a selection panel, screening and
interviews, etc. The assessors once selected should be passed through rigorous
training in the accreditation methodology and procedures. They should also be
passed through rigorous qualifying tests including dry-runs of actual
field-based assessment. The qualifying candidates may be then formally
certified for the role of assessors. Every assessee organization may be asked
to give confidential feedback about the performance, conduct and integrity of
the concerned assessors. Similarly, the Regional Accreditation Committees
should also be requested to give their feedback on the performance of assessors
from their region. Every assessor should face an annual appraisal resulting in
extension or termination of his / her certification as an assessor. Maintaining
a good network of qualified and certified assessors would be a key function of
the regional offices of NAC.
4. Steps and Tools
for Accreditation Procedure
A good accreditation
procedure is always a progression of well-defined stages that logically flow
out of each other and that are supported by precise tools of evidence-based
assessment. Suggestions are as follows:
4.1 Registration with NAC:
Every organization desirous
of undergoing the accreditation process should get itself registered with the
National Accreditation Council (NAC) at its regional / local offices / outlets
as defined by Sub Group II. The advantage of an independent registration by NAC
would be that a large population of otherwise unregistered organizations (such
as many SHGs / CBOs) will also get a forum for formal registration. The basic
registration should only require verification of the
Figure 1: Schematic Overview of Accreditation Procedure
identity and contact details
of the applicant organization. In addition, those already registered under the
various existing provisions (Public Trust Act, Societies Registration Act,
registration with the Registrar of Cooperatives, etc.) should also record their
registration number. NAC should maintain a database in the public domain of all
the organizations registered with it. The database may have different sections
for organizations merely registered, those accredited for the minimum /
desirable norms and those also graded / rated for particular competencies. Such
a database will have a great unifying effect on the voluntary sector and will
bring together the chunks of organizations currently operating under different
legal provisions or authorities. The database will also give certain minimum
visibility to each registered organization, whether big or small, and will help
in creating demand-supply linkages. It is suggested that a structured Form be
used for the purpose of registration. A Draft Registration Form is enclosed at Annex I for
consideration.
4.2 Review of Applications for
Accreditation
Once registered, every
organization desirous of undergoing accreditation will be asked to apply for
the same and will also have to give a written consent for parting with the
necessary information / data / documents during the assessment. The applicant
organization will also have to deposit the fee / charges for accreditation as
worked out by Sub Group IV. NAC will have to take a view on each application
and decide whether the organization concerned is really ready for
accreditation. A tiny SHG / CBO, for example, may not really be ready for
accreditation against the minimum / desirable norms. It may have to remain at
the level of basic registration for some more time till it develops the
necessary organizational faculties, which qualifies them for accreditation
screening.
4.3 Sending
Out Self-Assessment Forms
Organizations selected for undergoing the procedure of accreditation will be first sent certain Self-Assessment Forms to try their preparedness for the accreditation norms. The Forms are to be filled, certified and returned by the assessee organization. A set of two Self-Assessment Forms is proposed for this purpose. Draft Self-Assessment Forms are enclosed as Annex II.
§ Form A: consists of two section:
§ Section-I: Information regarding compliance to Minimum Norms
§ Section-II: Information regarding compliance to Desirable Norms
§ Form B: deals with the information relating to the Board to be filled and certified by the Board Members.
Along with Self-Assessment Forms detailed guidelines will be sent to the assessee organizations so as to ensure that the Forms are filled up correctly. Draft guidelines for VOs are enclosed at Annex III.
4.4 Desk Review
The Self-Assessment Forms filled and returned by the assessee organizations need to be passed through a critical desk review before a decision could be taken on whether or not to pursue the further procedure of accreditation of those organizations. The Forms with incomplete, ambiguous or doubtful information will be returned to the assessee organizations for the necessary corrective action. Further process of accreditation will be kept on hold till the organizations file the corrected / revised Forms and the same are cleared in the next round of desk review. To make the process of desk review systematic and transparent it is suggested that a structured Form be used to summarize its findings. Draft Desk Review Form is enclosed at Annex IV.
4.5 Assessment Visits to
Voluntary Organizations
The organizations qualifying the desk review are then visited by assessors for a detailed, first-hand verification of compliance with the accreditation norms. It is recommended that assessors always make such visits in pairs and each pair consists of one person with sound legal-financial understanding and the other with keen insights into the social-developmental programming. Such a composition of the assessment team helps in gaining a balanced understanding of the organizations preparedness for the accreditation requirements. The assessor’s visits are to be planned in consultation with the concerned assessee organizations. It is important to check the availability of all concerned – the organization’s staff, board members, target groups, etc., before scheduling the visit so that the time and resources spent on the visit get utilized optimally. Before the visit the assessors must get themselves thoroughly conversant with the information provided by the respective organizations through the Self Assessment Forms and the findings of the Desk Review. During the visit the assessors should undertake random check on various supporting documents to verify the authenticity of information presented in the Self Assessment Forms. The assessors also need to meet the important stakeholders in order to seek their perceptions and feedback on various point of assessment. It is important to use a structured Form to record the observations during the assessment visit so as to make the assessment process rigorous and transparent. Draft Assessment Feedback Form is enclosed as Annex V. Similarly, it is also important to provide handy guidelines, which could be referred to by the assessors during the visit. Draft guidelines are also enclosed at Annex VI. The feedback submitted by assessors serves as one the key grounds for the decisions of the Accreditation Committee. It is therefore necessary to design, conduct and monitor the assessment visits very carefully.
4.6 Assessment
Report
After the visit the assessors should share the assessment reports with the assessee organizations. At this stage the assessee organizations should be given an opportunity to make any revision / correction in the facts stated earlier and also to voice their opinion about the assessment report. Apart from detailed assessment documents a highly structured summary of assessment may be prepared to facilitate speedy disposal of cases by the Regional Accreditation Committee. Draft Assessment Summary Report is enclosed at Annex VII.
4.7 Screening
and Recommendations by Regional Accreditation Committees
The regional offices of NAC should receive the detailed documents of assessment along with the Assessment Summary Report from the concerned assessors and should forward the same to the Regional Accreditation Committee for screening and recommendations. The organizations found to be qualifying the accreditation norms may be recommended by the Committee to NAC for the award of accreditation. The organizations falling short of compliance may be informed about the specific compliance needs and be asked to apply again whenever it is ready for fresh assessment. In such cases, the applicant organization should be asked to pay additional fee / charges for a fresh round of assessment. The accreditation once granted should stand valid for a period of three years. Towards the end of this period the concerned organization could apply for renewal of certification. A fresh assessment would be carried out for taking a decision on the renewal and appropriate fee / charges will be levied on the organization for the same.
5.
Mechanisms of Grading of VOs
Unlike
accreditation that assesses an organization’s broad compliance with the minimum
/ desirable norms, the process of grading examines the specific competencies,
which provide a competitive advantage to an organizations over its peers. The
norms for grading, therefore, cannot be too general. It is desirable to define
the grading norms separately for each sector such as health, sanitation,
agriculture, watershed development, etc. It is suggested that NAC may
constitute Advisory Groups for each sector consisting of the representatives of
the concerned Central / State Ministry, donor organizations focusing on that
sector, technical experts, etc. These advisory committees should prepare and
revise from time to time the norms of grading for each sector. The
organizations desirous of applying for grading must have been accredited for
minimum and desirable norms. No organization should be allowed to apply
directly for grading unless its compliance with basic standards of
accreditation is established. The process of grading should use similar pattern
of steps and tools as those suggested for accreditation procedure. However, in
case of grading the assessors should necessarily be the technical experts from
the concerned field. As an example, an organization desirous of being graded in
the field of public health must be assessed by public health professionals of proven
competencies. Therefore, NAC will also have to raise sector wise teams of
experts who would carry out the assessment procedure for grading. In
consultation with the Advisory Groups some highly structured instruments of
grading and rating may also be evolved. Grading / rating agencies such as
CRISIL and M-CRIL may be taken on board for evolving and applying such
specialized instruments. The fee / charges for grading may have to be fixed
differently for each sector as the assessment requirements may vary hugely. The
Regional Accreditation Committees as well as the apex body of NAC should invite
and involve the sectoral Advisory Committees while taking final decisions on
grading.