Prologue: Does India really need a New National Education Policy? Is our educational reform held back by the datedness of the 1986/1992 education policy which was written before the internet and mobile phones? On this question, I tend to agree with what the current Prime Minister said back in 2013 – “India needs Action, not Acts.” So I admittedly approach the draft National Education Policy 2019 with some scepticism.

Further, in my opinion, a good policy should not be too long, should take stands on important issues, prioritise action items, readily provide evidences for the tenets it advances and draw extensively on the experience of people who have worked in the sector nationally and internationally. It should focus on the objectives that more of us can agree on, than on philosophies on which there will be more divergence. These points are important because in India we tend to write policies and Plan Documents in education that say the right things but are less effective in driving the changes that are needed.

At 484 pages, the current policy is definitely long. It makes some good points and takes strong stances on them, which is welcome. But there are also important areas which it either misses or does not have realistic solutions in.

In reviewing this draft policy, I focussed mainly on school education including the chapters on Teacher Education, the National Research Foundation, Technology in Education and the Regulatory System. I did not cover the aspects related to the higher education system and topics like vocational and adult education.

 

The Positives:

1. Emphasis on Research and the National Research Foundation (NRF): The emphasis on research and the recommendation to create an autonomous NRF is an excellent one. If India has to become a highly innovative society, it has to be fuelled by research. As the policy says, we currently invest 0.69% of GDP on research as against 2-4% in China, the US, Israel and South Korea. An annual grant of Rs. 20,000 crores is proposed (hopefully exclusive of the current annual spend on the IITs, IIMs, UGC, etc. which is around Rs. 13,000 crores – this is not clear) for the NRF. The policy states that intellectual property stay with the researchers – a welcome step.

Over the years, America’s National Science Foundation has driven high quality research in that country and NRF can do that for India. The link to school education is clear as we have always seen rote learning in schools and lack of research in universities as two sides of the same coin – each the cause and effect of the other. The proposal to place teacher education within the higher education system is also welcome. Educational research – including into how students learn different concepts and the misconceptions they have (what we at EI refer to as the ‘Science of Learning’) – will definitely get a huge fillip if these are implemented.

2. Emphasis on Foundational Learning: The second, equally important positive, is the emphasis for the first time in an Indian policy document, on Foundational Learning. We all know about the learning crisis that exists in India and it is acknowledged multiple times in the policy. A lot of this learning crisis can be attributed to children not learning to read fluently by grades 2/3 and not learning fluent arithmetic operations by grade 4/5. For us as a country today, focussing on foundational learning is key.

As we see for other aspects in the policy, there are many issues with the details discussed about Foundational Learning. The emphasis on Early Childhood Care and Education (ECCE) is welcome, but to further address the foundational learning crisis, we believe the need is to research reading and arithmetic gaps and their causes especially in the students from the lower socio-economic strata. This research and learning data must be used to train teachers to help students for the lowest socio-economic backgrounds who usually tend to be first generation learners as well. Monitoring our progress on students’ foundational skills through sample assessments and closing this gap within 5 years should be a national priority and is doable.

3. The policy candidly acknowledges some important problems in the Indian education system: In acknowledging problems, the policy does not mince words. It sayswe have been almost fatally slow in the adoption of technology to improve the quality of education’, and ‘salary, promotion, career management, and leadership positions in the school system and beyond tend not to have any formal merit-based structures, but rather are based on lobbying, luck, or seniority’ and further ‘the teacher education sector has been beleaguered with mediocrity as well as rampant corruption.’

Unfortunately, the policy seems to be less effective in proposing concrete solutions to these problems but acknowledging a shortcoming is a key step towards any solution.

4. Commitment to public education, investment in education and religious and other equity unequivocally re-affirmed: The draft policy re-affirms each of these and that is welcome. Only well-funded, public education can ensure that the quality of education a child receives is not dependent on her parental income and we need to strive towards that goal. The policy makes these arguments well. The commitment that education should be a tool to reduce inequity in society is also well-made. India can never achieve greatness if stark divides that exist today continue in society.

 

The Negatives:

1. Many of the biggest challenges facing Indian education are not addressed: We discuss 6 large challenges below. Most of them are mentioned in the policy but are not convincingly addressed.

a. The Learning Crisis: The learning crisis is acknowledged in the draft policy multiple times but neither the causes nor the specific solutions are discussed. The term rote learning is used but it is not clear what the authors mean. It says on page 76, “Learning will .. move away from rote memorisation; if and when rote learning is used, it will always be pre-accompanied by context and motivation, and post-accompanied by analysis, discussion, and application.” (emphasis added). Firstly, there is no discussion of how this will be achieved – a diktat will certainly not be enough. Secondly, it seems that memorisation (which is required) is being confused with rote learning (which is learning something mechanically or by memory without understanding it). The two are distinct and we believe that there is no situation where rote learning is good, while memorisation is a powerful tool in many situations.

The policy does not try to examine why rote learning is so widespread in our system. We see rote learning in our classrooms as a simple consequence of exams expecting recall of textbook facts and procedures and not understanding. This is not something individual teachers choose but the way Exam Boards set exams year after year (and to that extent, is possible to address if there is commitment to change this.) The policy says that Board Exams will be made ‘modular’ and ‘restructured to test only core concepts, principles, critical thinking, and other higher-order skills in each subject.’ Though positive, this sounds a little vague and jargonish. There is a need to change the type of questions that are asked in our exams and to mention this explicitly.

The worst aspect of the learning crisis is children not being able to read or do basic arithmetic by grade 5 or so. Even if they physically stay in schools, these children have been ‘pushed out’ of education often for life. The policy acknowledges this but does not discuss the causes for this except to suggest that there is ‘too little curricular emphasis on foundational literacy and numeracy (page 56)’. But there is curricular emphasis on reading and numeracy – we just fail to develop these skills in our children. There is need for research on teaching reading and numeracy to children from poorer backgrounds and training teachers on techniques that work with these children. There is also need to have national and state goals like ‘every child reading by grade 2’, for example, which should ideally be a part of a National Education Policy.

PISA is an international assessment that provides cross-national learning benchmarks and helps nations improving their learning levels. India has decided to participate in PISA in 2021 and 2024. (The last time we participated in PISA in 2009-10, we stood 73rd out of 74 countries). Many countries set goals that they will figure in the top ‘n’ countries in assessments like these within a certain number of years. The policy should clarify if India accepts these international benchmarking results and will strive to improve its PISA ranking. Both, I believe, are highly desirable and can be a powerful way to focus all stakeholders towards improving student learning. This will necessarily require us to reform our Board Exams and eliminate the scourge of rote learning from our system. It is thus a powerful way to address many aspects that are leading to the learning crisis.

b. The crisis of capacity in our system: Many long term educational observers believe that there is a root cause which explains why many of the educational initiatives undertaken in our system fail or do not produce all the benefits that were hoped for. That reason is a severe shortage of capacity – well-trained individuals and institutions that can implement initiatives, do research to know whether an initiative is working and build a body of knowledge about the same. Capacity includes both administrative capacity (for example, the ability to implement a programme properly) and educational capacity (an educational understanding and ability). In our experience, the latter is a bigger challenge as administrative capacity has improved over the years. Even officials tasked with educational roles (like block and cluster personnel) get sucked into administrative roles. Educational capacity includes abilities, for example, to:

  • set good quality assessments
  • teachers having strong content and pedagogical knowledge
  • ability to diagnose student learning gaps and remediate them

In recent years, the importance of head teacher training – addressing both their soft and hard skills – has been recognised. Institutional capacity – where skills reside and grow for long periods of time inside institutions like SCERTs and DIETs – are also critical in a large system like India’s. These large and related challenges in our educational system are not discussed much or concretely addressed currently in the policy.

c. Private Schooling, fee regulation and medium of instruction: While the policy is quite explicit in its denouncement of for-profit schools, it almost ignores the issue of private schools which educate about 40% of our children according to estimates. A related issue is fee regulation. The policy mentions that private schools should have the right to fix their own fees but not to increase them arbitrarily. But many states now have stringent rules limiting private school fees. This is an important issue on which a clearer stand – either way – is important in a national policy document.

A related issue is that of the medium of instruction. The policy reiterates the 3 language formula but does not talk about the craze for English-medium we are seeing in society. Issues like these are huge in India today. The exodus from government schools to private is partly due to the demand for English medium education. This is forcing many state governments to open new English medium schools or convert existing ones to English medium. The policy document should take a clearer stand on this.

d. Use EdTech effectively for maximum impact: The policy mentions India’s unique leadership in the IT space. The right policy and implementation push can help India become a global leader in educational technology solutions. Yet many challenges plague the successful implementation of Educational Technology in our own country. One is that most schools – both private and government – tend to focus more on hardware purchase – which is more tangible – than creating or procuring the right software or educational content. In other sectors of the economy, it is understood that hardware has become commoditised while the right software is key. Some guidelines – for example that tenders for procurement of hardware for schools should have a parallel software tender – may help correct this bias.

There are few steps in the policy to mandate a push towards greater technology use in education. Technology in schools should be seen as a key part of Digital India. Today, for example, most competitive exams in India have moved to computer-based testing, but assessments at the school level (including Board Exams) continue to be pen-and-paper. The policy could have mandated a time-frame to move assessments to computer-based testing. Both at the national and state level, various educational softwares could be empanelled or rated by an independent committee. Capacity to do impact assessment (relevant not only for educational software but all kinds of educational interventions) needs to be built at a national level. Finally, though the importance of creating high quality educational software is discussed on page 348, the opportunity to EdTech labs or incubators in our IITs and encourage private companies to create them (possible through challenge grants) and effectively use existing educational software that already  exists may be added to the policy.

The policy does recommend setting up a National Educational Technology Forum, “an autonomous body … to provide a platform for the free exchange of ideas on the use of technology to improve learning, assessment, planning, administration, and so on.” It seemed vague but could become a powerful idea if its role and strategies could be more clearly defined. Organisations like NASSCOM have played an effective role in related sectors. 

e. Compulsory Education: The policy seems to reaffirm its commitment to compulsory education. However, it is not clear if it means compulsory education the way it is normally meant (“…a period of education that is required of all people and is imposed by government…. involv(ing) both the duty imposed upon parents by law to see that their children receive instruction, and the prerogative of every child to be educated[1].”) or the, frankly absurd, alternative definition mentioned in the RTE Act of 2009 (“compulsory education means the obligation of the appropriate government to provide free elementary education…”). Most countries have recognised that sending a child to school cannot be a CHOICE that parents make. In India, including in this new draft policy, we keep that choice intact while still using the word ‘compulsory’.

f. AI as a national priority: Just as India strove to achieve leadership in some high technology areas like space and software, it has the opportunity to do so in the field of Artificial Intelligence (AI). AI is not just another sector but can fundamentally change a society’s competitiveness and levels of prosperity. We have the human resources needed to become a world leader, but do not, as yet, have the educational system it needs. But this should be one of the key focus areas as it can be force multiplier in our education reform efforts while paying off rich dividends for industry and the economy as well. Though AI is mentioned in the policy, it is mentioned only as a sector and not as a strategic priority area it can be.

2. No role is envisioned in the policy for private sector for-profit education players or learnings from international experience: I see the need for all sectors to work on solving India’s educational challenges, a critical requirement that has been well established by success stories in fields where India’s achievement are at world-class levels. There are many areas in education that need high quality research, data analysis and expertise building. These areas include assessments, technology-based learning, curriculum research, remedial education and many others. For-profit companies that operate in this sector not only contribute to economic growth, they also play a key role in expanding educational understanding. For example, our company EI has played a key role in shaping the national agenda in the areas of student assessments and adaptive learning. It has been considered a pioneer and thought leader in these areas and has worked with many state governments as well as international education regulatory bodies on multiple projects in these areas closely. There are other companies that have made a notable impact in the education field. The policy seems to see no role for them by not mentioning or acknowledging them in any way and must be immediately rectified.

To take a concrete example, why should the NCERT be seen as the sole body to do national assessments like the NAS? Why can’t organisations in the private sector actually be encouraged to do the same – would it not build capacities across the system? But the policy very clearly states this as the role only of the NCERTs and SCERTs – which has been the government’s stand too. 

Similarly, the policy ignores the fact that there may be learnings in the educational journeys of other countries. There is no mention of attempts to study what has worked and not worked elsewhere and learn from them or to have exchange programmes both to learn from and share our own learnings with others. This may also include being challenged and inspired by others’ successes and trying to emulate them while preserving our own strengths.

3. Many of the suggestions seem unrealistic or mere platitudes or made without a full understanding of the issues and challenges involved. The mismatch between the challenges and some of the solutions proposed are striking.

Consider this, for example: Two of the largest problems are the learning crisis, and the severe capacity shortages in the system, whether of skilled teachers, researchers who can build good assessments or educational functionaries who can implement high quality learning solutions. Some of the biggest solutions proposed are the creation of a Rashtriya Shiksha Aayog headed by the Prime Minister with Chief Ministers and others and similar Rajya Shiksha Aayogs and other regulatory bodies. While the latter would help build a national consensus and some priorities, our challenge is not that there are priority mismatches or differences in approach. Rather it is a skill and educational challenge and may need clearer action steps to strengthen bodies like the NCERT, SCERTs and DIETs while also building on such capacity outside these public bodies. These aspects have received little to no attention.

Across the report, many of the toughest problems that states and NGO’s have struggled to solve for decades have been re-written as diktats or platitudes, for example: “Teacher vacancies will be filled as soon as possible” (page 58) Even the way the timing is expressed means that the statement essentially means nothing.

Examples of directives that will be extremely time-consuming partly because they may require laws to be amended:

  • “..teachers will not be allowed any longer to conduct government work that is not directly related to teaching (except for rare events that do not interfere with their class work); in particular, teachers will not be involved in electioneering, cooking of midday meals” (page 118) though this is partly contradicted elsewhere in that chapter
  • “Special Education Zones will be set up in disadvantaged regions across the country.” (page 141)

Examples of directives which are just extremely unrealistic to achieve:

  • “All teachers, from Foundational stage teachers to Secondary school teachers, will be recruited with standard service conditions as per their work requirements and the same salary structure.” (page 130)
  • “The suggestion to create a larger group structure called the school complex, consisting of one secondary school together with all other schools offering lower grades in its neighbourhood, a radius of five to ten miles, was first made by the Education Commission (1964–66) but was left unimplemented.” (page 159) [Only Maharashtra tried School Complexes but didn’t persist with the experiment. The policy does not try to analyse why the idea didn’t take off and why it will be adopted now.]

Examples of directives that are basically platitudes which mean nothing:

  • “State Governments will prepare cadres of professionally qualified educators for early childhood education…” (page 52) The reasons they are not already doing it would need to be identified and addressed.
  • “The autonomous National Testing Agency (NTA) will comprise of numerous academic, educational, and psychometric experts, and from 2020 onwards will administer aptitude tests and tests in specific subjects that can be taken on multiple occasions during the year in order to reduce the intense and unnecessary pressures of the university entrance examinations system.” (page 109) [A serious capacity constraint is unlikely to be addressed just through an intent especially as the intent was expressed in 1986 also. The NTA is functioning since 2017 but there are challenges before it achieves its quality goals.]
  • “If every literate member of the community could commit to teaching one student/person how to read, it would change the country’s landscape very quickly; this mission will be highly encouraged and supported.” (page 58)
  • “To create a culture of reading, public and school libraries will be expanded across the country, and will contain books – particularly children’s books – in local and regional languages.” (page 64)

Examples where the context and / or issues are complex and may not have fully ben appreciated:

  • “Students will be expected to take a total of at least 24 subject Board Examinations, or on average three a semester.. Board Examinations will be significantly restructured to test only core concepts, skills, and higher order capacities in a range of required subjects and a range of elective subjects of the student’s choice.” (page 108) [The movement has been towards fewer centrally conducted Board Exam subjects]
  • “far too many children are enrolling in Grade 1 before the age of 6, due to a lack of any suitable pre-primary options;” (page 46) [More children are enrolling before the age of 6 because their states mandate 5 as the age for grade 1. Gujarat tried shifting it to age 6 a few years ago but it was not popular and was dropped.]
  • “At the school level, such developmental assessment of learning will be carried out periodically, and at least once a month, in all domains, to help both teachers and students continuously reassess and optimise learning plans.” (page 107) The word domain, used here, is not explained. If it refers to subjects, this will leave little time for teachers to teach.

4. The experience of people and organisations who have worked for years or decades the space, both within and outside government, does not seem to have been drawn upon: Many examples have been shared, especially in points 1 and 3 of this section, where the policy seems removed from the historical and day-to-day realities of the Indian education system. Yet there organisations which have worked with these ground realities for decades. There are individuals who have led these organisations and others in government who have grappled with these problems. With the exception of a few of these organisations like the MHRD, UNICEF and the Azim Premji Foundation, I felt these voices are completely missing in this policy. I am naming organisations here across the non-profit and for-profit space, most of which have worked for over 15-20 years, but do not seem to have been mentioned or their work consulted and acknowledged in creating this policy: Pratham, ASER, Eklavya Foundation, Digantar, Vidya Bhavan, Teach for India, Kaivalya Education Foundation, Centre for Civil Society, World Bank, Educational Initiatives, Akanksha, Boston Consulting Group, etc. This list is definitely incomplete, but I have tried to only name organisations that have worked either for a very long period of time with government systems and / or at scale. There are education officials within government who have developed deep experience and expertise whose voices seem to be missing in this policy.

5. Miscellaneous points which seemed unclear or erroneous: For example, it says on page 48 that ‘the traditional roles of families in raising, nurturing, and educating children also must be strongly supported and integrated.” But what about non-traditional, modern roles, eg. single parents, working mothers, LGBTQ parents, etc?

It is mentioned on page 55 that about 5 crore students have not attained the ability to comprehend basic text and carry out basic addition and subtraction with Indian numerals and that a large proportion of students that fall behind in fact fall behind already during the first few weeks of Grade 1. The reference to ‘Indian numerals’ and ‘the first few weeks’ were not clear.

 

In summary, I would reiterate the principles I would like to see in a National Educational Policy for India. We should have a few clear objectives that remain effective for a period of time like a decade or so, take stands that enable a decisive approach and will help us get to those objectives. Additionally, it should be evidence-based and strongly linked to ground realities as well as challenges. The current draft has done a little on these things, and  there are others that need to be focused on.

Sridhar Rajagopalan

Sridhar Rajagopalan

President & Chief Learning Officer at Educational Initiatives
Sridhar Rajagopalan is a co-founder of Educational Initiatives and its President and Chief Learning Officer.
Sridhar Rajagopalan