I could send my comments today to the DoPT. The comments are somewhat disjointed as I had to type the whole thing myself. Stenographic assistance could have helped in making it better and fuller. COMMENTS ON THE RECOMMENDATIONS ON STAFF SELECTION COMMISSION AND RELATED ISSUES 1. GENERAL i. The Composition of the Expert Group and its recommendations should have been placed in the public domain, along with the Working Group deliberations, for obtaining meaningful feedback from the public and other stakeholders on the recommendations. The public and the job aspirants have a right to know the details of the ‘experts’ included in the Expert Group. The Group appears to have worked for about nine months and obviously time was not a constraint. It is, therefore, strange that the Group did not give an opportunity to the public to interact with it. I had expressed a desire to the Chairman, SSC, for an opportunity to interact with the Group to share with them my perceptions of the changes to be brought about in the Policies and Procedures of the SSC in the context of present management deficit in SSC and the lack of transparency which have eroded the confidence of vast multitudes of the job aspirants who flock to the SSC’s examinations with the hope of timely results and seek levels of transparency they saw for four years prior to April 2013. The Department of Personnel and Training which is the nodal Department for matters connected with the Right to Information Act, 2005, which aims at infusing transparency in Governance, must be the modicum of transparency by placing all relevant papers in public domain. Transparency and Timelines have never been the hallmark of Staff Selection Commission (SSC) in the recent past, except for a brief period of about four years between 2009 and 2012, and it is too much to expect the SSC to give publicity about the Expert Group or its sittings. With no access to the Report of the Expert Group, further comments and suggestions are made in the following paragraphs on the basis of scanty information provided by the DoPT in its note on its website. ii. There is no mention in the DoPT’s note on the following major policy issues connected with the SSC. a) Status of the SSC. SSC is only an attached office of the DoPT and has enjoyed autonomy in its functioning sporadically only when it was headed by officers who did not believe in consulting the DoPT on day to day basis. A suggestion was made in 2012 to confer statutory status on the SSC and to modify the Rules to make it mandatory that its Chairman should be a Secretary level officer, with assured tenure of five years, in order to attract officers of better quality and talent. While the upgradation of the SSC is not the panacea for all evils, the Chairman of the SSC, with an assured tenure of five years, can review the process of recruitment and the in house procedures immediately after he takes over, and not when he knows that he would be leaving the Commission shortly as will be the case now, make changes as he may feel necessary consistent with his beliefs and faith and continue with them till he completes his tenure. 2 or 3 years is not an adequate tenure for the Chairman, SSC. It was further recommended that the Members should be of the rank of at least Additional Secretary to the Government so that they can effectively contribute to policy making in the SSC and can be expected to be impartial and not succumb to external pressure. A natural corollary to this suggestion is that the Chairman and the Members will cease to be Central Government employees on appointment to the SSC. It is strange that a few states have constituted State SSCs as statutory bodies with tenure of five years for the Chairman while the SSC in Government of India is an attached office of a Department. b) Separate cadre for the SSC It was agreed in principle by the DoPT in 2010 that the SSC would have its own cadre and not share officers and staff of the DoPT. With the change in the Secretary, DoPT in 2010, this was forgotten. The present situation leads to officers of inferior calibre barring a few, mostly those on the verge of retirement or whose wards are in need of employment, being placed in the SSC. You cannot produce good quality work with officers of indifferent quality. A recruiting organization needs to develop expertise which will not be possible with officers who come and go at their sweet will or at the dictate of the DoPT. It is common for the CSS officers posted in the SSC to threaten of reverting to the DoPT whenever their inadequacies or inefficiency are pointed out. If the SSC has to fulfil its role effectively and also build a reservoir of expertise, skill and knowledge in the sphere of recruitment, these suggestions need to be considered seriously. Otherwise, the present scenario of total disconnect with established principles of psychometrics will continue. When I took over as the Chairman, SSC, in April 2009, I inquired about the psychometricians who were advising SSC then and a Member asked who a psychometrician is! The situation may not be very different now. 2. National Screening Test DoPT’s note says that the Expert Group is not in favour of a National Screening Test but has opined that a decision may be taken after further debate on the issue. The premise on which they did not recommend it or the contours of the National Screening Test (NST) considered by them are not known. However, it is necessary to explain how the concept of National Screening Test developed. The SSC handled only about one million applications in FY 2008-09. We set about giving publicity to its examinations all over the country with focus on Western, Southern, North Eastern, Eastern and Karnataka- Kerala Region and the number of applications from all the regions recorded significant increase in FY 2009-10 itself. A Question Bank Workshop was held in Chennai in late2009 and a Seminar on Issues of Recruitment in the Government and Banking Sector was organized as part of the Workshop. A State PSC Chairman, the Chairmen of a Railway Recruitment Board and a Police Recruitment Board and the Director, Institute of Banking Personnel Selection, participated in the Seminar, beside the Chairman, SSC. One of the issues raised in the Seminar was the multiple examinations a job aspirant had to take while striving for various government jobs for which the job specifications and the examinations were almost identical. The Director, IBPS, and I had follow up discussions on the feasibility of a National Level Screening Test for analogous posts for which the educational qualification was identical. After the discussions we initiated proposals for a National Level Screening Test to the DoPT and the Department of Financial Services separately. The Common Written Examinations for Clerks and Probationary Officers for the Nationalised Banks took shape in the banking sector after receiving approval of the Department of Financial Services while SSC’s proposal to the DoPT remained unattended. The phenomenal increase in the number of applications for the SSC Examinations, reaching over 15 millions in FY 2012-13, from 1 million just four years ago, and MTS recruitment by the SSC necessitated a rethink on the National Level Screening Test. By then, the Banking Sector had conducted at least two separate Common Written Examinations for the Clerical and Probationary officers’ cadres. The concept of National Level Screening Tests for job aspirants with Matriculation, Higher Secondary and Degree qualifications is very much relevant if applied to the jobs in the Government, Railways and Banking sector with voluntary acceptance of the scores by the State PSCs, State SSCs, CAPFs and the CPSUs. It needs to be noted that GATE scores, primarily meant for selecting students for post graduate technical courses, now form the basis for shortlisting candidates for technical jobs in several CPSUs. The idea of a national Level test has been debated since the mid 1980s when the Government came up with the National Testing Service under the Department of Education. The broad contours of the NST can be: i. Online NSTs for Matriculates, Higher Secondary qualified job aspirants and Degree holders should be conducted in the last quarter of the financial year to provide scores valid for the next financial year. ii. The scores will be available in the public domain. iii. The Agency conducting the NSTs will also place the number of job aspirants available at each per cent of marks. iv. Individual recruiting agencies will advertise recruitments with shortlisting for further stages of recruitment on the basis of marks in the NST concerned. This will ensure that the energy and resources of the recruiting agency cal be focussed on refining further stages of recruitment which may be conducted mainly online with one descriptive paper for further shortlisted candidates, depending on the posts and the need for technical skills or written communication skills. It may be noted that the NST will not be necessary for technical posts for which even at present only a few lakhs of applications are received. 3. ONLINE EXAMINATIONS i. Online examination for a few million applicants was successfully conducted by the IBPS for the first time in 2012 with the involvement of an IT major. Given a few more months of additional tenure I would have conducted a major examination of SSC online in the first half of 2013 itself. Today, the technology is proven and private sector organizations capable of aggregating infrastructure available with a large number of agencies are available. Therefore, the decision to hold online examinations for objective type question papers should be given effect at the earliest. In fact, I had taken the initiative of meeting the Chairman, SSC, in January 2014 and suggesting immediate introduction of online examination in SSC. He stated that the DoPT was not in favour of the idea. ii. Aggregation of the infrastructure for the online examinations and their supervision should be a turnkey project offered to firms of proven calibre. SSC’s reputation today has reached its nadir and there should be no experimentation. iii. There should be effective control by SSC on the examination technology environment, servers and data centres and other infrastructure for a limited duration which will be from the time the question papers are handed over to the completion of the online test, evaluation and transmission of scores. There will be a temptation to establish, own and control such infrastructure by the Government and it will be unwieldy and expensive to yield to the temptation. It will be like buying and maintaining an elephant only because it will be occasionally used for ceremonies. iv. The recommendation that the SSC should supervise the conduct of the online examinations should not be accepted as major aberrations had been noticed in the online skill tests where the SSC officers were actively involved in 2011 and 2012, requiring several checks and counter checks to eliminate malpractices. A major spin off of online tests will be dispensing with a disparate group of supervisors some of who have connived and collaborated with scamsters and fraudsters. This major benefit should not be fritted away by diluting the responsibility of the firm which is entrusted with the responsibility of conducting online tests on turnkey basis. v. There are major issues such as use of a Mini Question Bank vs a Single Question Paper in each session. Further suggestions on this can be given by me on this if and when necessary. vi. Fraudsters have been known to be active in online tests too. Therefore, post examination analysis of performance of the candidates is necessary to detect and eliminate frauds. I understand that the SSC dispensed with the post examination analysis in 2013 due to court cases. To overcome legal impediments it is suggested that the DoPT should consider and approve a scientifically valid Post Examination Analysis Method to be scrupulously followed by the SSC. vii. Item analysis and post examination assessment of difficulty level of question papers is necessary today like never before due to huge difference in difficulty levels of question papers used by the SSC in different sessions of recent examinations. An examination should not become a lottery- that is how the candidates of SSC perceive the question papers of SSC today. 4 .ONLINE REGISTRATION OF APPLICANTS i. The suggestions on lifetime registration of applicants and 100% online applications should be accepted immediately. It was only due to DoPT’s insistence that offline paper applications continued to be accepted in addition to online applications by the SSC after 2010. The suggestion that the applications should be web based with mobile apps is laudable. ii. It is suggested that there is no need for a grace period of a few years for the NE candidates before switching over to 100% online applications. The SSC and UPSC introduced online applications simultaneously in January 2010 and 2015 is not 2010. To cite the experience of the UPSC in the initial stage of introduction of online application is difficult to appreciate. iii. It is suggested that the static information in case of lifetime registration should only be the names of the job aspirant and parents, Date of Birth and Aadhar Card details and all other information should be dynamic and updatable. User id and Password should be available to each job aspirant with facility of updation whenever the job aspirant wants. iv. A major issue of online applications is the non availability of the servers in the last week of registration. This aspect should be carefully studied and remedial measures introduced including addition of server capacity etc. v. The Tamilnadu PSC introduced the system of lifetime registration in 2012 and it is not known whether they continue with it. It will be worthwhile sharing their experience regarding this. 5. QUESTION BANK i. The DoPT’s Note states that the recommendations of the Expert Group on this issue are agreed upon. I am unable to comment on this as the Expert Group’s recommendations on the issue are not available. ii. If the SSC looks into the past records, it can find an approved method of coding, evolved by a top psychometrician of the country based on SSC’s needs. Coding is a necessary pre requisite for digitization of the Question items in the Bank. iii. All the other recommendation on the issue were already practised in the SSC till 2012 and it is only a matter of continuing with them avoiding fiddling with the systems on ad hoc basis due to ignorance or a highly inflated ego. iv. Question Bank Workshops are not administrative affairs; they are specialized academic meets where psychometricians should provide inputs and guidance. There are a few in the country today with IBPS and the private sector who are happy and content with contributing to a national effort rather than working for money. There is no stigma attached to seeking the assistance of known experts even if they are in the private sector when the Government itself depends on the private sector expertise for deriving inputs for policy making. Association with the private sector cannot be an excuse for recognising and utilizing expertise available outside an organization. 6. MARKING IN SSC EXAMINATIONS The recommendations are welcome though many of them are already being followed by the SSC. I have made suggestion regarding normalization under Online Examinations which are applicable here too. Uploading of question papers is not a major issue for the job aspirants and will require considerable server space. 7. PREVENTION OF MALPRACTICE IN EXAMINATIONS The aberrations in the examination process, whether the examination is online or offline, will be due to greedy supervisors, which term will include invigilation too, use of technology by scamsters and the recruiting agency’s officials, which term will include the service provider in case of online examinations. Connivance between a few supervising officials, in house or outsourced, and scamsters on one hand and agency’s officials and service providers have been seen in the past and will continue to be seen in future. A combination of use of technology, strict adherence to manuals and internal procedures with multiple checks will be necessary to counter such aberrations and their perpetuators. Unfortunately, technology is available to everyone including the fraudsters. Reports indicate that fraudsters have found ways of rendering photo identification and LTI infructuous in ingenuous ways or using technology and this will have to be kept in mind. Videography, CCTVs, biometric recording are all expensive affairs and the cost will need to be weighed against possible benefits. Records may exist but who will be responsible for using them and at what stage? These are issues to be resolved. I have received feedback from countless candidates of SSC examinations of use of low technology methods such as impersonation, passing of chits with answer keys through the ubiquitous water boys etc after introduction of expensive mobile jammers. Many of these aberrations will be rectified with introduction of online tests though not eliminated altogether. Expensive technology use should be accompanied by inexpensive analyses on the basis of data and records. 10. AWARENESS CAMPAIGN Awareness about the SSC examinations is at its peak since 2011 onwards including in the NER and J&K. The recommendations about creating awareness are rudimentary and are not required at this stage. The need of the hour is to restore confidence about the SSC Examinations and Processes through display of transparency. An organization receiving 15 million applications every year does not need an awareness campaign! All the measures listed by the Working Group were actually used in the mid 1980s to increase the level of awareness about the SSC and again in 2009-10 and bore results. Today, reinfusion of transparency in the working of the SSC of the same level as noticed in 2010-12 will in itself be an adequate campaign. There is no point in going through motions of doing things; things are to be done efficiently, in time and in a transparent manner. Customer orientation is the need of the hour. The candidates are as much the customers of the SSC as are the User Departments. The unemployed youth cannot be treated as uninformed errant children. Improvement in customer satisfaction will itself serve as a publicity campaign for the SSC. 9. RECRUITMENT TO THE CAPFS The recommendations of the Working Group indicate that the lower level officers of the CAPFs have had a say in drafting them! A Committee headed by the then Additional DG of a CAPF had recommended in 2010 that the recruitment of Constables (GD) should be entrusted to the SSC. When the then Home Minister invited me for discussions on this I laid down a few conditions, which were all accepted by him, as pre requisites for SSC to invite applications and to conduct the written examination. If the SSC does not do it the individual CAPFs will do so in association with a few private firms at considerable additional cost, entailing multiple applications, PETs and Medical Examinations for the same set of candidates every year. The savings for the country was huge in addition to saving in time and it is only a matter of weighing the savings against the CAPFs doing the recruitment on their own. The issue of reserve list has been examined several times over and it has found a place in the recommendations again. Infusion of technology in PET and Medical examination will be welcome. 10 CONCLUSION . The present plight of SSC is due to its inexplicable decisions in the past 18 months giving rise to the popular perception that there is lack of sincerity, purpose and transparency. One such issue is dispensing with State Allotment in certain examinations without any explanation. There is a recommendation by a Working Group that the user Departments will be requested to allot states as per the option of the candidates. But what prevents the SSC from making the State allotment in the first instance? Perhaps someone in the SSC thinks that he/she can gain legitimacy to his/her irrational decision to dispense with state allotment. This is an example of genuine anxiety of the candidates at present. Unfortunately, none of the Working Groups or the Expert Group appears to have deliberated on the present state of affairs and what the SSC ought to do to regain the candidates’ confidence. That unfortunately, but unequivocally, is the need of the hour.
Posted on: Sun, 04 Jan 2015 19:33:10 +0000
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