General comments
The Department of Basic Education (DBE) welcomes the report by Prof Mary Metcalfe and her Task Team, in particular the opportunity to comment on the draft report. The DBE believes that the report adequately captures the complexities of the section 100 (1)(b) intervention in the Limpopo province and the difficulties experienced by national government in terms of operationalising the provisioning of textbooks in that context. The DBE also appreciates that the team led by Prof Metcalfe worked under very tight timelines, and given the urgency of this matter and the public interest, the DBE receives the draft report with gratitude.
Specific comments
1. It is important to distinguish clearly between the national Department of Basic Education (DBE) and the Limpopo Department of Basic Education (LDOE) throughout the report. The two departments are at times conflated, creating the impression that the DBE is responsible for what is essentially provincial competencies, notwithstanding the section 100 (1)(b) intervention. The usage of the term “Department” throughout the report further contributes to this confusion.
2. The DBE will consider carefully the recommendations of the report and will fully respond to these in due course. It is important to point out though that some of the recommendations referring to the specifics of the current process will be implemented immediately. These refer, for example, to the urgent and clear communication to all schools; the institution of a comprehensive verification process of all deliveries against requirements and orders and the finalisation of the 2013 textbook procurement process.
3. In terms of recommendation 5, the involvement of District Senior Managers and Circuit Managers has enhanced the return rate of the PoDs from 34% of PoDs captured in the system on 05 July 2014 to 72% on 12 July 2012. On 13 July 2012, as part of strengthening our communication in this regard, a spreadsheet delineating exactly what PoDs have not been returned per Circuit and school, has been sent to the responsible District and Circuit senior managers for follow-up. The communiqué is quite explicit that if the PoDs are not returned on or before the end of the first week of the reopening of the schools the contracts with the distributors will be deemed to have terminated, and the department will resort to law enforcement agencies to recover the textbooks as assets of the State.
4. The scope of the work of the Task Team was limited to Grade1-3 and 10, as was the order of the Court. Grade 11 in Limpopo is part of the top-up exercise by the Department. The findings of the survey by the Task Team reflect a low rate in terms confirmation of receipt of textbooks, because some of the schools that have been selected to be part of the survey, were in effect outside the scope of the audit. For example, intermediate and independent schools, which cover Grades 4-7, were part of the schools sampled by the Task Team. This has somewhat distorted the actual outcome and picture of the exercise.
5. The reason for the withdrawal of the first order placed with publishers, was because the data used for those orders were incorrect.
6. In terms of the timeline provided it is important to point out as follows for 27 June: The preliminary report compiled and sent to both the DBE and Section27 on 28 June 2012, using the SP1 and 2 datasets, is quite clear that the distribution from both the central and district warehouses, in respect of Grades1-3 and 10, had been done, as indicated in graphic distribution representations. The graphic representations from SP1 and 2 were based on the books ordered and distributed to and from the warehouses. There is nowhere in the preliminary and subsequent reports where figures provided confirmed or inferred delivery directly to schools, in spite of the fact that the textbooks were moved from all warehouses. Instead, the preliminary report is quite clear on the challenges experienced in securing principals or nominated officials to come to their respective schools, to receive the textbooks and signed the PoDs. These challenges of the non-availability of some principals or nominated officials were confirmed by various stakeholders, and in particular the distributors in several meetings. The preliminary report further stated that the next consolidated report will provide verified information from the PoDs in terms of the actual direct deliveries to schools.
7. The draft report makes the assumption that “the books requisitioning process is fundamentally similar throughout the country” (p5) and as a result comes to a number of debatable conclusions. The fundamental question here though is whether this is within the terms of reference of the Task Team. It is advisable that the report limits itself to the Limpopo Department of Education and its procurement processes in this regard. Also, the procurement and delivery of textbooks has nothing to do with the DBE, and is the sole preserve and prerogative of the provincial education departments.
8. Dr Karodia was appointed on 1 February as administrator, but was only formally appointed as Accounting Officer on 24 February (see P10).
9. Mr Ron Swartz was appointed as administrator in Dec 2011, and not in January 2012 (p10).
10. With reference to footnote 5 (p12), this is incorrect. The DBE wrote to Mr Monde Tom on 26 January to request that funding for the requisitioning of textbooks be made available without delay. The DBE did not receive formal correspondence from either Mr Tom, or National Treasury in this regard. It is thus incorrect to claim (6.4.2) that “funds were demonstrably available.”
11. It is important to highlight that the Administrator for the LDOE also reported to the head of the national intervention team in the province, Mr Monde Tom. In this regard, it is advisable to differentiate clearly between the administrator for the department of education and the administrator for the province.
12. In terms of the legislative framework, it is the national executive, and not a national department (6.6.3) that assumes section 100 (1)(b) responsibilities. The national department then assumes responsibility for the provincial administrative function without additional capacity and resources. Additional financial resources are not necessarily provided and in fact section 100(1)(b) is deliberately not viewed as a national financial bail-out for struggling provinces.
13. The assumption that the province was unable to proceed with the procurement of textbooks at the end of 2011 “because the education budget for 2011/12 was exhausted before the end of 2011” (7.1) is not debateable. The LDOE had serious cashflow problems and projected serious overspending at the end of the financial year.
14. In (7.3.1) it should be the budget allocation of the 2011/12 budget, not 2012/13. The allocation for the preceding financial year, provides for the procurement and delivery of the LTMSs for the ensuing school calendar year.
15. The textbook policy of the DBE is that all textbooks are expected to have a 3-year use (a minimum of 3 years shelf life) as captured in 9.2.
16. The reduction of the Limpopo LTSM budget for 2012 is not adequately explained. The original order for LTSM developed by the LDOE in 2011 amounted to around R655 million. In January 2012 after a teleconference with the HoD of Limpopo, Mr Thamaga, the order developed by Edusolutions was made available to the DBE. This order was not credible for a number of reasons e.g. we found that some schools ordered 100% for top-ups; ordered various titles for the same grade per subject and ordered Maths and Science books (grade 10-12)which the DBE was providing free of charge. The order was cleaned up by the DBE which reduced the amount from R655million to R249 million. This was further reduced when publishers were requested to provide fresh quotations in a competitive bidding process. This further reduced the amount to R146 million (This should be R126m, not R146m).
17. It is important in this regard to rephrase 8.2 (p14) to reflect paragraph 7 above. The LDOE did not provide schools with a budgetary limit for textbook orders for the 2012 school year, which is an important aspect of ensuring that schools institute measures to ensure that textbooks are effectively retrieved each year and which enable the provincial education department to cost-effectively provide LTSMs to learners. This also explains why some schools were ordering 100% of new textbooks in subjects and grades where top-ups should have been done.
18. Re (8.2): Central procurement to ensure a core textbook for every subject per learner is the decision of the Council of Education Ministers (CEM). Negotiating prices with publishers with the view of increasing textbook coverage to 100% for every learner per subject by 2014, is an initiative that has already been taken by provinces such as Western Cape for the 2012 school calendar year. Limpopo Department of Education in respect of the current process benefitted immensely in following in the footsteps of provinces such as Western Cape. Needless to emphasise the fact that, given the financial situation of the province, it was most certainly inevitable and obvious that the department would NOT afford to procure as per the individual choices of the schools.
19. SP2 was brought in by the DBE as part of the rescue plan in order to meet the negotiated deadline with Section27 (p25).
20. The process described in terms of the appointment of distributors on p26 is incorrect. The distributors were identified through a formal procurement process, whose terms of reference, as per agreement with Treasury, were published for a shortened period of two weeks. All identified distributors met the tender requirements published.
21. Concerning the Phonic Programme books (p29), these are part of the back-orders for one component of the Grade 1-3. The consignment still expected comes from the addendum Catalogue and from those publishers had indicated they did not have stock at the time when the earlier ordering was done.
22. Despite the welcome section on “What resources did schools have” (p14-15), it lapses into claiming that “schools carried on without teaching and learning support materials for months after schools opened for 2012”(p24). This needs to be sensitively addressed throughout the report.
23. We think it might have been useful to elaborate on the point raised on p28 that “...unrealistic expectations were created by assuming that books could have been distributed within a considerably shorter period without significant increases in resources, capacity and infrastructure.” We are aware that the textbook procurement and distribution process is generally undertaken within an 18 months cycle, and we have been assured by the previous administrator that these timeframes could be short-circuited in order to ensure delivery within a six week period. It cannot be over-emphasised that the LTSM procurement and delivery process is an 18 months cycle. To suggest that starting this process from January of the school calendar year would have ensured timely completion of the procurement and delivery process, reflects a lack of the understanding of the complexities and magnitude of a project such as this one.
It must be remembered that funds only became available from the 2012/13 budget allocation, which in fact, should cater for the 2013 school calendar year. Therefore, Limpopo did not have the required funds to procure and deliver textbooks for 2012. A decision had to be taken to use the allocation from the 2012/13 budget to procure and deliver textbooks for the 2012 school calendar year.
24. Please consider the following corrections:
In 2012, the budget has only allowed ‘top-ups’ for Grade 11 and 12 (the 2012/13 budget). Schools have been asked to use existing stocks of Grades 4 – 9 textbooks and make alternative arrangements for shortages (para. 9.4).
Because of the introduction of CAPS, new (CAPS aligned) textbooks were ordered for all Grade 10 subjects except for Maths and Science as well as Grades 1-3. This decision was taken because Maths and Science had been distributed to all Grade 10 – 12 learners in the country in early 2012, including Limpopo. Minister Motshekga announced in her 2012 Budget Speech that 4 424 500 Physical Science and Mathematics supplementary textbooks had been distributed to all Grades 10-12 learners in partnership with the Shuttleworth Foundation. The team did not verify the delivery of these books in Limpopo but we understand that a formal audit has been conducted (para. 9.5).
The DBE has from 2011 introduced workbooks for learners, starting with Language workbooks in all official languages for Grades 1 – 6 (Grades R-6 not only Grades 1-6); numeracy workbooks for Grades 1 to 3 in all official languages; and in English and Afrikaans for Grades 4 to 6 (para. 9.6).
This was extended in 2012 to Maths workbooks for Grades 7 - 9 (Grades 1-9 and not only Grades 7-9) in English and Afrikaaans, Lifeskills for Grades 1 – 3 in all official languages, English First Additional Language for Grades 1 – 9 (Grades 1-6 and Grades 1-9), Home Language for Grades 1-6, and Grade R workbooks. A departmental flyer explaining the workbooks is reproduced below (para. 9.7).
This means that for the key subjects of Language and Maths, learners from Grade 1 to Grade 9 should have received their own copies of the workbooks. Grade 1 – 9 learners would have had access to the existing textbook stocks in schools, and Grade 10 learners would have received Maths and Science workbooks (textbooks not workbooks). Foundation Phase learners would have had access to existing stocks of reading material (para. 9.9).
Circular 124 of 2012 is critical in the communication timeline. It is reproduced below because this important information is likely to be only received by many schools when they return on 16th July as it would have been delivered by hand, if at all, to schools that were closed. Some Principals would have seen this circular, but the majority would have been unlikely to (para. 10.2).
INTRODUCTION: The process to deliver books to schools in Limpopo for the academic year 2012, started in July 2011 (contradictory – the HoD sent a Circular to schools in October 2011 – refer to Table 3) (para. 11.1)
The report provided by SP1 for 11th June (July NOT June) (para. 16.2.1)
25. The Task Team openly acknowledges in detail efforts to communicate in paragraphs 10.1 and 10.2, and simultaneously laments the “poor communication”.
26. (Page 26, para11.5) Verifying the amount of books delivered against the trip sheets. This process was later aborted because the DBE team felt it was time wasting. The SP1 process had trip sheets, but only SP2 processes did not have trip sheets at the outset, as a process imperative.
27. (Page 26, para. 11.5) A trip sheet for the driver with information on which district office, the schools packed for, the number of boxes or parcels to be delivered (Very true and correct, but contradicts the above inaccuracy)
28 (Page 27, para. 11.6.1) In the first few days of the arrival of textbooks into the central warehouse there was checking of the deliveries by publishers. However, when the volume of arrivals overwhelmed the warehouse staff, an instruction was given to speed up receiving processes and the verification of orders received was compromised. (There was agreement with SP1 that speeding up the receiving process would NOT compromise the systems control measures, as there was enough capacity within the SP1 and its systems to manage emerging risks in the system.)
29. (Pages 27-28, para. 11.6.1 The sample of 411 schools, include intermediate and private schools which were not identified to receive any delivery of textbooks in the first place. Therefore the variance identified could be linked to schools which were NOT supposed to be part of the sample, thus in the main provide a distorted picture of deliveries that are still to be made.
30 (Page 28, para 11.6.1) A full audit will have difficulties in establishing the reasons, as after the first few days, procedures were not followed to check receipt of books from publishers into the warehouse (ironically there was an official for the department who was specifically assigned to do this – Mr Semenya, would check, sign and hand over the signed documentation to SP1).
31 (Page 28) The team did find 13 instances where it took between 16 to 18 days between dispatching books from central warehouse to delivery to schools. It is assumed that the PODs that have still to be returned may have been those deliveries that had taken longer than the average to deliver. How were the 16-18 days arrived at when the relevant prerequisite documentation is still awaited?
32. (Page 28) SP2 systems have not been integrated resulting in reporting and information on distribution packs being significantly different from SP1. While SP2 followed its own systems, the process required integration on receipt of the PoDs; and this is underway. The final consolidated report will reflect this.
33. (page 28) It is not clear as to how the absence of the resources stated here could have compromised the delivery value chain. How could the Task Team compliment the processes as it is done in paragraph 11.5 in terms of the effective system that was in place to track delivery up to the end point, if the value chain was compromised? What justifies the argument that manual operations are NOT effective?
34. The systems used by SP1 and SP2 remained the sole property of these service providers with certain reporting functions delegated for officials to use. Officials were unable to interrogate the system to mediate between information reflected in the reports and the existing perception at the school level. The fact is officials of the LDoE had access to these systems and that there was joint cooperation between the SPs and the LDoE to monitor all processes involved, including ensuring functionality and accuracy of the systems. The process is not completed as yet, and therefore it cannot be determined that whatever property belonging to the LDoE will NOT be submitted by the SPs.
35. (Para. 12.3.1, page 31) The initial report, issued by the LDE, that about 99% of books were delivered was incorrect (the percentage is factual correct), because it compared books ordered against books dispatched from the central warehouse for delivery in the Capricorn District and to the district warehouses. Precisely the point and factual. Even the preliminary and subsequent reports stated this fact.
36. (Para. 12.3.2, page 31) We can confirm that not all books required by LDoE to be issued to schools were 100% received from Publishers (Affirmative, but nowhere in any our reports did we ever say or infer this). This could be attributed either to the ordering of insufficient books from Publishers (the EMIS data was used to place orders. To the contrary, we have a small surplus for Grades 1-3, and a sizeable number of Grade 10, which have been inspected by the auditing team at the central warehouses).
37. The footnote on page 32 needs to be revisited as the Administrator was not approached about the matter raised there. Please favour the Administrator with the information.
38. (Page 35, para 13.9) Principals’ Goodwill: It was heartening that so many principals were primarily concerned for the loss suffered by their students who did not receive textbooks timeously or at all. There is clearly a deep commitment on the part of many school authorities to provide for the students. There were several reports of principals paying for resources from their own pockets for learning resources. A few travelled long distances to fax their Proof of Delivery [PoDs] papers to the Call Centre, so demonstrating their support for its purpose. PoDs are colour-coded, and are in triplicates. What would have been the need to fax, who would they have faxed to, and for what reason? What is the fax number that these principals would fax to?
39. Some schools fetched their own textbooks from the warehouse but when they arrived they found that the books had not been sorted or that the books they needed were at the bottom of piles so had to come back repeatedly. In some cases it appears that Education Department officials delivered the books to schools themselves. Books were packed per school; the packs were clearly marked and identified with a unique sticker. Again, we wish to be provided with the details, including warehouses where this could have happened.
40. (Para 13.18, and Table 8, page 37) The unavailability of principals or persons delegated by them to receive books at their respective schools, has been harped upon several occasions and in a variety of reports.
41. (Para 14.1, page 39) PoDs provide information on incorrect or partial deliveries and these are immediately remediated.
42. (Para 15.13.2, page 47) The report to the Minister did not tell her that orders had not been placed for any IsiNdebele books, for isiXhosa phonics programmes, for Sepedi graded readers, for Setswana big books, for Tshivenda big books and phonics programmes, for Xitsonga big books and phonics programmes and for Afrikaans FAL big books. Nor did the report to the Minister tell her that delivery was incomplete for many of the foundation phase orders in process. It must be reiterated that the textbooks ordered from 03 June 2012 were those included in the National Catalogue, which in the main exclude the textbooks listed above. These materials included in the addendum Catalogue (isiNdebele Big Books and Phonics Programmes, and Graded Readers; isiXhosa Phonics Programmes; as well as Tshvenda Big Books and Phonics Programmes), which was released only on 12 June 2012. Setswana Big Books and Afrikaans FAL Big Books are neither included in the National or addendum Catalogue. Sepedi Graded Readers have a sole supplier listed in the National Catalogue, whose price was extremely expensive and unaffordable (+/-R50.4 million for +/- 15 000 packs). With the exception of the Sepedi Graded Readers, it therefore goes without saying that no provincial education department would have been ordered these textbooks, as the addendum Catalogue was only made available on 12 June 2012 or the books are not in stock.
43. (Para 15.13.3, page 47) The errors in this report could be a consequence of over-worked officials working under great pressure, with limited capacity and inadequate support. It must be emphasised that errors in interpretation of the preliminary and subsequent reports should not be blamed on these reports themselves, but solely on the reading of the content contained in these reports. It is important to recall that the preliminary report of 28 June 2012, provided cumulative status reports of previous similar reports sent to the DBE and Section27 in the same format. In addition the preliminary report highlighted challenges in respect of verification at the school level. There was not stage that the status reports in their format were ever contested.
44. (Para 15.13.4, page 47) However, if it is the case that the presentation of partial information was aimed at protecting the Minister in the face of immense public pressure, this was an error. The failure to provide full and accurate information to the Minister fundamentally undermined her as her office was communicating information to the public that was incorrect. As indicated in 15.13.2 and 15.13.3 above, it can be seen that there was absolutely no intention to sanitise the report to the Minister, the DBE and Section27, thus to be perceived as having misled them.
45. (Para 15.13.4, page 47) SECTION27 challenged this misrepresentation on the basis of evidence received from the public. This led to the agreement between the DBE and SECTION27 that a verification exercise should be conducted. The verification team has confirmed the inaccuracy of the information provided to the Minister. The fact that the principals decided to appoint a Task Team whose main focus would be to verify delivery, was an acknowledgement of the difficulties listed in the preliminary and subsequent reports. The Administrator and the team felt affirmed by this decision.
46. The schools affected in the audit sample are listed below:
Elica Primary
Gindikindi Senior Primary
John Marubini Primary
Jonkman Primary School
Lesedi Waldorf Centre
Lesodi Motlana Higher Primary
Mafadi Academy
Magandangele High
Makgodu Primary
Makgwadiba Primary
Mashakadzi Primary
Matakwe Primary
Mathula Primary
Mohlaba Primary
Morekhure Primary Farm
Motsephiri Primary
Muengedzi Senior Primary
Mukhuno Higher Primary
Myakayaka Secondary
Ntshiba
Ramagohu Primary School
Soka Leholo Higher Primary
Sweetwaters Christian School
Takalani Primary-2
Timothy Tshibvumo Primary
Tsherane Higher Primary
Tshivhazwaulu Christian Academy
Tshware Primary
The list confirms the point made earlier that a great number of schools chosen as part of the sample fall outside the scope of the work of the Task Team (see the schools highlighted in green font).
Conclusion
The DBE welcomes the report and trust that the above comments will be positively considered. The DBE again wishes to thank Ms Metcalfe and her team.