Free Education Policy Performance Audit Report 9 Recommendations - Tuition Fee Free Education Policy 2012-2018

The Auditor's General Office did a Performance Audit Report on the Tuition Fee Free Education Policy for the years 2012 to 2018. PNG Insight follows the free education agenda over the years and found this document to be an important review of the TFF policy.

The 9 recommendations presented in the Free Education Policy Performance Audit Report and the National Department of Education responses are highlighted below.

Read the report by sections or download the PDF from here:

Free Education Policy Performance Audit Report 9 Recommendations - Tuition Fee Free Education Policy 2012-2018

Free Education Policy Performance Audit Report 9 Recommendations 

Recommendation 1

The Auditor General's Office recommends that the National Department of Education should:

  • a) review and amend the TFF policy document and Manual Guide as a matter of urgency to capture the changes made by the Government regarding the TFF percentage payment components as well as recent changes to the TFF policy.

  • b) establish a clear communication strategy to enable timely and consistent communication of TFF information to schools and provinces on any subsequent changes made to the TFF policy to avoid confusion and misunderstanding by schools and parents in the way the TFF policy is managed and implemented.

National Department of Education response:

  • a) Noted. Completed and endorsed as per revised policy. The three (3) TFF components (ADMIN, INFRASTRUCTURE, TEACHING & LEARNING RESOURCES) were imposed to set as a guide for schools to budget and spend TFF funds accordingly. School acquittals should show clearly how much was spent according to the components.

  • b) Noted. NDoE is consistently exploring better ways of communicating with schools and provinces on a timely basis. Communication is delayed at the provincial divisions of education. NDoE has a well-established EdNet connected to all provincial divisions. Some provincial divisions of education do not maintain their bills which leads to disconnection from ISPs. We will explore other options or platforms.

Recommendation 2

The Auditor General's Office recommends that the National Department of Education should:

  • a) effectively coordinate and monitor the roles and responsibilities of the Provincial and District Education Authorities, TFF Coordinators and Standard Officers in charge of implementing the TFF policy at the Provincial level. The roles and responsibilities of the key players involved in the implementation of the TFF policy at the Provincial and District level need to be guided by policy terms and conditions directing the officers to carry out their duties as required under the TFF policy and Implementation Guides.

  • b) evaluate the trial of the decentralization of the TFF management functions in the six provinces to make informed decision-making as to whether to continue with the decentralization of the management functions in other provinces.

National Department of Education response:

  • a) Noted. However, the reporting structure presents challenges. It is impossible administratively, functionally and legally to have total control over provinces and districts by the National Department of Education. Provinces and district administrations operate under provisions directed by the Organic Law on the Provincial & Local Level Governments (1995) and not under Education Act 1983. Hence, we are pursuing decentralization. 

  • b) Noted. The policy is best implemented with support and collaboration from provinces. Responsibility and ownership by provinces is a challenge in implementing the policy as observed in audited sample provinces and decentralization may be the approach to ensure there is ownership by provinces and accountability as almost all the recipient schools are provincial institutions and owned by provinces.

Recommendation 3

Auditor's General Office recommends that the School Census Forms are sent to schools far
enough in advance to ensure that the National Department of Education (NDoE) receive completed forms by the first quarter of the school year. 

In addition, the NDoE need to ensure adequate school inspectors or standard officers are employed to monitor the schools in the country and assist schools in filling out their School Census Form.

Alternatively, the NDoE should review the process for data submissions and determine the best way to get a more timely response (eg. establish online data links and information sharing between provincial and national levels).

National Department of Education response:

It is the current practice as recommended. The SCFs are sent by the Corporate Data Branch at the beginning of the school year to the provinces. The provinces are delaying the delivery of the forms to schools. 

The roll-out of the MySchoolApp online data link which now registered more than 8,000 schools should ease some of these challenges. The School Inspectors with two inspectors per district will be boosted to three per district.

Recommendation 4

Auditors General Office recommends that the TFF management team should make a commitment to verify the schools that have genuine enrolment growth rates in order to pay their full amount of TFF funds. 

Data validation and verification of schools' bank accounts should be given priority before TFF payments are run.

National Department of Education response:

Noted. The current payment process observed this. Will look into this seriously. The only increases in student enrolments are expected at the entry grades of Grade 3 and Grade 9 and 11 with few transfers into all grades. 

NDoE may maintain a 5% acceptable growth validation process to control the submission of inflated or falsified enrolment data. The underpayments were due to the policy requirement on the use of the previous year’s enrolment data. 

The policy management gave that direction after assessing that real-time data would not be possible to obtain from provinces if the current year’s data was to be considered. There are also issues with communication means to reach schools. 

Excessive withdrawals and no funds to maintain the accounts cause continuous bank rejects. The policy’s Implementation Guide directed schools to maintain K100 minimum balance on every withdrawal to ensure the account is active. 

Rejected funds are reverted automatically into the Holding Trust Accounts and affected schools are advised per the bank’s rejects list to activate accounts to continue receiving the grants. Missed payments called “underpayments’ are backdated and paid to schools within the year.

Recommendation 5

To address the issue of inadequate and late payments of TFF funds as well as minimise the impacts on schools, the AGO recommends that the National Department of Education should:
  • a) in consultation with the Department of Finance and Treasury make sure that TFF funds appropriated in the annual budget are frontloaded into the TFF commercial banks Trust Account during the beginning of the school academic year and are managed and paid to schools each quarter and on time as required by the policy. Adequate funding should be paid to schools as per school valid enrolment numbers.
  • b) work closely with Provincial Education Authorities and provide support to provinces with student overpopulation to help them identify options to address the issue of overcrowding in schools by building enough classrooms and infrastructure facilities that will accommodate and aid student learning.

National Department of Education response:
  • a) Agree. The release of TFF funds to schools depended on the timely release of warrants from the Department of Treasury and payments from the Department of Finance. Further, the actual grants calculated and paid to schools have been less than the NEB Fee limits. Most schools use the NEB fee rates to establish budget estimates while the funding provided by the Government is less than the fee rates due to increased enrolment annually.
  • b) Noted. Functionally, the National Government cannot build all school infrastructures in the country. The elementary, primary and secondary schools are provincial institutions. The national government is providing funding under the policy. Planning and funding infrastructure for these institutions rests with the Provincial Governments and the LLGs and DDAs.

Recommendation 6

The Auditors General Office recommends that the National Department of Education should:

  • a) scrutinize and monitor the distribution and delivery process of teaching and learning materials so that schools received their supplies on time as required.
  • b) establish its own project management and monitoring team to provide effective monitoring and reporting on the procurement & supply and delivery of school materials instead of engaging private contractors to do this work. This will ensure the quality of work and credibility of information provided in the monitoring reports is not compromised.
  • c) carry out a needs base survey on the different types of schools in the country, to get information on what kinds/types of school materials are needed in order to procure and distribute needed supplies to schools.
  • d) conduct a specific review of the TFF Commodity Component Trust Account in order to assess the Value for Money achieved with respect to school teaching and learning materials procured and distributed to schools over the years.
National Department of Education response:
  • a) Noted. The Department of Education addressing this issue with new contract terms on delivery. The department encourages door-to-door delivery but does not have the funds to pursue that. Therefore, in the contract, all schools are required to sign the delivery notes so contractors can get their final payment.
  • b) Noted. Vital and Agree. Proposed to be effected in 2021. The issues are being addressed in 2020 by not contracting a management contractor with this responsibility reverted to the department of education to take charge and supervise work done by procurement and delivery contractors.
  • c) Noted. Department of Education has taken that approach but realised schools have different needs based on different locality needs, therefore a decision was made for schools to use the remaining 15% to cater for other additional needs.
  • d) Noted.

Recommendation 7

The AGO recommends that the National Department of Education should work closely with relevant government departments such as the Department of Finance and conduct regular quarterly audits on school bank accounts in order to prevent fraud and misuse of TFF funds by school management and the authorities concerned. 

Specific audit attention should be given to church-run schools to make sure that TFF funds are properly managed and used for TFF purposes.

National Department of Education response:

Noted for consideration with Department of Finance collaboration. The Department of Education is advocating on School Learning Improvement Plan (SLIP) which is a 3- year development plan in a school. 

The Department of Finance is also carrying out school financial audits in 2019/2020 and will provide further reports on this. Funding is a constraint.

Recommendation 8

Having the TFF policy implemented by various key players requires effective coordination and monitoring arrangements by the top management to ensure program delivery and outcomes are achieved. 

As a matter of urgency AGO recommends that the National Department of Education should:

  • a) put in place a holistic monitoring and reporting framework/ plans to guide the monitoring and reporting activity of the TFF policy. Funding should be also made available in the budget appropriations to fund the monitoring and reporting activity of the TFF policy.
  • b) take proactive action to make sure that the TFF-mandated reports required under the policy are compiled and sent to the Department and policymakers on time. These reports should contain sufficient and complete information on the TFF expenditure payment records, issues and challenges faced by schools, as well as the impacts and outcomes of the policy implementation over a period. This will assist policymakers in making a useful decision concerning the policy if there is a need for improvement in the way the policy is managed and implemented.
  • c) provide effective coordination with key players in charge of implementing the TFF policy at the provincial level to make sure that schools compile and furnish their TFF acquittal reports regularly as required under the policy guidelines.
  • d) develop key performance indicators (KPIs) and monitor and evaluate the policy over time to measure its progress in achieving the stated policy objectives and outcomes. Establishing a set of performance indicators with program evaluations would provide visibility to decision-makers on the management and performance of the TFF policy over time.

National Department of Education response:

  • a) Noted for consideration. This will be a priority as we are now decentralizing the government tuition fee services. We will set standards too.
  • b) Agree and noted. Impacts and outcomes were to be part of the report but TFF Coordinators have not been specific in their reporting. A new monitoring framework will capture a standard report.
  • c) Agree and noted. The acquittals process and procedures were addressed through Secretary’s Circular Instructions No. 7/2018 to schools. The Provincial Education Authorities failed in their part to put in place control measures to implement the directions.
  • d) Noted. It is agreed that the program has not been monitored or evaluated. The TFF Secretariat has had sets of Key Priority Areas to ensure TFF functions were carried out successfully annually. Key priority areas such as facilitating payments to schools, the roll-out of DEIC, decentralization of TFF, TFF policy awareness and quarterly IDSC meetings were the main focus though some of these priority areas were not been achieved due to funding constraints.

Recommendation 9

The Auditor's General Office recommends that the National Department of Education should:

  • a) put in place a TFF training plan and provide training to Head Teachers and the Board Of Management on how to maintain and aquit all TFF financial and accounting records adequately and accurately.
  • b) provide all school Head Teachers with the TFF Policy Manual Guide so that they know its requirements and compliance.

National Department of Education response:
  • a) Noted. More than 1,000 Head Teachers especially from primary schools were trained with funding assistance from the Australian Department of Foreign Affairs and Trade (DFAT) in 2017.
  • b) Noted.


Content layout

Executive Summary and Recommendations


Overall Audit Conclusions and Key Findings

Recommendations & NDoE Responses


  • Recent changes to the TFF policy
  • Audit rational
  • Audit objective and criteria
  • Audit scope and methodology
  • Previous audit coverage


  • Background
  • Applicable legislation and national education plans/policies
  • Alignment of TFF policy to broader education plans and legislation
  • TFF Policy implementation
  • Governance and management arrangements
  • Conclusion

  • Recommendation 1
  • Recommendation 2


  • School data collection and verification
  • Data management system and enrolment data validation and TFF calculations process
  • Financial management approval process and payments of TFF funds to schools 33
  • Timely payments of TFF funds and impacts on schools
  • TFF funds used to pay for administration expenses
  • Commodity components- Teaching and Learning Materials
  • Approval to withdraw TFF funds at the Provincial level
  • Conclusion
  • Recommendation 3
  • Recommendation 4
  • Recommendation 5
  • Recommendation 6
  • Recommendation 7


  • Background
  • Monitoring arrangements and framework
  • Reporting and acquittals of TFF funds
  • Performance measurement and evaluation
  • Conclusion
  • Recommendation 8


Recommendation 9


Performance Audit Report on Tuition Fee Free Education Policy 2012-2018

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