Open Letter to ANESRS: For a Clearer University Regulation

To the attention of the National Agency for Higher Education and Scientific Research (ANESRS)<\/strong>

And to the attention of the heads of universities and higher education institutions in Haiti<\/strong><\/p>

The GOC University welcomes any initiative aimed at strengthening the quality, transparency, institutional accountability, and credibility of Haitian higher education. It believes that coherent regulation, based on explicit requirements and shared procedures, is a key lever for improving the university system.<\/p>

It is in this spirit that we learned of circular note no. ANESRS-IES-02 dated October 19, 2026, concerning the submission of institutional files.<\/strong><\/p>

This circular presents the approach as a verification of the administrative, academic, and regulatory situation of higher education institutions. We endorse this objective. However, its implementation calls for clarifications on the practical modalities of submission, the criteria applicable to the review of files, and the possible outcomes resulting from it.<\/p>

Our questions are not intended to challenge the Agency's regulatory mission. They arise from a need for clarity<\/strong>, necessary to enable institutions to respond accurately, uniformly, and documented.<\/p>

1. Specify the scope and consequences of the approach<\/strong><\/h3>

While the general verification objective is announced, it would be useful to clarify its operational scope and institutional consequences.<\/p>

Is the collection a one-time operation or does it fall within a periodic follow-up framework? Which academic year or period should it cover? At what date should data relating to teachers, students, and teachings be finalized?<\/p>

It would also be appropriate to clarify how this approach relates to authorization, recognition, certification, or accreditation procedures when applicable.<\/p>

Administrative updates, regulatory compliance checks, and evaluations for accreditation purposes are distinct processes, even when they mobilize certain common information. Therefore, institutions should be able to clearly identify the procedure they are engaged in, the corresponding requirements, and the possible outcomes of the review.<\/p>

2. Communicate a common protocol for compilation and submission<\/strong><\/h3>

The circular refers to the submission modalities communicated by the Agency. In order for all institutions to have the same instructions, we request the communication or confirmation of an official protocol specifying in particular:<\/p>

• the submission channel: physical, electronic, or mixed;<\/li>
• the address, service, or reception platform;<\/li>
• the accepted file formats and their possible technical limits;<\/li>
• the number of required copies;<\/li>
• the filing plan of the file and the nomenclature of the annexes;<\/li>
• the rules for signing and certifying documents;<\/li>
• the models of tables and forms to be used;<\/li>
• the receipt acknowledgment and completeness verification procedure;<\/li>
• the transmission modalities for possible supplements.<\/li><\/ul>

  The provision of a standardized template would facilitate the preparation of files, their comparison, and administrative processing. It would also reduce interpretation discrepancies between institutions.<\/p>

  If such instructions have already been disseminated, their official reference and availability in a common space would enable uniform consultation.<\/p>

  3. Identify the applicable texts, norms, and criteria<\/strong><\/h3>

  Institutions must be able to distinguish between the information requested for administrative follow-up and the elements that will be used to assess their compliance or academic quality.<\/p>

  To this end, we request the communication of the texts, norms, and control grids applicable to the announced examination, or official references allowing for their consultation.<\/p>

  If the files must also feed into an institutional or program accreditation procedure, it would be necessary to clarify the corresponding framework, the steps of the evaluation, and the decision-making modalities.<\/p>

  Depending on the chosen scope, such a framework could notably address governance, programs, qualifications and competencies of teaching staff, appropriateness of teaching assignments, research, documentary resources, laboratories, infrastructures, student services, and internal quality assurance mechanisms.<\/p>

  The challenge is not to presume the criteria that the Agency intends to apply but to allow institutions to know which ones are actually retained and the expected evidence.

4. Clarify the consideration of prior authorizations and recognitions<\/strong><\/h3>

For institutions holding prior authorizations or recognitions, it is important to clarify how these acts will be taken into account in the current framework.<\/p>

Must the concerned institutions proceed with a document update, justify their compliance with defined requirements, or participate in a distinct recognition or accreditation procedure?<\/p>

We also request clarifications on any transitional provisions that may apply, the documents allowing for the scope of prior acts to be established, and the treatment of administrative procedures still in progress.<\/p>

An explicit response to these questions would contribute to a better understanding of each institution's situation and limit divergent interpretations.<\/p>

5. Define categories of teachers and declaration rules<\/strong><\/h3>

The circular asks to distinguish several categories of teaching staff: permanent, contractual, full-time, part-time, and adjunct.<\/p>

To enable uniform declaration, these categories would benefit from operational definitions specifying their articulation.<\/p>

We would particularly like to know:<\/p>

• the characteristics retained to qualify a teacher as permanent, contractual, or adjunct;<\/li>
• the criteria enabling the distinction between full-time and part-time;<\/li>
• the elements of the workload to be considered, beyond just the hours of teaching;<\/li>
• the supporting documents expected for each category;<\/li>
• the possible existence of minimum proportions applicable to an institution or a program, as well as their basis.<\/li><\/ul>

  We also request references specifying, where they exist, the minimum qualifications expected according to education levels and the criteria for adequacy between the professor's specialty, experience, and the subjects entrusted to them.<\/p>

  This clarification would distinguish the administrative completeness of a file from the academic assessment of a teaching assignment.<\/p>

  6. Provide the model for the competency profile<\/strong><\/h3>

  The request related to the competency profile of teaching staff refers to a regulatory institutional file.<\/p>

  We request the official corresponding model, its completion instructions, and the criteria used to review the declared information.<\/p>

  It would be particularly useful to clarify the respective place of academic qualifications, professional experience, pedagogical skills, research activities, supervision, mastery of digital tools, and relevant achievements in the taught field.<\/p>

  The communication of the expected supporting documents and the assessment method would enable institutions to create coherent and verifiable records, rather than resorting to heterogeneous presentations.<\/p>

  7. Specify the rules for declaration of teachings and hourly volumes<\/strong><\/h3>

  The list of teachings and corresponding volumes should be established according to a common method.<\/p>

  In this regard, it would be useful to specify:<\/p>

  • whether the hours to be declared are planned, realized, or presented in two distinct columns;<\/li>
  • the accounting period;<\/li>
  • the breakdown between lectures, tutorials, practical work, and other supervised activities;<\/li>
  • the treatment of courses shared between several teachers;<\/li>
  • the counting of repeated teachings between groups or sites;<\/li>
  • the rules applicable to synchronous and asynchronous distance activities.<\/li><\/ul>

    For distance or hybrid training falling within the scope of the review, we also request documented criteria to assess pedagogical organization, student follow-up, learning evaluation, and the technological means mobilized.<\/p>

    8. Regulate the transmission of students' personal data<\/strong><\/h3>

    The request for national identification of students requires specifying the exact nature of the expected identifier and the fields to be filled.<\/p>

    These personal data warrant special attention regarding their transmission, access, and preservation. We would therefore like to know:<\/p>

    • the purpose of their collection and use;<\/li>
    • the format of the nominative annex;<\/li>
    • the channel planned for its transmission;<\/li>
    • the persons or services authorized to access it;<\/li>
    • the preservation and updating modalities;<\/li>
    • the procedure applicable in case of error or missing identification.<\/li><\/ul>

      These clarifications would allow institutions to fulfill the request while organizing a controlled processing of the entrusted information.<\/p>

      9. Explain the examination and follow-up procedure<\/strong><\/h3>

      Beyond the submission, institutions should be able to know the main steps of the processing of their file.<\/p>

      We request clarifications on the completeness verification, notification of observations, the deadlines granted for providing supplements, and the modalities for communicating conclusions.<\/p>

      When a procedure is likely to lead to a decision affecting the situation of an institution or a program, it would also be appropriate to specify the steps, the possibilities for presenting observations, and the applicable appeals avenues.<\/p>

      The readability of these procedures would help strengthen trust in the system and clearly distinguish the receipt of a file, its documentary completeness, and the assessment of its compliance.<\/p>

      10. Organize common information and structured dialogue<\/strong><\/h3>

      We propose that the requested clarifications be compiled into a supplementary instruction accessible to all concerned institutions, accompanied by useful models and references.<\/p>

      A national information and consultation meeting, organized before the deadline for file submissions, would also address technical questions and harmonize interpretations. Its value would be reinforced by the subsequent publication of a written summary of the responses provided.<\/p>

      Pending these clarifications, GOC University continues the collection and verification of the requested documents. This approach does not aim to suspend this preparation or to request an extension of the deadline. It intends to contribute to a rigorous response while respecting the announced deadline.<\/p>

      Conclusion<\/strong><\/h3>

      Regulation of higher education calls for shared responsibility: that of institutions, required to produce accurate information and verifiable documents, and that of the regulatory authority, called to clarify the requirements, procedures, and criteria it implements.<\/p>

      GOC University wishes to contribute to this dynamic in a spirit of cooperation and continuous improvement. It respectfully invites ANESRS to communicate the necessary clarifications for a homogeneous compilation of files and a common understanding of the scope of their review.<\/p>

      The issue goes beyond the submission of a set of documents. It concerns trust in institutions, the credibility of training programs, and the quality of the service provided to students and Haitian society.<\/p>

      It is in this spirit of academic responsibility, dialogue, and institutional respect that we submit these observations to ANESRS and the entire university community.<\/p><\/div><\/div><\/div>