Opinion
of the management of VFU "Chernorizets Hrabar"
on a draft Decision of the Council of Ministers for approval of a draft Law on Amendments and Supplements to the Law on Higher Educatio

The opinion of the management of VFU "Chernorizets hrabar" on the draft Law on Amendments and Supplements to the Law on Higher Education is that the proposal rests on formal, incomplete and unsubstantiated reasons and impact assessment; applies measures of questionable effectiveness and efficiency, reviving policies that are outdated, unjust and deepening social division, while ignoring world-proven solutions; under the guise of guaranteeing rights, creates special privileges for certain persons and institutions, and thus special burdens for others; limits the diversity of public higher education institutions with increasingly differentiated educational needs of students and suppresses the competitive pressure for their creation of quality educational products; wastes a public resource and ultimately will not solve any of the problems in our education sector. There are a lot of strong arguments for rejecting the project. A good summary is provided by the opinion of the Institute for Market Economy.

We can join this opinion and oppose the project as another unfounded, unsynchronized and unsystematic imitation of changes. Or to look away because as a private university we are free to offer a service that has never been publicly funded and never was, is not and never will be free. This service is created by professionals who support themselves by providing it to users who have made their free choice to use it and finance it with their own money. Instead of denying the proposed project or passing it by with indifference, we consider it necessary to propose ideas for systemic changes. Bulgarian higher education needs them because it is in a crisis, the signals of which are the low quality and dissatisfaction of all interested parties, the bad reputation, the deficit of human capital and the academic resources running abroad, even the permanent attempts to reform. The status quo should neither be maintained nor improved. It has to be changed. Because if it doesn't change, the question of how much to pay for the educational product provided will resolve itself - it won't be worth paying.
 
We see the root of the problems in the disturbed balance between autonomy and state regulation and the blocking of competitive mechanisms. Under the existing rules and decisions, the National Assembly and the Ministry of Education determine: the opening of higher schools, professional fields and specialties of regulated professions, units and territorially outsourced structures; who, with what and for whom to do science; what educational products to create, at what price and to whom they should be offered; who and how to manage the higher institutions (the contracts with the rectors of State Higher Education, the structure and the way of management); with whom, for what and how to associate; where and what the students should study (the state gives the money through the state procurement and subsidization of State Higher Education, and the students naturally follow the money); what the lecturers' remuneration should be; under what conditions they should be hired and at what age, in what order they should retire. The development of the sector is driven by state coercion and centralized command mechanisms, not by the free choices and decentralized decisions of the participants in the educational process. The consequences are talent drain and shortage of human and social capital, weak incentives at the institutional level for modernization and development, skills inadequate to needs, low prestige and quality of educational products, irrational territorial and profile structure of higher education, which diverges from the social and economic development and the needs of the labour market in our country, low competitiveness and absence from the world education map, with the exception of medical specialties, etc.
The argument that state control is necessary to ensure the effectiveness of state investment in higher education is unfounded. Centralized decisions and command methods have proven ineffective in both business and non-business sectors. The state must definitely support higher education but not by suppressing competition and establishing state monopolies. In agriculture, the amount of support is six times larger, but it hardly occurs to anyone to impose that the funds go only to state farms and that the state decides what, where, in what amount and at what prices to grow the produce and to whom to sell. This is the case in all sectors - from health care to road construction. Yes, when someone distributes foreign money for foreign purposes, there is waste and a desire to limit competition, but the role of the state is not to guide this process, but to oppose it. Education is no less important than bread and health to leave it to politicians and bureaucrats to make the decisions.
 
The real necessary reform of the education sector, which currently no politician has the vision and courage to carry out, is in deregulation and ending dependence on the political market, supporting free competition in the education market and directly linking higher education to its demand. Bulgarian higher education does not need regulations subordinating free elections to centralized commands, but the construction of a competitive market environment that gives way and develops the potential of proactive and capable participants. The state should not decide who, where, what and at what price to study, nor what content and how to be offered by the higher institution, nor who and under what conditions to hire as academic staff. If the decisions of where, what and how to study were made by the students who bear the consequences of them through their realization on the labour market, they would be much better. The Commission for the Protection of Competition recalls it with its decision from September 2020: "As with all other markets, as with higher education, supply and demand, as well as competition between higher education institutions, must determine how many market participants there will be and whether they will be successful or exit from the market, and not for these issues to be resolved through regulations".

Undoubtedly, part of the necessary essential changes in the direction of the restoration of the educational market, the autonomy of higher education institutions and the establishment of a real separation of the state and higher education is the adoption of a new model of financing higher education institutions with an emphasis on directing state support directly to and through those in need of it using tools, such as: educational vouchers, state-guaranteed loans under reduced conditions (at the moment the conditions are more difficult than the standard ones), special taxation of those who used budget support (for example, an increase of the income tax by 5% for a period of 10-15 years), long-term employment contracts in the public sector with a requirement for proportional payment of costs in case of non-fulfilment (following the example of cadets at the Military University and the Academy of the Ministry of Interior), stimulation of private investment in human capital through legal regulation of this activity in private investment funds, recognition of costs for education for tax purposes, etc.
 
This would be a total re-engineering of the basic principles on which our education system is built. A real intellectual "revolution", giving more rights, but also more responsibilities to students, academic communities and their partners from practice. This poses the classic questions about the existence of a "revolutionary situation": Is there a mass feeling of the crisis of the current model and a demand for change? Are there living ideas for alternative Higher Education models in the public space? Is there anyone to head them? Do they enjoy enough active public support to be materialized?
 
Unfortunately, our answers are not positive and it is an illusion to think that the mentioned solutions can be implemented immediately. They are the ultimate goal of a long and arduous process that will require a lot of ambition, energy, resources and a willingness to cooperate.
 
Achieving this goal is necessary for the future of the Bulgarian higher education as soon as possible!