Friday, June 29, 2018

LETTER OF A.I.C.E.A. DATED 29TH JUNE 2018 TO C.G.A.  ON RESTRUCTURING OF AAO (CIVIL) EXAMINATION

All India Civil Accounts Employees Association


(RECOGNIZED BY GOVT. OF INDIA)
Central Headquarters
Phone No. 011-23345070, Mob. No. 9868520926 e-mail:aicaeachq@gmail.com

Central Office: -                                                                       Address for Communication:-
Room No. 351, ‘B’ Wing,                                                                                    17/2 – C, P & T Quarters,
Loknayak Bhawan,                                                                                                                 Kali Bari Marg,
Khan Market, New Delhi – 110003                                                                                       New Delhi-110001


No:- AICAEA/HQ/A-2/2018/215                                                                                      Dated: 29.06.2018

To,
          Shri Anthony Lianzuala,
          Controller General of Accounts,
          Ministry of Finance,
          Department of Expenditure,
          4th Floor, GPOA, Block-E, INA,
          New Delhi – 110023

Subject:- Restructuring of AAO(Civil) Examination.

Sir,
          The All India Civil Accounts Employees Association is very thankful to learn from your office letter No. A.34012/On line/MF.CGA (E)/522 dated 20th June 2018 that in response to its letter NO. AICAEA/HQ/A-2/2018/191 dated 26-05-2018 you have kindly agreed to convene  a meeting  with the representatives of the Association exclusively on the matter of restructuring  of AAO(Civil) Examination subject to the condition that the Association sends its comments within 30th June 2018 .

          Therefore, on behalf the All India Civil Accounts Employees Association, I am forwarding herewith our suggestions and comments in the enclosed Annexure “A” and Annexure “B” respectively.  In the Annexure A we have suggested and commented against the modifications in the pattern of the examination and in the annexure B we have done a brief analysis of Old &New pattern of AAO (Civil) exam based on Syllabus.
          The comments, suggestion and analysis forwarded by this Association are on the basis of the suggestions and proposals received from the Branches, Units and individual members of the All India Civil Accounts Employees Association and All India Civil Accounts Employees Association Category II spread throughout country. The suggestions, proposals and analysis represent democratically composed views of more than four thousand candidates and prospective candidates for AAO (Civil) examination.

          I have been directed by the Association to request you that, the All India Civil Accounts Employees Association being the sole monolithic employees organization representing the examinees of the AAO (Civil) Examination, a formal meeting with the National Executives of the Association may kindly be convened as per earlier precedents and meetings of 1980 and 2006 in particular before finalizing the new pattern and syllabus for the future  AAO (Civil) Examinations so that the Association could offer its oral deposition in support of the comments, suggestion and analysis it has forwarded.

          Since the suggestions, proposals and analysis from our field formations and members are still flowing in to Association headquarters, we may send additional suggestions/ proposals in continuation of the suggestions, comments and analysis we have forwarded through this letter.
         
Thanking you,
Yours Sincerely,

Enclo as above

(V. Bhattacharjee)
Secretary General
ANNEXURE “A”

Proposal of CGA  office
Comments/Suggestions of AICAEA and AICAEA CAT-II
2. (I) The examination will be conducted online through outsourced agency.
Conducting the examination through an outsourced agency would further increase the chances of malpractices and an invitation of technological intervention. At present, in the exams conducted by SSC, DSSSB etc. we have seen that conducting exams through an outsourced agency is not at all secured and it becomes a bone of contention to the commission. In present ambience of technology it is easier for the hackers to provide the questions on the platform of social media.
The recently conducted Combined Graduate Level Examination 2017 conducted by Staff Selection Commission through online mode with outsourced agencies proved to be a disastrous one. 17 people including 10 employees of an outsourced agency have been found guilty by CBI for leakage of question papers. The question has already been raised how a fair examination can be conducted by an outsourced agency.
If the online mode of examination becomes so warrant, the same may be conducted (in existing 8 paper patterns) departmentally with the help of NIC and not by any outsourced agency.
2. (Ii) The Examination will be completely of objective multiple choice questions.
Conducting all the exams on completely objective multiple choice questions pattern is an initiative towards ease the examination process and reducing the time frame. But, in existing pattern of the examination each paper has 2 parts (35 marks objective and 65 marks subjective).  In such pattern of examination the objective knowledge as well as the practical knowledge and writing skill of a candidate is wholly judged. He has to answer some compulsory practical questions in each paper, which has a set pattern of answer.
Hence, making the exam completely objective will leave the candidates bereft of the comprehensive view of the syllabus which is the foundation for the work profile of an AAO.
2.(iii)The Examination will be comprised of 4 papers details of which are at Annexure A & B
The Examination should be comprised of existing 8 Papers.  The old syllabus may be updated with the proposed modifications e.g. Supply Accounts Section of existing Paper 7 may be replaced by Information Technology (e-Office, e-Payment, GeM, NTRP, PFMS, e-Lekha, WRPS, APMS, BHAVISHYA, CPGRAMS etc.)/Banking Arrangement.
The concept of 8 Paper systems has been unchanged in CA&G’s Organization even after switching over to Online Examination system. Hence same may continue.
2.(iv)Each paper will have 100 objective multiple choice questions for one mark each. There will be no negative marking.
 As per the proposed pattern of the examination, there would be only 4 papers comprising the whole old syllabus with many new topics. While examining the new syllabus it has been noted that Paper 3 has subsumed all the papers relating to accounting procedures viz. (Paper 3, 6 & 8) with many new topics relates to electronic portals. It has more than 20 books to be referred and shall make the candidate over burdened.  Current procedure is more logical
                 In this context, following points are suggested that there should be 8 papers instead of 4 papers so that candidates can get sufficient time to prepare for the papers.
i)                   The new topics may be added in the relevant papers accordingly.
ii)                In 8 papers, there is no need of merging the syllabus, so that the candidates can easily go through the whole syllabus.
iii)              In 8 papers, there would be healthy question bank to test the wisdom of the candidates.
2. (V) 65% will be of basic level, 25% will be of advance level and 10% will be difficult.
Proposed pattern of 4 papers on almost all subjects cannot give justice to fair practice in exam system and difficulty level of questions cannot be ensured.
Current system is more logical.
2. (VI) Time allowed for each paper will be two hours.
In the proposed pattern time is being allowed 2 hours for 100 multiple choice questions. In the existing pattern there are 35 objective questions and time allowed to answer these questions is 1 hour. Moreover, books are also allowed to answer the questions.  
It is therefore, suggested to increase the time limit from 2 to 3 hours, so that candidates have sufficient time to answer all the questions.
2. (Vii) The present examination with its open book system does not appropriately test the skill of the candidates as copying from books is not enough to pass the examination. Therefore no books will be allowed in any of the 4 papers under the revised pattern.
In the existing pattern of the examination, books are allowed in Papers 2 to 7 and the candidate has to quote the rule positions while answering the questions Unfortunately, it has been concluded that merely copying books is enough to pass AAO (C) Exam. It is not too easy to answer all the questions from copying the referral books. While answering the questions, candidates have to go through all the referral books and it is not feasible for them to mug up the whole syllabus to answer in objective manner. It is experienced that it is quite tough to clear the exam by merely copying the books with a laymen’s knowledge about the subject and without having sound knowledge/concept of the papers. In the last conducted AAO (C) Exam (2017), only about 8% candidates (138 of 1823) have cleared the examination. And it is about 4% candidates (69 of 1823) who have successfully passed all the 08 papers in a single attempt which clearly shows that passing AAO (C) Exam is not a copy work at all. There are hardly any candidates available who have appeared in the examination without books and still majority of the candidates have passed only 1 or 2 or 3 papers.
Hence, books may be allowed in future examinations in revised pattern, as was done in previous years since inception of this examination in this Organization.
2(viii) Minimum marks for pass in each paper is 50 for General Category and 45 for SC/ST. A candidate who passes in all the four papers will be declared as passed in the Examination.
Accepted but the no. of Papers should be 8 instead of proposed 4. Existing policy of granting promotion to the LDCs as Accountants on passing 4 papers should continue and the facilities should be extended to the candidates below the level of Accountant appearing the examination. MTS being Gr.C, Graduate among them should be allowed to appear the AAO (Civil) examination.

2.(ix)A candidate who fails to pass the Examination as a whole in one attempt but secures a minimum of 50 or 45 marks, as the case may be, in one attempt in any paper will be exempted for reappearing  in that paper of the immediately succeeding Examination. If the candidate fails to avail the opportunity and passed the Examination as a whole in the said succeeding Examination, he/she will have to reappear in all the 4 papers of the second succeeding Examination or any other subsequent Examination.
 Exemption by securing 50/45 marks in any paper may be treated as valid for ensuing years till passing the remaining papers within consecutive six chances instead of valid for only one immediate succeeding year.
It is proposed that for all candidates who have cleared few papers upto AAO (C) Exam 2017 be given chance to clear remaining papers in future attempts restricted to overall 6 attempts.

2.(x)Exemption secured upto and including the AAO (C) Examination,2017 will not be valid under  the revised pattern.
This is really a traumatic proposal for the candidates who had secured upto 7 exemptions in the previous exams. The hard work and the expensive time which was spent for this examination will go in vain.  In the revised pattern we have seen that almost all the syllabus is same except some new topics. Hence, there is no need of making the exemptions invalid.
However, following points are suggested/raised in this regard:-
i)                   While in new pattern Instead of 4 papers 8 papers on new pattern, exemptions can continue without any problem
ii)                In the existing pattern, candidates who had passed 4 papers were promoted from LDC to Accountant, but this revised pattern is silent over the criteria of promotion.
2.xi)A candidate will have get 6 chances to pass the Examination.
 Agreed. Whether old or new pattern, 6 consecutive/ continued chances to clear the 8 papers must be given to all.
2.(xii)There will be no requirement for passing the CCC Examination conducted by NIELIT. Basic skills in computer operations can be imparted during the Induction Training at INGAF.
Agreed.
2.(xiii)Eligibility to appear in the Examination will remain the same except  (i) the cutoff date for determining the eligibility will be the first day of month in which Examination is held as against 1st October of the year of Examination under the existing pattern and (ii) the prospective candidates should have successfully completed the period of probation in the existing grade.
 Agreed.
2.(xiv)All successful candidates will have to undergo mandatory Induction Training for not less than 4 weeks in  INGAF after qualifying the AAO( C) Examination and getting promoted as AAO. The training is followed by a test.
Agreed with the following slight modification.
The proposed provision of ‘Test’ after completion of Induction Training on passing AAO (C) Examination may be done away with.


Finally the following new proposals are submitted for the sake of new dynamic and energetic examinees of this organization.
1.     Sample question papers for all the 8 papers of the new syllabus along with training video of various procedures to be done in on line examination may be available in the website cga.nic.in for habituating with the new concept adopted first time in this organization.
2.     Study Materials as far as possible at least the Govt. Publications may be made available in the website cga.nic.in well in advance.
3.     The candidates may be provided sufficient time for preparation after finalization and notification of the revised examination procedure as it is to be introduced first time in this organization.
4.     Scope of proper training facility may be provided for the candidates, appearing first time in this examination, in INGAF or any other suitable Training Institutes in Government cost.



ANNEXURE “B”
BRIEF ANALYSIS OF OLD &NEW PATTERN OF AAO (CIVIL) EXAM BASED ON SYLLABUS
As per proposed syllabus, neither subjective papers nor language paper is there, in this circumstance, it would not be possible to judge whether the prospective AAO will be skillful as AAO post is of supervisory nature which needs acute knowledge in noting and drafting.  Academicians are of the opinion that language is the best tool to judge the very personality of human being. The practical / subjective kind of paper is a must to perform the nature of duty of AAO in well manner. How can any one measure efficiency of AAO without checking any practical papers.
How is this possible for an official to memorize all the rules thoroughly including all the correction slips which are revised / amended from time to time. Furthermore, all these rules are scattered in about 55 numbers of books. So, it is not feasible for the aspirants to learn by heart all the rules accurately contained in all books stated above. These apart, being in Accounts office AAO does scrutiny / referential kind of work, which requires concerned reference rule books along with its applicability. Hence it is essential that exam should be conducted with books instead of without books.
As per new pattern, timings of paper in exam is 2 hours each for four papers (8 hours as a whole). If talking about the old pattern timings of paper was 3 hours each for 8 papers (24 hours as a whole) along with the allowed books. Timing dedicated in new pattern is 1/3rd times when compared to old pattern. The percentage of successful candidates is around 7.6 % in old pattern with books. Keeping the time frame in view as per proposed exam pattern, it may be deduced that the percentage of success will become 2.5 % approximately with respect to time provided as a whole in the new pattern, if without books is taken into consideration then this success ratio will tend to zero. Henceforth as per above clarification we may assume that the proposed new syllabus will be fruitful neither for the organization nor for the candidates.
Moreover, it is also not feasible for the office of CGA to cover whole syllabus of 9 papers (including CCC) in just four papers. If it is made possible, then it cannot be ensured that the candidates who will clear AAO (civil) examination will have desired knowledge.

The description for the contents of paper wise syllabus is detailed in Table-A and Table-B below.
Table-A
Paper as per new Syllabus
Old Pattern papers involved/merged
Paper-I
Paper 1 (whole syllabus), Paper 2 (whole syllabus)& Paper 5
Paper-II
CCC (Whole syllabus), Paper 3, Paper 4, Paper 5 &Paper 7
Paper-III
Paper 3, Paper 6 (whole syllabus), Paper 7 &Paper 8 (whole syllabus)
Paper-IV
Paper 4 & Paper 7



Table-B Old pattern papers
Paper as per old syllabus
Books allowed/Books not allowed
Type of Papers
Approach of papers
Minimum time required for preparation from scratch
Paper 1
Books not allowed
Language
Requires grip in language, able to express views
2 months
Paper 2
Books allowed
Min. no. of books 10
Practical based
Minimum 2 numerical questions compulsory
Theory questions related to service rules etc.
Requires practical knowledge of forms and formats used and
Knowledge of syllabus content of each book
4 months
Paper 3
Books allowed
Min. no. of books 06
Practical based
Minimum 2 numerical questions compulsory
 Theory questions related to working of CGA organizations etc.
Requires practical knowledge of forms and formats used and
Knowledge of syllabus content of each book
4 months
Paper 4
Books allowed
Min. no. of books 06
Theory questions related to constitution, GFR, Budget, loksabha etc.
Knowledge of GFR, budget and syllabus content of each book
1 months
Paper 5
Books allowed
Min. no. of books 10
Theory questions related to GFR, CBDT, CBEC Manual, Office procedure, conduct rules etc.
Knowledge of CBDT, CBEC, Conduct rules, CCS CCA rules and syllabus content of each book
2 months
Paper 6
Books allowed
Min. no. of books 07
Practical based
Minimum 2 numerical questions compulsory
 Theory questions related to CPWD department, GFR etc.
Requires practical knowledge of forms and formats used in CPWD and
Knowledge of syllabus content of each book
4 months
Paper 7
Books allowed
Min. no. of books 10
*(Numerical based before AAO 2017)
Theory questions related to Audit, Procurement, GeM, Acts (limitation, Central sales) etc.
Knowledge of Audit manual, GeM, NTRP, latest technologies used in different ministries and syllabus content of each book
2 months
Paper 8
Books not allowed
Completely Practical and numerical based
Minimum 4 numerical question based compulsory
Knowledge of basic principles of accounting, Management Accounts etc.
6 months
* The syllabus of paper-7 was revised in a very short notice and was given meager time to prepare for AAO Exam 2017.

In view of the above table B, it can be inferred that total months required to compete the examination is more than a year, so exemption of previous papers required.
As per the old syllabus of AAO exam (upto 2017), there were 8 (eight) papers and 1 (one) paper i.e., CCC (Course on Computer Concept) need to qualify by the candidates to pass AAO (civil) examination.
With reference to the OM regarding Restructuring of AAO (Civil) Examination issued by O/o CGA, the new syllabus has been proposed. According to which there will be 4 papers only. But, when we go through the content of the syllabus designed for all 4 papers, we will find that all 9 papers (including CCC) are combined haphazardly in just 4 papers. This seems impractical to study and the same is already explained above in tabular format.
After doing a comparable study and detailed scrutiny of both syllabus and pattern, detailed analysis and comments on new patterns is discussed below keeping new syllabus papers into consideration and as a base for detailing:
1.     Paper-I of New Pattern-It is noticed that contents of Paper-I of new pattern comprises of Paper-2, Paper-5 & Paper-1 of old pattern. Now talking about the old pattern Paper-2 is related to Service Rules, minimum number of books used while studying in paper-2 is 16 (including practice set, hand book and objective guide). As this is basic working of Civil Accounts Organization. The officials need to have a practical knowledge along with the knowledge of prescribed forms and formats used in day to day working of office. Officials should be aware about the rules and its applicability involved in these forms. In view of this, there is a requirement of vast knowledge and effort by an individual to master in it.
If talking about the paper-5 of old syllabus, through this is a theory paper, it deals with  the disciplinary proceedings involved if any misconduct been performed by any official, it also deals about the procedure to be followed in an office for its smooth functioning and increases also office’s productivity. One new topic is introduced in paper-I of new syllabus which is e-office, which is again a vast and of large domain, it alone requires well knowledge of paper-2 and paper-5 of old syllabus which will become very tough for the individual to memorize all rules and apply it wherever needed.
                   Moreover, this paper also includes whole syllabus of paper-1 of old syllabus i.e., the knowledge of grammar and comprehension, which is again becoming extra over head to the examinee along with paper-2 & paper-5 of old pattern. It is recommended that there should be two separate papers keeping in view of such a large syllabus involved in this paper.

2.     Paper-II of New Pattern-In this paper after doing comparative study of both old pattern and new pattern, it came to notice that this paper comprises paper-3, paper-4, paper-5 & CCC (whole syllabus) of old pattern.
                   Talking about the practical papers paper-3 of old pattern, which requires knowledge of preparation of appropriation accounts and CAM-33 which is alone a tough task for the candidates not only need to memorize major heads including sub-heads but also need to remember the procedure and proper methodology to solve appropriation and CAM-33 problems. It requires a lot of practice.
                   CCC (Course of Computer Concepts), this paper alone requires working knowledge of computer along with proper terminologies involved in it. This is again a vast area.
                   Some part of paper-4 of old pattern like principles of budgeting, DFPR is taken into this paper.
          CBDT Manual and CBEC Manual which are specific to some ministries were a part of paer-5 in old pattern. In this scenario, candidates working other than these ministries need to memorize without any practical acquaintance which is again a tough task.
          Talking about the volume of paper-II in new pattern, it is again very hard for any one to memorize and perform in this paper. It is recommended that there should be two separate papers keeping in view of such a large syllabus involved in this paper.
3.     Paper-III of new pattern- In this paper, paper-3, paper-5, paper-6 (complete syllabus), paper-7, paper-8 (complete syllabus) of old pattern are included.

          Paper-6 and paper-8 of old pattern are  practical papers, which require numerical approach to be clear.Paper-6 is specific to Public Works Department and very few group B and C non-Gazetted officials get the opportunity of exposure to this kind of official work. So, it requires lot of efforts to go through the problem been asked in examinations especially practical questions and requires a lot of practice to meet the accuracy upto some extent to be successful in exam.
          Paper-8 of old pattern is also a practical paper and is without books. This paper deals with the accounts subject usually use to study in academic classes of XIth and XIIth std. This paper alone requires 6 months of rigorous study to ensure passing in this paper.

          Out of these 4 papers introduced in new pattern. Paper-III of new pattern is the vast one. There should be at least three separate papers based on the syllabus involved in this paper.

4.     Paper-IV of new pattern- This paper included paper-4 and paper7 of old pattern. Both papers are of theory nature. It also includes new topics like eRAS, APMS which is not in old pattern. Thus, it makes again an extra burden to the candidates.

Conclusion: As per detailed stated above It can be inferred that there should be 8 papers with books allowed in place of 4 papers without books for AAO (Civil) Exam.



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