NSFAS claims procurement rules ‘don’t apply’ to R500k adviser deals — Treasury disagrees

Following Daily Maverick’s reporting that the National Student Financial Aid Scheme (NSFAS) splashed public funds on hotel stays for administrator Hlengani Mathebula, with double-bookings that could result in fruitless expenditure, the scheme is now under fresh scrutiny because of payments to Mathebula’s advisers.

NSFAS says Public Finance Management Act (PFMA) procurement requirements “do not apply” to its multimillion-rand adviser contracts because the advisers were appointed in terms of a ministerial Government Gazette rather than standard procurement channels.

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This comes after new invoices leaked to Daily Maverick reveal that two of the four newly appointed advisers to Mathebula – Nonkululeko Manyika and Dudu Hlatshwayo – used their private companies, Nonisa and ChangeEQ, to submit monthly corporate tax invoices to the scheme, drawing close to R500,000 for 30 days without having gone through an open supply chain management (SCM) tender process.

Leaked internal banking records dated 31 July 2026 reveal a single FNB payment-run batch totalling R459,140.18, transferred directly from NSFAS’s primary administration account to two corporate entities. 

The Ministry of Higher Education disclosed that Mathebula’s four-member advisory team carries an official price tag of R9.9-million per year, averaging R2.47-million per adviser annually; leaked invoices reveal that individual advisers are billing well above that threshold.

By invoicing R254,973.51 a month through her private firm Change EQ, adviser Hlatshwayo is on track to collect more than R6.1-million over a 24-month tenure, exceeding her allocated two-year share by more than R1-million. Furthermore, by operating as corporate vendors, the firms are padding their monthly bills with commercial expenses, including a R32,500 monthly VAT charge and direct accommodation claims, pushing the total advisory bill far beyond the ministry’s public estimates.

Nonisa, owned by Manyika, invoiced R204,166.67 for July 2026 for consulting and financial advisory services.

In a state entity such as NSFAS, public funds disbursed for human capital strictly fall under two statutory channels: 

• The Human Resources (HR) payment channel, in which natural persons hired as employees or statutory office-bearers are placed on the internal payroll. Their remuneration is subject to standard salary grades, statutory PAYE deductions, and, crucially for an administrator’s advisers, prior written approval from Finance Minister Enoch Godongwana under Section 17C of the NSFAS Act.

• The SCM procurement channel. External corporate service providers or consultancies hired to perform institutional work must undergo competitive bidding under the Public Finance Management Act (PFMA).

Section 5.6.3 of the NSFAS SCM policy says any commercial contract for goods or services exceeding R1-million must be openly advertised on the National Treasury e-Tender portal for a minimum of 21 calendar days to allow for fair competition.

By invoicing via corporate entities (Change EQ and Nonisa) for contracts projected to reach R6-million each, the advisers are acting as commercial vendors. Yet, neither contract was ever subjected to a public tender.

‘PFMA does not apply,’ says NSFAS

When Daily Maverick put these direct questions to NSFAS and subsequently sought a right of reply from Hlatshwayo and Manyika on why their private firms were invoicing the scheme, NSFAS spokesperson Khulani Qoma responded on behalf of all parties.

“The entire premise of your query is inaccurate. Advisers are not appointed to NSFAS through the normal recruitment policy as employees of NSFAS. Neither do the procurement requirements, as per the PFMA, apply because they have been appointed in terms of the Government Gazette issued by the Minister of Higher Education and Training,” he responded.

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NSFAS added that the current corporate payment method was “advised by human resources as being compliant with all the relevant legislation”, asserting that no law had been broken.

When specifically asked to clarify why Hlatshwayo and Manyika were charging via private corporate entities rather than standard payroll, NSFAS responded: “Have seen questions sent directly to Dudu. The earlier response is still applicable. This comment too must be attributed to NSFAS.”

Higher Education and Training Minister Buti Manamela’s statement dated 14 July 2026 said: “The ministry also wishes to clarify that the appointment of the administrator and the approval of technical advisers are distinct from the statutory process relating to the determination of remuneration and allowances, which is governed separately by section 17C of the NSFAS Act.”

National Treasury rejects NSFAS claim

National Treasury spokesperson Tabby Tsengiwe flatly rejected NSFAS’s claim that a ministerial gazette creates a legal shield exempting it from the PFMA. In a direct response to Daily Maverick, the National Treasury confirmed it holds no record of any such exemption.

“National Treasury is not aware of any exemption granted to NSFAS from applicable PFMA and SCM prescripts in relation to these appointments. NSFAS would be best placed to account for the legal basis for the appointments and the processes followed,” the Treasury noted.

Clarifying the rules governing executive advisers, Treasury added: “The PFMA does not provide for a separate, standalone framework for the appointment of advisers. Public entities and departments are, however, required to ensure that any such appointments comply with the PFMA principles, Treasury regulations, applicable Instruction Notes, and the entity’s approved policies.”

Furthermore, the National Treasury confirmed that Finance Minister Enoch Godongwana has still not granted statutory written concurrence for the administrator’s or his advisers’ compensation under Section 17 C of the NSFAS Act, noting that the request remains “currently under consideration”.

This follows a report from News24 that Godongwana had rejected the annual salary package of R5.5-million for Mathebula.

Daily Maverick also sent questions to Higher Education spokesperson Matshepo Seedat on whether the department is aware of allowances or payments made to technical advisers, and whether NSFAS remains fully subject to the PFMA and standard SCM procurement prescripts. Seedat replied: “We sent it to NSFAS. Please check with them.” DM