• Guidance note: Financial assessment

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    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    Why does TEQSA do financial assessments?

    The financial status of a higher education provider can significantly affect its ability to support quality in its higher education delivery to students. The financial status can influence, for example, a provider’s: 

    • capacity to invest in sufficient facilities and infrastructure (physical assets and information communication technology) to support the student learning experience
    • ability to maintain adequate staffing levels and academic leadership in order to support academic quality and integrity
    • capacity to provide support services to students
    • ability to continue to operate sustainably into the future.

    A registered higher education provider is required under the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) and the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) to ensure it is able to maintain its higher education operations and meet the Standards on an ongoing basis. 

    This guidance note explains how TEQSA assesses the financial basis for a provider’s ability to continue to meet the Standards.

    Relevant Standards in the HES Framework 

    The principal Standards concerned with financial assessment are in Part A of the HES Framework: Standards 6.2.1b, 6.2.1c and 6.2.1d. These in turn have links to other related Standards concerning financial standing (such as Standards 7.3.1d and 7.3.1k). 

    Intent of the Standards 

    The intent of Standards 6.2.1b, 6.2.1c and 6.2.1d is to ensure that the corporate governing body is demonstrably exercising effective oversight of financial aspects of the provider’s operations and that providers are financially viable and sustainable. 

    A provider should be ensuring that it is not merely financially viable but that financial resources are being managed in a sustainable way to support quality at existing and planned level of activity. The members of the corporate governing board of a provider should ensure that they are financially literate and have access to financial expertise to provide sufficient assurance about financial matters.

    TEQSA approach to financial analysis

    At the time of initial registration, TEQSA assesses new applicants against all of the Standards in the HES Framework; this includes a financial assessment of the applicant. After a provider has been registered for the first time, a financial assessment does not form part of the ‘core’ Standards assessed at the time of any further regulatory event for existing providers (such as a renewal of registration). 

    TEQSA will employ a risk-based approach to determine whether a financial assessment is necessary as part of any scheduled or unscheduled regulatory activity, taking into consideration a range of factors, including a provider’s:

    • annual risk assessment
    • operating context
    • business model. 

    TEQSA also works closely with the Department of Education and Training and the Australian Skills Quality Authority in determining whether to include a financial assessment as part of a provider’s upcoming regulatory activity. 

    TEQSA’s risk assessments include an assessment of a provider’s overall risk to financial position. This assessment rating is informed by an analysis of a range of financial metrics which analyse a provider’s short- and longer-term financial viability and sustainability.

    Key concepts

    TEQSA employs an approach to financial assessment that is similar to that used by lending institutions and credit ratings agencies. In determining whether a provider meets the Standards in the HES Framework relating to financial viability and sustainability, TEQSA considers a higher education provider’s:

    • financial capacity
    • financial capability
    • financial trajectory.

    These concepts are explained in further detail below.

    Financial capacity

    Financial capacity is considered to be the provider’s ability to apply and continue to apply sufficient financial resources to achieve its higher education objectives. This includes a provider’s capacity to operate both in the short-term (financial viability) and over the longer-term (financial sustainability). Both are prerequisites and ongoing requirements for higher education providers.

    Some of the questions considered by TEQSA to determine financial capacity include:

    • has the provider exhibited a consistent track record of financial performance?
    • has the provider maintained sufficient levels of liquidity and investment to support key academic functions?
    • what have been the trends in key financial performance elements?
    • has the provider exhibited a consistent track record of financial prudence?
    • has there been sufficient and rigorous business planning?
    • has there been reliance on a related party?
    • how has the provider anticipated, and responded to, key sector drivers and trends affecting the business model?

    Financial capability

    Financial capability considers a provider’s access to resourcing and combines both financial resources and non-financial resources.

    A provider’s financial resources includes its:

    • earnings and cash
    • assets
    • credit rating
    • insurance
    • ability to grow revenue and manage expenditure.

    A provider’s overall management capability is critically influenced by:

    • the quality of financial and business planning, budgeting and alignment with the institution’s strategic plan
    • its financial monitoring, reporting and analysis
    • fraud management
    • financial risk identification and management
    • oversight by the board
    • interactions with auditors.

    Financial trajectory

    A provider’s financial trajectory is a key element in demonstrating its ability to sustain quality in higher education. 

    When TEQSA assesses a provider’s trajectory, it considers both historical and forecast information together, and where available has regard to a provider’s business strategy, benchmarking to like providers, available market trends, known policy and funding events. It is important for any forecasts to reflect realistic projections, particularly with respect to:

    • student enrolment numbers that are supported, where applicable, by historic trends and robust research or market analysis.
    • academic and non-academic staff numbers.
    • asset investment plan, such as floor space and facilities.

    TEQSA’s collection of financial data

    TEQSA collects financial information through various means that are designed to be efficient and not to create an unreasonable burden for the provider, while also meeting the requirements of the TEQSA Act and HES Framework. 

    The table below shows the ways through which TEQSA obtains financial data.

      New application or renewal Annual data collection Ongoing disclosure
    Source

    Provider registration

    Course accreditation

    CRICOS registration

    Provider (via annual submission to the Department of Education and Training) Material change notifications
    Information requested

    Historical financial statements

    Forecast financial information

    Business plans

    Governing body meeting minutes

    Historical financial statements

    Standardised historical financial report

    Detailed key operating metrics (student/staff numbers)

    Further information may be requested based on the nature of material change notification

     

    Resources and references

    TEQSA (2014), TEQSA’S Risk Assessment Framework version 2.0, March 2014.

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au

     

    Version # Date Key changes
    1.0 21 October 2016 Made available as beta version for consultation. Replaces previous information sheet on ‘TEQSA’s approach to financial assessment’.
    1.1 11 April 2019 Consultation advice incorporated into “Key Concepts – Financial Trajectory” section.

     

     

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  • Guidance note: Financial standing

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    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    What is financial standing?

    Financial standing is a broad term which can take on different meanings depending on the context within which it is being applied. 

    For the purposes of the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework), financial standing relates to the core financial information a stakeholder would need access to in order to make an informed decision about whether to enter into an agreement with a higher education provider. This applies in particular to students seeking to undertake a course of study. 

    Relevant Standards in the HES Framework 

    The principal Standards concerned with financial standing are in Part A of the HES Framework: 7.3.1d and 7.3.1k. These Standards require a provider to publish information about its ‘financial standing’, and providers that are required to prepare public annual reports should make these available. These Standards in turn have links to other related Standards concerning corporate governance (6.2.1b, 6.2.1c and 6.2.1d) and the provision of information to students (7.2.1). 

    Intent of the Standards 

    The intent of Standard 7.3.1 is to establish a set of information about the provider and its courses which can be accessed by, and meet the needs of stakeholders most importantly current and prospective students. 

    From a financial perspective, students need to be satisfied that a provider is in a position to continue as a going concern and to deliver the advertised course of study, consistent with the requirements of the HES Framework, until they graduate. Higher education providers that do not publish their annual financial statements can best provide assurances about these matters to stakeholders through a Statement of Financial Standing.

    How can registered providers meet the requirements?

    The requirements can be met by publishing on the provider’s website either:

    • a provider’s audited annual financial statements OR
    • a statement of financial standing.

    Some providers publish their annual audited financial statements, which provide sufficient information for stakeholders to form a view about their status as a going concern. Providers that rely on publication of their annual financial statements to fulfil the requirement to make their financial standing publicly available should ensure that stakeholders, in particular students, can easily access them, for example by including a prominent link to them from the most visible and accessible webpage with general information about the provider.

    Not all providers however are required to publish financial statements. This reflects current Australian accounting standards and legal requirements. It is not the intention of the Standards to impose requirements on providers that are inconsistent with accounting standards and legal requirements. 

    A Statement of Financial Standing should summarise the key points in their respective financial statements, which are important in informing a decision about financial standing. 

    TEQSA’s guidance to providers for meeting Standard 7.3.1d aims to address the core information needs of stakeholders, in particular students, without imposing excessive burdens on providers.

    • For newly registered higher education providers that are yet to have prepared a set of financial statements, TEQSA would expect the provider to publish items 1 and 3 of Appendix A. 
    • Newly registered higher education providers with pre-existing operations (e.g. as a Registered Training Organisation) should prepare the Statement of Financial Standing in full as described in Appendix A, noting that the audited accounts refer to the entity as it was prior to higher education registration.

    Contact the Enquiries Management team at providerenquiries@teqsa.gov.au for additional specific guidance on how to comply with the relevant Standard in the Threshold Standards (Part A of the Threshold Standards: 7.3.1d).

    What TEQSA will look for in a Statement of Financial Standing?

    This section provides guidance on the content of a Statement of Financial Standing that TEQSA would accept as meeting the requirements of Standard 7.3.1d. An example statement has been included at Appendix A. 

    The model Statement of Financial Standing draws on existing disclosures that most providers are already required to make in order to satisfy other legislative requirements. TEQSA expects that such a Statement and any other relevant information about the provider’s financial standing would be made available on the provider’s website. An appropriate Statement of Financial Standing would contain the following 3 sections:

    1. Directors’ declaration or equivalent (such as Statement by Appointed Officers or Statement by Members of the Board). Refer to Table 1 below for further guidance.
    2. Auditor’s opinion (where an auditor’s opinion relies on a going concern note in the financial statements, the note should also be reproduced), and
    3. Tuition assurance arrangement details.

    Where a provider is required to make its financial statements public, the fourth item below would also be included: 

    1. A hyperlink to the location of the provider’s financial statements (Standard 7.3.1k).

    Table 1. Examples of Directors’ Declaration or equivalent for different entity types

    Company Proprietary Limited Company Limited by Guarantee University Incorporated Association
    Directors’ declaration Directors’ Declaration Financial Statement Certification/Statement by the Vice-Chancellor and Chief Financial Officer Statement by Members of the Board

    Note: The examples listed above are not exhaustive and terminology differences may exist between providers.

    Resources and references

    Australian Government, Corporations Act 2001, section 295.

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team providerenquiries@teqsa.gov.au
     

    Version # Date Key changes
    1.0 19 August 2016 Made available as beta version for consultation.
    2.0 4 November 2016 Further elaboration provided in the ‘How can providers meet the requirements?’ section.
    2.1 13 December 2016 Requirements for newly registered providers clarified.
    2.2 11 April 2019 Consultation advice incorporated into “Appendix A, example Statement of Financial Standing”.

     

    Appendix A

    Example Statement of Financial Standing

    Provider details

    • Provider Name: XYZ Pty Ltd
    • ABN: 999 999 999
    • Date of Statement of Financial Standing: DD/MM/YYYY

    1. Directors’ declaration or equivalent (Refer to Table 1)

    Note to providers: 

    The directors’ declaration should include the: 

    • directors’ opinion regarding the provider’s ability to pay its debts as and when they become due and payable
    • signature and name of the director/s making the declaration, and
    • date that the directors’ declaration was made 

    2. Auditor’s opinion 

    Note to providers: 

    The auditor’s opinion should include:

    • the name of the auditor
    • the date of the audit opinion
    • the auditor’s opinion, and 
    • a reproduction of the going concern note (where an auditor’s opinion relies on a going concern note in the financial statements). 

    3. Tuition Assurance Arrangement details

    Note to providers:

    The tuition assurance arrangements should include: 

    • the name of the scheme 
    • date of registration as a member of the scheme
    • currency of coverage, if applicable.

    If the provider is required to make its financial statements public by Standard 7.3.1k.

    4. A hyperlink to the location of the provider’s financial statements 

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  • Guidance note: Grievance and complaint handling

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    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    What does ‘Grievance and Complaint Handling’ encompass? 

    ‘Grievance and Complaint Handling’ encompasses the policies and procedures implemented by higher education providers in response to a grievance or complaint expressed against the provider by another party, including students, staff or members of the wider community. However the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) section on Grievances and Complaints is specific to those involving students, so for the purposes of this Guidance Note, grievance and complaint handling is confined to grievances and complaints from students1. The term ‘grievance’ is used from this point as a generic term including any expression of dissatisfaction with some aspect of a student’s experience with the provider (including with agents or other related parties who represent or act on behalf of the provider).

    Grievances typically fall into two classes: 

    • minor issues that are suitable to be addressed informally and usually resolved easily (e.g. by a discussion with local staff, clarification of a misunderstanding etc)
    • those that involve a formal process for resolution (such grievances are typically known as a ‘complaint’ or a ‘formal complaint’, to distinguish them from matters that are resolved informally). 

    Purpose of this note

    The purpose of this note is twofold:

    • to give guidance to providers about TEQSA’s expectations
    • to help students understand what they can expect from providers. 

    Relevant Standards in the HES Framework 

    The HES Framework addresses student grievances in several ways. They are addressed directly in Section 2.4 (Standards 2.4.1-2.4.5), which encompasses the requirement for providers to have mechanisms to address them, as well as various process requirements for formal complaints relating to:

    • costs
    • advocacy and support for students
    • timeliness
    • confidentiality
    • fairness
    • access to an independent third party if needed. 

    Information about a provider’s grievance resolution process is to be in the public domain (e.g. on the provider’s website) and accessible to students (see Standard 7.2.2f). The information must be accurate, relevant and timely (Standard 7.2.1). Providers are required to document and record responses to formal complaints (Standard 7.3.3c). The provider’s corporate governing body is required to assure itself that the occurrence and nature of formal complaints are monitored and action is taken to address underlying causes (Standard 6.2.1j). This should be supported by regular reporting to the governing body, and providers should give consideration to making summary information publicly available. Students are to be given opportunities to provide feedback on their experience and student feedback should inform a provider’s monitoring, review and improvement processes (Standard 5.3.5). 

    Staffing requirements (Section 3.2) include students having access to teaching staff for individual assistance (Standard 3.2.5). This is a situation where students may take the opportunity to raise grievances. It may also be an important potential means for informal resolution. The governing body is also required to take steps to create an environment in which students are treated equitably, and are able to participate in the deliberative and decision making processes of the provider (Standard 6.1.4). This too may represent a means to identify and resolve and/or prevent grievances in a collective sense through systemic changes to a provider’s operations. 

    Intent of the Standards 

    The overarching intent of the Standards is to achieve resolution of grievances as effectively as possible, to minimise the occurrence of unresolved grievances, and to achieve these goals with minimal adverse consequences for the provider or student(s) involved. 

    While some types of grievances are best resolved locally and informally, more serious grievances, including allegations of assault or sexual harassment, are unlikely to be suitable for informal resolution. Some providers have had success with establishing a forum for restorative dialogue, and  some complaints need to be referred to the police. This needs to be acknowledged within the policy framework.

    The Standards promote access to grievance processes in various ways and encourage an environment of evidence-based organisational learning to generate preventative improvements that aim to obviate the recurrence of similar issues. There is an expectation that students will be able to access institutional processes without charge or at reasonable cost and that access to review by a third party will be available in the event the provider’s internal processes do not lead to resolution of a formal complaint. 

    The Standards do not, and cannot, require that all grievances or complaints will be resolved to the satisfaction of all parties. The Standards do however require that there is a genuine attempt to resolve genuine complaints, through consistent and fair application of policies and procedures without retribution. These requirements encompass delivery arrangements with other parties, which are required to be quality assured by the primary registered provider (Standards 5.4.1-5.4.2) and this includes responsibilities for grievance handling (Standard 2.4.1).

    The scope of the Standards concerned with student grievances does not include handling grievances and disputes from staff or other parties. Appeals about academic decisions generally operate through academic processes and policies (usually approved by an academic governing body) and typically require application of particular academic expertise that may not be required for resolution of more general grievances. How such matters are dealt with (i.e. through separate or similar processes) is up to the provider. The Standards do however require that the relevant processes are made explicit to students (Standard 7.2.2f).

    Some Standards also require providers to make available specific information to assist international students studying in Australia (e.g. Standard 7.2.2g). Careful attention to this requirement may obviate grievances arising in this area. Other Standards also attempt to obviate potential sources of dissatisfaction e.g. through clarifying student rights and obligations prior to enrolment (Standard 1.1.2) and through giving reasonable notice of changes to a provider’s operations that may affect students’ participation in an intended course(s) of study (Standard 7.2.4). 

    Risks to quality 

    Failure to engage in effective grievance handling, including implementation of preventive improvements informed by previous grievance cases, may manifest in various ways. These might include:

    • poor communication with students leading to expectations that fuel complaints
    • unresolved student dissatisfaction and consequent impact on demand
    • diminished educational achievements
    • avoidable disadvantage to students 
    • adverse publicity, actions and reputational risk
    • disruption and diversion of resources 
    • recurrence of preventable issues, especially those relating to quality
    • reduced performance on national quality indicators e.g. student experience, graduate satisfaction. 

    What TEQSA will look for

    This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, related to grievance handling. 
     

    For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards. 
     

    For existing providers, the scope of Standards to be assessed and the evidence required for particular applications may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education. 
     

    The evidence required for particular types of application is available from the application guides on the TEQSA website. 
     

    Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

    TEQSA recognises that providers may meet the requirements of the HES Framework in various ways, particularly in view of variations in the scale of providers and the nature of different courses of study. Students may also have varying expectations depending on previous experiences (e.g. entry via a pathway program) and the level of study involved (e.g. undergraduate vs postgraduate study). Nonetheless, TEQSA will need to be satisfied that providers are meeting and can be expected to continue to meet the requirements of the HES Framework, whatever their circumstances. In so doing, TEQSA will expect providers to demonstrate the following capabilities in particular. 

    • Policies and Procedures:

    TEQSA must be satisfied that these exist, are current, and are known to staff responsible for their implementation. TEQSA must also be satisfied that the provider’s policies and procedures are likely to be fit for their purpose and are consistent with the requirements of the standards, particularly Standards 2.4.1-2.4.5. This will include delegations of authority for implementation of procedures consistent with the scale and nature of the provider, and evidence that the relevant staff are equipped for their role in administering grievances, including through training. TEQSA will also need to be satisfied that the provider’s approach caters for grievances about any aspect of a student’s experience, including with agents and related parties (Standard 2.4.1) 

    Grievances about particularly sensitive issues (such as assault and sexual harassment) may require more specific approaches, and TEQSA will need to be satisfied that a provider’s processes and staffing allocations are appropriate to deal with these matters. 

    Dealing with grievances about sexual assault and sexual harassment requires an especially clear reporting and response pathway that offers students choices about how the information provided by them will be processed and responded to. Students may wish to disclose and receive support, but not proceed with a formal complaint. Policies and procedures need to focus on the safety and the support of the students involved, and staff should be specifically trained to receive such disclosures. The student decides whether an incident is reported to the police. 

    • Communication and Access by Students: 

    A provider will need to show that all relevant information required for students to access and participate in grievance processes is accurate, current and easily-locatable in the public domain (Standard 7.2.2.f), e.g. through a dedicated section of the provider’s website. TEQSA will need to be satisfied that students have been informed about grievance processes and how to access them by mechanisms that are relevant to the student cohorts involved e.g. online, via a student app, or a student handbook. Information for students will need to include who to contact and may include any additional advice that the provider regards as helpful e.g. advice to seek local resolution where practicable and how this might be done. If local (and informal) resolution is encouraged, TEQSA will expect that staff do not discourage students from lodging formal complaints where a student is not satisfied with the outcome of informal discussions.

    Additionally, sexual assault and sexual harassment related grievance information needs to include definitions of behaviour that constitutes sexual assault or sexual harassment and contact details for support services. 

    • Implementation: 

    TEQSA will need to be satisfied that the provider’s handling of formal complaints (or future handling in the case of a new provider) is consistent with both the provider’s policies and the detailed requirements of the HES Framework, particularly the process requirements of Standards 2.4.2-2.4.4 concerning:
    - costs
    - consistency
    - fairness
    - confidentiality 
    - absence of reprisal
    - provision of advice 
    - support
    - recording decisions and informing the student in writing of the outcome and the reasons.

    In so doing, TEQSA may draw on records of handling previous complaints (Standard 7.3.3c). TEQSA acknowledges that there may be a need for specific processes to handle vexatious complainants. Providers should make every effort to resolve complaints within reasonable timeframes that should be stated within the policy framework.

    • Review and Improvement: 

    TEQSA will need to be satisfied that there are processes for analysis and monitoring of complaints handling to generate improvements and implement preventative mechanisms where possible (see Standards 2.4.4, 6.2.1j), drawing on institutional records where needed (Standard 7.3.3c). Are there patterns of recurring complaints relating to particular issues or processes, and if so, what action is taken to address this? 

    • Independent review: 

    Providers must make provision for review by specified independent third parties (other than TEQSA) in the event that internal processes do not resolve a complaint, and ensure that records of the complaint are made available to the reviewer. Third party complaint-handling bodies for all students at public providers and international students at private providers are outlined on the TEQSA Complaints page. All students at public higher education providers have an avenue of appeal to the relevant Commonwealth, State or Territory Ombudsman, about administrative actions or decisions and the related processes, but only after all internal processes for resolution have been followed and concluded. Domestic students at private providers can contact the relevant state government consumer protection agency about issues covered by the Australian Consumer Law. The Overseas Students Ombudsman (OSO) investigates complaints from international students about private providers that relate to administrative actions or decisions made by the provider and the related processes, but not about broader educational quality issues. 

    Private providers must make specific arrangements for independent review of complaints about issues not covered by a consumer protection agency or the OSO. 

    Providers may make arrangements for grievances to be considered by an external qualified dispute resolver. This arrangement must provide for matters to be determined by the dispute resolver if mediation is not acceptable to either party or if mediation is undertaken but does not prove to be successful.

    Guidelines for students

    This section of the Guidance Note is intended as a prompt for students who are experiencing difficulties with a provider that are affecting their educational experience. The points raised here are based on typical practical experiences in the higher education sector and are intended to be helpful to students. 

    Please note that these points are not exhaustive and do not replace the requirements of the HES Framework. Nor are they prescriptive, and they do not bind either TEQSA or providers in interpretation or application of the HES Framework.

    Students who are dissatisfied about aspects of their educational experience could consider the following points:

    • Your higher education provider (your provider) is required to have policies and procedures to resolve grievances and to tell you about them (e.g. on a website or in a student handbook). This includes policies and procedures about sexual assault and sexual harassment. You should look at these in relation to your circumstances. There will be particular procedures for appealing against, for example, an academic result. 
    • Your provider is required to provide points of contact for resolution of grievances.
    • You should clarify what the problem is, so that you can easily tell someone else, and you should also decide what you hope might be a satisfactory outcome.
    • Some types of complaints or grievances are suitable to being addressed locally and informally at least in the first instance. Points of contact and/or advice on ways of going about this should be provided. This may be as simple as contacting your lecturer, another staff member or a student contact officer. You should not be discouraged from making a formal complaint if you are not satisfied with the outcome of an informal process. Some incidents will not be suited to informal resolution at all, including cases of assault or sexual harassment. 
    • You should note that a provider’s policies may place some legitimate restrictions on matters that can be dealt with in its grievance-handling processes. For example, there may be quite separate processes for handling general matters (e.g. perceived tardiness in marking assignments) and some particular matters (e.g. academic decisions, such as disputing a grade awarded). Some matters may also be protected against a complaint or appeal e.g. organisational policy decisions taken by bodies legitimately established for such purposes, such as an academic board or a governing council. 
    • If you feel it is necessary to proceed with a formal complaint, you should note that this is a formal process and acquaint yourself with the process. Some matters that you should be aware of include that a formal process will require you to express your complaint in writing and records of the process will need to be maintained. Formal responses from the provider will be in writing. Providers may or may not be able to respond to anonymous complaints, depending on their legal framework.
    • When you disclose an incident of sexual assault or sexual harassment, unless there are legal requirements because of your age, you decide whether a formal report is made, and whether the incident is reported to police. 
    • You should note that providers cannot impose unreasonable costs for handling a complaint and that you are able to have support in the process (e.g. from a friend or an advocate, such as a member of the student association, but not normally from a legal representative). In the case of sexual assault or sexual harassment your provider should connect you with counselling and academic support as required. 
    • A provider is required to deliver timely resolution of complaints and to keep you informed of progress. You should note that resolution of complaints can sometimes be complex and, in some cases, it may be to your advantage to agree to allowing extra time, e.g. where you would have more time to prepare your case.
    • A complaints-handling process should be confidential and preserve your privacy, unless you choose to do otherwise or disclosure is required by law. 
    • Once a resolution has been reached, the provider should notify you in writing and implement any follow up actions as soon as reasonably practicable. 
    • In the event that a complaint cannot be resolved by internal processes, a provider is required to identify an avenue for review by an independent third party. This may be within the provider (e.g. an independent student ombudsman) or an external reviewer.
    • Grievance and complaints-handling processes assume the parties involved act in genuine good faith with a view to resolution. 

    Resources and references

    AS/NZS 10002:2014 Australian/New Zealand Standard™, Guidelines for complaint management in organizations.

    Commonwealth Ombudsman (2009), Better Practice Guide to Complaint Handling.

    Commonwealth Ombudsman, Overseas Student Ombudsman, and Australian Capital Territory (ACT) Ombudsman (2016), Complaint Handling at Universities: Australasian Best Practice Guidelines.

    General advice on making complaints in the sector available on the TEQSA website.

    Guidelines available on the Ombudsman New South Wales website.

    Jackson, J., Fleming, H., Kamvounias, P., and Varnham, S. (2009), Good Practice Guide for Handling Complaints and Appeals in Australian Universities.

    Resources for education providers (including fact sheets, best practice complaint handling checklist, and provider e-Newsletter) available on the Commonwealth Ombudsman website.

    Resources for international students available on the Commonwealth Ombudsman website.

    TEQSA, Guidance Note: Wellbeing and Safety

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au
     

    Version # Date Key changes
    1.0 23 October  2017 Made available as beta version for consultation.
    1.1 22 February 2019 Amended in response to consultation feedback and to include the reference to the Guidance Note on Wellbeing and Safety.

     

     

    Notes

    1. 'Students' may include prospective students who have had some interactions with the provider (e.g. via an agent), current students (irrespective of mode of participation) and past students (most likely limited to a defined period after completion).
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  • Guidance note: Joint and dual awards

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    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    What do joint and dual awards encompass?

    Joint and dual awards are typically offered through collaborative or cooperative arrangements between two or more higher education providers[1], involving either a single course[2], different courses, or variations on a single course (with common components). Many descriptors are used for such arrangements. These include: dual, joint, double, multiple, tri-national, collaborative, integrated, international, combined, concurrent, consecutive, parallel, simultaneous, overlapping, conjoint and common degree courses. Different countries, different institutions and different regulatory bodies have different understandings of these terms (see Knight, 2008, p.13).

    TEQSA uses the terms ‘joint award’ and ‘dual award’ to distinguish between two types of collaborative arrangements for courses of study.

    Relevant Standards in the HES Framework

    The Standards in the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) concerned with joint and dual awards include: the standards in sections 1.5 (Qualifications and Certification) and 3.1 (Course Design), as well as those in section 5.4 (Delivery with Other Parties). In so far as credit is granted for recognition of prior learning or credit transfer arrangements, the relevant Standards for granting credit and recognition of prior learning apply.

    Joint awards

    Joint awards involve a single course of study arranged and delivered jointly by two or more providers that leads to the award of a single qualification that is recognised within the Australian Qualifications Framework (AQF) and is typically conferred jointly by the providers involved.

    Joint awards involve close cooperation between the providers in the design of the course of study, curriculum development, course delivery, assessment of learning outcomes and on the requirements for awarding the qualification.

    In the case of joint awards, following completion of the joint (single) course, students are issued with a single testamur, which states the name of both providers that are awarding the qualification.

    In some countries, awarding one qualification from two or more institutions is illegal. This is not the case in Australia. However, the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) does require that the providers and persons authorised to issue the award are correctly identified on all testamurs (hence joint awards are also often called ‘dual badged’ or ‘jointly badged’).

    For some joint awards, students may select a single provider to be enrolled in and this will be the provider that oversees conferral of the qualification and issue of the (jointly badged) testamur. In other cases, students may be enrolled at both providers. For example, arrangements may reflect an ‘active’ enrolment for the period spent studying at one provider and ‘on leave’ or similar status when the student is studying at the other provider.

    The concept of joint awards does not encompass cases of a higher education provider formally recognising units/subjects or courses of study offered by another institution (including a Registered Training Organisation [RTO] delivering vocational education and training) for the purpose of enabling students to gain advanced standing or credit into a course of study leading to a regulated higher education award offered by the provider. This is simply recognition of prior learning.

    Joint awards may be one aspect of collaboration with a partner institution as part of a wider mission or policy agenda such as facilitation of exchanges of staff and students, recruitment of international students and/or forging stronger research linkages.

    Stronger research linkages are, in some cases, supported through the use of joint higher degrees by research (HDR). The Australian Government has developed Principles for Joint Higher Degrees by Research between Australian Higher Education Providers (May 2011). The Principles provide guidance to higher education providers (HEPs) entering into agreements for the management and delivery of joint awards of HDRs. Joint HDR awards are defined in the Principles as ‘a Research Doctorate, including a Professional Doctorate, or Research Masters… where the student spends a minimum time equivalent to the total of one year or one-third full-time candidature over the course of their award enrolled at each HEP’. While the Principles do not form part of the HES Framework against which TEQSA regulates, they may provide useful guidance for providers that are planning to offer joint HDR awards.

    Dual awards

    Dual awards involve one or more courses of study that leads to the award of two separate qualifications. Where the course involves an arrangement between two providers (a registered provider and another entity, which is also typically a registered provider), one of the qualifications is typically conferred by each provider. A dual award may involve one AQF level, or two sequential AQF levels - for example, two Masters degrees (MBA/MA) or a Bachelor and Diploma qualification (BSc/Dip Ed). ‘Collaborative double-degree courses’ are a form of dual award.

    Like joint awards, dual awards involve a formal relationship between the providers, particularly in relation to academic and student requirements. However, the relationship is inherently different in several respects, particularly in that components of the overall course are typically designed and delivered largely separately by the two providers, rather than jointly, or there are two separate courses, usually with some common components. The award of two qualifications distinguishes dual awards from courses that include a major specialisation, e.g. BA (Music), or a combined degree with one testamur, e.g. BA (Arts Law).

    There is typically a mutual interdependence between the courses of study and the award of the qualifications in a dual award, e.g. mutual transfer of credit between the two providers. Because of this, and possibly other streamlining of requirements, dual awards may provide students with an opportunity to achieve two qualifications in a shorter time than if they were completed separately. However, because of the interdependence of the courses, the awarding of qualifications, while done separately by each provider, may be delayed until the requirements of both courses have been fulfilled. The content of the two courses may be cognate (e.g. BA/MA) or different (e.g. BSc/BEc).

    In the case of ‘cotutelle’ awards, as defined under French law, two separate testamurs must be issued despite the fact that there is only one single course.

    Similarities and differences

    Table 1: Key similarities and differences between joint and dual awards

    Joint awards Dual awards
    May also be referred to as a ‘jointly-badged’ or ‘collaborative’ award May also be referred to as a ‘collaborative double degree’ or ‘combined degree’
    Single qualification awarded with (normally) a single testamur jointly conferred by two or more providers Two qualifications conferred separately by the two providers, each with its own testamur from the individual provider concerned
    Joint course of study – close collaboration in course and curriculum design, course delivery, and requirements for awarding qualification Two courses of study, with varying extent of academic or administrative interdependence
    Student may be enrolled at both providers or at one Student enrolled at both providers
    Duration of the course is not normally extended compared to an individual course May provide students with the opportunity to complete two awards in a shorter timeframe than if completed separately
    Physical and/or virtual mobility of students and/or staff and/or course content Physical and/or virtual mobility of students and/or staff and/or course content
    Facilitated through a MOU or formal agreement between two or more providers. Facilitated through a MOU or formal agreement between two providers

    Regulation by TEQSA

    TEQSA’s jurisdiction covers all courses of study offered by registered higher education providers. Where TEQSA has jurisdiction over any course, it will hold the provider accrediting that course responsible for meeting the applicable Standards.

    Intent of the Standards

    The intent of the Standards is to ensure high quality education and student experiences and credible qualifications, in the same way as the Standards apply to any other mode of participation, irrespective of arrangements between providers.

    Risks to quality

    While courses of study that lead to joint/dual awards offer a number of potential benefits to students, to providers and to the diversity and efficiency of Australian higher education, there are also potential risks to the quality of education and/or student experiences including:

    • unclear or confused allocation of responsibilities between providers for delivery of the elements of the course(s) of study
    • lapses in oversight and monitoring of student progress and students at risk
    • inaccurate, misleading or insufficient information for students from different providers about joint/dual arrangements
    • unresolved conflict of academic policies or cultural norms between the different providers involved
    • excessive or inappropriate granting of credit between mutually interdependent courses of study, resulting in ‘double counting’ and:
      • credit granted for learning outcomes not achieved
      • employers and other stakeholders being led to believe that graduates have undertaken more study than is in fact the case
    • premature commencement of a higher level course of study without sufficient academic or other preparation arising from a lower level of pre-requisite study e.g. in a combination bachelor/masters dual degree
    • potential lapses of academic integrity across joint arrangements
    • unmanageable workloads for students and/or insufficient opportunities for engagement with each area of study in dual-degree courses
    • logistical difficulties for students in engaging with two courses or providers
    • unintended adverse consequences for CRICOS registration and/or international students, or
    • insufficient diligence in establishing and monitoring partnering arrangements.

    What TEQSA will look for

    This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to joint and dual awards.  

    For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.  

    For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.  

    The evidence required for particular types of application is available from the application guides on the TEQSA website.  

    Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

    TEQSA will need to be satisfied that joint and dual awards meet the requirements of the HES Framework in the same way as any other course of study. In so doing, TEQSA will have regard to the specific risks associated with particular arrangements.

    Assessment of joint and dual awards by TEQSA is likely to occur in the following circumstances:

    • a sample course of study as part of an application for renewal of registration (for providers with self-accrediting authority)
    • an application for accreditation or renewal of accreditation of a course of study
    • a compliance assessment resulting from identification of risks or concerns.

    TEQSA will need to be satisfied in particular that registered providers assume responsibility for the oversight and management of the arrangement, both jointly and separately, as required by the HES Framework for their particular arrangement. This includes rigorous approval of courses through the academic governance processes of each provider involved in formally issuing a qualification and/or offering a course of study (see Section 5.1 of the HES Framework), and quality assurance of joint arrangements (Section 5.4) by management reporting to governing bodies. TEQSA will also need to be satisfied that granting of credit does not disadvantage students or affect the standing and integrity of qualifications awarded. Further, TEQSA need to be confident that information provided to students is consistent with the needs of student cohorts, and is accurate and not misleading.

    When assessing joint or dual awards involving a provider(s) from outside of Australia, TEQSA will have regard to differences across a range of issues that may pose challenges in establishing such awards to ensure a quality learning experience for students. These include differences in: regulatory systems, the self-accrediting status of a partner, academic calendars, credit systems, teaching approaches, examination requirements, language capacity and language of instruction, academic workload requirements, entrance and exit requirements, course fees and funding, and course completion requirements.

    [1] Dual awards are also offered within the same institution by some providers e.g. PhD/MBA, BSc/BEc, BA/BEd. This guidance note focuses mainly on dual awards that involve an arrangement between two providers.

    [2] A ‘course’ is sometimes known as a ‘program’, and an ‘award’ is sometimes called a ‘qualification’.

    Resources and references

    Australian Government, (May 2011), Principles for Joint Higher Degrees by Research between Australian Higher Education Providers.

    European Consortium for Accreditation (2014), Assessment framework for joint programmes in single accreditation procedures.

    European Consortium for Accreditation (2010), How to assess and accredit joint programmes in Europe.

    European Consortium for Accreditation (2010), The recognition of qualifications awarded by joint programmes.

    Knight, J. (2008), Joint and Double Degree Programmes: Vexing Questions and Issues, The Observatory on borderless higher education, September.

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the Enquiries Management team at providerenquiries@teqsa.gov.au
     

    Version # Date Key changes
    1.0 September 2013  
    2.0 19 August 2016 Updated for the HESF 2015 and made available as beta version for consultation. Replaces previous information paper on ‘TEQSA’s approach to the assessment of joint and dual awards’.
    2.1 11 October 2017 Addition to ‘What will TEQSA look for?” text box.
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    Version 2.1
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  • Guidance note: Monitoring and analysis of student performance

    Body

    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    Context

    While many higher education providers monitor and analyse student performance data in some form, TEQSA has identified that, in many instances, student performance data could be enhanced and used more effectively by providers to identify problems and risks early. This includes, for example, identifying problems with English language admissions settings, agents, course delivery, or academic integrity risks (among many others).  

    The Higher Education Standards Framework (HES Framework) requires providers to monitor and analyse student performance data. TEQSA considers this as a key component of a provider’s self-assurance processes.  

    This guidance aims to assist providers in undertaking monitoring and analysis of student data in line with the requirements of the Standards. TEQSA recognises that every provider is different and compliance with the HES Framework can be demonstrated in different ways according to the context of the provider. Each provider should determine the most effective way to implement this type of monitoring and analysis in its particular circumstances.

    What does ‘student performance’ encompass?

    All providers want their students to perform well and achieve the expected learning outcomes.  Providers must be able to identify students that are at risk of not performing well (this could be a predicted risk or an observed risk).  This enables providers to intervene early, to support students and mitigate against these risks occurring in the future. 

    Typical indicators of student performance include:

    • attrition rates
    • progress rates
    • completion rates
    • grade distributions
    • student satisfaction
    • graduate success.

    Analysis of student performance: How it relates to quality

    Understanding student performance through monitoring and analysis is critical to successful higher education. The insights and benefits are considerable, including enabling:

    • early identification of problems, allowing remedial action to be taken to avoid a lasting adverse impact 
    • identification (and support) of students at educational risk, especially previously unpredicted or unmitigated risks
    • testing/validation of a provider’s capability in predicting risks for particular groups of students
    • evaluation of the effectiveness of a provider’s management of predicted risks
    • identification and correction of underlying causes of poor achievement 
    • development of an evidence-based diagnostic understanding of risks and causal factors to improve performance and prevent future under-performance
    • demonstration that a provider meets, and can continue to meet, the requirements of the HES Framework in relation to student achievements. 

    Together, these benefits can enhance outcomes for students, with consequent enhancement of the reputation of both the provider and Australian higher education overall. 

    What do ‘monitoring and analysis’ encompass?

    For the purposes of this Note, ‘monitoring’ encompasses the regular collection of data on student performance as required by the HES Framework. The data will encompass data sets that are routinely collected by the provider, data from national data bases such as the Higher Education Information Management System (HEIMS) and data collected by the provider for particular purposes (such as monitoring breaches of academic integrity, agent performance or students at risk).

    ‘Analysis’ encompasses the provider’s approach to understanding the underlying patterns and causes of any identified lapses or deteriorations in student performance (i.e. whether they are apparently temporary or part of longer-term trends), as a foundation for corrective and preventive actions. Such analysis ideally includes:

    • predetermined elements such as routine analysis of data from pre-identified groups of students, e.g. international students, annual intakes to a course of study or students studying within a particular field of education, and 
    • ‘data-driven’ analysis of performance data aimed at detecting areas of risk that are not necessarily pre-determined or anticipated, for example, detecting a group of underperforming international students who have been handled by a particular agent or a cluster of students with academic integrity breaches with a similar profile – country of origin, agent used, basis of English language admission etc. 

    TEQSA acknowledges that the scope and depth of monitoring and analysis that can be undertaken by a provider will be determined in part by the scale of the provider and the types of methods that are applicable to that scale. For example, a large provider may be able to obtain large data samples that are amenable to sophisticated statistical analyses and/or data-driven business intelligence systems, while a small provider may need to place greater emphasis on a detailed understanding of individual circumstances in relatively small groups of students. Despite such variations in scale and approach to analysis, all providers must analyse and understand the performance of their students to address risks, inform continual improvement and continue to meet the requirements of the HES Framework.    

    What are identified student cohorts?

    For the purposes of this Note, ‘identified student cohorts’1 are groups of students whose members are identified as sharing some particular characteristics that may have a bearing on their success in a proposed course of study, such as a particular educational background, for example. In general, ‘cohorts’ are typically identified prospectively and monitored routinely, although retrospective identification of commonalities may also occur as a result of data-driven analyses (see ‘Other Identified Students’ below). 

    Identified cohorts typically fall into one or more of the following classes: 

    1. pre-determined cohorts that are traditionally identified in the Australian education system, such as students in individual fields of education, courses or units of study, international students, mature-age students, socially disadvantaged students, Indigenous students, annual intakes and students at different locations or participating in different modes of study (ideally the performance of such groups is monitored over time, i.e. cohort analysis in the formal sense)
    2. cohorts that providers should deliberately and predictively identify in the course of admission, such as students in diversity groups (e.g. Indigenous students), students who may have some potential educational disadvantage and students who may be at risk and are expected to require additional support after admission
    3. students who have been offered substantial credit for prior learning (e.g. a third or more of the course of study) through a standing arrangement or other mechanism
    4. other routinely predetermined groups of significance to particular providers, such as students with particular post-graduate requirements, e.g. initial teacher education. 

    The matters raised in this Note generally apply to the individuals within a cohort as well as to the cohort as a whole.   

    Other identified students

    In addition to prospective identification of cohorts, a provider’s monitoring and retrospective analysis of its overall student performance data (so called ‘data-driven’ analysis) may reveal other groups/individuals who demonstrate poor performance that was not necessarily anticipated, such as:    

    1. groups of students (or individuals) that are identified by either an episode, or a continuing history, of low academic achievements, including poor performance in early assessments, failure in other assessments, slow completions or attrition
    2. previously unrecognised groups or individuals that are identified in diagnostic analyses of performance (e.g. where a provider’s assumptions about educational preparedness of a particular group are not realised)
    3. low performing students that can be associated with particular market niches (e.g. a new international market, admission by particular mode of instruction, admission by type of English language proficiency evidence, admission through particular agents or particular pathway providers, both onshore and offshore)
    4. students who are demonstrating particular difficulties that are affecting their education (e.g. breaches of academic integrity, or the emergence of particular learning difficulties).

    Such retrospective data-driven analysis, as with prospective cohort analysis, gives providers important information to help to identify problems that have occurred and their cause. Most importantly, the analyses should lead to the identification and correction of underlying root causes, so that the problems do not continue to occur in the future.  

    Relevant Standards in the HES Framework 

    The HES Framework addresses, or has a direct bearing on, student performance in several ways at a number of levels. This begins with a fundamental requirement of admission that students who are admitted to a provider will have no known limitations that would impede their progression or completion (1.1.1)2, as well as ensuring students are informed about their prospective experience and obligations (1.1.2, 7.1.1 – 7.1.5, 7.2.1 – 7.2.4) and that any credit offered for prior learning does not disadvantage them (1.2.2a). 

    Section 1.3 (Orientation and Progression 1.3.1 – 1.3.6) sets out the obligations on providers to assess the needs of cohorts, to provide early assessment of student progress and targeted support, if required, and to monitor trends in student performance to enable review and improvement. In particular, this section of the standards notes that students should have equivalent opportunities for progression, irrespective of their background, entry pathway or mode or place of study (1.3.6).

    Section 2.2 (Diversity and Equity 2.2.1 – 2.2.3) deals with accommodation of diverse groups such as Indigenous students and disadvantaged groups, and imposes specific requirements for monitoring the performance of identified sub-groups of students and using the findings to improve admissions policies, teaching, learning and support for those groups. 

    The HES Framework sets requirements at the institutional level for monitoring and review of academic performance, including a requirement to obtain student feedback (5.3.5) and to use student performance data and feedback to inform both admission practices and the provider’s other academic approaches (5.3.7).

    The Standards also specify corporate and academic governance responsibilities for overarching oversight of the range of activities already mentioned above. These include ensuring that there is corporate oversight of academic governance (6.2.1f), that the corporate governing body has identified risks to the provider’s education operations (6.2.1e) and that academic oversight of monitoring, review and improvement of academic activities is effective (6.3.2g).  The HES Framework also requires effective monitoring and reporting to the corporate governing body on the quality of teaching and research (6.3.2h), together with relevant delegation of authority (for monitoring and reporting on student performance in this case) and that the implementation and effectiveness of those delegations are monitored and reviewed (6.1.3b). A provider is also expected to set and monitor institutional benchmarks for academic quality and outcomes (6.3.1b); for which monitoring and analysis of student performance is a fundamental requirement. 

    A provider is required to maintain accurate and up-to-date records, including data on enrolments, progression and completion (7.3.3a) and any lapses in compliance with the HES Framework (7.3.3d). 

    Intent of the Standards 

    The general intent of the Standards is for providers to develop a detailed understanding of the performance of their students and to create an evidence base for improvements to all aspects of the provider’s academic activities, both at the local level (e.g. delivery of a course of study at faculty/departmental level) and for the provider as a whole, through improved oversight and policy refinement that leads to enhanced student outcomes.

    This understanding is expected to be nuanced according to identified (or identifiable) cohort data, where relevant, and is intended to extend to:

    • the effectiveness of a provider’s predictions and assumptions that underlie admissions policies and practices, and
    • the causes of poor performance of admitted students, both in transition to their course of study and throughout their studies (whether because of, or irrespective of, deficiencies in admission practices). 

    The Standards intend that a provider will develop a sound quantitative understanding of student achievements, which will inform both established practices and improvement strategies. Such an understanding is intended to be evidence-based, to be able to demonstrate correlations and associations, and to identify underlying causal relationships that will inform improvements. 

    The necessary analyses are intended to be nuanced by examination of the needs and performance of identified groups of students, while at the same time demonstrating that all students have equal opportunity for successful progress irrespective of background. A provider’s data-driven analyses may identify a previously unrecognised focus of potential disadvantage. 

    While the Standards seek to proscribe admission of students with known impediments to success, this does not preclude admission of students who may face additional but manageable risks, e.g. students who are expected to need additional academic support. This requires sound judgement by a provider, including predictive analyses, the assumptions of which are expected to be tested through the provider’s subsequent analyses of student performance, as required by the HES Framework. It also necessitates that they make that additional support available.

    Risks to quality

    The principal risks to quality stemming from an insufficient understanding of student performance relate to poor student outcomes (with potential reputational risks to the provider and to Australian higher education).  The causes of poor outcomes generally fall into three broad classes:

    1. personal factors
    2. admission of students who are inadequately prepared to undertake their course of study 
    3. deficiencies in the learning environment such as inadequate teaching or insufficient access to, or uptake of, student support services.

    TEQSA has identified a number of shortcomings among providers in relation to understanding student performance, including:

    • paying insufficient attention to, or ignoring, available data to detect particular risks (e.g. not responding to obvious data that demonstrate poorer performance by a particular group of students, which was not predicted by the provider)
    • failure to establish an evidence base to fully understand and validate a provider’s policies and approaches (e.g. admission practices, detection of students at risk, provision of targeted learning support, related institutional policies) 
    • not undertaking sufficient in-depth analyses of cohort performance to identify underlying causes of poor performance
    • failing to track cohorts over time (e.g. systematically tracking and monitoring student performance data based on identified risks such English language proficiency or on the basis of recruitment and admission)
    • undertaking analyses of performance, but not acting on the findings to bring about improvements, particularly through institutional academic governance and quality assurance processes
    • deficiencies in academic and corporate governance e.g. governing bodies not seeking sufficient information to understand risks to student performance, to be satisfied about educational risk management and to oversee corrective and preventive actions that are, or should be, implemented
    • unclear or insufficiently accountable delegations of authority for performance analyses and tracking, and/or failure to monitor the effectiveness of such delegations in detecting and addressing issues of concern. 

    Particular issues of concern include inadequate analyses and tracking to understand and address:

    • insufficient English proficiency that is traceable to different types of admission (e.g. alternative language testing vs standardised testing such as IELTS, criteria not based on testing such as language of previous instruction, exemptions from the normal criteria, the effectiveness or otherwise of different agents, on-shore and off-shore cohorts)
    • whether or not a provider’s admission policies or other policies are effective in achieving their intended policy outcomes (e.g. whether the additional support provided to cohorts with known risk on admission are indeed effective and whether the particular approach to admission is tenable in the light of performance data)
    • whether or not all students have equivalent chances of success irrespective of their background, mode of entry and mode of participation
    • whether or not groups of students were sufficiently informed, or not misinformed, about the requirements of their chose course of study
    • whether or not particular types of students are prone to particular concerns e.g. breaches of academic integrity.  

    What TEQSA will look for?

    This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to the analysis and understanding of student performance.

    For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.  

    For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.

    The evidence required for particular types of application is available from the application guides on the TEQSA website.

    Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

    TEQSA expects a provider to be able to demonstrate an effective system to track and analyse the performance of identified student cohorts and that this provides an evidence base sufficient to diagnose, address and prevent issues with particular cohorts.  The scope of such a system must encompass the relevant sections of the HES Framework (see above) and involve all relevant levels of the organisation, as required by the HES Framework.

    An example would be a scenario in which international students in Information Technology had higher and increasing rates of attrition compared to domestic students, and compared to international students in Business. TEQSA would expect management to inquire into the possible causes of this, under the oversight of the governing bodies, and initiate improvements, which might take the form of changes to the relevant admissions criteria, agent management, delivery or assessment. Any improvements would then be reported back to the governing bodies to complete the improvement loop at governance level.

    Overall, TEQSA expects that a provider is able to demonstrate that there is an established framework of regular review and response to quantitative analysis3 and resultant evidence to show that:

    1. the provider knows that admitted students have no known impediments to their prospective progress (1.1.1)
    2. admitted students have sufficient academic preparation and proficiency in English to participate in their chosen course of study (1.1.1)  
    3. student cohorts have been identified meaningfully and rationally (evidence based) in the context of the provider’s mission and that the needs and risks for those cohorts are understood and anticipated (1.3.2a)
    4. identified student cohorts have equivalent opportunity for success, irrespective of their educational background, entry pathway and mode or place of study (1.3.6)
    5. there is both an evidence-based rationale and a framework of delegated authority for adopting or varying admission requirements for any cohort (6.1.3b), including the admission of students who have some identified educational disadvantage that is believed (with evidence) to be manageable with additional support
    6. additional targeted support is provided where needed and there is evidence that it is effective (1.3)  
    7. granting of credit for prior learning does not disadvantage any cohort (1.3.2c)
    8. student progression is monitored during transition and throughout their course of study (1.3.5) and the resulting data are used to guide provision of additional support where needed (1.3.2c) and to inform institutional review and improvement (5.3.7), including improving the effectiveness of policies and procedures that are intended to enhance student achievement  
    9. data on student progression are considered and acted on at the institutional level (6.1.3b, 6.2.1e, 6.2.1f, 6.3.2e – h)
    10. the provider’s data on student progress is accurate and up-to-date (as is reasonably practicable) (7.3.3.a)
    11. known difficulties with student progress do not reflect deficiencies in the provider’s representation of its offerings (whether directly or via agents) (7.1.1 – 7.1.5) or the information that is provided to students (7.2.1 – 7.1.4)
    12. the effectiveness of delegated authority for understanding and reporting on student progress is monitored at institutional level (6.1.3b, 6.3.1a-d)
    13. agents and third-party arrangements operate in the interests of all students involved with those parties (5.4.1 – 5

    Notes

    1. The term ‘cohort’ is used more broadly here than in the specific technical sense some readers may be familiar with in formal statistical cohort analyses – tracking of performance over time).
    2. Encompassing but not limited to proficiency in English, educational preparedness, appropriate recognition of prior learning. The intent of this standard is to ensure that providers actively consider the preparedness of particular types of students and predict any likely challenges a group may face, with a view to providing targeted support where warranted.
    3. Except in rare circumstances where it is impractical to do so (such as an immature provider) or when qualitative evidence may be more appropriate.

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au

    Version #

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    1.0 6 January 2020 Made available as beta version for consultation.
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    Beta version 1.0
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  • Guidance note: Nested courses of study

    Body

    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    What do ‘nested’ courses of study encompass?

    ‘Nested courses’ is not a term used in the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework), but in this context is interpreted to mean a set of courses of study that are offered sequentially and can lead to qualifications at different Australian Qualifications Framework (AQF) levels. Courses at the lower qualification levels are described as ‘nested’ within the courses leading to qualifications at the higher levels (as represented in Figure 1 below). Nested courses are typically offered by a single provider but could be offered through a third-party arrangement (see separate guidance note on third-party arrangements). It is also possible that components of the nested program may be completed at different independently registered providers and the ‘nesting’ achieved by credit transfer arrangements between the providers.

    This guidance note focuses solely on coursework, but nesting arrangements are also found in higher degrees by research in some specific circumstances.

    Figure 1 - A diagrammatic representation of nested courses of study at undergraduate and postgraduate levels1.

     'HE Diploma' is nested within 'Assoc Deg' which is nested within 'Bachelor'. Within the Postgraduate box are three label

    Differing models of student participation

    A nested arrangement of courses and qualifications potentially enables multiple entry and exit points for students. Students may exit with a qualification at one of the lower levels after completing a defined subset of the total program. They may also enter at different levels depending on their prior experience or qualifications in the field of study and the provider’s requirements for recognition of prior learning. 

    Students who are admitted in the first instance only to a lower level course and complete that course successfully, will typically be granted a defined amount of credit towards admission into the higher-level courses, should they wish to proceed. In a three-stage program that contains exit points at the end of each stage, this would typically entail one- third credit being granted for completion of each level.

    However, students who are enrolled directly into the higher course at the outset are not normally granted credit for completion of each level. Instead, they normally proceed through the entire program of study just like any other non-nested course of study, unless they change their plans and decide to exit at a lower level.

    The first scenario (enrolment in a lower level) can be referred to as an ‘opt-in’ model, and the second (enrolling for the highest level at the outset) can be referred to as an ‘opt-out’ model. The nature and requirements of the model chosen must be made fully transparent to prospective and current students.

    Relevant Standards in the HES Framework

    The Standards that are primarily concerned with nested courses of study are the same as those that apply to all individual courses of study that lead to the award of a higher education qualification that is recognised in the AQF. These are the Standards in Domain 1 (Student Participation and Attainment), Domain 2 (Learning Environment), Domain 3 (Teaching) and, if applicable to the provider, Domain 4 (Research and Research Training). 

    The Standards apply to all of the nested components individually where they may lead to the award of a qualification, even if the qualification is not awarded because a student decides to continue with a higher course of study rather than exit with a lower qualification. 

    The requirements for institutional approval of courses (Section 5.1 Course Approval and Accreditation) apply equally to scrutiny and approval of nested arrangements, through the provider’s peak academic governance bodies. This applies whether or not a provider has self-accrediting authority.

    Intent of the Standards

    The intent of the Standards is to ensure that the requirements of the HES Framework for admission, recognition of prior learning, orientation and progression, achievement of learning outcomes and award of qualifications are met, irrespective of which level of study is undertaken and which qualification may be awarded. The requirements for the learning environment, course design, staffing, learning resources and educational support also apply to every component of a nested program. 

    Each course of study within a nested set that may lead to an AQF qualification must meet the requirements of all of the relevant Standards in its own right, irrespective of any nesting arrangement. This includes the requirement that all qualifications that are awarded are consistent with the level classification of the qualifications in the AQF. 

    For example, it follows that in the nested programs illustrated in Figure 1:

    • the course of study leading to the Bachelor or Master degree must have specified expected learning outcomes that are consistent with the level classification of the AQF for a Bachelor or Master degree
    • the course of study leading to the Associate Degree or Graduate Diploma must have specified expected learning outcomes that are consistent with the level classification of the AQF for Associate Degree or Graduate Diploma
    • the course of study leading to the Diploma or Graduate Certificate must have specified expected learning outcomes that are consistent with the level classification of the AQF for Diploma or Graduate Certificate.

    Risks to quality

    There are many examples of successful nested arrangements. They are however vulnerable to a variety of risks, including where:

    • the integrity, coherency, overall level of study, or learning outcomes of the courses leading to qualifications awarded at the higher and highest levels of study are compromised or diluted by excessive lower-level material
    • students who complete the requirements of a lower level and then decide to proceed to higher levels are not sufficiently prepared to undertake the higher level of study
    • lower level components are ill conceived to achieve both of their two possible roles; either a coherent terminating course of study leading to the award of an appropriate qualification or an effective preparation for continuing study at a higher level 
    • the course leading to the highest level of study is not conceived as a coherent whole, but is a collection of unrelated parts, thus degrading the qualification awarded 
    • excessive or inappropriate award of credit for prior learning that compromises the integrity of the course(s) and/or disadvantages the students concerned - this risk mainly arises where credit is awarded for a qualification completed at a third party provider (refer to the guidelines in The Australian Qualifications Framework second edition 2013. The Pathways Policy section 2.1.10 is a reference point)
    • teaching staff in lower levels are not sufficiently qualified and experienced to lead students who will be progressing to higher levels, or
    • cohorts of students with differing learning needs (e.g. planning to exit at a lower level versus continuing to higher levels) are taught jointly, leading to the different learning outcomes not being met for some students. 

    Such adverse outcomes may jeopardise the TEQSA accreditation of a course(s) of study.

    What TEQSA will look for

    This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to nested courses of study.

    For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards. 

    For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.

    The evidence required for particular types of application is available from the application guides on the TEQSA website. 

    Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

    TEQSA will need to be satisfied that each and every nested component of the course of study meets the requirements of the HES Framework as a stand-alone course and that any combination of nested elements meets the requirements of the HES Framework, especially for the highest level of study and qualification awarded. The provider needs to demonstrate that students who are enrolled in a lower course at the outset, but have the option of continuing on to complete the higher courses in the nested set, achieve the learning outcomes for their initial course in the first instance, while at the same time positioning themselves to achieve the learning outcomes for courses leading to awards at higher levels if they proceed through the nested sequence. This applies regardless of whether the course conforms to an opt-in model or an opt-out model.

    TEQSA will need to be confident that the inclusion of subjects and subject elements at lower levels does not undermine the integrity of the highest level of course being delivered. This issue goes to the level of each subject, its content, its teaching staff and its assessment. The greater the proportion of subjects with learning outcomes that are below the AQF level for the higher course, the greater the risk that the higher course will not meet the HES Framework requirements for course accreditation.
    In assessing a course proposal, TEQSA needs to be able to see clearly where each of the learning outcomes for each course is taught and assessed, and that the learning outcomes are consistent with the level of study and the highest level of qualification involved. Where providers are presenting nested courses for assessment, it will be of assistance to TEQSA if an explanation and/or mapping is provided that shows where and how course learning outcomes are addressed and assessed throughout the entire program.

    Approval and Design of Nested Programs

    TEQSA expects to see, for all nested courses of study where students:

    • enrol, or could enrol, at the highest level initially (an opt-out model), or 
    • can study at more than one level of the nested arrangement based on completion of a lower level(s) (an opt-in model),

    the nested program has been designed and approved as a whole, in its entirety, by the provider. The provider must be able to demonstrate in particular that the learning outcomes and their assessment at each level of the program are not only appropriate for issuing a subsidiary qualification if a student should exit at one of the lower levels, but also that the learning outcomes at these levels position students for progression through an opt-out model in its entirety should students undertake that option. The learning outcomes for all levels of the program must also be consistent with the issue of an AQF qualification at the highest level of the nested program. 

    In other words, TEQSA expects the nested arrangement to be designed and approved as if it were a three-level course of study, irrespective of the mode of participation by students. The difference is only that learning outcomes for each level must also be consistent with the award of an AQF qualification at that level should students exit at that level. Design and approval of the program in its entirety must also involve reviewers with a relevant qualification at least one AQF level above the highest qualification being offered, as would be required of a non-nested arrangement (Standard 3.2.3). 

    Staffing of Nested Programs

    The HES Framework requires that staff who have oversight of and teach in a course of study must be qualified to at least one level higher than the course of study being taught, or have equivalent relevant professional experience (3.2.3). The HES Framework also requires that staff who do not meet the requirements of 3.2.3 in their entirety, such as experienced practitioners involved with specialised components, must have their teaching guided and overseen by staff who do (3.2.4). For the purposes of an opt-in model, TEQSA requires that staff who teach at any level of a nested program must be qualified at least one AQF level higher than that being taught, or have equivalent professional experience. 

    Oversight of Teaching

    Should the nested program cater for opt-out students, at a minimum the teaching of such staff at the lower levels of the program must be guided and overseen by staff who are qualified at least at one AQF level above the highest qualification being offered, or equivalent. Alternatively and preferably, there are teaching staff at all levels of an opt-out program who are qualified at one AQF level above the highest qualification offered and such staff are able to oversee and guide other staff who may not be so qualified. Where equivalent professional experience is claimed, the provider should have formal criteria for evaluating this (see TEQSA’s guidance note on determining equivalence of professional experience and academic qualifications). In this context, ‘oversight’ is taken to mean observation, guidance and monitoring of at least course delivery, content and assessment, including monitoring of student progress and feedback.  

    Minimum Teaching Qualifications

    Notwithstanding a minimum requirement for AQF+1 qualifications at lower levels of a nested program (3.2.3), TEQSA expects that teaching staff in higher education must be qualified with at least a bachelor degree relevant to their teaching, in order to meet the broader content and skills requirements of the HESF (e.g. 3.2.2, 3.2.3a, 3.2.3 b). Thus, where AQF+1 may otherwise be less than a bachelor degree for the lower levels of a nested arrangement, the minimum requirement is still a relevant bachelor degree.

    Applicants may be admitted into any of the nested courses based on prior academic achievement, or in some cases equivalent professional experience. Where admission is on the basis of professional experience, providers must have reason for their confidence that students will be able to achieve the academic standards required; bearing in mind that professional experience may not always equip applicants with the requisite academic study skills. 

    Where applicants are admitted to any of these courses with advanced standing based on prior academic achievement, to maintain the integrity of their course the provider must be able to demonstrate to TEQSA that it has taken into account the comparability and equivalence of the learning outcomes, volume of learning, program of study (including content and learning and assessment approaches), with those of the provider’s own course.

    Above all, the provider must be able to demonstrate that all students admitted to any course have sufficient grounding in knowledge and skills to be able to achieve the learning outcomes of each course in the time available, taking into consideration the course design. Students must be required to have sufficient grounding to complete all the units that are necessary for them to achieve the course learning outcomes, given their potentially different starting points in prior knowledge and skills.

    Resources and references

    Australian Qualifications Framework Council (2013), Australian Qualifications Framework Second Edition January 2013.

    Australian Qualifications Framework Council, Addendum to the AQF Second Edition January 2013: Amended Qualification Type: Masters Degree, May 2014 (replaces pages 59-62 of the AQF Second Edition January 2013).

    Australian Qualifications Framework Council (November 2012), Clustered Qualifications: An Explanation.

    Australian Qualifications Framework Council (November 2012), Proportion of Components of a Qualification at a Level: An Explanation.

    TEQSA (2016), Guidance Note on Course Design, Learning Outcomes and Assessment

    TEQSA (2016), Guidance Note on Determining Equivalence of Professional Experience and Academic Qualifications.

    Notes

    1. The diagram portrays an arrangement for a single provider but it is not intended to preclude arrangements with third parties or between independent providers.

     

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au
     

    Version # Date Key changes
    1.0 March 2013  
    2.0 19 August 2016 Updated for the HESF 2015 and made available as beta version for consultation.
    2.1 11 October 2017 Addition to ‘What will TEQSA look for?” text box.
    2.2 13 August 2019 Amendments relating to minimum qualifications of teaching staff and course approval in light of stakeholder feedback.

     

     

    Subtitle
    Version 2.2
    Stakeholder
    Publication type
  • Guidance note: Research requirements for Australian universities

    Body


     

    TEQSA’s guidance notes are concise documents designed to provide high-level, principles-based guidance on interpretation and application of specific standards of the Higher Education Standards Framework (Threshold Standards) 2021. They also draw attention to other interrelated standards and highlight potential risks to compliance. They do not introduce prescriptive obligations. 
     

    The definitive instruments that set out providers’ obligations in delivering higher education remain the Threshold Standards (as amended on advice from the Higher Education Standards Panel to the Minister for Education from time to time) and the TEQSA Act
     

    In late 2022, TEQSA consulted stakeholders with a draft version of Research Requirements for Australian Universities and considered all feedback. 
     

    This guidance note was finalised on 30 April 2024. 
     

    The purpose and intent of the guidance note about research requirements is to support providers who aspire to enter and remain within the Australian University provider category ensure they undertake research at the level and depth required for Australian Universities. 
     


     

     

    Research requirements for Australian universities

    The undertaking of research that leads to new knowledge and original creative endeavour, together with research training, represents a fundamental and defining feature for any higher education provider (provider) seeking status as an ‘Australian University’.

    This guidance note focusses on the requirements specifically applying to Australian Universities and the quality and quantity of research that is undertaken at an institutional level.1

    In accordance with the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) s59A(1), the quality of research undertaken by a provider must be considered by TEQSA if the provider is:

    • applying under section 18 for registration in the Australian University category
    • applying under section 38 to change to the Australian University category
    • currently in the Australian University category.

    Standards B1.3.16-19 of the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards), set threshold levels for the breadth and quality of research for a provider in the ‘Australian University’ category.

    The ‘benchmark standards’ for research quality are:

    • research that is world standard measured using best practice indicators, and/or (B1.3.19a)
    • research of national standing in fields specific to Australia, in the case of research that is not easily captured by existing standard indicators (B1.3.19b).

    Providers registered in a category using the title ‘university’ before the 2021 Threshold Standards came into effect

    For any provider registered in the ‘Australian University’ category after the Threshold Standards 2021 came into force on 1 July 2021 and registered immediately prior to that date in a provider category permitting the use of the word ‘university’, there are two transitional research requirements (B3.2):2

    • Within 5 years, providers must undertake research that meets one or both benchmark standards for research quality and leads to the creation of new knowledge and original creative endeavour in:
      • 30%, or at least three, broad Fields of Education in which the provider delivers courses of study (whichever is greater), or
      • (for universities with a specialised focus) all broad Fields of Education for which the provider has authority to self-accredit (B1.3.17).
    • Within 10 years, providers must undertake research that meets one or both benchmark standards for research quality in:
      • 50%, or at least three, broad Fields of Education in which the university delivers courses of study (whichever is greater), or
      • (for universities with a specialised focus) all broad Fields of Education for which the university has the authority to self-accredit (B1.3.16).

    Providers not registered in a category using the title ‘university’ before the 2021 Threshold Standards came into effect

    For any provider that becomes registered in the ‘Australian University’ category after the Threshold Standards came into force on 1 July 2021 and which was not immediately prior to that date registered in a provider category permitting the use of the word ‘university’, there are two transitional research requirements:

    • upon entry to the ‘Australia University’ category, providers must meet the requirements of B1.3.17, and
    • within 10 years from entry to the ‘Australian University’ category, meet the requirements of B1.3.16.

    Moreover, regardless of when a provider is registered in the ‘Australian University’ category, once it has met the requirements of B1.3.16 it will be assessed against that standard and not the more relaxed B1.3.17.

    Indicators of research quality

    TEQSA recognises the quality requirements for research in the Threshold Standards are based on Fields of Education whereas many indicators of research quality are based on Fields of Research (Australian Bureau of Statistics, ANZSRC3. Indicators of research quality based on Fields of Research include national or other assessments conducted by the Australian Research Council (ARC) and measures of research activity and performance outlined in the Quality of Research Determination 2021 (Determination 2021). To assist, TEQSA has developed a concordance table that maps the Fields of Education (ASCED4) to the ANZRC Fields of Research (Attachment A).

    TEQSA acknowledges the review of the Australian Research Council, announced in 2022 by Minister Clare and led by Professor Margaret Sheil recommended changes to the current Excellence in Research for Australia (ERA) methodology. TEQSA’s processes will adapt to any research regime changes implemented by the Australian government.

    What TEQSA will look for

    TEQSA acknowledges there is no single approach to assessing research quality. This is reflected in the Determination 2021, which sets out a variety of matters that TEQSA must have regard to when assessing the quality of research at a regulated entity.

    In considering research quality, TEQSA will rely on a number of approaches. For example, it will consider whether the provider can demonstrate through the marshalling of evidence that it meets the standard of research required under the Threshold Standards (see Research and Research Training). As set out in the Determination 2021, TEQSA must also consider measures of quality such as the quantity of citations of publications and quality of the publication in which research outputs appear, the prevailing practices for a given discipline, Australian Research Council (ARC) research assessments such as the ERA (or alternatives), and other verifiable data collections. TEQSA will calibrate its approach to assessment with reference to each provider’s self-assurance maturity, risk profile and the Fields of Education in which it delivers courses of study.

    TEQSA will also look for a provider’s systematic approach to self-assurance of research quality. This approach must be embedded in its governance framework, policies and institutional quality assurance and performance mechanisms. Further, like academic quality requirements, this approach must have appropriate oversight by the provider’s governing bodies to assure themselves of compliance with the Threshold Standards.

    In assessing whether a provider meets the research requirements for Australian Universities, TEQSA may request additional evidence including:

    • the provider’s processes for evaluation of research quality including the nature and extent of any peer review processes
    • the results from an external expert review of the provider’s research quality
    • copies of reporting to and assurance of corporate and academic governing bodies
    • data, such as citation and quality metrics, and benchmarks against which the data has been compared
    • the volume of research outputs over time or other evidence of sustained research quality
    • evidence of success in securing competitive research funding
    • other evidence as per the Determination 2021, where applicable. For example, evidence to demonstrate a provider has a suitable research environment.

    In addition to the matters set out in the Determination 2021, TEQSA will refer to standards within Part A, as well as the criteria in Part B of the Threshold Standards that support research quality.

    The below table sets out relevant requirements of these two instruments:

    Threshold Standards (2021) Key considerations
    3.2.3a: Staffing
    • Staff responsible for academic oversight/with teaching and supervisor roles hold knowledge informed by continuing scholarship, research or advances in practice.
    5.2: Academic and Research Integrity
    • Policies and procedures uphold research integrity, mitigate risks, ensure guidance is provided, and integrity maintained in third-party arrangements.
    6.1.1: Corporate Governance, and 
    6.2.1k: Corporate Monitoring and Accountability
    • The governing body of the provider assures itself of compliance with the Threshold Standards and that any lapses are identified and addressed, including the requirement to meet the research quality benchmarks.
    6.3.1 and 6.3.2: Academic Governance
    • Academic governance processes and structures maintain academic oversight of research.
    B1.3 ‘Australian University’ Category
    • Delivers the required proportion of research at national standing or world standard
    • Meets the requirements to become and remain an Australian University
    B3.2 Transitional research requirements
    • Providers registered in the ‘Australian University’ category after the 2021 Threshold Standards comes into force, and, immediately before the commencement date were in a provider registration category that permitted use of the word ‘university’, achieves benchmarks set out in B1.3 within the required timeframes.

     

    Benchmark standards for quality of research

    Overall, in considering an application, TEQSA will assess a provider’s evidence against the two research quality benchmarks specified in Part B1.3.19.

    In assessing a provider’s evidence of research at either world standard or national standing, TEQSA will rely on evidence of:

    • achievements which meet agreed definitions of research, and
    • research quality assessments informed by expert external review.

    This includes nationally agreed approaches to the assessment of non-standard research outputs, approaches to peer review and citation profile analysis, and the assessment of published works, such as books and book chapters.5

    Research at world standard

    Where a Field of Education is covered sufficiently by one or more Fields of Research that have been assessed via a national assessment system, weight will be given to this assessment.

    The ARC has the expertise and responsibility to assess the quality of research in Australian higher education institutions, including the establishment of benchmarks relative to research conducted nationally and internationally to determine whether the provider’s research meets the ‘world standard’ benchmark. In its evaluations, the ARC recognises research in fields specific to Australia may be published less frequently in highly ranked international journals and/or be cited less by overseas researchers. The ARC has the expertise to assess these matters when evaluating those Fields of Research. Therefore, TEQSA will give weight to the ARC’s expertise when assessing the world standard benchmark.

    TEQSA also acknowledges that there may be other international measures that align to world standard. Where a provider relies on international measures, evidence must demonstrate to TEQSA that these measures align to world standard and are equivalent in quality and volume.

    Research of national standing in fields specific to Australia

    ‘National standing’ refers to research not easily captured by existing standard indicators. Examples of research to which this may apply is research about Aboriginal and Torres Strait Islander peoples and Australian history.

    National standing is not a lesser standard than that of world standard. The category of ‘national standing’ is intended to allow researchers to convey their research in a way that is sensitive to recognised cultural practices and beliefs in Australia. This is most relevant to the field of research Indigenous Studies.

    The circumstances where TEQSA will look to the benchmark of national standing in fields specific to Australia include, but are not limited to:

    • a provider applying to the Australian University category, where a national assessment of world standard cannot be evidenced
    • an existing provider where a national assessment of world standard cannot be evidenced due to it being ineligible or not meeting volume thresholds for ERA (or equivalent assessment)
    • the research of a provider is not easily captured by typical indicators of world standard.

    TEQSA does not expect evidence beyond the requirements in the Threshold Standards and the Determination 2021. TEQSA will look for the use of national indicators and quality metrics that are common and accepted in the relevant field, as well as robust processes, such as peer reviews which demonstrate sustained research of quality. TEQSA may request additional information, where relevant, as outlined above.

    Mapping from 4-digit Fields of Research to 2-digit Fields of Education

    In demonstrating the quality of research for a 2-digit Field of Education meets the requirements of the Threshold Standards, a provider may also undertake its own mapping from the 4-digit level of Fields of Research to the 2-digit Field of Education. This mapping must be underpinned by a clear and rational methodology.

    In relying on this mapping, a provider must supply TEQSA with evidence of both its mapping and methodology for consideration. Assessors will review this evidence and take into consideration the requirements (at a minimum) outlined in the Determination 2021.

    When research requirements are not met

    In some situations, a provider in the category ‘Australian University’ may not comply with the research quality requirements. In these situations, TEQSA will expect to see evidence of a robust research strategy and framework that outlines how the provider will meet the requirements within the timeframe set out in the Threshold Standards.

    Where TEQSA is not satisfied a provider is compliant or will return to compliance within a reasonable period, it may take regulatory action.

    Identified issues

    Within the context of the Threshold Standards, TEQSA has identified issues which warrant further consideration. These items may prompt closer scrutiny by TEQSA assessors as they could indicate risk of non-compliance. These include, but are not limited to:

    • In the evidence provided with an application, there is an overreliance on certain projects, sub-fields, or researchers without appropriate contingency plans to account for if a key project fails or a key researcher leaves.
    • Failing to link evidence provided in support of an application to the Australian University category to the standards and expectations set out by the Australian Research Council (or equivalent).
    • Failing to provide any evidence of competitive research grants or other direct funding for research noting that providers may participate in applications with established universities and seek out other categories of research funding.
    • Lack of evidence demonstrating sustained research quality over time.
    • The application relying on research quality assessments that are singular or unique and are not benchmarked:
      • internationally, in the case of the world standard, or
      • nationally (against national indicators or metrics), in the case of the national standing.
    • Claiming that research in a Field of Education meets the benchmark because some parts meet one benchmark while others meet another benchmark; the 2-digit Field of Education must be world standard and/or of national standing.
    • Claiming that a field of research passes the national standing test only because:
      • it cannot be compared to international research, but it is nonetheless important for the national interest or another national reason, or
      • it is about an Australian topic.
    • Insufficient investment of resources in research necessary to maintain research quality over the period of a provider’s registration in the Australian University category. For example, casual employment of high-profile researchers for part of a year to augment the provider’s research profile and output when the researcher is under the auspices of another provider.
    • Poor alignment in the four-digit Fields of Research and two-digit Fields of Education; any mapping between the two must be underpinned a strong, clear rational methodology that can be evidenced.
    • An absence of peer review to ensure quality assurance of research outputs in either in the following two forms:
      • ‘developmental and supportive’ peer review: peer review that seeks advice from other researchers, industry, or the wider community through seminars, conferences, and participation in committee or institutional activities to strengthen research and identify opportunities for collaboration
      • ‘blind’ or ‘at arm’s length’ peer review: peer review that involves impartial and rigorous reviews of research according to sector-wide or global standards of excellence. 

    Notes

    1. TEQSA’s guidance note on Research and Research Training provides more detailed guidance on these areas in relation to Part A of the Threshold Standards.
    2. The provider categories that permitted the use of the word ‘university’ before the Threshold Standards (2021) commenced on 1 July 2021 were: ‘Australian University’, ‘Australian University College’, ‘Australian University of Specialisation’, ‘Overseas University’, and ‘Overseas University of Specialisation’.
    3. Australian and New Zealand Standard Research Classification (ANZSRC), 2020.
    4. Australian Standard Classification of Education (ASCED), 2001.
    5. See for example: ERA 2023 Submission Guidelines.

    Related resources

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the Threshold Standards can be met in different ways according to the circumstances of the provider. Provided the requirements of the Threshold Standards are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au.

    Version # Date Key changes
    1.0 29 July 2022 Initial release for consultation
    2.0 18 January 2023 Post-consultation updates and public release
    2.1 30 April 2024 Further updates


     

    Attachment A

    Subtitle
    Version 2.1
    Stakeholder
    Publication type
  • Guidance note: Staffing, learning resources and educational support

    Body

    Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time. 

    What do ‘staffing’, ‘learning resources’ and ‘educational support’ encompass?

    In the context of the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework), the Sections on Staffing, Learning Resources and Educational Support encompass academic resources specifically made available for a particular course of study such as:

    • the complement of staff[1] (academic, professional or other staff) who are involved directly in the supervision and/or delivery of the course
    • the learning resources that are specific to supporting learning within that course (e.g. specific online reference material), even if provided from a general resource such as a library collection
    • the educational (academic) support services that foster learning more generally for students in that course (e.g. learning management system).

    Other staffing, facilities and resources that are of a more general nature and are not primarily academic services or specific to a particular course of study are covered elsewhere in the HES Framework, e.g. under Sections 2.1 (Facilities and Infrastructure) and 2.3 (Wellbeing and Safety). Staffing for research and research training is dealt with separately in the research Standards (Domain 4).

    Relevant Standards in the HES Framework

    The Standards concerned with staffing are at Section 3.2 and learning resources and educational support are covered at 3.3. Staffing related to research is encompassed by Standards 4.1.2 and 4.2.3, and is not covered by this guidance note.

    Intent of the Standards

    The overall intent of the staffing Standards for each course of study is to ensure that sufficient staffing is provided of a level and type that reflects the nature and level of the course and the educational and other needs of the students concerned (Standard 3.2.1). This implies that some form of analysis is undertaken by the provider to understand and meet the needs of students, including needs for individual student access to staff outside of formal teaching (3.2.5).

    The Standards address the teaching qualifications and skills of staff in three different ways, through:

    • the provision of oversight of the course at a level appropriate for academic leadership of the level of the course concerned as well as the level of teaching resources (3.2.2)
    • specific detailed requirements for academic leadership, supervision and teaching within a course of study (3.2.3)
    • requirements for supervision of teachers who are involved with limited or specialised components of a course of study  (3.2.4).

    The Standards (at 3.2.4) recognise the practical reality that it is often desirable to involve some teachers who may not fully meet the requirements of 3.2.3 but nonetheless meet a particular educational need in a course (e.g. involvement of experienced practitioners), provided their involvement is guided and overseen by staff who do meet the requirements of 3.2.3.

    The teaching qualifications, skills and experience needed in staff will vary according to their levels of responsibility, and a useful point of reference for this is the Australian University Teaching Criteria and Standards Framework.

    The Standards concerning the capability of teachers (including contemporary knowledge, continuing scholarship and relevant teaching skills) presuppose continuing professional development of teaching staff if a provider is to meet and continue to meet the Standards, although the Standards do not specify how this might be achieved.

    The intent of the Standards for learning resources and educational support (at Section 3.3) is to ensure that the learning resources for a course are specifically and directly relevant, up-to-date and accessible to students when needed, including via a learning management system if applicable. The Standards seek to preclude unexpected barriers to access to learning resources, including:

    • those resulting from significant charges for access to resources  that were not made known to students before they enrolled
    • mandatory use of uncommon or unduly expensive technology or platforms
    • requirements for impractically high internet speeds
    • limited physical access points.

    The Standards also intend to ensure that learning resources and access to them are consistent with the learning needs of students, irrespective of their mode of participation. This includes resources that are specific to a course of study as well as more general learning support (Standard 3.3.4) such as support for:

    • developing study skills
    • development of English language proficiency
    • international students who are unfamiliar with living in Australia.

    Risks to quality

    The focus of the Standards on staffing is to avoid students being taught by inexperienced and/or underqualified staff, particularly staff whose level of qualifications, teaching and professional/practical experience is lower than the level of course they are teaching (including research experience for research training if applicable to the provider). The Standards also seek to avoid an environment where academic leaders have insufficient academic skills and experience to provide the necessary scholarly leadership to credibly guide and oversee teaching and learning. This includes, for example, the leadership necessary to determine academic policies and standards for the provider overall, and to guide and supervise less experienced staff. In addition, the Standards seek to prevent erosion of the quality of teaching that is inevitable if individual staff do not undertake continuing professional development appropriate to their role.

    The Standards for learning resources seek to prevent:

    • poor quality resources (e.g. irrelevant, obsolete, non-authoritative or insufficiently rigorous material) being provided or used
    • non-timely provision, and/or
    • barriers to access (insufficient resources, complex learning systems, specialised technology requirements, ineffective outsourcing of provision or inappropriate provision such as relying on the resources of a community library).

    The Standards for learning resources also seek to provide more general academic support where needed for students to participate effectively in higher education at their chosen level of study, to prevent students from becoming at risk of reduced academic progress.

    What TEQSA will look for

    This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to staffing, learning resources and educational support.
     

    For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.
     

    For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.
     

    The evidence required for particular types of application is available from the application guides on the TEQSA website.
     

    Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

    Staffing

    TEQSA will want to be satisfied that the level and type (‘profile’) of staffing for all courses of study meet the requirements of the HES Framework in respect of the overall planned or current complement of staff and the capabilities of individual teachers.

    New applicants applying for registration for the first time will need to provide a workforce plan showing how they will systematically build the staff needed to support students to achieve the learning outcomes of the planned courses.

    The suitability of current teaching staff will be assessed in relation to their knowledge, teaching capability and qualifications (see Standard 3.2.3) as relevant to the particular course of study. TEQSA will need to be satisfied that teachers have knowledge of contemporary developments in the discipline or field they are teaching, and that they have skills in contemporary teaching methods appropriate to their role.

    The requirements of the Standards presuppose continuing professional development to maintain the currency and competence of teachers, e.g. through a relevant combination of continuing scholarship (of the field of education, specific discipline, and/or of teaching and learning), research or advanced practice. TEQSA will need to be satisfied that a provider’s staff are indeed maintaining their capabilities as required by the Standards. TEQSA will not seek to prescribe how such development occurs, but will require a provider to provide evidence that the development occurs and that it is fit for purpose and effective in meeting and continuing to meet the relevant Standards for teachers, both individually (Standard 3.2.3) and collectively (Standard 3.2.2).

    In relation to qualifications, staff who have significant teaching roles and/or responsibility for oversight and leadership of the course of study must have a qualification at least one level[2] higher than the level of course/qualification they are teaching, or have relevant equivalent experience[3]. Where a provider recognises equivalent experience in place of a higher qualification, TEQSA will want to be assured that this reflects the particular educational needs of the course of study (rather than simply a matter of convenience for the provider) that cannot reasonably be addressed in other ways, and that the process of recognition of equivalent experience is guided by a credible policy that is applied consistently.

    TEQSA will expect the staffing of a current or planned course of study to be determined by the learning outcomes of the course and analyses of the learning needs of students, including needs for access to staff outside of formal teaching.

    TEQSA will also seek evidence that the overall staffing of the provider includes a level of academic leadership that is consistent with the provider’s scale and level of educational offerings, and capable of developing and maintaining a higher education learning environment. Students are entitled to expect that their educational experiences are grounded in a strong foundation of academic leadership and communities of scholarship. In the case of a new applicant, this should be made evident through the workforce plan, but TEQSA also expects that overall academic leadership would need to be in place during the planning phases.

    TEQSA has found academic leadership to be a critical success factor, especially for providers applying to enter higher education for the first time.

    Learning resources and educational support

    In assessing the learning resources and educational support that is offered overall, TEQSA will be concerned with three broad dimensions:

    • quality
    • sufficiency
    • access.

    In relation to the quality of the resources, TEQSA will need to be satisfied that the resources are:

    • relevant to the expected learning outcomes
    • appropriate to the level of study
    • authoritative, and up to date.

    TEQSA may seek the views of experts in the relevant field of education.

    TEQSA will assess the adequacy of information resources overall as well as for each field of education offered (in the context of an application for registration) and the adequacy of information resources for each course (in the context of an application for course accreditation). This will include the availability and accessibility of full-text digital access for information resources listed (as required) on academic outlines, including book chapters, journal articles and conference papers, and to support scholarship and research in the field of education.

    TEQSA recognises that information resources are increasingly available online, and that the Standards do not explicitly require the provision of a physical library space with physical books.

    If a physical library is not provided, TEQSA will expect the provider to ensure that students can readily access all the materials they are referred to by their lecturers, including those online and in various textbooks. A provider may also reach agreement with another provider for students to access its library for supplementary resources. In such cases, the library resources must be readily accessible to the students and the provider must ensure that the available resources (either provided directly or through the arrangement with the provider) are capable of meeting student needs.

    Standard 3.2.1 requires in general that: ‘The staffing complement for each course of study is sufficient to meet the educational, academic support and administrative needs of student cohorts undertaking the course’.

    TEQSA will expect students to have access to appropriately qualified staff, such as a librarian, to help them locate the information resources they need. If not located onsite, these qualified staff members should be accessible online. This is necessary to support students in developing their capacity for independent learning and inquiry. Students should also be given training in locating information resources during their orientation program (Standard 1.3.1).

    In addition, Standard 2.1.1 requires that facilities are fit for purpose and accommodate the education activities of students and staff, and 2.1.3 requires: ‘The learning environment, whether physical, virtual or blended, and associated learning activities support academic interactions among students outside of formal teaching’. If a library space is not provided, in the case where students are taught at a campus TEQSA will expect to see some other form of open-access space where students can study and collaborate.

    TEQSA will also assess the adequacy of more general educational support provided to students who are at risk (or potentially at risk) of not making sufficient progress, such as support for language development and building of academic study skills (e.g. see Section 3.3). In so doing, TEQSA will have regard to the adequacy of educational facilities overall (see Sections 2.1 and 2.3) for the relevant student cohorts and their level and mode of participation.

    Evidence of processes to manage and review the provision of learning resources and how a provider ensures that they are appropriate may also be sought.

    Should a provider wish to outsource provision of learning resources, e.g. to another higher education provider, TEQSA will need to be satisfied that:

    • the arrangement is subject to a formal agreement
    • there are no unreasonable barriers to access
    • it is practicable for students (e.g. not involving unreasonable travel time).

    TEQSA will not accept a model in which the provider makes no provision for information resources itself and refers students to a public library, which is unlikely to provide full access to the scholarly resources required.


    [1] For the purposes of the HES Framework, ‘staff’ means those who undertake particular roles, irrespective of whether they are actually employees of the provider, e.g. may include volunteers.

    [2] For this purpose ‘level’ means a level of qualification in the Australian Qualifications Framework (AQF) or equivalent.

    [3] Academic, professional or practice-based.

    Resources and references

    Australian Qualifications Framework Council (2013), Australian Qualifications Framework Second Edition January 2013.

    Australian Library and Information Association website.

    The University of Western Australia, Murdoch University, Curtin University, Edith Cowan University and Notre Dame University, Australian University Teaching Criteria and Standards Framework.

    Council of Australian University Librarians (2016), Principles and Guidelines for Australian Higher Education Libraries 2016.

    Council of Australian University Librarians website.

    Quality Assurance Agency (March 2015), Subject Benchmark Statement: Librarianship, Information, Knowledge, Records and Archives Management.

    TEQSA (2016), Guidance Note on Determining Equivalence of Professional Experience and Academic Qualifications.

     

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au
     

    Version # Date Key changes
    1.0 19 August 2016 Made available as beta version for consultation. Replaces previous guidance notes on ‘Workforce Planning’ and ‘Information Resources’.
    1.1 1 March 2017 Additional CAUL resource added.
    1.2 8 March 2017 Updated to refer to the need for a workforce plan for prospective providers.
    1.3 22 November 2017 Clarification that students must have access to a qualified librarian, and addition to ‘What will TEQSA look for?’ text box.

     

     


     

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  • Guidance note: Scholarship

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    Providers should note that guidance notes are intended to provide guidance only. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time.

    What does scholarship encompass?

    In the context of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework), ‘scholarship’ refers to those activities concerned with gaining new or improved understanding, or appreciation and insights into a field of knowledge, or engaging with and keeping up to date with advances in the field.

    Engagement in scholarship can be considered:

    • across a provider (e.g. policy frameworks, resource allocation, institutional expectations, staff development), or
    • at the level of individual activity (e.g. part of an individual’s personal professional development, teaching, research or professional practice).

    Various aspects are relevant to higher education, but a key component is that scholarship:

    • advances knowledge or professional practice in a field, or
    • transmits advances through contemporary approaches to teaching and learning, or research and training.

    TEQSA acknowledges that notions of scholarship may vary within and amongst providers and that the mission and category of the provider may influence the type of scholarship practised. TEQSA also recognises the diverse strategies used to develop, support and sustain scholarship, both at the institutional level and for individual staff.

    TEQSA recognises there is no singular definition of scholarship and acknowledges that providers may utilise various approaches to organise the full range of their scholarly activities. However, TEQSA requires evidence of a systematic approach to organising scholarship irrespective of the type of scholarship practised (e.g. suitable, recognised and current approaches or models for arranging scholarly activity).

    What TEQSA will look for

    The HES Framework requires TEQSA to consider a provider’s engagement with scholarship at several levels. These include the following standards and criteria from the HES Framework:

    Part A: Standards for HE Providers Key considerations
    3.1.2:Course Design
    • Scholarship contributing to the design and delivery of particular courses of study

     

    3.2.3: Staffing  
    4.2.2 (if applicable): Research Training
    • Scholarship associated with research and research training
    Part B: Criteria for HE Providers Key considerations
    B1.1.2: Staff scholarly activity
    • Scholarship directly associated with informing teaching and learning, including disciplinary scholarship
    • Institutional encouragement and support for scholarship across all courses of study
    B1.2.6 and B.1.3.9: Systematic approach to scholarship  

    TEQSA will need to be satisfied that evidence of scholarship relates directly to approaches in teaching and learning in a field or advances in knowledge. To assess this, TEQSA may consider:

    • institutional policies and operations
    • institutional course design approval processes and evidence that course design has been informed by relevant scholarship
    • staffing policies that recognise and encourage scholarship (e.g. recruitment, promotion, professional development)
    • evidence that both staff with academic leadership and staff with course delivery responsibilities are involved in relevant, continuing scholarship consistent with the AQF level of the course(s)
    • processes to ensure students are referred to, and engage with, relevant scholarship throughout their course of study
    • resource allocation (e.g. journal access, scholarly library collections, conference attendance)
    • institutional activities (e.g. seminars, workshops)
    • requirements for the provider’s category and self-accrediting authority.

    In an environment of scholarly activity, TEQSA would expect a range of different forms of scholarship, such as:

    • peer reviewed scholarly output/publication/communication (e.g literature reviews, conference presentations, journal publications)
    • scholarly review, original research or teaching practice that collectively contribute to course development
    • synthesising and communicating advances in evidence-based practice (e.g. presentations/podcasts/feature articles on current knowledge, practice, or teaching and learning in a field)
    • teaching practice engaging the latest ideas, debates and issues (e.g. improved pedagogies, learning processes, curricula, academic policies and learning materials)
    • contributions to relevant professional bodies or communities of practice (e.g. development of new standards, knowledge resources, codes of practice)
    • active and ongoing involvement in relevant scholarly academic societies, editorial roles or peer review
    • undertaking higher level qualifications that lead to scholarly activity, in particular higher degrees by research
    • undertaking advanced specialised practice or scholarly secondments.

    Creative works as scholarly outputs require a different approach. To assess the extent to which performance or creation of creative works constitute scholarship (e.g. music, drama, art and design) TEQSA will need to be satisfied that:

    • scholarship informs individual teaching or supervision
    • scholarship participation informs teaching practice as required by the HES Framework. 

    Although performance or production can be evidence of scholarship, it is TEQSA’s view that not all performance or production may constitute scholarship. To meet the HES Framework requirements the provider would need to demonstrate how the creative work meets the criteria for scholarship listed above where relevant.

    Identified issues 

    Within the context of the HES Framework, TEQSA has identified a range of examples that do not represent sufficient evidence of scholarship. These include, but are not limited to:

    • personal or professional development activities that constitute lower-level training or are unrelated to the teaching role (e.g. undertaking a Moodle training session, attending an Emotional Intelligence training workshop, learning unrelated software, an unrelated research technique or taking a course in an unrelated field)
    • membership on one or more academic governance committees
    • dated or irrelevant scholarly activity (e.g. content or methods that are no longer employed in the field) 
    • unrelated research in disciplines/fields being taught (e.g. information systems teacher conducting research in art history) 
    • basic or routine practice that does not engage with advances in practice, or is unrelated to the discipline/field (e.g. an accountant preparing personal tax returns for individuals while teaching corporate finance or training in software use)
    • involvement in professional/community groups or activities unrelated to the content or teaching methods of the discipline/field being taught (e.g. an engineering lecturer attending a literary discussion group)
    • similar activities at a lower AQF level (e.g. teaching in a related field at a lower level)
    • attendance at conferences or membership of a professional body.  

    TEQSA recognises that scholarship can occur across disciplines in unrelated fields that inform and contribute to advances in knowledge and professional practice (e.g. a collaborative research project between arts and science on the impact of climate change). TEQSA acknowledges the benefits and value of multi-disciplinary scholarship.

    However, it will be necessary for a provider to demonstrate the link between scholarship in an apparently unrelated field/discipline and the scholarship informing teaching practice in the subject area being taught.

    TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its Guidance Notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au.

    Version # Date Key changes
    1.0 26 May 2014  
    2.0 19 August 2016 Updated for the HESF 2015 and made available as beta version for consultation.
    2.1 20 October 2016 Additional resource added.
    2.2 13 December 2016 Paragraph added relating to creative activity and scholarship.
    2.3 4 September 2017 Clarification to differentiate and define ‘scholarship’ and ‘scholarly activity’.
    2.4 4 December 2018 Amendment to the end of the section on 'What does scholarship encompass?' in relation to the Boyer Model of Scholarship.
    2.5 12 December 2018 Minor clarification added to the section on ‘The intent of the Standards’ on p.3 in relation to the intent of the criteria.
    3.0 4 May 2022 Major revision.

     

     

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