Scope and intent of the Domain

This Domain (Sections 5.1-5.4) of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) encompasses:

• whether the provider has a credible and effective process for internal approval of all courses of study that is applied consistently and involves competent academic oversight and scrutiny independent of those directly involved in the delivery of the courses of study (Section 5.1)
• the effectiveness of the policy framework and processes that are applied to maintain academic integrity throughout the provider’s academic activities (including arrangements with other parties) and to address and prevent lapses in academic integrity (Section 5.2)
• the mechanisms for regular review of the quality of higher education activities and how the findings of such reviews are used to bring about improvements (Section 5.3)
• how delivery arrangements with other parties are quality assured, including verification of the continuing compliance of those arrangements with the requirements of the HES Framework (Section 5.4).

Our commentary

5.1 Course Approval and Accreditation

TEQSA’s main focus will be on ensuring that the provider has an effective internal process for approval of all courses, which includes rigorous academic scrutiny through the institutional academic governance processes of the provider, independently of those involved directly in delivery of the course of study. All providers are expected to have such an approval process, whether they have self-accrediting authority or their courses are accredited by TEQSA. If we accredit a course of study, the point of departure will be the evidence of rigorous internal approval of the course carried out by the provider prior to making an application for course accreditation. Once we are satisfied that a provider’s approval process is capable and continues to be so, less detailed evidence about the approval process itself may be required for regulatory purposes. Any course of study submitted to us for approval must have been both considered and approved by the responsible internal academic governance body or bodies or it will not be accredited.

5.2 Academic and Research Integrity

TEQSA will need to be satisfied that there is an institutional policy framework to maintain and support academic integrity of students and staff that is backed by processes and practices that implement institutional policies effectively. Providers will need processes for detecting and addressing instances of plagiarism and other forms of ‘cheating’. Once a provider is operating, evidence of effectiveness will be provided in part by records of management of incidents as required by Paragraph 7.3.3c. 

Reference points

• Australian Government, Australian Code for the Responsible Conduct of Research (2018).
• Reports of studies on good practice commissioned by the Office for Learning and Teaching and the Australian Learning and Teaching Council (2011-2013).
• Tertiary Education Quality and Standards Agency, Academic Integrity Toolkit (2020).

5.3 Monitoring, Review and Improvement

This Section requires a provider to conduct periodic, comprehensive reviews of all courses (at least every seven years with evidence to be provided as part of the renewal of registration application to TEQSA), backed by more frequent monitoring of the day-to-day delivery of courses of study, for example, periodic reviews of units and annual review of student performance. We will expect to see that such reviews are conducted (or will be conducted in the case of a new provider or course of study) according to the requirements of the Standards as part of the provider’s normal operations, and that the findings of the reviews are evidently used to generate improvements. In demonstrating that it meets this Standard, a provider will need to demonstrate in particular that reviews of courses of study involve considered oversight by the institutional academic governance processes, external referencing (which can include moderation of assessment against other programs, benchmarking of student success and course design against programs at other providers) and feedback from students. 

5.4 Delivery with Other Parties

Where a provider delivers courses of study or parts of courses of study through arrangements with other parties, TEQSA will need to be satisfied that the provider remains accountable for such arrangements, that the delivery of the program is monitored and quality assured by the provider and that both the program delivery and the student experience with other parties comply with the requirements of the HES Framework. How this is demonstrated may vary with the circumstances. If in doubt, contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au. However, the starting point will be the terms and conditions of the contract between the registered provider and the third party, and how the registered provider reviews compliance with these.

Relevant guidance notes

The following guidance notes can be accessed at our Guidance notes page, or from the links below:

• Academic governance
• Academic and research integrity
• Academic monitoring, review and improvement
• Academic quality assurance
• Corporate governance
• Delivery with other parties
• Nested courses
• Research and research training
• Scholarship
• Technology-enhanced learning
• Transnational higher education
• Work-integrated learning

Scope and intent of the Domain

This Domain (Sections 7.1-7.3) of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) encompasses:

• whether the providers' representations (whether directly or through other parties) about themselves and the course(s) of study they offer are accurate, ethical and not misleading in their claims (Section 7.1)
• whether there is sufficient publicly available information to assist students in making informed choices about selecting a course of study, to enable effective and informed participation in a chosen course of study and to resolve grievances if necessary, including the particular needs of international students studying in Australia (Section 7.2)
• the existence of a readily accessible public description of the provider and its operations
• the requirement that the provider’s information management system meets certain critical requirements concerning content, security and integrity (Section 7.3).

Our commentary

7.1 Representation

TEQSA’s main interest will be in the materials that the provider uses to represent itself and its offerings, whether to particular students or more generally. This can include marketing materials, claims about career outcomes arising from courses of study and the like. Where a provider is represented by agents, we will seek evidence of a formal contractual engagement with the agent(s) that is consistent with the requirements of the Standard, that agents are correctly informed about the provider’s operations and offerings and that the performance of agents is monitored, including that corrective action is taken if necessary. It is expected that much of the evidence required in relation to representation will already be in the public domain (e.g. websites, brochures, prospectuses, advertisements etc.) and that it will be easy for providers to direct us to that material (some materials may be equally applicable to other Sections such as 7.2 and 7.3). We will need to be satisfied that the provider’s representations are accurate, ethical and not misleading.

In relation to Standard 7.1.4, a short narrative about the provider’s use of agents accompanied by examples of existing contractual arrangements, the resources provided to agents and an outline of monitoring arrangements and any corrective actions undertaken could illustrate that this Standard is met, where required. The Standards also call for providers to have controls in place over the way its courses are represented to prospective and current students by any third party, including through third party websites.

7.2 Information for Prospective and Current Students

Standards 7.2.1 and 7.2.2 require the public disclosure of a range of information, aimed largely at informed choices and participation by students (including international students if applicable). Information about the design and structure of courses, factors taken into account in selection (such as the use of ATAR and other requirements), all obligations and liabilities incurred by students (such as fees and charges and HELP liabilities), and the student support and facilities being made available, must be disclosed transparently. Students should be able to readily access all information needed for them to estimate realistic prospects for admission to each course. All information relating to professional accreditation of the course must be disclosed, as discussed in relation to Section 1.1 and Standard 3.1.5.

TEQSA will need to be satisfied that the information required is indeed publicly available, accessible (including to individuals with special needs) and accurate. While Standard 7.3.1 requires a ‘repository of publicly-available current information about the higher education provider’, we do not require the creation of a dedicated repository that is separate from a provider’s existing sources of information, nor do we seek to prescribe the format of its presentation. For example, a provider may for operational reasons, choose to present its information in groupings or blocks of data that are different from the groupings specified by the Standard, and in various sections of its website. This is not of concern, provided that the information requirements of the Standard are met (providers should note that Standards 7.3.1 and 7.3.2 impose particular requirements on the content of some information required by Section 7.2).

In relation to Standard 7.2.3, where applicable, we will expect a provider to be able to describe, and illustrate by example, the mechanisms that are in place to monitor achievement of statutory obligations in relation to the Education Services for Overseas Students Act 2000 and the National Code of Practice for Providers of Education and Training to Overseas Students 2018 in relation to international students.

In relation to Standard 7.2.4, we will expect to see that any formal offer made to students contains warnings of potential changes to fees and charges or other known changes expected in an intended course of study.

Information in the public domain is subject to monitoring at any time. This may mean that a provider will not always be required to submit evidence in relation to Section 7.2 in submissions for regulatory purposes. On the other hand, monitoring of a provider’s public information may raise concerns that lead to a request for further information/clarification outside of the provider’s normal regulatory cycle.

7.3 Information Management

Standard 7.3.1 contains a number of specific requirements for publicly available information. As mentioned in relation to Section 7.2, TEQSA does not seek to specify the form of presentation of this information, however it does expect the requirements of Standard 7.3.1 to be readily accessible, ideally from a single starting point. There could be, for example, a link from a provider’s website home page to another page that will in turn link to all of the types of information listed in 7.3.1 (a to m). 

The information to be made available about the provider’s financial standing is specified in a separate Guidance note and is designed to give prospective students some assurance that the provider is a going concern. This information is separate to what we require in order to assess the financial risk of a provider, either as part of the annual risk assessment or as part of the assessment for registration, re-registration, course accreditation or re-accreditation. 

Information about enrolment numbers (7.3.1i) in the list of a provider’s course(s) should give prospective students an indication of the scale of the provider and learning environment. The information should be based on recent actual enrolments in the case of an existing course, or realistic projections in the case of a new course. A range could be used (e.g. ‘we expect to enrol between x and y students’). In the case of nested courses, the numbers should be for the whole course. 

As long as the requirements of Standard 7.3.2 are met in achieving Section 7.2, we will not require further reiteration in relation to 7.3.2. For Paragraph 7.3.3a, we will require a description and, possibly, a demonstration of the capability of the provider’s information system to meet the requirements of this Standard. Achievement of Paragraph 7.3.3b will require identification of the policies, processes and practices in sufficient detail for us to be satisfied that this Standard is met and that predictable risks are being mitigated as far as is reasonably possible for the nature and scale of the provider’s operations - including the onus on the provider to issue qualifications legitimately (as required by Paragraph 6.2.1h). In relation to Standard 7.3.3d, we will require a description of the systems, processes and reporting that support achievement of this Standard (and support the corporate accountability of the governing body in this respect [Standard 6.1.1]). This may be achieved by reference to mechanisms already described in relation to other Standards (e.g. Institutional Quality Assurance or Governance and Accountability) and, if so, reiteration of the detail for the purpose of demonstrating compliance with this Standard will not be required.

Once we are satisfied that a provider has demonstrated that its systems meet, and are likely to continue to meet, Standard 7.3.3 (a-c), we may require only limited evidence of continuing compliance with these Standards. However, will always have an interest in reviewing the management of complaints and misconduct (Paragraph 7.3.3c), irrespective of the capability of a provider’s information management systems. 

Reference points

• Australian Government, Australian Consumer Laws (Schedule 2 of the Competition and Consumer Act 2010) and the Trade Practices Act 1974
• Australian Government, National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018
• Australian Government, Privacy Act (1988) and the Australian Privacy Principles
• Australian Government (July 2009), Using Education Agents
• British Council, Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants (The London Statement) (2012) released by the British Council
• International Education Association of Australia, Education Agent Code of Ethics (2016)
• Web Content Accessibility Guidelines Working Group (WCAG WG), Web Content Accessibility Guidelines Version 2.0

Relevant guidance notes

The following guidance notes can be accessed at our Guidance notes page, or from the links below:

• Academic governance
• Academic and research integrity
• Academic monitoring, review and improvement
• Academic quality assurance
• Course design, learning outcomes and assessment
• Corporate governance
• Diversity and equity
• Financial assessment
• Financial standing
• Research and research training
• Technology-enhanced learning
• Third-party arrangements

Scope and intent of the Domain

This Domain (Sections 1.1-1.5) of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) encompasses:

• the basis for admission of students to a course of study, including requirements for adequate academic preparation for the course and formal explicit contractual arrangements between the provider and students
• assessment of credit granted for prior learning is consistent with the credit and recognition of prior learning policy in the Australian Qualifications Framework (AQF)
• assurance that any credit granted for prior learning does not disadvantage the student concerned or compromise the integrity of the course of study
• orientation to a course of study, support for transition to a course of study, early feedback on student performance, detection and support for students at risk of unsatisfactory progress and monitoring of success rates at cohort level
• equivalence of opportunities for success irrespective of a student’s background or mode of participation
• specification, assessment, achievement and external referencing of expected learning outcomes
• legitimate issuing and certification of qualifications. 

Our commentary

1.1 Admission

TEQSA will need to be satisfied that students who are admitted are equipped to succeed in their chosen course of study (e.g. level of academic preparation, learning skills, proficiency in English) and that ill-prepared students are not knowingly admitted. Factors taken into account in selection (such as prior qualifications or the use of the Australian Tertiary Admission Rank [ATAR]), and all information needed by students before applying for a course must be disclosed transparently (see also Domain 7 – Representation, Information and Information Management). Students must be able to readily access all information needed for them to estimate realistic prospects for admission to each course. 

Prospective students must be made aware of any inherent requirements for undertaking a course, or parts of a course, that may affect those students in special circumstances or with special needs (such as a particular type of practicum), especially where a course of study leads to a qualification that may lead to registration as a professional practitioner by a registering authority. On a related topic, where a course must be accredited by a professional body as a requirement of professional registration of graduates (particularly where registration is required by law), this accreditation must be obtained and sustained, as required by Standard 3.1.5. Information about the current accreditation status must be made available to prospective and current students, as required by Section 7.2.

Where individual students or cohorts are initially at some known risk of not succeeding (e.g. those engaged in an initiative that is targeting an educationally disadvantaged group of students), such risks need to be not only identified but also managed, for example, by targeted support. Relevant evidence at the provider level will include organisational policies and procedures, while at the course level, specific selection criteria should be included in course documentation.

We will also need to be satisfied that the provider’s arrangements with students are based on adequate disclosure and informed choice, particularly on key matters such as fees and charges, specific obligations placed on students, arrangements and implications for withdrawal from enrolment and particular obligations for international students where applicable. Providers seeking help in assessing overseas qualifications may refer to the Australian Government’s Country Education Profiles, available on a subscription basis.

Reference points

• Australian Council of Graduate Research Inc., Australian Graduate Research Good Practice Principles.
• Australian Government, Country Education Profiles.
• Australian Government, National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018.

1.2 Credit and Recognition of Prior Learning

TEQSA supports granting of credit for prior learning, and will need to be satisfied that this is guided by institutionally approved policies and evidence-based procedures that are applied transparently and consistently, with explicit (written) outcomes for credit decisions provided to students. The relevant policy framework is required by Section 7.2. We expect providers to take a positive attitude to the award of credit wherever practicable, but we must also be satisfied that the granting of credit will not disadvantage students (e.g. by admitting students who are insufficiently prepared to undertake the level of higher education required) or diminish the integrity of the qualification awarded. This could occur, for example, where the award of credit would result in a disproportionate amount of the program representing levels of education/experience below that of the qualification offered, such as a Masters degree program comprising, in effect, predominantly undergraduate content.

Reference point

• Australian Qualifications Framework Council, Australian Qualifications Framework Pathways Policy.

1.3 Orientation and Progression

TEQSA expects a provider to be able to demonstrate that students are not only assisted in their transition into their course of study but also that the arrangements for transition are sensitive to the needs of particular cohorts of students, including:

• students enrolled in different modes of participation (for example, online-only)
• students with special needs
• international students, where applicable.

Early assessment of progress, early detection of students at risk of poor progress and targeted support programs are given high priority by the Standards for all courses of study (this includes research training where offered).

The Standards also require a registered provider to be able to demonstrate and internally report rates of retention, progression and completion for all cohorts of students over time (as a basis for detailed analysis and improvement, as also required in Domain 5) and we will expect to see reports containing the relevant data and analyses (typically in relation to Domain 5, in the case of registered providers) including analysis of the factors that might be driving any variations. New applicants should be able to demonstrate that they have made provision for such monitoring and reporting.

Reference points

• Australian Council of Graduate Research Inc., Australian Graduate Research Good Practice Principles.
• Australian Government, National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018.

1.4 Learning Outcomes and Assessment

The Standards in this Section present detailed requirements for the specification and assessment of learning outcomes and include a requirement for credible external referencing of the outcomes against national and international comparators, for example, by comparing the provider’s learning outcomes and methods of assessment with those of comparable programs at a reputable Australian higher education provider and (for learning outcomes) an international higher education provider. TEQSA will need to be satisfied that the processes of course accreditation employed by self-accrediting providers meet these Standards and, in the case of non-self-accrediting providers, the providers will need to demonstrate to our satisfaction that the requirements of the Standards have been met for each course. In practice, learning outcomes and methods of assessment are likely to be considered in conjunction with the overall design of the course of study (see Domain 3 [and Domain 4 if research training is undertaken]).

In particular, we will seek to confirm that the specified learning outcomes are consistent with the Australian Qualifications Framework (AQF) level of the higher education qualification offered and that student achievement of the course learning outcomes is credibly assessed, whether through:

• aggregations of assessments at unit level
• specific assessments of general course learning outcomes such as a capstone unit
• a combination of both.

To demonstrate that the course is designed in a way that these Standards are met will require at a minimum, some form of mapping of where expected course learning outcomes are taught, practised and assessed and how they are aligned with unit learning outcomes and assessment. We may engage external discipline experts to assist in its deliberations about learning outcomes and assessment and may also have regard to an accreditation of the course of study by a professional body where applicable. The expected learning outcomes for research training (1.4.5–1.4.7) only apply where research training is offered through higher degrees by research.

Reference points

• Australian Council of Graduate Research Inc., Australian Graduate Research Good Practice Principles.
• Australian Qualifications Framework Council, Australian Qualifications Framework Second Edition January 2013.
• Learning outcomes statements developed for the field of education or discipline by discipline communities or professional bodies.
• The requirements for professional accreditation of the course of study and registration of graduates where applicable.

1.5 Qualifications and Certification

The Standards in this Section provide detailed specifications for the issuance of qualifications, the way they are certified and secured and the records of attainment that are available to students. The issuance of qualifications links to the corporate responsibility of the provider to issue qualifications legitimately (see Paragraph 6.2.1h). TEQSA has a particular interest in the onus the Standards in this Section place on the provider to ensure that any qualification awarded within the Australian Qualification Framework (AQF) is positioned at a level that corresponds with the level of the AQF it purports to meet.

Once a provider has demonstrated that it is able to manage the issue of qualifications competently and legitimately, we may give less emphasis to the administrative process but will remain concerned that course(s) of study are appropriate to the level of qualification issued (see also 1.4.1). In the case of self-accrediting providers, we will need to be satisfied about the adequacy of internal approval processes to meet this requirement, and may test selected course documentation in a sample of courses.

Providers should take steps to ensure the security of digital records and certification of qualifications.

Reference points

• Australian Government (November 2013), Guidelines for the Presentation of the Australian Higher Education Graduation Statement.

Relevant guidance notes

The following guidance notes can be accessed at our Guidance notes page, or from the links below:

• Academic monitoring, review and improvement
• Course design, learning outcomes and assessment
• Diversity and equity
• Nested courses
• Scholarship
• Technology-enhanced learning
• Work-integrated learning

Scope and intent of the Domain

This Domain (Sections 2.1-2.4) of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) encompasses:

• the nature, access to and fitness for purpose of the learning environment under the control of the provider (without presupposing any particular model of participation or delivery), diversity of participation and the wellbeing of staff and students
• access to effective mechanisms to address students’ grievances should they arise.

Much of the background material to demonstrate that these Standards are met must be publicly accessible (see Domain 7).

Our commentary

2.1 Facilities and Infrastructure

This Section focuses on a provider demonstrating that there are sufficient facilities and infrastructure for delivery of a provider’s course(s) of study and that they are appropriate for their intended educational purpose. This includes necessary access to secured ICT facilities and systems. Specific facilities and resources for particular course(s) of study are covered at Domain 3 (e.g. Section 3.3).

These Standards are intended to apply to any mode of delivery and participation, rather than presuppose any particular model. The onus is on the provider to demonstrate to TEQSA that its facilities and infrastructure support students to achieve the expected learning outcomes. Irrespective of the chosen mode of delivery, the Standards require a provider to offer opportunities for students (including international students) to interact outside of formal teaching, for example, group work, team building, informal learning. This does not mandate physical spaces; interaction via ICT may be suitable in various settings.

2.2 Diversity and Equity

This Section focuses primarily on the creation of equivalent opportunities for academic success regardless of students’ backgrounds, within a relevant policy framework, and within the context of the provider’s mission. Providers may wish to link this requirement to their admission requirements (see Section 1.1) and transition support arrangements (see Section 1.3). Providers should note that the Standards require providers to monitor the participation and success of any identified groups (such as an identified equity group) and use that information to improve academic and support strategies for such groups.

The requirement to give ‘specific consideration to the recruitment, admission, participation and completion of Aboriginal and Torres Strait Islander peoples’ means that this particular group must be specifically referred to in the policy and monitoring frameworks.

Reference points

• Australian Disability Clearinghouse on Education and Training (1998), Students with Disabilities: Code of Practice for Australian Tertiary Institutions.
• Australian Government, Disability Standards for Education 2005.
• Universities Australia (October 2011), National Best Practice Framework for Indigenous Cultural Competency in Australian Universities.

2.3 Wellbeing and Safety

This Section encompasses a series of general and specific facets of a provider’s operations that are aimed at the promotion of safety and wellbeing. TEQSA will expect providers to tailor their response to these Standards according to the scale, scope and nature of their circumstances and offerings. In the case of online or blended learning, the requirement for a safe environment also applies to security of internet communications and to policies and procedures related to online harassment.

2.4 Student Grievances and Complaints

This Section seeks to ensure that students have access to mechanisms that resolve grievances effectively, at reasonable cost and with appropriate protection for complainants from breach of confidentiality or reprisal. This should be formulated within the policy framework, and students should be able to easily access a facility to lodge a complaint. Complaints-handling mechanisms are required to be publicly documented (see Domain 7). These Standards distinguish formal complaints from informal grievances, and records of the incidents and resolution of formal requirements must be kept, including time taken to reach a resolution (see institutional accountability at 6.2.1.j). While the Standards require policies and procedures to provide for students to access independent professional advice, TEQSA does not take this to require providing for students to access legal advice.

As part of its regulation of Australia’s higher education sector, we monitor the compliance of higher education providers with the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) and the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework). As stated on our Complaints page, we have a defined approach for handling complaints. We will pursue any reliable information that indicates that a provider might not meet any of the Standards and will maintain confidentiality in regards to the informant. We receive complaints on a range of matters relating to providers, including the provider’s compliance with HES Framework and TEQSA Act, and in relation to possible false or misleading statements about a provider’s registration and accreditation status. 

TEQSA is not empowered to intervene in disputes about marks for an individual student’s assessment, but will expect the provider’s policy and procedures to be followed where a student lodges a complaint or appeal. These policies and procedures should explicitly make provision for review by an appropriate independent third party if internal processes fail to resolve any grievance, and should specify indicative time frames for resolution of complaints.

Third party complaint-handling bodies for all students at public providers and international students at private providers are outlined on our Complaints page. Domestic students at private providers can contact the Australian Competition and Consumer Commission (ACCC). The Overseas Students Ombudsman (OSO) investigates complaints from international students on student visas about private providers that relate to administrative decisions made by the provider, but not about broader educational quality issues. All students at public higher education providers have an avenue of appeal to the relevant Commonwealth, State or Territory Ombudsman, who can also investigate administrative decisions. 

Providers are required to make available to their students specific avenues of appeal to independent third parties for matters not within the jurisdiction of the ACCC or an ombudsman.

We may seek further information from a provider if we have reason to believe that a complaint or a pattern of complaints indicates that they might not be meeting one or more of the Standards.

Reference points

• Australian Council of Graduate Research Inc., Australian Graduate Research Good Practice Principles.
• Australian Government, National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018, Part B, Standard 10.
• Standards Australia (2014), Australian Standard AS ISO 10002-2014, Guidelines for complaint management in organisations.

Relevant guidance notes

The following guidance notes can be accessed at our Guidance notes page, or from the links below:

• Corporate governance
• Diversity and equity
• Nested courses
• Technology-enhanced learning
• Wellbeing and safety
• Work-integrated learning

TEQSA’s regulatory policies inform the way we undertake our regulatory work. Publication of these policies supports transparency, and helps higher education providers and the public better understand how we approach our responsibilities as Australia’s independent national quality assurance and regulatory agency for higher education.

View our policies below:

• Complaints about providers policy
• Complaints about TEQSA policy
• Core Plus model for regulatory assessments policy
• Course accreditation and re-accreditation policy (registered providers) - currently being updated
• Extensions to the period of provider registration or course accreditation
• Initial provider registrations policy
• Lawful disruption of access to online services policy
• Material change notification policy
• Procedures for determining breaches of the Code of Conduct and for determining sanction
• Public statements on TEQSA’s regulatory decisions and processes
• TEQSA's approach to changes of control or ownership of a higher education provider

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