• Guide for CRICOS providers undertaking an independent external audit

    Body

    Purpose

    This guide sets out TEQSA’s expectations for the independent external audit (external audit) process for providers with self-accrediting authority (SAA) applying to renew their CRICOS registration.

    Standard 11.4 of the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) requires providers with SAA to undertake an external audit no more than 18 months prior to applying to renew their CRICOS registration. The purpose of this guide is to support providers in meeting this requirement, provide advice on best practice for this process, and highlight commons issues TEQSA has observed in this area.

    External audit report

    The results of the external audit should be outlined in a report (audit report) that includes the findings, conclusions, and recommendations of the auditors. The audit report informs TEQSA’s assessment of the application for re-registration.

    The report should:

    • outline the scope of the audit, specifying what the audit will include and exclude
    • outline the methodologies of the audit (such as policies and internal reviews, interviews of staff, verifying student files) and provide a rationale explaining why the methodology is fit-for-purpose
    • identify the policies, procedures and processes used by the provider to manage compliance with the Education Services for Overseas Students Act 2000 (ESOS Act) and National Code
    • assess the provider’s implementation of its policies, procedures, and processes against the requirements of the ESOS Act and National Code
    • detail areas of non-compliance, risks of non-compliance, and the risks that arise from these areas of non-compliance.

    When applying for renewal of CRICOS registration, providers should include an action plan, detailing the actions required to address any areas of non-compliance identified by the external audit, who is responsible for these actions and when they will be completed.

    TEQSA recognises that providers may not always have completed all elements of their action plan prior to applying to TEQSA for re-registration. However, TEQSA expects providers to submit evidence of their capacity, resources, and approach to implementing the action plan within a reasonable time frame.

    The audit report also offers an opportunity for providers to gain a better understanding of their regulatory obligations and to improve their internal quality assurance processes. Furthermore, the audit report and the provider’s response to the findings in the report should enhance the quality of education and overall experience for overseas students at that institution.

    Identified issues

    In the past, not all audit reports submitted to TEQSA have provided us with sufficient clarity to determine whether a provider is compliant with the requirements of the National Code. This can result from deficiencies in the external audit process or the report itself where:

    • the scope of the external audit is not clearly outlined or is not sufficiently broad to demonstrate compliance with all requirements of the National Code
    • the methodology of the external audit is not clearly explained to show how findings were made
    • findings of compliance are made without reference to evidence
    • findings of compliance are made without explaining how the evidence demonstrates compliance
    • findings of compliance are made on the basis that a policy or procedure exists, without assessing whether it is fit-for-purpose and meets the requirements of all applicable National Code Standards
    • responsibilities for key remedial actions are not clearly specified.

    An audit report with one or more of these issues may result in TEQSA being unable to be satisfied that all standards have been met. In these circumstances TEQSA will request further evidence from the provider.

    What TEQSA will look for

    TEQSA’s ability to efficiently assess a provider’s application for renewal of CRICOS registration is greatly assisted by a high-quality audit report. A high-quality report will include the following key information:

    • the policies, procedures, processes and supporting documentation that the auditor has considered
    • the basis for which the policies, procedures, processes and supporting documentation were selected as representative of the state of compliance with each Standard
    • the types of evidence, including samples, assessed
    • the findings of non-compliance or risks of non-compliance and how the provider’s action plan will fully address these risks.

    When reviewing an audit report, TEQSA assesses the provider’s compliance with each of the 11 Standards of the National Code. The table at Figure 1 outlines, for each of the Standards, the key considerations and evidence that TEQSA recommends should be considered by the auditor to inform their assessment.

    TEQSA considers Standards 2, 3, 4, 6, and 8 as critical to ensuring the quality of education delivered to overseas students. As such, TEQSA recommends that the external audit closely review these Standards and their associated risks to ensure each is fully satisfied.

    TEQSA welcomes the diversity of educational delivery across the sector and recognises that the requirements of the ESOS Act and National Code can be met in different ways according to the circumstances of the provider. TEQSA’s approach is to ensure that the requirements of the ESOS Act and National Code are met, not to prescribe how they are met. If you are preparing an application for re-registration and are unsure about the forms of evidence to include, please contact the ESOS/CRICOS team at cricos@teqsa.gov.au.

    Figure 1 – Key considerations and evidence for external audit

    Key considerations

    Key evidence

    Standard 1

    Marketing and recruitment policies, procedures, and processes that ensure the accuracy of:

    • recruitment and marketing communications including social media,
    • information about onshore third-party providers
    • international student transfers
    • the publishing requirements for CRICOS registered name and registration number.

    Marketing materials, including:

    • website links
    • course guides
    • promotional flyers
    • campus specific prospectuses
    • social media sites including Facebook, Instagram, You Tube and LinkedIn
    • onshore third-party provider/s materials.

    Standard 2

    Information about:

    • admissions requirements
    • enrolment deferral, suspension, and cancellation
    • refunds
    • credit transfer, advanced standing, and articulation arrangements
    • Recognition of Prior Learning (RPL)
    • records management
    • work-integrated learning component, if applicable
    • welfare arrangements for younger overseas students, if applicable.

    Additional supporting documentation may include:

    • application forms
    • information for tuition fees and non-tuition fee charges
    • processes for recording course credit on PRISMS and issuing CoEs with reduced course duration.

    Marketing materials, including:

    • course-specific brochures
    • international student handbooks
    • course information on the provider’s website.

    Sample of a valid number of student files to assess the consistent application of guidelines for:

    • admissions, including English language pre-requisites
    • credit transfer and RPL
    • cohort tracking of student outcomes
    • evidence of credit transfer and/or RPL precedent registers or database.

     

    Standard 3

    Documents such as:

    • current letter of offer template
    • policy and procedure relating to offer acceptance for under 18 students, if applicable
    • refund policy
    • complaints and appeals policy.

    Sample of a valid number of student files, including under 18s if applicable, to assess:

    • the letters contain the requisite information
    • refund policy matches conditions in letter of offer and reflect ESOS Act student and provider default provisions

    Standard 4

    Documents that demonstrate compliance with the agent recruitment and management process, including:

    • agent recruitment and management policy
    • agent agreement template
    • agent application forms,
    • training and induction
    • agent updates and meeting notes
    • reports on performance indicators, such as enrolled students and success
    • reports on corrective actions
    • Board and Committee minutes and relevant agenda items on agent performance
    • agent list on the provider’s webpage and PRISMS agent list.
    • Sample recruitment applications and appointments
    • Sample agent periodical review reports – including evidence that the provider took corrective action and/or terminated
    • reports to Boards and Committees on agent management
    • sample PRISMS reports with agent performance data, including the number and proportion of visa refusals per agent.

    Standard 5

    Policies, procedures, and processes relating to under 18 student admissions, provider transfers, managing welfare arrangements for younger overseas students, working with children checks and/or other regulatory requirements relating to child welfare and protection:

    • homestay agreements, policies, and processes for selecting, screening, and monitoring
    • communication materials and resources
    • age-appropriate orientation
    • critical incident policy and procedures; provisions specific to under 18 students.

    Sample of a valid number of under 18 student files:

    • letter of offer
    • parent or guardian consent
    • Confirmation of Appropriate Accommodation and Welfare (CAAW) arrangements
    • evidence that the Working with Children legislative requirements were met by provider staff, homestay hosts, as well as continued monitoring by the homestay provider and provider
    • evidence of six-monthly reviews of homestay arrangements and follow up action if issues have been identified
    • critical incident reports and register.

    Standard 6

    Policy, procedures, processes, and information relating to student academic and non-academic support, managing student critical incidents and emergencies, ESOS training:

    • orientation program, including slides, PowerPoint or Word document
    • student handbooks and website information relating to pre-arrival information, health and well-being, counselling services, academic support, advocacy, complaints, facilities, accommodation, legal services, course progress requirements and international students’ study expectations, adjusting to living in Australia, safety, working in Australia and employment rights and emergency contact details for assistance
    • critical incident policy and procedure
    • HR recruitment or training policies, ESOS training and/or induction manuals and examples of training undertaken.
    • internal reviews of student support services; uptake, experience
    • critical incident reports and register
    • samples of position descriptions or induction or training.

     

     

    Standard 7

    Policy, procedures, and processes for overseas students transferring to and from the provider (including for under 18 students):

    • international student transfer policy and procedure
    • release letter templates, both for granting, refusing, and accepting a release
    • process for complaints and appeals when a student is not granted a letter of release.
    • Sample of a valid number of student files to verify application of policy and procedure
    • PRISMS report on students who have transferred between providers.

    Standard 8

    Policy, procedures, and processes for course progression and monitoring academic progress and attendance, if applicable, managing students at risk, course rules and enrolment period extensions:

    • course progression policy and procedure
    • monitoring attendance policy and procedure
    • processes to extend course duration,
    • letter templates and examples, of warning/show cause letters for unsatisfactory course progress and attendance, if applicable.
    • Sample a valid number of student files to demonstrate course progression and attendance monitoring policy and procedures and the application of the CoE extension process
    • Course progress review meeting minutes or committee meeting agendas and minutes
    • PRISMS Student Course Variation (SCV) reports.

    Standard 9

    Policy, procedures and processes for deferrals, leave of absence, or provider-initiated suspensions and cancellations:

    • change of enrolment policies and procedures
    • letter templates and examples of correspondence
    • process for reporting a SCV change to PRISMS.
    • Sample a valid number of student files for students relating to deferrals and leave of absence, or provider-initiated suspension or cancellation.
    • PRISMS report on students who have deferred, been suspended, or had their enrolments cancelled
    • PRISMS Student Course Variation (SCV) reports.

    Standard 10

    Policy, procedures and processes for complaints and appeals

    • complaints and appeals policy and procedure
    • information on how to lodge a complaint, as well as appeal avenues, both internal and external and links to the relevant policy and procedures
    • relevant committee meeting agendas and reports on complaints and/or appeals
    • letter templates and examples of correspondence used to advise students of outcomes of complaints and appeals.
    • Sample valid number of student files involved in a complaint, internal and external appeal.
    • Complaints and appeals register that record outcomes.

    Standard 11

    Policy and procedures to govern course design and delivery in alignment with requirements relating to third-party provider arrangements (TPA), mode of study, including limitations on online and work-based learning, course duration, full-time study load and the management of student capacity:

    • TPA service agreements
    • course design and delivery guidelines
    • Academic Board Committee agendas and minutes for consistent delivery of accredited courses by third-party providers including the provision of suitable resources and facilities
    • process for assessing and monitoring the maximum number of overseas students at each location.
    • reports on periodic internal reviews of third-party providers.

    Document history

    Version #

    Date

    Key changes

    1.0

    		 14 October 2022

     
    Stakeholder
    Publication type

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  • TEQSA Conference 2022

    The Sixth Annual TEQSA Conference was held on 23–24 November 2022 at the Sofitel Melbourne on Collins and online.

    The theme was Fit for the Future: Leadership, Quality, Integrity.

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    Videos of the sessions are available on our YouTube channel.

    Conference presentation slides

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    The agency implemented the security enhancements in light of the heightened threat environment globally, and in response to specific advice received from the Australian Cyber Security Centre about data breaches. 

    This means next time you need to access the provider portal, you will need to send an email to crm@teqsa.gov.au requesting access.

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  • Sector update: Maintaining up to date academic integrity policies and procedures

    TEQSA wishes to remind providers of the importance of maintaining clear and contemporary academic integrity policies and procedures. Academic integrity is fundamental to the reputation and credibility of Australia’s higher education sector. Providers’ policy frameworks should highlight their commitment to academic integrity and their expectation that all staff and students uphold, and act with, academic integrity.

    Key points

    Academic misconduct generally refers to a breach of academic integrity through acts such as cheating, plagiarism, and fabrication or falsification of data. The Higher Education Standards Framework (Threshold Standards) 2021 Part A, Section 5.2 sets out four broad requirements regarding academic and research integrity, which state that a provider must:

    • have policies that promote and uphold academic and research integrity and policies and procedures that address allegations of misconduct
    • take action to mitigate foreseeable risks to academic and research integrity
    • provide students and staff with guidance and training on what constitutes academic or research misconduct and the development of good practices in maintaining academic and research integrity
    • ensure that academic and research integrity are maintained in arrangements with any other party involved in the provision of higher education.

    To ensure appropriate action can be taken where breaches of academic integrity are identified, institutional policies and procedures need to reflect the evolving risks to academic integrity. Consideration of emerging forms of academic misconduct, such as file sharing and the use of artificial intelligence writing tools, will support institutions and staff to uphold the integrity of their awards.

    Providers

    Providers should regularly review and update their academic integrity policies and procedures to ensure they address new and emerging forms of academic misconduct. In 2022, TEQSA reviewed all providers’ policies and frameworks and identified that:

    • Most policies include clear definitions of academic integrity breaches such plagiarism, cheating, falsification of information, collusion, third-party involvement and reusing one’s own work without appropriate acknowledgement
    • Many policies made explicit mention of commercial academic or contract cheating (understood as paying a third party to complete an assessment) as a breach of academic integrity
    • Only a small number of providers include clear definitions of how use of technology could constitute contemporary forms of cheating such as:
      • file sharing as a form of academic misconduct, where exam questions and assignments are exchanged internally or uploaded or downloaded through a third-party platform
      • artificial intelligence (AI) software or paraphrasing tools as a form of contract cheating, where substantial parts of exam questions and assignments are written by text generating software.

    Practical ways institutions can facilitate an ongoing culture of academic integrity within their staff and student communities include:

    • providing all students with guidance on what constitutes academic misconduct when they commence their study and ensuring that emerging threats to integrity are clearly explained
    • reinforcing messages about upholding academic integrity throughout the student’s study journey
    • considering, and clearly articulating, the acceptable and prohibited uses of emerging practices and technologies such as file sharing and AI writing tools
    • engaging students in regular and genuine conversations about what it means to act ethically and with integrity
    • recognising that staff, like students, come from diverse background and should receive clear information about the institution’s policies, procedures and reporting obligations.  

    Good practice

    A strong policy and procedure framework and ongoing commitment to a culture of academic integrity is the basis for consistent decision making. TEQSA has developed a variety of good practice resources to support institutions to uphold academic integrity:

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    TEQSA released a draft version of this guidance note in July 2022 for consultation, and the published version incorporates feedback from the sector.

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  • Chief Commissioner outlines academic integrity risks in 2023

    TEQSA Chief Commissioner Professor Peter Coaldrake AO has written to all registered higher education providers about academic integrity risks facing the sector in 2023.

    In addition to the ongoing threat posed by commercial academic cheating services, Professor Coaldrake reminded Australia’s higher education sector that it needs to be proactive in responding to advancements in generative artificial intelligence (AI).

    “Institutions must balance the best way to leverage these potential benefits while mitigating the risk that generative AI presents to academic integrity,” Professor Coaldrake said.

    “The power of generative AI tools requires a deep rethink of approaches to teaching and learning and assessment practices and how higher education institutions are ensuring that students have attained the skills and knowledge they need to graduate with their awards.”

    To support providers to respond to these risks, TEQSA is developing new resources in partnership with the sector including an online masterclass to deter and detect contract cheating.

    TEQSA is also working with Deakin University’s Centre for Research in Assessment and Digital Learning on developing a series of webinars exploring the challenges and opportunities for the sector posed by AI.

    More information about the webinars and online masterclass will be shared via TEQSA’s website and social media channels shortly.

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