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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 course design?

Course design can be defined structurally as the content, duration and sequencing of the elements (units) of a course of study[1]. This structural definition is broadened by the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) to include various other design characteristics including entry requirements and pathways, the nature of the content, the expected learning outcomes, their sequence of attainment and assessment, and professional accreditation if required. For the purpose of meeting the requirements of the HES Framework, the Framework effectively defines course design through the scope of the relevant Standards.

Relevant Standards in the HES Framework

The principal Standards concerned with course design are at Section 3.1. Learning outcomes and Standards concerned with their assessment are at Section 1.4. These are linked to various elements of Domain 7 in relation to the publication of information about courses of study to inform prospective students and other stakeholders. There are also links between learning outcomes (Standard 1.4.1) and the level of an AQF qualification awarded (Standard 1.5.3).

Intent of the Standards

The overall intent of the course design Standards is to identify what is required in the design of a course of study that leads to a higher education qualification. Standard 3.1.1 outlines the items that constitute the specification of the design. This specification gives an overall picture of the course of study in sufficient detail for an expert in the field to undertake an initial assessment of the scope and nature of the course and for prospective students to make an informed choice about the course (see Section 7.2). Section 3.2 focuses in detail on the nature of the content required of a higher education course, including its consistency with the level of study concerned and the expected learning outcomes. How the design of the course is intended to enable progressive and coherent achievement of the expected learning outcomes is encompassed by Standard 3.1.3, and it is expected that this should occur irrespective of the mode of participation or delivery (Standard 3.1.4). The design of the course of study also needs to address accreditation of the course of study by a professional body where this is required for registration to practise (Standard 3.1.5).

The Standards for learning outcomes require a provider to specify the learning outcomes for a course, including demonstrating their consistency with the field of education and level of qualification awarded. The Standards also require a provider’s specification of learning outcomes to be informed by national and international comparators, without specifying how a provider chooses to achieve this requirement. The Standards require achievement of different classes of learning outcomes (see Standard 1.4.2) including specific, generic, employment-related and life-long learning outcomes, and that all learning outcomes are assessed prior to completion of the course of study, irrespective of how and where they are assessed (Standard 1.4.4). Methods of assessment also need to provide students with timely feedback on their progress towards achieving course learning outcomes (Standard 1.3.3).

There is a specific requirement to demonstrate the appropriateness, fitness of purpose and effectiveness of all methods of assessment for all providers (Standard 1.4.3) and there is specific detail on the requirements for and assessment of learning outcomes for research training by higher degrees, if undertaken by a provider.

Risks to quality

In addressing course design and learning outcomes, the HES Framework seeks to prevent a series of important risks to the quality, outcomes and reputation of higher education. Failure to adequately and publicly specify the design of a course inhibits comparisons of courses and informed choice by students. It also indirectly potentially diminishes the standing of Australian higher education if international comparisons cannot be made, as do learning outcomes that are not informed by international comparators.

Failure to meet the requirements of the HES Framework leads to risks of learning outcomes and course designs not being fit for higher education, particularly in relation to the level of advanced inquiry involved, with a consequent degradation of qualifications. There is also a risk that learning outcomes are poorly defined or not defined at all, and that they may be narrowly focused rather than embracing specific, generic, employment-related and life-long learning outcomes as expected of contemporary higher education. Inadequate consideration of different modes of participation or delivery may lead to disadvantage for some individuals/cohorts.

If the achievement and assessment of expected learning outcomes are not aligned for the course of study overall, there is a risk of learning outcomes not being achieved or not being adequately assessed, or of some outcomes being assessed excessively to the detriment of others that are given little attention or ignored. Insufficient diligence in selecting methods of assessment may result in invalid or otherwise unreliable assessment, to the extent that students may graduate who have not in fact achieved the learning outcomes of the course.

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 course design, learning outcomes and assessment.
 

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.

When providers apply to TEQSA for course accreditation, they are required to provide detailed course documentation. In other circumstances (i.e. if an issue arises outside the scope of a formal application) TEQSA may be in a position to readily form a view on the basis of the publicly available information (required under Standard 7.2.2). Such an issue may also prompt a request for further information, which in turn may also be influenced by the provider’s previous record of meeting the requirements of the HES Framework in course design for cognate or different fields of education.

Broadly speaking, the specification of the design of the course provided to TEQSA for a course accreditation application should allow a peer to form a view on the standing and quality of the course, and allow prospective students to compare comparable offerings from different providers.

TEQSA requires that a provider be able to demonstrate that the content and learning activities of the course are of a sufficiently advanced level and otherwise appropriate to higher education, and are consistent with the field of education and the level of qualification involved. TEQSA will probe these aspects intensively in relation to the requirements of Standards 3.1.2 and 3.1.3. A provider may wish to advance credible national or international comparators in support of the course design (note that this is required for learning outcomes at Standard 1.4.1). Reference may also be made to the specifications of the AQF for the level of qualification concerned. In the case of ‘nested’ course designs, TEQSA will pay particular attention to entry and exit pathways and to the integrity of course design and learning outcomes for each exit point.

Where the provider’s intention is to offer a course of study in different locations or by different modes of participation or delivery, TEQSA will need to be satisfied that the design of the course is such that students have equivalent opportunities to achieve the expected learning outcomes irrespective of their mode of participation. As for external accreditation of the course by a professional body (Standard 3.1.5), providers are encouraged to review the application guides on the TEQSA website.

Just as TEQSA will be concerned that a course of study and its content are fit for higher education, it will be similarly diligent in relation to the nature, quality and level of the expected learning outcomes for the course (Standards 1.4.1-1.4.2). This will include an assessment of the credibility of comparators advanced by the provider (Standard 1.4.1) and may involve expert/peer review. Similarly, TEQSA will wish to be satisfied that the methods of assessment of learning outcomes that are used throughout the course are credibly capable of valid assessment of the various outcomes concerned for the level of qualification offered (see also Standard 1.5.3). The Standards require that all specified learning outcomes are assessed before completion of the course of study (Standard 1.4.4) and that progressive and coherent achievement of learning outcomes is planned in the design of the course (Standard 3.1.3).

TEQSA will expect some clear information demonstrating where course learning outcomes are taught, practised and assessed, whether at unit level or at course level (e.g. via a ‘capstone’ assessment and/or an assessment against a set of occupational or professional standards) or a combination of these (Standard 1.4.4). TEQSA may require an appropriate demonstration that the learning outcomes that are assessed at individual unit level (and/or within a capstone unit) reasonably demonstrate achievement of overall course learning outcomes on graduation. The Standards also require that any grades awarded reflect the level of student attainment (Standard 1.4.3). TEQSA will expect providers to be able to advance credible evidence (such as moderation exercises, peer reviews, benchmarking studies) that will satisfy TEQSA in this respect.

For those providers that offer research training by higher degrees, TEQSA will need to be satisfied that the additional requirements for the specification and assessment of learning outcomes for research training are met (Standards 1.4.5-1.4.7). This may involve an assessment of the relevant policies and procedures governing assessment for research degrees, and their implementation, as exemplified by assessment of actual reports from examiners for a sample of relevant assessments. The details of this will be covered in the assessment request for information. Providers are encouraged to review the application guides on the TEQSA website.

Scope of assessments

If, as a result of looking in detail at the provider’s capabilities in course design and assessment of learning outcomes, TEQSA is satisfied that the provider’s processes meet the requirements of the HES Framework and that there is evidence of continuing sustainability and effectiveness of these processes, this may allow TEQSA to reduce its evidence requirements for other Standards and/or for subsequent regulatory activities for other courses of study. On the other hand, if concerns are raised in relation to the provider’s capabilities, this may require TEQSA to probe the design and assessment of other courses in more detail.

Resources and references

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

FLIPCurric website.

Office for Learning and Teaching project, Assuring Graduate Capabilities.

Office for Learning and Teaching, Assuring Learning.

Publications developed by the Assessing and Assuring Graduate Learning Outcomes Project.

Quality Assurance Agency (2014), UK Quality Code for Higher Education, Chapter B1: Programme Design, Development and Approval.[2]

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	13 April 2016	Made available as beta version for consultation.
1.1	19 August 2016	Incorporated feedback from consultation, including clarification of what TEQSA will look for, elaboration of learning outcomes assessed at unit level, and an addition to the resources and references.
1.2	12 September 2016	Addition of additional reference Office for Learning and Teaching, Assuring Learning
1.3	11 October 2017	Addition to ‘What will TEQSA look for?” text box.

 

 

 

 

 

[1] A course of study is a coherent sequence of units of study leading to the award of a qualification. The use of ‘course of study’ in the Standards includes both coursework and higher degree by research programs unless otherwise specified. Courses of study are sometimes known as ‘programs’ and units of study are sometimes called ‘modules’ or ‘subjects’.

[2] This document sets out expectations for providers of UK higher education.

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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. 

How is equivalence of professional experience determined?

Higher education students are entitled to expect that they are being taught by someone who is qualified in the particular field of education (also known as field of study) at a level more advanced than the level of the course being taught, and that the teacher’s expertise has been clearly established through an assessment of formal academic qualifications, equivalent professional experience, or a combination of both.

Where providers identify a need to rely on an assessment of professional equivalence for the purpose of appointing staff, TEQSA expects that they will have a policy and procedure under which professional equivalence is determined and approved.

Relevant Standards in the HES Framework

The Standards in the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) concerned with staffing require registered higher education providers to ensure that academic staff appointed to teach students are appropriately qualified in the relevant discipline for their level of teaching (see Section 3.2). In particular, the Standards specify that academic teaching staff must be qualified to at least one level[1] of qualification higher than the course of study being taught (AQF+1), or have equivalent relevant academic, professional or practice-based experience and expertise, except for staff who are supervising doctoral degrees, who must have a doctoral degree or equivalent research experience (see Section 3.2.3). The Standards for research (Section 4.1) and research training (Section 4.2) also canvass experience. TEQSA’s guidance note on nested courses discusses how the requirements apply to courses at one level that have components within them of courses at a lower level.

This guidance note explains how TEQSA assesses whether providers have met the requirement to determine equivalence in line with the HES Framework, where staff do not have AQF+1 qualifications. For the sake of brevity, the range of relevant types of experience mentioned in the Standards is referred to collectively as ‘professional experience’ in this guidance note.

Assessing professional equivalence

Key features of an effective policy

A framework for determining equivalent professional experience needs to be codified in a policy, to avoid inconsistent and ad hoc judgements being made. Equivalent professional experience goes well beyond a measure of the time spent by a person working in a particular profession. Assessment must also take into account how the professional experience demonstrates achievement that is equivalent to the specific knowledge and skills established in the learning outcomes of the required AQF level being considered. A provider’s policy and procedures should recognise that these learning outcomes are specific for each field of education, as well as AQF level, and that therefore the criteria for equivalence would need to be tailored to each field and level of education under consideration.

A provider may find it useful to benchmark the knowledge and skills that can be attained through professional experience against the learning outcomes of its own courses, or against those of other providers.

In addition, any policy dealing with the assessment of professional equivalence should include consideration of:

• the full range of professional experience
  
  • including teaching experience (i.e. teaching at lower AQF levels, conducting professional development seminars, giving public lectures), scholarship and professional practice
• a minimum requirement for academic qualification(s)
  
  • for example where staff are able to meet the AQF+1 requirement through professional experience, they could be required nonetheless to hold an academic qualification at least equivalent to the AQF level of the course of study being (or proposed to be) taught, and
• the specific criteria for assessing professional equivalence at each level
  • where a policy points to multiple criteria, the policy should be clear about whether each criterion is sufficient on its own, or is to be assessed in combination with others.

The evidence to be considered when assessing the professional experience of an individual may include evidence of:

• leadership in the development of professional standards
• performing in a role that requires high order judgement and the provision of expert advice, or roles at a senior level
• managing significant projects in the field
• testimonials, awards or other recognition that acknowledges leadership or expertise in the field of education
• contributions in the field of education through participation in advisory boards and professional networks
• peer reviewed publications in the field of education
• other publications such as books and reports
• leadership or management of research acknowledged by peers.

TEQSA recognises that in fields of education that are professionally focused, emergent academic disciplines or highly professional specialist subjects within a discipline, a policy may allow for some flexibility in its application while maintaining the robustness of the policy intent. However, TEQSA would expect that where an individual staff member may not yet strongly meet all of the criteria outlined in the policy, there would be an explicit and time-limited professional development plan, or other strategies put in place such as mentoring or team teaching, to enable the individual to make the transition to academic teaching successfully. In the case where teachers are engaged on a continuing basis to teach specialised components of a course because of their specialised expertise, but do not fully meet the general requirements of Standard 3.2.3, they are supervised by staff who do meet the requirements (see Standard 3.2.4).

Assessing research equivalence

In the case of staff supervising doctoral degree students who do not themselves have a doctoral degree, TEQSA would expect a higher education provider to analyse the nature, amount and duration of research previously undertaken, including the extent of independent research involved, against the usual requirements for the award of the relevant research qualification e.g. PhD. Such an analysis would be expected to be undertaken by a person or a body, e.g. a research committee, that has sufficient research experience to make an informed judgement about equivalence. 

Risks to quality

The focus of the Standards relating 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 at or below the level of course they are teaching (including research experience for research training if applicable to the provider).

Where staff do not have the required level of qualifications and experience, they may be unable to lead students in intellectual inquiry and achieve learning outcomes appropriate for the level of the course.

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 professional equivalence.
 

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 recognises that approaches to assessing professional equivalence are likely to vary between providers, but in establishing the effectiveness of the implementation of the policy framework, a provider should be able to demonstrate:

• how the policy is communicated to current and future academic teaching staff and to human resource staff
• who is delegated to apply the policy, and that there are processes for ensuring transparency and equity in relation to its application.
• how the provider assures itself that the policy is applied to all existing staff, as well as new appointments
• how the outcomes of any assessment of professional equivalence may inform a staff member’s professional development activities
• how the policy will be subject to a periodic review.

Resources and references

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

TEQSA (2016), Guidance Note on Nested Courses of Study.

TEQSA (2016), Guidance Note on Staffing, Learning Resources and Educational Support.

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	18 September 2014
2.0	19 August 2016	Updated for the HESF 2015 and made available as beta version for consultation. Replaces previous guidance note on ‘Equivalence of professional experience to academic qualifications’.
2.1	18 April 2017	Updated to refer to guidance note on Nested Courses.
2.2	11 October 2017	Addition to ‘What will TEQSA look for?” text box.

 

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 constitutes diversity and equity?

The terms ‘diversity’ and ‘equity’ as used in the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) refer broadly to the creation of equivalent opportunities for access and success in Australian higher education for historically disadvantaged or underrepresented student populations, other groups protected in Equal Opportunity and anti-discrimination legislation, and those covered by the Higher Education Participation and Partnerships Program.

The relevant Standards in the HES Framework require higher education providers to focus on ensuring equivalent opportunities for student academic success. They do not refer to the appointment of staff.

Relevant Standards in the HES Framework

The principal Standards concerned with diversity and equity are in Part A, Section 2.2, Diversity and Equity, which set out three broad requirements that apply to providers and courses of study:

1. Institutional policies, practices and approaches to teaching and learning are designed to accommodate student diversity, including the under-representation and/or disadvantage experienced by identified groups, and create equivalent opportunities for academic success regardless of students’ backgrounds.
2. Specific consideration is given to the recruitment, admission, participation and completion of Aboriginal and Torres Strait Islander peoples.
3. Participation, progress, and completion by identified student subgroups are monitored and the findings are used to inform admission policies and improvement of teaching, learning and support strategies for those subgroups.

Requirements for providers to consider diversity and equity are also woven into other Standards, reflecting the typical stages of being a student.

Standard 1.1.1 on Admission requires providers to ensure that admitted students have the academic preparation and proficiency in English needed to participate in their intended study, and no known limitations that would be expected to impede their progression and completion.

Also relevant to student admissions is Section 7.2 on Information for Prospective and Current Students, which requires that accurate, relevant and timely information for students is publicly available and accessible, including access for students with special needs, to enable informed decision making about educational offerings and experiences.

Standard 7.2.2d requires providers to give prospective students, prior to acceptance of an offer, access to current academic governance policies and requirements, including policies and requirements in respect of equity and diversity.

Section 1.3 on Orientation and Progression requires providers to tailor their orientation programs to the needs of student cohorts, to assess the needs and preparedness of individual students and cohorts, and to ensure that students have equivalent opportunities for successful transition into and progression through their course of study, irrespective of their educational background, entry pathway, mode or place of study.

Section 2.3 on Wellbeing and Safety requires that the nature and extent of support services available to students are informed by the needs of student cohorts, including mental health, disability and wellbeing needs (see Standard 2.3.3).

Section 3.3 on Learning Resources and Educational Support includes requirements that need to be considered in regard to student diversity and equity. Standard 3.3.3 requires that access to learning resources does not present unexpected barriers, costs or technology requirements for students, including for students with special needs. Standard 3.3.4 requires that students have access to learning support services that are consistent with the requirements of their course and mode of study, and with the learning needs of student cohorts.

Part B1, on provider categories, sets out requirements for use of the title ‘university’. Any provider seeking to use the title ‘university’ must demonstrate a commitment to social responsibility in its activities.

Paragraph 2d of Part B2 requires that any provider seeking authority from TEQSA to self-accredit nominated courses must demonstrate that it has:

• completed at least one cycle of review and improvement in relation to the provider’s efforts to meet Standard 2.2.3 in its reviews and improvement activities of all courses proposed for self-accreditation
• demonstrated successful implementation of evidence-based improvements arising from the reviews
• established these review and improvement activities as effective sustainable features of the provider’s operations.

Intent of the Standards

Section 2.2 applies to all students, including students undertaking higher degrees by research.

The overall intent of the Standards is to ensure that providers consider and plan to meet the learning and support needs of all their students, so that as far as possible all students have equal opportunities for academic success. These learning and support needs often are broadly similar but they can also differ quite markedly for individuals or groups of students.

The Standards necessitate that providers have: an understanding of the concepts of diversity and equity, and have considered the implications for their operations, including the creation of a culture that welcomes diversity (on campus and online). The individual mission of each provider gives the context for the development of institutional approaches to valuing diversity and supporting equity in its many forms. Where students are expected to make a commitment to support that mission (for example through a Statement of Faith), this should also not contravene a provider’s obligation to support freedom of speech and academic freedom (Standard 6.1.4 and Category Criterion B1.1.1). Measures taken to accommodate diversity should not contravene the standards, including Standard 6.1.4 and Category Criterion B1.1.1.

All providers can expect that there will be diversity in the backgrounds and characteristics of their student body. They need to plan to accommodate this diversity by:

• being aware of their obligations under Australian law
• carefully considering their targeting of, and marketing to, prospective students
• ensuring that prospective students are aware of, and can access information about, any requirements associated with successful completion of a course, including those that might represent impediments for members of particular groups, such as students with disabilities
• committing resources to provide learning and other support likely to be required by their diverse student body, including international, off-campus, and online students
• ensuring that institutional data systems capture relevant information for monitoring of participation, progress and completion.

TEQSA accepts that the extent to which providers commit resources to accommodate and support student diversity will be conditioned by the scale and scope of each provider’s activities, as well as by its mission.

Standard 2.2.1 makes specific reference to the need for providers to accommodate the under-representation and/or disadvantage experienced by identified groups. Providers are expected to be aware of under-represented groups in higher education.

The Standards do not require providers specifically to achieve ‘representational equity’ in the proportion of historically under-represented student populations they choose to admit, but providers must give specific consideration to the recruitment and admission of Aboriginal and Torres Strait Islander peoples (Standard 2.2.2).

In Australian higher education, there is an established tradition of acknowledgement of and support for specific equity groups that from time to time include, or have included:

• Aboriginal and Torres Strait Islander peoples
• people from lower socio-economic backgrounds
• people with disability
• people from remote, rural or isolated areas
• people who are the first in their family to attend a university or other higher educational institution
• people from non-English speaking backgrounds
• women, especially in areas of study where they have been under-represented, such as engineering.

Providers should consider, in the light of their missions, any other groups of prospective students that may have experienced disadvantage.

While international students studying in Australia may not be under-represented or have experienced disadvantage, the principles of support for diverse learners and inclusive education should be applied to them as to all students.

The Australian legislation relating to diversity and equity that providers need to comply with includes:

• Racial Discrimination Act 1975 (Cth)
• Sex Discrimination Act 1984 (Cth)
• Disability Discrimination Act 1992 (Cth)
• Disability Standards for Education 2005 (Cth)
• Australian Human Rights Commission Act 1986 (Cth)
• Workplace Gender Equality Act 2012 (Cth)
• Age Discrimination Act 2004 (Cth)
• Various State and Territory Anti-Discrimination legislation.

Section 22 of the Disability Discrimination Act (1992) applies specifically to education, and prohibits providers from discriminating, directly or indirectly, against a person on the grounds of a person’s disability by:

• refusing or failing to accept the person’s application for admission as a student
• denying the student access, or limiting the student’s access, to any benefit provided by the educational authority
• expelling the student
• subjecting the student to any other detriment
• developing curricula or training courses having content that will exclude the person from participation.

Further, the Disability Standards for Education impose certain obligations on providers. Providers must take ‘reasonable steps’ to enable students with disability to apply for and participate in a program on the same basis as other students, and make ‘reasonable adjustments’ to assist a student with a disability to apply for admission or enrolment; to participate in the course or program and to use facilities or services on the same basis as a student without a disability.

The Standards in the HES Framework require that providers develop and implement systems to monitor and use data on the:

• participation
• progress
• completion of identified student subgroups.

For some providers this is also an Australian Government requirement related to funding.

Under the HES Framework, all providers are expected to have and to use information reflecting diverse student groups. The selection of groups is not mandated by the HES Framework but must include Aboriginal and Torres Strait Islander peoples (Standard 2.2.2). Guidelines for how to measure and monitor participation, progress, and completion are available in various publications (see for example AIHW, 2014; Pitman and Koshy, 2014).

Risks to quality

The major risks of a failure by a provider to implement plans for diversity and equity among its student cohorts are:

• a poor experience for learners and potential damage to their self-esteem and prospects for future learning
• low retention and completion rates among under-represented groups or those that have experienced disadvantage, due to the lack of adequate support or an appropriate learning environment
• a failure to meet legal obligations by the provider not being aware of actions that are discriminatory or unfair, which in turn could result in legal action and/or reputational damage.

The social and emotional consequences for individuals of not achieving and succeeding in higher education can be severe. While not every student will complete their studies, providers are expected to mitigate the risks to students who experience disadvantage or come from under-represented groups by providing appropriate support and a suitable learning environment.

What will TEQSA 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 management of diversity and equity.
 

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 for renewal of registration or course accreditation 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.

In the first instance, TEQSA will consider the provider’s statements in respect of diversity and equity, including the policy frameworks and procedures to create and maintain equivalent opportunities for academic success regardless of students’ backgrounds, within the context of the provider’s mission. TEQSA will consider the implementation of policies for teaching and learning for the extent to which they accommodate diversity and create equivalent opportunities for students.

As noted above, in advance of offering higher education, a provider needs to understand and consider:

• their legal obligations, including obligations not to discriminate
• the characteristics of their expected student mix
• their stance on diversity and equity
• how they will incorporate inclusivity in admissions practices, course design and education and learner support (student services, resources and infrastructure), and
• how they will monitor participation, progress and completions.

Any provider that admits students without considering how all students will have equivalent opportunities for academic success and an appropriate learning environment is likely to face multiple difficulties in meeting the HES Framework.

TEQSA will consider whether a provider’s admission requirements (Section 1.1), advice to prospective and enrolled students (Section 7.2) and transition support (Section 1.3) are consistent with its statements and policies on diversity and equity, and adequate to meet Standard 2.2.1. As part of this consideration, TEQSA will explore how the provider has assessed the needs and preparedness of individual students and cohorts. TEQSA will also have regard to how the provider has given specific consideration to the recruitment, admission, participation and completion of Aboriginal and Torres Strait Islander peoples. For other identified groups, TEQSA will review the arrangements for monitoring participation, progress and completions, and the outcomes achieved.

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 Standards do not require providers to achieve equality of outcomes, however they do require them to ensure equivalent opportunities for all groups.

TEQSA will investigate whether the nature and extent of support services available for students are informed by the needs of student cohorts (Standard 2.3.3). TEQSA will consider the adequacy of these services, taking into account the scale and scope of the provider’s operations. Similarly, TEQSA will be interested to see how students with special or specific needs have access to learning resources and learning support services (Section 3.3).

For providers seeking to use an Australian University title under Part B1, TEQSA will consider the extent to which the provider has demonstrated a commitment to social responsibility. This may include an exploration of the provider’s commitment to valuing diversity and to representational equity. This may also include consideration of the provider’s track record in ensuring equivalent support to diverse student cohorts to enable them to achieve the best possible outcomes they are capable of achieving.

For providers seeking authority from TEQSA to self-accredit nominated courses of study under Part B2, TEQSA will check that the review requirements of Section 2.2 relating to diversity and equity for all proposed course(s) of study have been implemented.

Further inquiry

If concerns are raised over a provider’s understanding or implementation of policies or legislated responsibilities concerning student diversity and equity, TEQSA may explore the extent to which these concerns reflect any systemic challenges for the provider’s ability to meet the HES Framework. In determining whether to explore the issue further, TEQSA will take account of the scale and scope of the provider’s activities. 

Resources and references

Australian Government, Age Discrimination Act 2004.

Australian Government, Australian Human Rights Commission Act 1986.

Australian Government, Disability Discrimination Act 1992.

Australian Government, Disability Standards for Education 2005.

Australian Government (2015), Final Report for the 2015 Review of the Disability Standards for Education 2005.

Australian Government, Racial Discrimination Act 1975.

Australian Government, Sex Discrimination Act 1984.

Australian Government, Workplace Gender Equality Act 2012.

Australian Human Rights Commission (2016), A quick guide to Australian discrimination laws.

Australian Institute of Health and Welfare (2014), Towards a performance measurement framework for equity in higher education.

Higher Education Participation and Partnerships Programme.

Research reports available through the National Centre for Student Equity in Higher Education, Curtin University (2016 and previous).

National Education Association [NEA] (2015), Diversity Toolkit Introduction.

Pitman, T. and Koshy, P. (2014), A Framework for Measuring Equity Performance in Australian Higher Education – Draft Framework Document.

Universities Australia (October 2011), National Best Practice Framework for Indigenous Cultural Competency in Australian Universities.

Various State and Territory legislation, Anti-Discrimination Acts.

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.
1.1	9 May 2017	Amended as a result of consultation feedback.
1.2	11 October 2017	Amendment to ‘What will TEQSA look for?” text box.

 

 

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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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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: 

4. 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 

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 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).

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 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.

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?

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 #	Date	Key changes
1.0	6 January 2020	Made available as beta version for consultation.