• Preparing a CRICOS renewal application (Stage 1)

    Stage 1: the provider prepares a CRICOS renewal application

    Legislative requirements

    Your application should demonstrate that your governing body is assured of your institution’s current, and continuing, compliance with the requirements of the:

    Evidence requirements

    TEQSA has revised its approach to the evidence required for applications to renew CRICOS registration. We have done this to reduce the volume and scope of evidence required to demonstrate compliance with the National Code.

    Applications to renew CRICOS registration should include the following evidence:

    1. A self-assurance report
    Outlining how the governing body manages key sector risks, how it assures itself of the quality of its higher education operations and that it is compliant with the National Code.
    1. An index of supporting evidence
    Referenced throughout the report.
    1. An independent external audit report or additional supporting evidence

    The report of a recently conducted independent external audit of the effectiveness of the provider’s internal mechanisms for self-assurance and compliance with the National Code (including planned and completed actions arising from these reviews).
     

    Or, if the provider does not have self-accrediting authority, and chooses not to provide a recently commissioned independent external audit, additional supporting evidence.

    1. For providers with a Foundation Program – an additional self-assurance report
    Focused on the requirements for renewing a Foundation Program.
    1. For providers with an ELICOS course – an additional self-assurance report
    Focused on the requirements for renewing an ELICOS course.
    1. For providers with an under 17 exemption – additional supporting evidence
    Satisfying the requirements to renew exemptions to enrol students under the age of 17 in Foundation Programs.

    CRICOS registration renewal: Self-assurance report

    A self-assurance report provides an opportunity to demonstrate the effectiveness of your self-assurance mechanisms.

    The self-assurance report for applying to renew CRICOS registration should be a maximum of 10 pages. It should outline how your governing body assures itself of the quality of your education operations, and your current and continued compliance with the requirements of the ESOS Act, the National Code 2018, and where relevant, the ELICOS Standards, and the Foundation Program Standards.

    When applying to renew CRICOS registration, your self-assurance report should include:

    1. Evidence of how risks have been identified, managed and mitigated, and how your institution will manage these risks going forward (including areas for continuous improvement and any associated actions and measures which are in place to monitor success).
    2. Demonstration of how you manage key sector risks in the following areas:
    Student recruitment and admission

    TEQSA recommends considering our:

    Student participation, support and experience

    TEQSA recommends considering:

    Student attainment

    TEQSA recommends considering:

    1. Where applicable, the findings, actions (planned and completed) and outcomes of at least one external audit. This audit should have been undertaken, by a suitably qualified discipline expert, no more than 18 months before applying to renew CRICOS registration. A copy of the audit should be included, as an attachment, to the self-assurance report.
    2. The findings, actions and outcomes of the most recent review report on recruitment performance, including the performance of agents (e.g. student numbers enrolled and succeeded, meetings with agents and terminations of agents). The following attachments should be included with the self-assurance report:
      • policies and procedures regarding recruitment and management of agents
      • an example of a written agreement between your institution and an education agent.
    3. A copy of an example agreement used where third-party providers are engaged to provide welfare and/or accommodation arrangements to students under the age of 18.
    4. Evidence of a culturally and age-appropriate orientation program, including the presentation used for overseas students.
    5. Details of any third-party arrangements for the delivery of a course or courses to overseas students.

    Note: All claims made in the self-assurance report must be substantiated by evidence, with reference to specific supporting documents in-text. 
     

    Where possible, supporting evidence should be directly accessible via in-text hyperlinks, included as attachments to the report, or listed in the index and available for later submission on request.

    Index of supporting evidence

    Your application should include an index of all supporting evidence referenced in the self-assurance report. At a minimum, the index should include:

    Items to be listed with hyperlinks to their location on your website
    • Policies and procedures regarding:
      • marketing and recruitment
      • credit and recognition of prior learning (RPL)
      • admission
      • assessment of English language proficiency
      • fee refunds
      • students under the age of 18
      • critical incidents
      • student support
      • orientation
      • staff development
      • health and safety
      • overseas student transfers
      • monitoring, recording and assessing course progress, including intervention strategies for students at risk
      • monitoring and recording attendance (where applicable)
      • assessing, approving and recording deferment, suspension and cancellation
      • complaints and appeals.
    • Current marketing and promotional material for current and prospective students, including sample course brochures and promotional material published on social media
    • Overseas student handbooks
    • A current list of education agents engaged to formally represent the provider
    • Samples of information given to students under the age of 18 outlining emergency contacts and how to seek assistance and report on incidents of actual or alleged sexual, physical or other abuse.
    Items may be listed without hyperlinks and TEQSA may request copies of these items at any time
    • Details of marketing materials provided to agents
    • A register of students granted credit within the last 24 months
    • An example of a Letter of Offer and a written agreement between your institution and a student for a course of study
    • Details of any training and development programs provided to agents
    • Evidence demonstrating that the suitability of accommodation for students under the age of 18 has been verified, prior to the accommodation being approved and at least every 6 months thereafter
    • Policies and procedures for selecting, screening and monitoring any third parties your institution has engaged to organise and assess welfare and accommodation arrangements (where applicable)
    • Evidence of compliance with Commonwealth, state and territory legislation, or other regulations regarding child welfare and protection requirements
    • A copy of the Working with Children Check register
    • A copy of the critical incident register, or other written record, for at least the last 2 years
    • Details of ESOS training and ongoing professional development undertaken by staff
    • A description of student services for overseas students, including:
      • legal services
      • emergency and health services
      • academic and English language student support
      • welfare support services
      • other student support services.
    • Examples of correspondence sent by your institution to overseas students when you:
      • intend to refuse a transfer request
      • intend to report the student for unsatisfactory course progress or attendance
      • are notifying the intention to suspend or cancel the student’s enrolment
      • are notifying that a deferral, suspension or cancellation has taken place
      • are notifying the outcome of an internal appeal process for both favourable and adverse decisions.
    • A report of all decisions to defer, suspend or cancel the enrolment of overseas students in the preceding 12 months, with a description of reasons and outcomes
    • A report of all student complaints and appeals received in the preceding 12 months, with evidence of processes implemented and a description of outcomes and actions taken
    • Evidence of quality assurance and monitoring arrangements between your institution and any third party engaged for the delivery of a course
    • An outline of changes to current third-party arrangements for course delivery and a copy of the amended contract if, since being approved by TEQSA, any of the following areas have been impacted:
      • roles and responsibilities of each party
      • delivery site location
      • duration of contract length.
    • A report of all refund requests and outcomes from the previous 12 months, with evidence that refunds provided were reported in PRISMS within the required timeframe (where applicable)
    • Where relevant, evidence your institution is meeting its obligation to maintain the ‘Protected Amount’ (all pre-paid tuition fees must be held in a designated bank account which is separate to day-to-day operating expense accounts)
    • A copy of relevant policies and procedural documents that ensure your institution has robust mechanisms for maintaining the Protected Amount.

    Independent external audit

    Standard 11.4 of the National Code requires providers who are self-accrediting to undertake an independent external audit within 18 months of their registration’s expiry.

    TEQSA strongly encourages all providers (including those who do not have self-accrediting authority) to undertake an independent external audit of their compliance with the ESOS Framework in the second half of their registration period.

    An independent audit is an opportunity for your institution to have a person, or persons, with significant expertise evaluate the effectiveness of your internal mechanisms for self-assurance, to ensure they align with contemporary practice and support continuous improvement.  TEQSA’s ability to efficiently assess your application to renew your CRICOS registration is greatly assisted by a high-quality independent audit report.

    If your institution does not have self-accrediting authority, and you do not submit a recently conducted independent external audit report with your application, you will need to provide additional supporting evidence (see the guidance on preparing additional supporting evidence below).

    A guide for providers undertaking an independent external audit is available. The audit report should be accompanied by your institution’s response, including any completed or in-progress actions which look to address issues the report identified and when they have been, or will be, undertaken.

    Additional supporting evidence

    If your institution does not have self-accrediting authority, and you do not submit a recently conducted independent external audit report, you are required to submit the following items with your application:

    • examples of credit and recognition of prior learning (RPL) decisions, with copies of relevant records and correspondence
    • examples of admissions with copies of relevant records and correspondence, capturing a variety of student cohorts, for example:
      • recruited onshore
      • recruited offshore
      • recruited via a pathway
      • recruited via an agent
      • recruited without an agent
      • admitted with academic qualifications
      • admitted with professional qualifications
      • admitted with prior study at an Australian provider
      • admitted with English language proficiency
      • admitted with an English language waiver.
    • examples of assessment of English language proficiency, with copies of relevant records and correspondence
    • examples of care arrangements for students under the age of 18 and their monitoring, with copies of relevant records and correspondence
    • examples of intervention strategies for managing students at risk and the outcomes of these, with copies of relevant records and correspondence
    • examples of deferments, suspensions and cancellations, with copies of relevant records and correspondence
    • examples of complaints and appeals by students and the outcomes of these, with copies of relevant records and correspondence
    • evidence demonstrating that the suitability of accommodation for students under the age of 18 has been verified before the accommodation was approved and at least every 6 months after its approval
    • policies and procedures for selecting, screening and monitoring any third-parties engaged by the provider to organise and assess welfare and accommodation arrangements (if applicable)
    • a copy of the Working with Children Check register
    • a copy of the critical incident register, or other written record, for at least the last 2 years
    • a description of student services for overseas students, including:
      • legal services
      • emergency and health services
      • academic and English language student support
      • welfare support services
      • other student support services.
    • evidence of quality assurance and monitoring arrangements between the provider and any third-party engaged for the delivery of a course
    • an outline of changes to current third-party arrangements for course delivery and a copy of the amended contract if, since being approved by TEQSA, any of the following areas have been impacted:
      • roles and responsibilities of each party
      • delivery site location
      • duration of contract length.
    • a report of all refund requests and outcomes from the previous 12 months, with evidence that refunds provided were reported in PRISMS within the required timeframe (where applicable)
    • where relevant, evidence that the provider is meeting its obligation to maintain the ‘Protected Amount’ (all pre-paid tuition fees must be held in a designated bank account which is separate to day-to-day operating expense accounts)
    • a copy of relevant policies and procedural documents that ensure that the provider has robust mechanisms for maintaining the Protected Amount.

    Foundation Program renewal

    TEQSA requires CRICOS-registered providers who deliver Foundation Programs to apply for re-accreditation of their Foundation Program(s) at the same time they apply to renew their CRICOS registration. For these providers, the application to renew Foundation Program(s) is integrated into the application to renew CRICOS registration.

    These providers will submit an additional self-assurance report as part of their CRICOS renewal focused on the Foundation Program requirements.

    In instances where a Foundation Program has been added within 2 years of applying to renew CRICOS registration, the provider may limit their Foundation Program renewal application to: a self-assurance report; and, an index of supporting evidence (focused on the Foundation Program requirements), omitting any other attachments.

    ELICOS renewal

    TEQSA requires CRICOS-registered providers who deliver ELICOS courses to apply for re-accreditation of their ELICOS course(s) at the same time they apply to renew their CRICOS registration. For these providers, the application to renew ELICOS course(s) is integrated into the application to renew CRICOS registration.

    These providers will submit an additional self-assurance report as part of their CRICOS renewal, focused on the ELICOS course requirements.

    In instances where an ELICOS course has been added within 2 years of applying to renew CRICOS registration, the provider may limit their ELICOS renewal application to: a self-assurance report; and, an index of supporting evidence (focused on the ELICOS requirements), omitting any other attachments.

    Under 17 exemption renewal

    TEQSA requires providers who have existing exemptions to enrol students under the age of 17 in Foundation Programs, to apply to renew their exemption when they apply to renew their CRICOS registration.

    To renew exemptions to enrol students under the age of 17 in Foundation Programs, you will need to submit the following evidence as an appendix to your CRICOS renewal application:

    • policies and procedures which are in place to manage the provision of welfare arrangements for students under the age of 17, including critical incident policies and procedures
    • details of appropriate arrangements which are in place for student accommodation and wellbeing, including evidence demonstrating that the suitability of accommodation for students under the age of 17 was verified before the accommodation was approved and at least every 6 months after its approval
    • an example of any agreements with third-party providers who have been engaged to provide welfare and/or accommodation arrangements to students under the age of 17
    • policies and procedures for selecting, screening and monitoring any third party your institution has engaged to organise and assess welfare and accommodation arrangements (if applicable)
    • details of appropriate arrangements which are in place for the orientation of students that are under the age of 17, including samples of information given to them relating to emergency contacts and how to seek assistance and report on incidents of actual or alleged sexual, physical or other abuse
    • evidence of appropriate arrangements which are in place for academic progress review of students that are under the age of 17
    • evidence of compliance with Commonwealth, state and territory legislation, or other regulations, regarding child welfare and protection requirements
    • a copy of the Working with Children Check register
    • evidence staff receive training in child protection principles, as part of the staff induction process.
    Last updated:
  • Guidance note: Academic monitoring, review and improvement

    Body

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

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

    In August 2023, TEQSA consulted stakeholders with a draft version of the Academic Monitoring, Review and Improvement guidance note, and considered all feedback.
     

    This guidance note was finalised on 19 March 2024.
     

    The purpose and intent of the guidance note about academic monitoring, review and improvement is to support providers by encompassing key elements of institutional quality assurance.
     

    1. What does monitoring, review and improvement encompass?

    In the context of the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards) monitoring, review and improvement are key elements of institutional quality assurance.

    The Threshold Standards provide that all higher education providers (providers) carry out ongoing monitoring and review to improve their operations, and that providers comprehensively review all their registered courses of study (courses) at least every 7 years. For each course of study, a comprehensive review should encompass:

    • design and content
    • expected learning outcomes – their methods of assessment and student achievement
    • emerging developments in the relevant field of education
    • mode of delivery
    • changing needs of students
    • identified risks to quality
    • trend analyses over a range of factors (e.g. completion rates) for different student cohorts and subgroups. 

    Alongside student feedback, such continuous monitoring and reviews should also inform ongoing improvement activities. As the Explanatory Statement of the Threshold Standards notes, the purpose of monitoring and review is “to maintain and enhance [the] quality and effectiveness” of the provider’s educational offerings.1

    To ensure a provider’s improvement cycle both maintains and enhances its offerings, the Threshold Standards place 2 quality assurance conditions upon comprehensive reviews.

    The first condition is that comprehensive reviews involve benchmarking activities such as external referencing. Although the Threshold Standards do not define ‘external referencing’, TEQSA understands this term to describe activities wherein a provider assesses an aspect of their operations against an external comparator. Examples of external referencing include, but are not limited to:

    • peer review
    • moderation of courses
    • course accreditation by professional bodies
    • engagement with and feedback from industry groups
    • comparisons with identified good practices in the sector
    • comparisons grounded in publicly available information or market intelligence
    • comparisons developed through collaboration with other providers, peak bodies, employers, or industry.

    The second condition placed upon comprehensive reviews is that they are overseen by peak academic governance processes. Such oversight aims to ensure a provider’s monitoring, review and improvement activities are not ad hoc but instead reflect a systematic approach to quality assurance.

    At the same time, oversight by academic processes should also serve to ensure the systematic approach a provider adopts to monitoring, review and improvement is appropriate to the specific character of the provider. For example, the Threshold Standards describe more developed processes of review, monitoring, and improvement for providers granted self-accrediting status, and for those who seek to enter ‘higher’ provider categories. But across any such variations, TEQSA holds all providers to a common expectation of being able to demonstrate an understanding of how their own monitoring, review and improvement operations provide an appropriate form of ongoing and systematic quality assurance.

    2. What TEQSA will look for

    TEQSA considers relevant standards from the Threshold Standards in the context of academic monitoring, review and improvement, among which most notably are:

    Threshold Standards (2021) Part A Key considerations

    1.3.3 Orientation and Progression 
     

    2.2.3 Diversity and Equity 
     

    4.2.1(c) Research Training 
     

    5.4 Delivery with Other Parties 
     

    7.1.4 Representation
     

    The provider monitors:

    • student progress within or between units and in research training
    • trends in rates of retention, progression and completion of student cohorts through courses of study
    • participation, progress and completion of identified subgroups through courses of study
    • its arrangements for delivery of education with other parties and the other parties’ performance
    • the performance of agents and other parties representing the provider

    1.4 Learning Outcomes and Assessment 
     

    3.1.5 Course Design 
     

    5.3.1–5.3.4 Monitoring, Review and Improvement 
     

    7.3.3 Information Management

    • at least every 7 years, all accredited courses of study are subject to a comprehensive review covering:
      • course design and content
      • expected learning outcomes
      • methods of assessment
      • student achievement of learning outcomes
      • emerging developments in the field of education
      • modes of delivery
      • changing needs of students
      • identified risks to quality.
    • comprehensive reviews are overseen by academic governance processes
    • comprehensive reviews and improvement activities draw upon external referencing of student cohort success
    • learning outcomes for each course of study are informed by national and international comparators
    • courses of study are professionally accredited by a relevant professional body where accreditation is required for graduates to practice
    • student data is securely and confidentially maintained.

    1.3.5 Orientation and Progression 
     

    2.2.3 Diversity and Equity 
     

    5.3.7 Monitoring, Review and Improvement

    • improvement activities draw upon regular interim monitoring and review, comprehensive reviews, external referencing  and student feedback
    • improvement activities aim to mitigate future quality risks, and use data about student progress to improve admissions criteria, course design, teaching, supervision, learning and academic support. 
    5.3.5 and 5.3.6 Monitoring, Review and Improvement
    • students have regular opportunities to provide feedback, and have membership on governing bodies
    • teachers and supervisors have opportunities to review feedback about their teaching and research supervision.

    6.1.3(d) and 6.2.1(f) Corporate Governance 
     

    6.3.1(b), 6.3.1(d), and 6.3.2 Academic Governance 
     

    6.2.1(f–k) Corporate Monitoring and Accountability 
     

    • competent academic governance processes have been implemented and operate according to an institutional academic governance policy framework
    • academic governance processes provide:
      • effective academic oversight of teaching, learning, research and research training quality
      • institutional benchmark setting and monitoring for academic quality
      • advice to management and the corporate board on academic matters.
    • effective academic oversight of quality is secured through:
      • continuous monitoring, review and improvement of academic policies and, academic and research activity
      • monitoring of potential risks
      • the evaluation of monitoring, review, and improvement processes.
    • there are periodic independent reviews (at least every 7 years) of the effectiveness of the governing body and academic governance processes.  
    Threshold Standards (2021) Part B Key considerations

    B1.2.2, B1.2.5, and B1.2.7–B1.2.9 ‘University College’ Category 
     

    B1.3.2, B1.3.8, B1.3.10, B1.3.12 ‘Australian University’ category 

    • providers registered in either the ‘University College’ or ‘Australian University’ category demonstrate a mature level of development and a track record of compliance regarding:
      • mature and advanced processes for the monitoring, review, quality assurance and improvement of courses of study, and the maintenance of academic integrity
      • identifying, implementing, and sharing good practices in teaching and learning
      • having a sufficient depth of academic leadership and academic expertise to guide teaching, learning and academic governance
      • engagement with employers, industry, or the professions to inform the development, review and improvement of educational offerings.
    B2 Criteria for Seeking Self-Accrediting Authority
    • providers seeking partial self-accrediting authority (SAA) have completed at least one review and improvement cycle, demonstrated successful implementation of evidence-based improvements grounded in monitoring and review, and established effective review and improvement activities across all courses of study
    • providers seeking full SAA also demonstrate, across at least 3 (2-digit) fields of education, mature and advanced processes for:
      • design, delivery, accreditation, quality assurance, monitoring, review and improvement of courses of study
      • the maintenance of academic integrity.

    Obligations applying to providers of education to overseas students in Australia

    Where it applies to a provider, TEQSA considers the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) and the Education Services for Overseas Students Act 2000 (ESOS Act).

    The sections of the National Code relevant to monitoring, review and improvement are 4.1, 4.2.3, 8.1, 8.3, 8.6 – 8.8.

    Sections 4.1 and 4.2.3 require providers engaging an education agent to enter into a written agreement that outline processes for monitoring the agent’s activities, particularly regarding whether the agent is giving students accurate information on the provider’s offerings. The agreement should also include corrective action to be taken if it is determined that the agent is not complying with the terms of the agreement.

    Sections 8.1 and 8.3 require providers to monitor student’s attendance and progress to ensure they are on track to complete their studies in the duration specified by their Certificate of Enrolment. Sections 8.6, 8.7 and 8.8 provide for more detailed requirements for monitoring the attendance and progress of students enrolled in ELICOS, Foundation Programs and higher education programs, and for having intervention strategies to support students when necessary.

    3. Identified issues

    Within the context of the Threshold Standards, TEQSA has identified a range of issues which may indicate potential problems in a provider’s approach to monitoring, review, and improvement:

    Monitoring and data gathering

    • Lack of investment in adequate time, staff, or resources to effectively complete monitoring, data gathering or data analysis, or a lack of focus on areas that pose the greatest risk to students and the integrity of the provider, which may lead to:
      • insufficient data being available to identify problems and engage in evidence-based improvement in areas such as academic integrity, progression, completion, and admissions
      • a failure to monitor or provide support to students with equity backgrounds
      • insufficient oversight of education agents and other third parties, increasing the risk to the students of being misled or receiving a poor quality of education
      • courses being subject to ad-hoc changes.
    • Not monitoring cohorts of students who are more likely to be at risk academically, i.e. students with a low socio-economic status background.
    • Not monitoring English language skills as a risk factor that may impact on students’ successful completion of courses.

    Quality assurance systems

    • Quality assurance systems are absent, too complex, or poorly enacted, which may result in:
      • a provider being unable to validate the quality of its educational offerings
      • courses of study not being sufficiently reviewed or updated.

    Student feedback

    • Lack of timeliness or neglecting student feedback in monitoring and improvement processes, resulting in:
      • failing to adequately address barriers and risks to sub-groups of student cohorts progressing through courses of study
      • the hinderance of course improvement based on the end users’ (students’) experience
      • constraining improvements of other aspects of the student experience including campus and facilities, course enrolment and student information systems, and issues of student wellbeing and safety
      • elevated reputational and market risks.
    • Declining responses to student feedback, which may impact on providers’ approaches to monitoring and review.
    • Lack of mechanisms to screen student feedback to identify abusive or discriminatory comments or feedback that indicates that there may be a risk of harm, resulting in:
      • teachers and supervisors failing to review student feedback due to concerns about psychosocial hazards or harms
      • providers failing to identify students at risk of harm
      • providers failing to protect staff from abusive or discriminatory feedback.

    Integrity of operations

    • Insufficient attention to the integrity of a provider’s operations, including the academic integrity of its offerings, that raises concerns about the credibility and legitimacy of any qualifications issued.

    External referencing

    • A lack of external referencing within an institution limiting the awareness of advances in a particular field of education, leaving a provider ‘reinventing the wheel’ or providing outdated education.
    • A lack of stakeholder perspective via external referencing jeopardising claims about the quality and standing of courses, providers, and the Australian higher education sector more broadly.
    • No involvement of industry stakeholders and advisory boards or other stakeholders external to the institution in benchmarking to ensure graduates are best placed to succeed in their industries.

    Lacking the general capability to monitor, review and improve in a way expected given the character of the provider

    • Absence of any systematic policies and approaches to an ongoing improvement cycle.
    • A lack of mature and advanced processes appropriate to the provider category in which the provider is registered.
    • Failure to systematically collect and analyse data for trend analyses on student progress and success across different cohorts and student subgroups.

    Related resources

    Notes

    1. Explanatory Statement Higher Education Standards Framework (Threshold Standards) 2021, p.11.

    Document information

    Version # Date Key changes
    1.0 19 March 2024 Document finalised
    Subtitle
    Version 1.0
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    Publication type

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