Initial registration

Report on initial registration of ISN Psychology Pty Ltd

TEQSA has determined, under section 21(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), that registration of ISN Psychology Pty Ltd as a higher education provider be granted for a period of seven years to 1 February 2024 in the provider category of 'Higher Education Provider'.

TEQSA has accredited, under section 49 of the TEQSA Act, the following higher education courses of study offered by ISN Psychology Pty Ltd for a period of seven years until 1 February 2024:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)
• Bachelor of Psychological Science

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed a condition on the accreditation of the following three courses of study:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)

Condition 1: ISN Psychology Pty Ltd must not enrol any students in the Master of Psychology (Clinical), Bachelor of Psychology (Honours) or Bachelor of Psychological Science (Honours) until it has obtained from the Australian Psychology Accreditation Council the accreditation status of 'Conditional Accreditation' for these accredited courses of study.

The course accreditation covers delivery at all Australian sites.

Main Reasons for Decision

As part of the initial registration process, TEQSA has assessed the registration and course accreditation for the Master of Psychology (Clinical), Bachelor of Psychology (Honours), Bachelor of Psychological Science (Honours) and Bachelor of Psychological Science submitted by ISN Psychology Pty Ltd against the Higher Education Standards Framework (Threshold Standards) 2011 for Provider Registration and Course Accreditation.

TEQSA considers that the decision to apply a condition to the application for course accreditation by ISN Psychology Pty Ltd is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as ISN Psychology Pty Ltd is at risk of not complying with Provider Registration Standard 6.3 and Provider Course Accreditation Standard 2.4 of the Higher Education Standards Framework (Threshold Standards) 2011, which requires the disclosure to prospective and current students of accurate and current information about the accredited courses of study.

The purpose of the courses is to provide students with a grounding in the study of psychology, with a pathway, through the Master of Psychology (Clinical), to registration as a psychologist. However, if the course does not obtain accreditation from the Australian Psychology Accreditation Council prior to the enrolment of students, there is a substantial risk that students would enrol in the course without being aware that their purpose of enrolment is not capable of being achieved. Accordingly, to address the risk that the courses may not meet the requirements of the Higher Education Standards Framework (Threshold Standards) 2011, TEQSA considers it necessary to impose this condition on the accreditation of the three courses of study.

Initial registration

Report on initial registration of ISN Psychology Pty Ltd

TEQSA has determined, under section 21(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), that registration of ISN Psychology Pty Ltd as a higher education provider be granted for a period of seven years to 1 February 2024 in the provider category of 'Higher Education Provider'.

TEQSA has accredited, under section 49 of the TEQSA Act, the following higher education courses of study offered by ISN Psychology Pty Ltd for a period of seven years until 1 February 2024:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)
• Bachelor of Psychological Science

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed a condition on the accreditation of the following three courses of study:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)

Condition 1: ISN Psychology Pty Ltd must not enrol any students in the Master of Psychology (Clinical), Bachelor of Psychology (Honours) or Bachelor of Psychological Science (Honours) until it has obtained from the Australian Psychology Accreditation Council the accreditation status of 'Conditional Accreditation' for these accredited courses of study.

The course accreditation covers delivery at all Australian sites.

Main Reasons for Decision

As part of the initial registration process, TEQSA has assessed the registration and course accreditation for the Master of Psychology (Clinical), Bachelor of Psychology (Honours), Bachelor of Psychological Science (Honours) and Bachelor of Psychological Science submitted by ISN Psychology Pty Ltd against the Higher Education Standards Framework (Threshold Standards) 2011 for Provider Registration and Course Accreditation.

TEQSA considers that the decision to apply a condition to the application for course accreditation by ISN Psychology Pty Ltd is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as ISN Psychology Pty Ltd is at risk of not complying with Provider Registration Standard 6.3 and Provider Course Accreditation Standard 2.4 of the Higher Education Standards Framework (Threshold Standards) 2011, which requires the disclosure to prospective and current students of accurate and current information about the accredited courses of study.

The purpose of the courses is to provide students with a grounding in the study of psychology, with a pathway, through the Master of Psychology (Clinical), to registration as a psychologist. However, if the course does not obtain accreditation from the Australian Psychology Accreditation Council prior to the enrolment of students, there is a substantial risk that students would enrol in the course without being aware that their purpose of enrolment is not capable of being achieved. Accordingly, to address the risk that the courses may not meet the requirements of the Higher Education Standards Framework (Threshold Standards) 2011, TEQSA considers it necessary to impose this condition on the accreditation of the three courses of study.

Initial registration

Report on initial registration of ISN Psychology Pty Ltd

TEQSA has determined, under section 21(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), that registration of ISN Psychology Pty Ltd as a higher education provider be granted for a period of seven years to 1 February 2024 in the provider category of 'Higher Education Provider'.

TEQSA has accredited, under section 49 of the TEQSA Act, the following higher education courses of study offered by ISN Psychology Pty Ltd for a period of seven years until 1 February 2024:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)
• Bachelor of Psychological Science

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed a condition on the accreditation of the following three courses of study:

• Master of Psychology (Clinical)
• Bachelor of Psychology (Honours)
• Bachelor of Psychological Science (Honours)

Condition 1: ISN Psychology Pty Ltd must not enrol any students in the Master of Psychology (Clinical), Bachelor of Psychology (Honours) or Bachelor of Psychological Science (Honours) until it has obtained from the Australian Psychology Accreditation Council the accreditation status of 'Conditional Accreditation' for these accredited courses of study.

The course accreditation covers delivery at all Australian sites.

Main Reasons for Decision

As part of the initial registration process, TEQSA has assessed the registration and course accreditation for the Master of Psychology (Clinical), Bachelor of Psychology (Honours), Bachelor of Psychological Science (Honours) and Bachelor of Psychological Science submitted by ISN Psychology Pty Ltd against the Higher Education Standards Framework (Threshold Standards) 2011 for Provider Registration and Course Accreditation.

TEQSA considers that the decision to apply a condition to the application for course accreditation by ISN Psychology Pty Ltd is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as ISN Psychology Pty Ltd is at risk of not complying with Provider Registration Standard 6.3 and Provider Course Accreditation Standard 2.4 of the Higher Education Standards Framework (Threshold Standards) 2011, which requires the disclosure to prospective and current students of accurate and current information about the accredited courses of study.

The purpose of the courses is to provide students with a grounding in the study of psychology, with a pathway, through the Master of Psychology (Clinical), to registration as a psychologist. However, if the course does not obtain accreditation from the Australian Psychology Accreditation Council prior to the enrolment of students, there is a substantial risk that students would enrol in the course without being aware that their purpose of enrolment is not capable of being achieved. Accordingly, to address the risk that the courses may not meet the requirements of the Higher Education Standards Framework (Threshold Standards) 2011, TEQSA considers it necessary to impose this condition on the accreditation of the three courses of study.

Renewal of registration and accreditation

Report on renewal of registration and accreditation of JMC Pty Limited

TEQSA has renewed the registration as a higher education provider, under Section 36(1) of the Tertiary Education Quality and Standards Act 2011 (TEQSA Act), of JMC Pty Limited (JMC) until 31 December 2019 in the provider category of Higher Education Provider.

TEQSA has, under subsection 32(1) of the TEQSA Act, imposed two conditions on the registration of JMC as a higher education provider.

Condition 1:

JMC to report annually on 31 January until further notice on implementation of the Action Plan developed in response to TEQSA's summary of findings. The report must provide documentary evidence of action taken and consideration by the governing body and Academic Board, including:

• Risk Framework including both academic and non-academic risk areas (the framework itself to be submitted by 31 January 2017)
• New Strategic Plan (the plan itself to be submitted by 31 January 2017)
• New Learning and Teaching Plan (the plan itself to be submitted by 31 January 2017)
• Self-Review of the Academic Board
• Academic Policies and Procedures
• Improved processes for monitoring, review and improvement, including across campuses
  
  • student performance data such as attrition, progression and completion rates, by entry pathway, mode of study and place of study
• Professional development and scholarship activities of all staff (the policies and procedures to be submitted by 31 January 2017)
• JMC Benchmarking Framework
• Workforce profile, including reports for each campus on the number of staff employed, position, qualification level relative to the course taught.

Condition 2:

JMC to submit its policy register which contains the status, origin date, last review date, next review date, and date of approval of all policies and procedures (academic and non-academic) by 31 January 2017, and evidence of ongoing implementation each year on 31 January until further notice.

TEQSA has also renewed the accreditation, under section 56 of the TEQSA Act, of the following higher education courses of study offered by JMC until 31 December 2019:

• Bachelor of Creative Technology (Audio Engineering and Sound Production)
• Associate Degree of Audio Engineering and Sound Production
• Diploma of Audio Engineering and Sound Production.

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed three conditions on the accreditation of the above courses of study.

Condition 1:

By 31 January 2017, JMC must complete its planned review of the courses including a thorough review against AQF level 5, 6 and 7 requirements, by a committee including at least two independent experts in the field of education, with the particular academics to be approved by TEQSA. The review must include consideration of the TEQSA external expert report, TEQSA draft summary of findings, and include the revised unit outlines and a summary of the changes made to the versions of units submitted to TEQSA in April 2015.

Condition 2:

JMC to submit approved policies/procedures relating to the admission criteria for the courses, covering standard admission requirements, special admission (mature age and other), and English language requirements as per Provider Course Accreditation Standards Section 3 by 31 January 2017.

Condition 3:

JMC to report on admission decisions by education qualification, other criteria, or non-academic criteria for all courses over the last 2 years by 31 January 2017.

Main Reasons for Decision

As part of the renewal of registration and accreditation process, TEQSA has assessed the applications submitted by JMC against the Threshold Standards. The scope of the assessment included all its Australian sites.

TEQSA found that JMC meets the Threshold Standards overall, and that many elements of the required governance and policy frameworks are in place. JMC has reinforced its capability to further review and develop these frameworks and to ensure they are implemented consistently.

TEQSA considers that the decision to apply conditions to JMC's registration and accreditation is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as JMC is at risk of not complying with a number of the Threshold Standards.

• The broad issues which relate to JMC's registration include risks relating to:

  a) the corporate governing body effectively monitoring, developing and implementing mitigating strategies to address identified critical risks

  b) the corporate governing body approving a current strategic plan that guides management decision making and through which actual performance and outcomes are measured against key performance indicators

  c) corporate and academic governance arrangements effectively quality assuring its higher education operations through systematic monitoring, review and improvement, and maintaining academic standards

  d) human resources being managed to ensure effective professional development of its personnel and that academic staff are active in scholarship that informs their teaching

  e) use of benchmarking and feedback to improve its higher education operations

  f) maintaining appropriately qualified personnel to manage and provide academic leadership for its higher education operations

  g) effective development, implementation and review of all policies and procedures.

• The broad issues which relate to JMC's course accreditations include risks relating to:

  a) ensuring compliance of unit and course learning outcomes to the Qualification Standards

  b) providing appropriate engagement by students in intellectual inquiry consistent with the nature and level of all units being taught and the expected learning outcomes

  c) admissions criteria ensuring that students have adequate prior knowledge and skills to undertake the courses of study successfully.

Renewal of registration and accreditation

Report on renewal of registration and accreditation of JMC Pty Limited

TEQSA has renewed the registration as a higher education provider, under Section 36(1) of the Tertiary Education Quality and Standards Act 2011 (TEQSA Act), of JMC Pty Limited (JMC) until 31 December 2019 in the provider category of Higher Education Provider.

TEQSA has, under subsection 32(1) of the TEQSA Act, imposed two conditions on the registration of JMC as a higher education provider.

Condition 1:

JMC to report annually on 31 January until further notice on implementation of the Action Plan developed in response to TEQSA's summary of findings. The report must provide documentary evidence of action taken and consideration by the governing body and Academic Board, including:

• Risk Framework including both academic and non-academic risk areas (the framework itself to be submitted by 31 January 2017)
• New Strategic Plan (the plan itself to be submitted by 31 January 2017)
• New Learning and Teaching Plan (the plan itself to be submitted by 31 January 2017)
• Self-Review of the Academic Board
• Academic Policies and Procedures
• Improved processes for monitoring, review and improvement, including across campuses
  
  • student performance data such as attrition, progression and completion rates, by entry pathway, mode of study and place of study
• Professional development and scholarship activities of all staff (the policies and procedures to be submitted by 31 January 2017)
• JMC Benchmarking Framework
• Workforce profile, including reports for each campus on the number of staff employed, position, qualification level relative to the course taught.

Condition 2:

JMC to submit its policy register which contains the status, origin date, last review date, next review date, and date of approval of all policies and procedures (academic and non-academic) by 31 January 2017, and evidence of ongoing implementation each year on 31 January until further notice.

TEQSA has also renewed the accreditation, under section 56 of the TEQSA Act, of the following higher education courses of study offered by JMC until 31 December 2019:

• Bachelor of Creative Technology (Audio Engineering and Sound Production)
• Associate Degree of Audio Engineering and Sound Production
• Diploma of Audio Engineering and Sound Production.

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed three conditions on the accreditation of the above courses of study.

Condition 1:

By 31 January 2017, JMC must complete its planned review of the courses including a thorough review against AQF level 5, 6 and 7 requirements, by a committee including at least two independent experts in the field of education, with the particular academics to be approved by TEQSA. The review must include consideration of the TEQSA external expert report, TEQSA draft summary of findings, and include the revised unit outlines and a summary of the changes made to the versions of units submitted to TEQSA in April 2015.

Condition 2:

JMC to submit approved policies/procedures relating to the admission criteria for the courses, covering standard admission requirements, special admission (mature age and other), and English language requirements as per Provider Course Accreditation Standards Section 3 by 31 January 2017.

Condition 3:

JMC to report on admission decisions by education qualification, other criteria, or non-academic criteria for all courses over the last 2 years by 31 January 2017.

Main Reasons for Decision

As part of the renewal of registration and accreditation process, TEQSA has assessed the applications submitted by JMC against the Threshold Standards. The scope of the assessment included all its Australian sites.

TEQSA found that JMC meets the Threshold Standards overall, and that many elements of the required governance and policy frameworks are in place. JMC has reinforced its capability to further review and develop these frameworks and to ensure they are implemented consistently.

TEQSA considers that the decision to apply conditions to JMC's registration and accreditation is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as JMC is at risk of not complying with a number of the Threshold Standards.

• The broad issues which relate to JMC's registration include risks relating to:

  a) the corporate governing body effectively monitoring, developing and implementing mitigating strategies to address identified critical risks

  b) the corporate governing body approving a current strategic plan that guides management decision making and through which actual performance and outcomes are measured against key performance indicators

  c) corporate and academic governance arrangements effectively quality assuring its higher education operations through systematic monitoring, review and improvement, and maintaining academic standards

  d) human resources being managed to ensure effective professional development of its personnel and that academic staff are active in scholarship that informs their teaching

  e) use of benchmarking and feedback to improve its higher education operations

  f) maintaining appropriately qualified personnel to manage and provide academic leadership for its higher education operations

  g) effective development, implementation and review of all policies and procedures.

• The broad issues which relate to JMC's course accreditations include risks relating to:

  a) ensuring compliance of unit and course learning outcomes to the Qualification Standards

  b) providing appropriate engagement by students in intellectual inquiry consistent with the nature and level of all units being taught and the expected learning outcomes

  c) admissions criteria ensuring that students have adequate prior knowledge and skills to undertake the courses of study successfully.

Renewal of registration and accreditation

Report on renewal of registration and accreditation of JMC Pty Limited

TEQSA has renewed the registration as a higher education provider, under Section 36(1) of the Tertiary Education Quality and Standards Act 2011 (TEQSA Act), of JMC Pty Limited (JMC) until 31 December 2019 in the provider category of Higher Education Provider.

TEQSA has, under subsection 32(1) of the TEQSA Act, imposed two conditions on the registration of JMC as a higher education provider.

Condition 1:

JMC to report annually on 31 January until further notice on implementation of the Action Plan developed in response to TEQSA's summary of findings. The report must provide documentary evidence of action taken and consideration by the governing body and Academic Board, including:

• Risk Framework including both academic and non-academic risk areas (the framework itself to be submitted by 31 January 2017)
• New Strategic Plan (the plan itself to be submitted by 31 January 2017)
• New Learning and Teaching Plan (the plan itself to be submitted by 31 January 2017)
• Self-Review of the Academic Board
• Academic Policies and Procedures
• Improved processes for monitoring, review and improvement, including across campuses
  
  • student performance data such as attrition, progression and completion rates, by entry pathway, mode of study and place of study
• Professional development and scholarship activities of all staff (the policies and procedures to be submitted by 31 January 2017)
• JMC Benchmarking Framework
• Workforce profile, including reports for each campus on the number of staff employed, position, qualification level relative to the course taught.

Condition 2:

JMC to submit its policy register which contains the status, origin date, last review date, next review date, and date of approval of all policies and procedures (academic and non-academic) by 31 January 2017, and evidence of ongoing implementation each year on 31 January until further notice.

TEQSA has also renewed the accreditation, under section 56 of the TEQSA Act, of the following higher education courses of study offered by JMC until 31 December 2019:

• Bachelor of Creative Technology (Audio Engineering and Sound Production)
• Associate Degree of Audio Engineering and Sound Production
• Diploma of Audio Engineering and Sound Production.

TEQSA has, under subsection 53(1) of the TEQSA Act, imposed three conditions on the accreditation of the above courses of study.

Condition 1:

By 31 January 2017, JMC must complete its planned review of the courses including a thorough review against AQF level 5, 6 and 7 requirements, by a committee including at least two independent experts in the field of education, with the particular academics to be approved by TEQSA. The review must include consideration of the TEQSA external expert report, TEQSA draft summary of findings, and include the revised unit outlines and a summary of the changes made to the versions of units submitted to TEQSA in April 2015.

Condition 2:

JMC to submit approved policies/procedures relating to the admission criteria for the courses, covering standard admission requirements, special admission (mature age and other), and English language requirements as per Provider Course Accreditation Standards Section 3 by 31 January 2017.

Condition 3:

JMC to report on admission decisions by education qualification, other criteria, or non-academic criteria for all courses over the last 2 years by 31 January 2017.

Main Reasons for Decision

As part of the renewal of registration and accreditation process, TEQSA has assessed the applications submitted by JMC against the Threshold Standards. The scope of the assessment included all its Australian sites.

TEQSA found that JMC meets the Threshold Standards overall, and that many elements of the required governance and policy frameworks are in place. JMC has reinforced its capability to further review and develop these frameworks and to ensure they are implemented consistently.

TEQSA considers that the decision to apply conditions to JMC's registration and accreditation is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as JMC is at risk of not complying with a number of the Threshold Standards.

• The broad issues which relate to JMC's registration include risks relating to:

  a) the corporate governing body effectively monitoring, developing and implementing mitigating strategies to address identified critical risks

  b) the corporate governing body approving a current strategic plan that guides management decision making and through which actual performance and outcomes are measured against key performance indicators

  c) corporate and academic governance arrangements effectively quality assuring its higher education operations through systematic monitoring, review and improvement, and maintaining academic standards

  d) human resources being managed to ensure effective professional development of its personnel and that academic staff are active in scholarship that informs their teaching

  e) use of benchmarking and feedback to improve its higher education operations

  f) maintaining appropriately qualified personnel to manage and provide academic leadership for its higher education operations

  g) effective development, implementation and review of all policies and procedures.

• The broad issues which relate to JMC's course accreditations include risks relating to:

  a) ensuring compliance of unit and course learning outcomes to the Qualification Standards

  b) providing appropriate engagement by students in intellectual inquiry consistent with the nature and level of all units being taught and the expected learning outcomes

  c) admissions criteria ensuring that students have adequate prior knowledge and skills to undertake the courses of study successfully.

Renewal of course accreditations

Report on renewal of accreditation of two higher education courses of study offered by Top Education Pty Ltd

A delegate of TEQSA has renewed the accreditation, under Section 56 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), of the following higher education courses of study offered by Top Education Pty Ltd for a period of seven years until 30 June 2023.

• Graduate Diploma of Accounting
• Graduate Certificate in Accounting

Main reasons for decision

TEQSA has determined that the two higher education courses of study submitted by Top Education Pty Ltd for accreditation comply with the Provider Course Accreditation Standards and arrangements for delivery at all Australian sites.

Renewal of course accreditations

Report on renewal of accreditation of two higher education courses of study offered by Top Education Pty Ltd

A delegate of TEQSA has renewed the accreditation, under Section 56 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), of the following higher education courses of study offered by Top Education Pty Ltd for a period of seven years until 30 June 2023.

• Graduate Diploma of Accounting
• Graduate Certificate in Accounting

Main reasons for decision

TEQSA has determined that the two higher education courses of study submitted by Top Education Pty Ltd for accreditation comply with the Provider Course Accreditation Standards and arrangements for delivery at all Australian sites.

Renewal of registration

Report on the application for renewal of registration of ParaPharm Pty Ltd

TEQSA has agreed to orders made by the Administrative Appeals Tribunal under which the registration of ParaPharm Pty Ltd trading as Paramount College of Natural Medicine as a higher education provider will be renewed until 31 December 2019 under subsection 36(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act) in the provider category of 'Higher Education Provider'.

These orders also involve the imposition of conditions on the registration of ParaPharm Pty Ltd under subsection 32(1) of the TEQSA Act. A copy of the conditions is available at Attachment 1.

TEQSA has also agreed to orders made by the Administrative Appeals Tribunal under which:

• the accreditation of the following courses of study offered by ParaPharm Pty Ltd is renewed until 31 December 2019 under subsection 56(1) of the TEQSA Act:
  
  • Bachelor of Health Science (Naturopathy)
  • Bachelor of Health Science (Nutritional Medicine)
  • Bachelor of Health Science (Western Herbal Medicine)

• pursuant to section 57A of the TEQSA Act, the deemed accreditation of ParaPharm Pty Ltd' Bachelor of Health Science (Homoeopathy) course of study under item 18 of Schedule 3 of the Tertiary Education Quality and Standards Agency (Consequential Amendments and Transitional Provisions) Act 2011 (Cth) is extended until 24 February 2017, and

• pursuant to section 57A of the TEQSA Act, the deemed accreditation of ParaPharm Pty Ltd's Bachelor of Health Science (Mind Body Medicine) course of study under item 18 of Schedule 3 of the Tertiary Education Quality and Standards Agency (Consequential Amendments and Transitional Provisions) Act 2011 (Cth) is extended until 31 July 2017.

As a result of these orders the Bachelor of Health Science (Homoeopathy) and Bachelor of Health Science (Mind Body Medicine) will cease to be offered by ParaPharm Pty Ltd as at 25 February 2017 and 31 July 2017 respectively.

These orders also involve the imposition of conditions on the accreditation of the Bachelor of Health Science (Mind Body Medicine) under subsection 53(1) of the TEQSA Act. A copy of the conditions is available at Attachment 2.

Background to Decision

ParaPharm Pty Ltd applied to TEQSA for registration in the category of Higher Education Provider under Part 3 of the TEQSA Act.

TEQSA considered ParaPharm Pty Ltd's application and sent ParaPharm Pty Ltd a draft summary of findings with details of the assessment of ParaPharm Pty Ltd's application by the responsible case management team. TEQSA's Commission considered ParaPharm Pty Ltd's response to the draft summary of findings and made a decision to not grant ParaPharm Pty Ltd's application for registration and the renewal of accreditation of five courses of study on 24 June 2015 on the basis that it was not satisfied that ParaPharm Pty Ltd met the Threshold Standards.

TEQSA's reasons for not granting ParaPharm Pty Ltd's application included, but were not confined to, TEQSA's lack of satisfaction that ParaPharm Pty Ltd:

• Ensured its course design was appropriate and consistent with the Qualification Standards and that assessment ensured learning outcomes were achieved;
• Ensured that staff who teach in the course of study were appropriately qualified
• Had the financial resources and financial management capacity to sustain higher education operations
• Showed sound corporate and academic governance
• Managed its higher education operations and its human resources appropriately
• Ensured there are safe, well-maintained physical and electronic resources and infrastructure sufficient to enable the achievement of its higher education objectives

ParaPharm Pty Ltd applied for review of TEQSA's decision in the Administrative Appeals Tribunal (AAT). In the course of the proceedings, ParaPharm Pty Ltd made submissions and provided further information and evidence about the matters raised in TEQSA's decisions.

TEQSA engaged external experts to review the further material.

It is well established that absent a specific legislative provision to the contrary, the AAT is generally required to make a decision on review based on the evidence available at the time of the AAT's decision on review, and that the AAT is not confined to the evidence available at the time of the primary decision. Accordingly, TEQSA accepted that the AAT was required to take account of the further material submitted to TEQSA after TEQSA had not granted ParaPharm Pty Ltd's application.

Main Reasons for Decision

After reviewing the further material submitted by ParaPharm Pty Ltd and participating in mediation with ParaPharm Pty Ltd, TEQSA was satisfied that ParaPharm Pty Ltd meets the Threshold Standards. However TEQSA considered that there remained a number of risks related to ParaPharm Pty Ltd's capacity to meet the Threshold Standards in the future. On this basis, TEQSA agreed that it was appropriate to substitute TEQSA's initial decision to not grant the application with decisions to register ParaPharm Pty Ltd until 31 December 2019 and to impose a number of conditions on that registration.

The conditions are designed to address the following risks:

• The effectiveness of ParaPharm Pty Ltd's corporate and academic governance of its higher education operations and ParaPharm Pty Ltd's capacity to manage and effectively quality assure those operations in accordance with Provider Registration Standards (PRS) 3.7 and 3.8 and Provider Course Accreditation Standard (PCAS) 6.1;
• The quality of the courses of study in accordance with PCAS 1.1, 1.3, 1.7 and 5.1 and Qualification Standard 1.1; and
• The application of sufficient and appropriate resources to ensure the numbers, qualifications, experience and expertise of staff is appropriate to teach the courses of study in accordance with PCAS 4.1 and 4.2; and
• The adequacy of physical and information resources in accordance with PRS 2.1, 2.2, 7.1 and 7.2 and PCAS 2.1, 2.2 and 2.3,

TEQSA is satisfied that the conditions will provide a framework for TEQSA to oversee the key risks associated with ParaPharm Pty Ltd's corporate and academic governance arrangements and the quality assurance of its higher education operations. The conditions will also enable TEQSA to closely monitor the effectiveness of ParaPharm Pty Ltd's response to expert findings in relation to its courses of study.

In accordance with subsections 32(2) and 32(3) of the TEQSA Act, TEQSA may vary or revoke a condition imposed on the registration of a higher education provider, either on its own initiative, or upon application by the provider for variation or revocation. Accordingly, TEQSA will have the capacity to vary or revoke the conditions as ParaPharm Pty Ltd addresses the risks identified above., particularly in relation to the course design and arrangements for clinical practice, The adequacy of physical and information resources and the corporate and academic governance practices of the College.

Attachment 1

Conditions imposed on the registration of ParaPharm Pty Ltd trading as Paramount College of Natural Medicine:

i. ParaPharm Pty Ltd must review the following three courses of study:

• Bachelor of Health Science (Naturopathy)
• Bachelor of Health Science (Nutritional Medicine)
• Bachelor of Health Science (Western Herbal Medicine).

  and its information resources in light of the matters described in the 2016 expert reports and, within three months of the date of these orders, provide TEQSA with the following:

  1. a list of the changes to be made to each of the courses;
  2. evidence that the changes have been considered and approved by ParaPharm Pty Ltd's Academic Committee; and
  3. evidence from an independent expert (approved by TEQSA prior to his/her appointment) that the revised courses and information resources will allow students to achieve the learning outcomes of the courses (Condition 1);

ii. ParaPharm Pty Ltd must not enrol any new students in the following three courses of study:

• Bachelor of Health Science (Naturopathy)
• Bachelor of Health Science (Nutritional Medicine)
• Bachelor of Health Science (Western Herbal Medicine).

  until A and B of Condition 1 are met (Condition 2);

iii. ParaPharm Pty Ltd must, within one month of the date of these orders and, at least one month prior to the beginning of each financial year in which it is registered, provide TEQSA with the following:

1. a budget describing ParaPharm Pty Ltd's planned expenditure on staffing, facilities and educational resources for the financial year, which includes details on how ParaPharm Pty Ltd intends to address the concerns raised in the 2016 expert reports in relation to the currency of ParaPharm Pty Ltd's information resources and the adequacy of ParaPharm Pty Ltd's physical facilities (particularly its specialised facilities); and
2. evidence that the budget has been considered and approved by ParaPharm Pty Ltd's Board of Governors, with the benefit of advice from the ParaPharm Pty Ltd's Academic Committee (Condition 3);

iv. For six months from the date of these orders, ParaPharm Pty Ltd must provide TEQSA with a copy of the minutes of each meeting of its Board of governors and Academic Committee (minutes) no later than 21 days after the meeting takes place. After the initial six month period, ParaPharm Pty Ltd must provide the minutes no later than two weeks after the date the meeting takes place. The minutes must:

1. demonstrate a process consistent with the TEQSA Guidance Notes for the relevant bodies on the matters the subject of discussion;
2. include consideration of the matters required to be considered by the relevant bodies under the Higher Education Standards Framework, including risk management, delegations, course review, student performance, financial sustainability, facilities and staffing; and
3. specify the extent to which the discussion took account of external advice or input(Condition 4);

v. Within one month of the date of these orders, ParaPharm Pty Ltd must provide to TEQSA revised position descriptions for its Faculty Manager and another person or other persons, which set out the specific responsibilities of those staff to guide and support students to access library and information resources (Condition 5); and

vi. Within six months after the date of these orders, ParaPharm Pty Ltd must provide TEQSA with a report from an independent external expert (approved by TEQSA prior to his/her appointment), which reviews ParaPharm Pty Ltd's clinic arrangements and confirms that those arrangements provide for appropriate supervision, resources and student experiences to prepare students for practice in the field of their course of study (Condition 6).

Attachment 2

Conditions imposed on the accreditation of the Bachelor of Health Science (Mind Body Medicine) offered by ParaPharm Pty Ltd trading as Paramount College of Natural Medicine:

i. ParaPharm Pty Ltd must not enrol, or allow to be enrolled, any new students in the Bachelor of Health Science (Mind Body Medicine) course (Condition 1);

ii. any students currently enrolled in the Bachelor of Health Sciences (Mind Body Medicine) course who are scheduled to complete the course by 31 July 2017 may continue studying the course (Condition 2); and

iii. any students currently enrolled in the Bachelor of Health Sciences (Mind Body Medicine) course who are not scheduled to complete the course by 31 July 2017 must be transferred to another appropriate course or be provided with an appropriate refund within three months of the date of these orders (Condition 3).