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).

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).

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).

Imposing a condition on accreditation

Report on imposing one condition on the accreditation two higher education course of study offered by Raffles College Pty Ltd (t/a Raffles College of Design and Commerce ("RCDC"))

On 9 June 2016, a delegate of TEQSA imposed, under subsection 53(1) of the TEQSA Act, one condition on the accreditation of the following courses of study:

• Bachelor of Design
• Bachelor of Arts (Visual Communication)

Condition 1

RCDC must arrange for an independent and external review of the library and learning resources for students of RCDC's higher education courses in Hong Kong and Kuala Lumpur. If a reviewer other than Ms Selena Griffith is to conduct the review RCDC must obtain TEQSA's approval for the reviewer before appointing the reviewer. The report arising from the review must be provided to TEQSA and RCDC simultaneously and not later than 24 June 2016.

Main Reasons for the Decision

TEQSA considers that the decision to apply a condition on the accreditation of the Bachelor of Design and Bachelor of Arts (Visual Communication) courses of study is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as it is a necessary and proportionate response to risks that RCDC is not complying with Provider Course Accreditation Standards (PCAS) 1.9, 2.2, 2.3 and 2.4.

TEQSA notes that RCDC agreed to the imposition of this condition.

On 10 March 2016, a delegate of TEQSA imposed, under subsection 53(1) of the TEQSA Act, one condition on the accreditation of the following courses of study:

• Bachelor of Design
• Bachelor of Arts (Visual Communication)

Condition 1

RCDC provide TEQSA by 30 April 2016, in respect of its Kuala Lumpur and Hong Kong associate college delivery sites, evidence of:

1. the acquisition of appropriate on-line and physical library holdings and resources;
2. a report from an independent discipline expert or librarian on the appropriateness of library resources at both sites; and
3. access to appropriately qualified library support staff at both associate college delivery sites to support the delivery of the courses.

The independent expert report provided under paragraph b of this condition expressed concern about the functionality and adequacy of resourcing of the libraries in Hong Kong and Kuala Lumpur.

While TEQSA considered further information provided by RCDC, TEQSA remained of the view that RCDC is at risk of not complying with the PCAS in respect of:

• PCAS 2.2, 2.3 and 2.4 relating to the adequacy of course resourcing and of access to library and information services, and to the adequacy of IT resources; and
• PCAS 1.9 in respect of the courses ensuring equivalent student learning outcomes regardless of a student's place or mode of study

Imposing a condition on accreditation

Report on imposing one condition on the accreditation two higher education course of study offered by Raffles College Pty Ltd (t/a Raffles College of Design and Commerce ("RCDC"))

On 9 June 2016, a delegate of TEQSA imposed, under subsection 53(1) of the TEQSA Act, one condition on the accreditation of the following courses of study:

• Bachelor of Design
• Bachelor of Arts (Visual Communication)

Condition 1

RCDC must arrange for an independent and external review of the library and learning resources for students of RCDC's higher education courses in Hong Kong and Kuala Lumpur. If a reviewer other than Ms Selena Griffith is to conduct the review RCDC must obtain TEQSA's approval for the reviewer before appointing the reviewer. The report arising from the review must be provided to TEQSA and RCDC simultaneously and not later than 24 June 2016.

Main Reasons for the Decision

TEQSA considers that the decision to apply a condition on the accreditation of the Bachelor of Design and Bachelor of Arts (Visual Communication) courses of study is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as it is a necessary and proportionate response to risks that RCDC is not complying with Provider Course Accreditation Standards (PCAS) 1.9, 2.2, 2.3 and 2.4.

TEQSA notes that RCDC agreed to the imposition of this condition.

On 10 March 2016, a delegate of TEQSA imposed, under subsection 53(1) of the TEQSA Act, one condition on the accreditation of the following courses of study:

• Bachelor of Design
• Bachelor of Arts (Visual Communication)

Condition 1

RCDC provide TEQSA by 30 April 2016, in respect of its Kuala Lumpur and Hong Kong associate college delivery sites, evidence of:

1. the acquisition of appropriate on-line and physical library holdings and resources;
2. a report from an independent discipline expert or librarian on the appropriateness of library resources at both sites; and
3. access to appropriately qualified library support staff at both associate college delivery sites to support the delivery of the courses.

The independent expert report provided under paragraph b of this condition expressed concern about the functionality and adequacy of resourcing of the libraries in Hong Kong and Kuala Lumpur.

While TEQSA considered further information provided by RCDC, TEQSA remained of the view that RCDC is at risk of not complying with the PCAS in respect of:

• PCAS 2.2, 2.3 and 2.4 relating to the adequacy of course resourcing and of access to library and information services, and to the adequacy of IT resources; and
• PCAS 1.9 in respect of the courses ensuring equivalent student learning outcomes regardless of a student's place or mode of study

Initial registration

Report on initial registration of National Institute of Organisation Dynamics Australia Ltd (NIODA)

TEQSA has determined, under subsection 21(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), that registration of the National Institute of Organisation Dynamics Australia Ltd as a higher education provider be granted for a period of four years to 13 October 2020 in the provider category of 'Higher Education Provider'.

TEQSA has, under subsection 32(1) of the TEQSA Act, imposed seven conditions on the registration of the National Institute of Organisation Dynamics Australia Ltd as a higher education provider.

Condition 1:

Within three months of the notice of decision (and prior to enrolment of any students), NIODA is required to supply TEQSA with evidence demonstrating that it has in place formal arrangements with an external authority for referral of student grievances which have not been resolved within the organisation.

Condition 2:

Within three months of the notice of decision (and prior to enrolment of any students), NIODA is to provide details of arrangements for students to complete an equivalent course with a suitable Australian-registered higher education provider in the event that NIODA does not have capacity to teach out the course.

Condition 3:

NIODA must notify TEQSA within two weeks of being notified by the CAE/Box Hill Institute that it proposes to change the arrangements for use of space at the CAE.

Condition 4:

NIODA is to inform TEQSA in the event that the actual staffing expenditure falls 10% or more below those shown in the revised projected income and expenditure statement submitted to TEQSA on 6 June 2016. In addition, NIODA is to inform TEQSA in the event that staffing positions are not filled or significantly reduced in FTE during the registration period on the basis of the projected staff numbers submitted to TEQSA on 6 June 2016.

Condition 5:

In the event that the contingency fund is accessed, NIODA must inform TEQSA within two business days and must provide a revised financial forecast (including financial projection in the form of income statement, balance sheet, cash flow statement and student projection) within one month.

Condition 6:

NIODA is to provide a revised financial forecast (including financial projection in the form of income statement, balance sheet, cash flow statement and student projection) if student enrolments in the first year of the Master program are below commencing numbers of students in the projected student numbers submitted to TEQSA on 6 June 2016.

Condition 7:

Within six months from the notice of decision, NIODA is to provide TEQSA with a detailed scholarship plan which outlines the scholarship objectives and costings for research and scholarship activities for the period 2017-2020.

TEQSA has accredited, under section 49 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), the following higher education course of study offered by the National Institute of Organisation Dynamics Australia Ltd for a period of seven years until 13 October 2023:

• Master of Management (Organisation Dynamics)

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

Condition 1:

Within three months of the notice of decision NIODA is required to:

a) Review the subject Socio-technics and Organisation Design (MM1) in the course;

b) Identify suitable changes to MM1 to include a range of organisational management theories in the reading and suitable activities to demonstrate that these theories are critiqued within the MM1 subject; and

c) Provide TEQSA with evidence to demonstrate that the changes described in paragraphs (a) and (b) of Condition 1 have been implemented.

Condition 2:

Within three months of the notice of decision, NIODA is required to:

(a) Review the assessment tasks for the subjects: Systems Psychodynamic Consulting (MM4), Organisational Role Analysis (MM6) and Authority and Leadership for Role and Task(MM8);

(b) Ensure that there are a variety of assessment tasks included in each subject;

(c) Develop a chart showing how the assessment tasks will enable students to achieve the proposed student learning outcomes; and

(d) Provide TEQSA with evidence to demonstrate that the changes described in paragraphs (a), (b) and (c) of Condition 2 have been implemented.

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 Management (Organisation Dynamics) submitted by the National Institute of Organisation Dynamics Australia Ltd against the Threshold Standards for Provider Registration and Course Accreditation.

NIODA has demonstrated that it complies with the seven sections of the Provider Registration Standards (PRS). TEQSA considers that the decision to shorten the registration and apply conditions is to address a number of matters that may affect NIODA's capacity to manage and deliver its higher education awards.

• The broad issues which relate to NIODA's registration are risks that:

  a) NIODA may fail to realise its projected student numbers in the future, with implications for meeting its objectives for scholarship and provision of adequate staffing, facilities and resources;

  b) a change in arrangements with Box Hill Institute's facilities may be detrimental to the interests of enrolled students;

  c) NIODA's current arrangements may not adequately ensure that NIODA is able to meet its responsibility to maintain business continuity and safeguard the interests of students should NIODA cease to operate; and

  d) NIODA may not have effective arrangements to ensure the equitable treatment of students through the appointment of an external arbiter for student complaints.

• The broad issues which relate to the Master of Management (Organisation Dynamics) include:

  a) NIODA is at risk of non-compliance with PCAS 1.7 as students may not achieve a wider understanding of organizational management and achieve a greater depth in thinking due to the limited theoretical points of view presented in the literature and assessment.

  b) NIODA is at risk of failing to satisfy PCAS 1.5 as some subjects are assessed with one learning task and the single assessment tasks may not provide sufficient opportunities for students to demonstrate achievement of expected learning outcomes.

Course accreditation

Report on accreditation of one higher education course of study offered by Institute of Health & Management Pty Ltd

A delegate of TEQSA has accredited, under section 49 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), the following higher education course of study offered by Institute of Health & Management Pty Ltd (IHM) for a period of seven years until 23 September 2023

• Graduate Certificate in Nursing (Program For Internationally Qualified Nurses)

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

Condition 1:

IHM must not market or enrol students in the course.

Condition 2:

IHM must provide evidence by 1 January 2017 which confirms accreditation of the course by the Australian Nursing & Midwifery Accreditation Council (ANMAC).

Condition 3:

IHM must provide, within 4 weeks of receiving the notice of decision, evidence to demonstrate the full complement of staff required for the coordination and delivery of the Graduate Certificate in Nursing (Program for Internationally Qualified Nurses) as per Provider Course Accreditation Standard (PCAS) 4.1 and PCAS 4.2 to the satisfaction of TEQSA. The evidence must include the name, position title, responsibilities including units taught, qualification/s, teaching experience, professional experience, employment status (full-time, part-time, casual), full-time equivalence, current term (months), current duties classification type and level code.

The course accreditation covers delivery at all Australian sites.

Main reasons for decision

TEQSA considers that the decision to apply conditions to Institute of Health & Management Pty Ltd application for accreditation of one course of study is consistent with the basic principles for regulation in Part 2 of the TEQSA Act, as Institute of Health & Management Pty Ltd is at risk of not complying with a number of the Threshold Standards. TEQSA considers that the risks of non-compliance with the Threshold Standards involve a number of matters that may affect Institute of Health & Management Pty Ltd capacity to manage and deliver its higher education awards.

• The broad issues which relate to the Graduate Certificate in Nursing (Program for Internationally Qualified Nurses) include:

  a) PCAS 2.4 There is a risk that accurate and current information and advice about the course of study is not provided to prospective and current students

  b) PCAS 4.1 There is a risk that the numbers, qualifications, experience, expertise and sessional/full-time mix of both academic staff who teach or tutor the course of study and support staff, are appropriate to the nature, level and mode of delivery of the course of study and the attainment of expected student learning outcomes will not be met.

  c) PCAS 4.2 There is a risk that the staff who teach students in the course of study will not meet the following:

  • Are appropriately qualified in the relevant discipline for their level of teaching (qualified to at least one AQF qualification level higher than the course of study being taught or with equivalent professional experience);
  • in the case of supervision of students in a course of study that leads to a Doctoral Degree (Professional) award located at level 10 of the AQF, are qualified at level 10 of the AQF or have equivalent professional experience;
  • in the case of supervision of students in a course of study that leads to a Doctoral Degree (Research) award located at level 10 of the AQF, are qualified at Doctoral Degree (Research) level or have equivalent research experience;
  • have a sound understanding of current scholarship and/or professional practice in the discipline that they teach;
  • have an understanding of pedagogical and/or adult learning principles relevant to the student cohort being taught;
  • engage students in intellectual inquiry appropriate to the level of the course of study and unit being taught; and
  • are advised of student and other feedback on the quality of their teaching and have opportunities to improve their teaching

Course accreditation

Report on accreditation of two higher education courses of study offered by Alphacrucis College

A delegate of TEQSA has accredited, under section 49 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), the following higher education courses of study offered by Alphacrucis College for a period of seven years until 30 May 2023:

• Bachelor of Applied Social Science
• Graduate Diploma of Applied Social Science

Main Reasons for the Decision

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

Course accreditation

Report on accreditation of two higher education courses of study offered by Alphacrucis College

A delegate of TEQSA has accredited, under section 49 of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act), the following higher education courses of study offered by Alphacrucis College for a period of seven years until 30 May 2023:

• Bachelor of Applied Social Science
• Graduate Diploma of Applied Social Science

Main Reasons for the Decision

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