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TEQSA Corporate Plan 2020-24

29 January 2021

Prepared in accordance with the Public Governance, Performance and Accountability Rule 2014 (PGPA Rule), TEQSA’s Corporate Plan sets out our priorities for the four reporting periods from 2020-21 to 2023-24. 

Introduction

As the accountable authority of the Tertiary Education Quality and Standards Agency (TEQSA), we are pleased to present the TEQSA Corporate Plan 2020-24 as required under paragraph 35(1) of the Public Governance, Performance and Accountability Act 2013 (PGPA Act) and s160(1) of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act). The Corporate Plan is prepared in accordance with the Public Governance, Performance and Accountability Rule 2014 and covers four reporting periods from 2020-21 to 2023-24.

Professor Nicholas Saunders AO
Chief Commissioner

Professor Peter Coaldrake AO
Commissioner

Professor Joan Cooper
Commissioner

Professor Cliff Walsh
Commissioner

November 2020

From the Chief Commissioner

I am pleased to present the Tertiary Education Quality and Standards Agency (TEQSA) Corporate Plan for the years 2020-21 to 2023-24. This corporate plan sets out TEQSA’s mid-term priorities, in an environment of significant change and uncertainty for higher education, both in Australia and internationally. These priorities include: a revised approach to assessing sector risks; addressing the threat of contract cheating to academic integrity; evolving TEQSA’s approach to monitoring compliance; building on the partnership approach developed during the pandemic; and improving the timeliness with which we assess applications.

In response to the disruption caused by the COVID-19 pandemic, TEQSA has revised its approach to assessing risk so that the agency can continue to advise the government on the state of the sector, in particular its financial viability. TEQSA will also be closely monitoring other pandemic-related developments.

The establishment of the Higher Education Integrity Unit will bring renewed focus on issues of academic integrity, and their impact on the quality and reputation of the higher education sector. New legislation to enable the blocking of websites offering contract cheating services is an important start. Other areas of focus, with an emphasis on collaborating with providers, will include: admissions standards; English language proficiency; foreign interference; and student wellbeing.

This corporate plan also covers the proposed commencement of revised cost recovery arrangements for TEQSA’s regulatory services, which has been deferred by the government due to the impacts of the pandemic. TEQSA expects to consult the sector on revised arrangements, which may also change our approach to regulation, during 2021.

TEQSA will continue to engage providers and other stakeholders on our performance as a regulator, and on developments in quality assurance. In past years, this has included an annual stakeholder survey as well as meetings with peak bodies, forums with groups of providers, visits to and from individual providers, and the annual TEQSA conference.

Focus groups conducted with provider peak bodies and members in 2020 have helped to inform this plan, and have confirmed support for the partnership approach TEQSA initiated in previous years. The Higher Education Standards Panel (HESP), and the outcomes of the recent Australian National Audit Office (ANAO) performance audit, have also contributed.

The timeliness and responsiveness of TEQSA’s registration, re-registration and course accreditation services will remain a priority, as will TEQSAs compliance and risk assessments. TEQSA will also improve its capacity to respond to concerns regarding the higher education sector raised directly by members of the public and others.

In responding to the COVID-19 pandemic, TEQSA will continue to exercise its duty of care in ensuring the welfare and productivity of TEQSA staff. Significant investments in TEQSA’s business processes and information management, which began in 2019-20, are expected to improve agency operations.

This plan is a living document and will be revised as the agency continues to adapt and respond to changes in our operating environment and in Australia’s higher education sector.

Professor Nick Saunders AO
November 2020

TEQSA’s purpose

TEQSA’s purpose is to ensure the reputation of the higher education sector in Australia and to protect the interests of students.

As an independent quality assurance and regulatory agency, TEQSA adopts a risk-based approach that is guided by principles of necessity, risk and proportionality, and which supports quality, diversity, innovation, and excellence in tertiary education.

TEQSA has three strategic objectives in delivering its purpose:

  1. promote good practice and support effective self-assurance
  2. identify, analyse and respond to sector risks
  3. ensure quality and compliance through effective and efficient regulation.

The core functions of TEQSA are to register all providers that offer higher education qualifications in or from Australia, and to accredit their courses (except for universities and other providers that have authority to accredit their own courses of study).

TEQSA’s compliance and quality assessments are carried out against the Higher Education Standards Framework (Threshold Standards) 2015, covering student participation, learning, teaching, research, quality assurance, governance, and information management.

TEQSA also provides advice and recommendations to the Commonwealth Minister for Education, and collects, analyses, interprets, and disseminates information relating to quality practice and improvements in higher education.

TEQSA’s performance: objectives, measures and targets

TEQSA’s purpose is realised through three key organisational objectives, underpinned by a range of performance measures. Each of these objectives is accompanied by both outcomes-based performance measures, and qualitative and quantitative targets.

More detailed targets are set out in TEQSA’s annual operational plans and associated business plans for each of TEQSA’s organisational units.

In turn, individual performance and development plans for TEQSA officers directly reflect the business unit activities that are relevant to their roles and responsibilities.

Objective 1: Promote good practice and provide support for effective self-assurance

Performance measure - evidence of achievement of objectives Target
1.1 Education and guidance materials are developed to encourage self-assurance, in consultation with the sector. Support materials and initiatives are highly rated by providers
(source: stakeholder survey).
Resources developed to support providers are accessed by providers
(source: website visits).
1.2 Engagement with the sector is broadly based. 80 per cent or more of providers participate annually in TEQSA engagement activities.
The student section of the TEQSA website is increasingly accessed
(source: website visits).

Objective 2: Identify, analyse and respond to sector risks

Performance measure - evidence of achievement of objectives Target
2.1 TEQSA monitors the performance of registered providers, identifies risks, and assesses provider risk mitigation. The annual risk assessment of providers and the sector is completed, reported to individual providers, and key themes are shared with the sector.

TEQSA’s sector risk monitoring activity contributes to the annual setting of its risk priorities.
2.2 Initiatives to respond to sector risks are delivered. An annual report of progress and outcomes of projects is undertaken, and the results are shared with stakeholders and other agencies.

Objective 3: Ensure quality and compliance through effective and efficient regulation

Performance measure - evidence of achievement of objectives Target
3.1 TEQSA’s assessment and compliance approach aligns with principles of regulatory necessity, risk-reflective and proportionality. TEQSA takes action to ensure that serious non-compliance by registered and non-registered providers is disrupted or addressed.
3.2 Assessment and compliance activities are streamlined and coordinated / regulatory activity is undertaken efficiently. The year-on-year trend in processing times demonstrate improvement.

Increase in positive ratings from providers with regard to TEQSA’s efforts to reduce administrative burden
(source: stakeholder survey).
3.3 TEQSA is open and transparent in its dealings with regulated entities. TEQSA engages annually with all providers to address any questions or concerns regarding compliance with requirements.

TEQSA’s activity

 

TEQSA has a range of functions and activities to achieve its purpose that align to the strategic objectives set out above.

Objective 1: Promote good practice and support effective self-assurance

TEQSA offers materials and support to assist providers in meeting required standards and to promote quality enhancement. These include application guides, guidance notes, good practice notes and, more recently, conferences, seminars, workshops, digital offerings and toolkits.

The subject areas have varied and have been in response to identified needs. TEQSA uses feedback from a range of sources such as providers, the HESP, peak bodies and students, as well as observations from cyclical and compliance assessments and the annual risk cycle, to establish the areas and forms of support to be developed.

Objective 2: Identify, analyse and respond to sector risks

Formal, systematic risk assessments for each provider serve as a fundamental regulatory tool that informs TEQSA’s policy work and regulatory operations. TEQSA undertakes an annual cycle of risk assessment for all registered higher education providers. We use the outcomes to engage individual providers on their management of identified risks, and to respond to sector-wide risks.

In 2019-20, TEQSA reviewed the Risk Assessment Framework in consultation with the sector. The outcomes from the review have contributed to an enhanced risk monitoring approach. Over the last three years, TEQSA has responded to sector risks such as academic integrity, transparency of admission processes, English language proficiency, and sexual assault and sexual harassment.

TEQSA will continue to analyse and respond to these and other emerging sector-wide issues, firstly in collaboration with the sector, and then where necessary through regulation. The creation of TEQSA’s Higher Education Integrity Unit and contract cheating legislative provisions in 2020 will be important tools for TEQSA.

Objective 3: Ensure quality and compliance through effective and efficient regulation

TEQSA’s core regulatory work includes:

  • assessing applications for registration and re-registration as a higher education provider
  • accrediting and re-accrediting courses offered by higher education providers
  • registering and re-registering providers delivering higher education courses, Foundation programs, and English Language Intensive Courses for Overseas Students (ELICOS) to international students
  • compliance monitoring and assessments, including in response to material change notifications received by, and complaints about, higher education providers
  • ensuring that regulated academic awards are not offered by unregistered providers.

Improving the efficiency of TEQSA’s regulatory activity, with a focus on reducing the administrative burden of regulation for higher education providers (particularly independent private providers that are subject to both registration and course accreditation), will remain a priority for TEQSA.

Operating context

TEQSA has a complex legislative framework and operating environment for its functions and activities.

TEQSA’s legislative framework

TEQSA’s guiding legislation is the TEQSA Act. The TEQSA Act confers TEQSA’s quality assurance and regulatory powers and functions.

TEQSA also has responsibilities under the Education Service for Overseas Students Act 2000 (ESOS Act) in relation to all providers delivering higher education to overseas students studying in Australia, including Foundation programs and ELICOS.

Recent and forthcoming amendments to the TEQSA Act will allow TEQSA to block access to websites offering contract cheating services and manage student records in the event of provider closure. This will be an early focus for the new Higher Education Integrity Unit established within TEQSA.

Operating environment

TEQSA’s operating environment is made up of 182 higher education providers, offering a diverse range of course of study across five registration categories, with over 1.5 million students.

Almost one quarter of providers are established public and private universities, accounting for over 90 per cent of students enrolled in higher education. About 30 per cent of providers have the authority to accredit all or some of the courses of study they deliver.

Just over 70 per cent of the sector is made up of a diverse range of smaller, independent for-profit and not-for-profit private providers, accounting for less than 10 per cent of total student numbers. These providers are required to have their courses of study accredited by TEQSA. As of 14 September 2020, TEQSA had accredited 1248 courses offered across 11 broad fields, principally in the fields of: management and commerce; society and culture; the creative arts; and health.

The previous rapid growth and diversification of the sector, both in terms of provider and student profiles, has now been significantly challenged by the COVID-19 pandemic. The high level of uncertainty, characterised principally by a likely sharp reduction in international student enrolments, as well as changes to course delivery from pandemic-induced restrictions, has introduced significant pressures on the sector.

A principal risk to the sector as a result of the pandemic is the financial viability of providers, which may drive significant change – including in ownership and structure – over the course of this TEQSA corporate plan. The financial viability of providers – and any impacts on the quality of provider offerings – will be a focus of TEQSA’s monitoring and regulatory activity.

The broad challenge for TEQSA, as the sector regulator, will be in monitoring change and predicting risks, and adjusting the quality assurance and regulatory focus and methodology. An important priority will be in enabling innovation and responsiveness to the impacts of the pandemic, while also ensuring that quality is maintained and enhanced, and that students remain protected.

Specific developments

Specific developments of key interest to TEQSA over the course of this corporate plan will include:

  • the ongoing, and at this early stage highly uncertain, impacts of the COVID-19 pandemic
  • the rapid expansion of online delivery of courses, with impacts on provider operations and the student experience
  • legislative provisions to inhibit contract cheating services, and a need to monitor the response of such services to TEQSA’s actions
  • cost recovery for TEQSA’s regulatory and other services to the sector, which is likely to undergo further change, as a result of the government’s response to the impacts of the pandemic
  • changes in provider registration categories, including new requirements for the level of research training and standards of research, which TEQSA will need to manage
  • government and sector expectations of further deregulatory initiatives from agencies, which for TEQSA includes improvement in the timeliness and efficiency of registration and accreditation processes.

TEQSA’s stakeholders

TEQSA has a range of stakeholders across the domestic and international higher education sector, government and professions.

Department of Education, Skills and Employment

TEQSA will continue to work closely with the department on policy-related matters, and on data held by the department (such as student information), which can be used to deliver more timely data for TEQSA’s risk assessments.

TEQSA will also continue to provide advice to the department regarding initiatives such as the Australian Qualifications Framework, the retention and management of student records, tuition protection services, new provider categories, and powers to block contracting cheating websites.

Higher Education Standards Panel

The responsibilities of the HESP include monitoring the operation of, and recommending changes to, the Higher Education Standards Framework (Threshold Standards) 2015. More recently, the HESP has been given the role of advising and making recommendations to TEQSA regarding its performance, including: approaches to deregulation; strategic objectives; the corporate plan; streamlining of activities; and resourcing requirements.

Australian Skills Quality Authority

TEQSA will continue to meet regularly with the Australian Skills Quality Authority (ASQA), particularly in relation to ‘dual sector’ providers, including in developing best-practice regulatory approaches and methods.

ERIC

TEQSA will continue to contribute to the multi-agency Education Regulators and Immigration Committee (ERIC), to help safeguard the integrity and sustainability of the international education sector. TEQSA’s focus will be on identifying and mitigating risks and influencing whole-of-government operational settings.

Students

TEQSA will continue to develop its Student Expert Advisory Group (SEAG) to discuss risks to student interests and to receive feedback on TEQSA’s activity and initiatives. TEQSA will also further develop consultation with students as part of its application-based and compliance assessments.

Provider peak bodies

TEQSA will work closely with provider peak bodies as part of its partnership approach with the sector, in particular in relation to the regulatory framework and TEQSA’s performance. Peak bodies are an important source of information about a provider’s experience of working with TEQSA, while also detecting emerging risks for the sector.

Industry professional bodies

TEQSA and industry professional accreditation bodies with links to the higher education sector have a mutual interest in maintaining and improving quality of the provision of Australian higher education.

TEQSA’s agreements with industry bodies facilitate the sharing of information and seek to reduce regulatory burden on higher education providers through joint and streamlined approaches to assessment.

Other stakeholders

TEQSA seeks to: engage with its stakeholders at all levels through open, two-way communication; reflect on feedback; and take action where appropriate. Our stakeholder engagement activities allow us to gain a greater understanding of the key issues in the higher education sector and help to build stakeholder capacity to meet regulatory requirements.

We have developed an engagement framework which outlines our commitment to working with stakeholders and includes a five-step stakeholder engagement model.

TEQSA’s regulatory capacity

Capability requirements

In order to deliver this corporate plan, TEQSA will need to continue to: develop an effective workforce; ensure an appropriate pool of subject matter experts; implement new IT infrastructure to support our complex and growing information management needs; and strengthen our relationships with providers.

Workforce planning

TEQSA employees are required to be highly skilled with a wide range of knowledge and expertise in higher education, quality assurance, regulation, risk assessment and public sector administration. TEQSA seeks to be an employer of choice, offering employees diverse and challenging work that embraces innovation, diversity and agility.

Our workforce consists of specialist regulatory operations staff, as well as staff working in a range of functions that support our core regulatory capability and operations. These functions include policy and analysis, legal advice, communications, liaison, governance, information and communication technology, human resources, and finance.

Workforce planning over 2020-24 will focus on:

  • Leadership and capability – development of capability is critical in a changing environment. We will leverage internal talent and foster innovative approaches to leadership.
  • New ways of working – agile and flexible working, principle-based frameworks, and communities of practice will reposition TEQSA for the challenges ahead.
  • Culture – our culture needs to support and reward people to think and behave productively by fostering inclusiveness, harnessing diversity, and enhancing wellbeing and flexibility.
  • Talent – TEQSA will find better ways to leverage digital channels, implement contemporary talent solutions and define our Employee Value Proposition.

We will promote opportunities to:

  • equip staff with transferable skills through development opportunities, through a commitment to constant skill renewal, and by building a culture to support lifelong learning
  • strengthen stakeholder relationships through improved performance outcomes and engagement
  • better integrate with technology
  • increase diversity of thought through a more diverse and inclusive workforce and leverage the benefits of flexible working
  • work collaboratively within the APS and across the higher education sector.

TEQSA experts

In undertaking regulatory assessments, TEQSA staff use external experts in a range of discipline areas. These expert assignments are predominantly for regulatory operations in the areas of course accreditation and registration applications.

TEQSA is also using experts to provide and develop advice on thematic issues of relevance to the sector, such as online learning and academic integrity.

During 2020-24, we will continuously review and manage our Register of TEQSA Experts to ensure an appropriate diversity, level and spread of expertise across TEQSA’s quality assurance and regulatory priorities, in line with our risk assessments.

Information and Communications Technology and Information Management capability

Timely access to, and appropriate use of, trusted data is required by TEQSA for informed decision making, and to enable innovation and support high quality regulation. TEQSA’s information management priorities include: integrating existing data systems; ensuring a fit-for-purpose case management system; and developing an analytics and predictive capacity for monitoring the sector.

TEQSA digital communications

TEQSA makes use of a range of digital communication channels to promote and support good practice, improve compliance and enhance quality. These include the TEQSA website, social media (Twitter, LinkedIn) and e-newsletters. TEQSA’s digital products are targeted at key audiences including students, providers and academics, as well as media, peak bodies, government agencies and partner agencies in other jurisdictions.

During 2020-24, TEQSA will develop a podcast series to promote good practice, compliance, and quality enhancement for Australia’s higher education sector. TEQSA will also grow social media audiences by 15 per cent, enhance the TEQSA website to improve the user experience, and develop a new digital communications strategy to engage higher education students.

Legal capability

TEQSA’s Legal Group assists the Commissioners and their delegates to make legally-informed and effective administrative decisions. The group also manages claims by or against TEQSA, including Administrative Appeals Tribunal proceedings involving the agency, and manages the agency’s corporate legal obligations.

Through its Quality Assurance Team, the Legal Group also supports internal quality within TEQSA by documenting TEQSA’s regulatory assessment processes and conducting reviews of those processes to ensure they are efficient and effective.

In 2020-24, TEQSA will ensure that its legal and quality assurance capabilities reflect the needs of the agency, particularly in the context of the additional responsibilities in relation to contract cheating, management of student records and other responses to risks to the integrity of Australia’s higher education sector. The Legal Group will also support the ongoing evolution of TEQSA’s approach to regulation and quality assurance.

Risk oversight and management

TEQSA has developed systems of risk oversight, risk management, and internal control within the agency, and is committed to the continuous improvement of risk management practices.

TEQSA will continue to develop and refine its Enterprise Risk Management Framework, which identifies and addresses key material risks relating to its oversight and regulatory functions, internal administration and stakeholder relationships. This framework is made up of a risk register, a risk appetite statement, and an accompanying risk management policy and internal controls.

TEQSA’s Audit and Risk Committee provides independent assurance to the Accountable Authority on TEQSA’s financial and non-financial performance reporting responsibilities, risk oversight and systems of internal control. This includes reviewing the internal audit program to ensure alignment with TEQSA’s key areas of financial and operational risk.

During 2020-24, TEQSA will be focused on developing the agency’s risk culture, in particular the level of staff understanding and application of risk principles, and TEQSA’s fraud and anti-corruption controls.

Governance

TEQSA’s corporate governance framework incorporates:

  • regulatory, strategy and management decision-making bodies
  • an integrated planning and reporting framework
  • Accountable Authority instructions
  • policies and procedures
  • an ethical and accountable organisational culture
  • transparency in public reporting.

The Commissioners, acting as TEQSA’s Accountable Authority, have overall responsibility for TEQSA’s:

  • regulatory functions
  • governance
  • planning (corporate plan, budget estimates)
  • financial management
  • risk oversight and management
  • security oversight
  • internal control
  • performance reporting (including annual reports, annual financial statements, and annual performance statements) under the TEQSA Act and the PGPA Act.

Subsection 154(1) of the TEQSA Act states that the CEO of TEQSA is responsible for the management and administration of TEQSA. Subsection 156(2) of the TEQSA Act states that for the purposes of the Public Service Act 1999, the CEO and staff of TEQSA together constitute a statutory agency, and the CEO is the head of that agency.

Agency security

Under the Protective Security Policy Framework, the Commissioners as the Accountable Authority are answerable to the Minister for Education and the government for the security of TEQSA. This requires the Commissioners to:

  • determine TEQSA’s tolerance for security risks
  • manage the security risks of TEQSA
  • consider implications that their risk management decisions have for other entities, and share information with those entities on risks where appropriate.

TEQSA joined the partnership program of the Australian Cyber Security Centre (ACSC) in 2019-20 to improve the capacity of the agency to address cyber security threats.

During 2020-24, TEQSA will focus on the implementation of the mandatory requirements under the Protective Security Policy Framework in a balanced and proportionate way, including having regard to Information and Communications Technology (ICT) changes at TEQSA, available resources, and TEQSA’s risk profile.