Re-registration 11 April 2018
Renewal of registration
Report on renewal of registration of Kent Institute Australia Pty Ltd
TEQSA has agreed to orders made by the Administrative Appeals Tribunal under which:
- the registration of Kent Institute Pty Ltd is renewed, under section 36 of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act), in the category of Higher Education Provider, for a period of four years until 31 March 2022.
- the accreditation of Kent Institute Pty Ltd's Bachelor of Business and Bachelor of Accounting courses is renewed, under section 56 of the TEQSA Act for a period of four years until 31 March 2022.
TEQSA has also agreed that six conditions be imposed on the registration of Kent Institute Pty Ltd under subsection 32(1) of the TEQSA Act.
A copy of the conditions is at Attachment 1.
Main reasons for the decision
The conditions have been imposed in light of risks identified in relation to the following aspects of Kent Institute Australia Pty Ltd's higher education operations:
- corporate and academic governance;
- academic quality assurance in relation to course design, benchmarking, course assessment and moderation, and the use of comparative student performance data; and
- the adequacy of Kent Institute Australia Pty Ltd's staffing arrangements, including its approach to staff scholarship and professional development.
TEQSA's assessment considered Kent Institute Australia Pty Ltd's arrangements for delivery at all Australian sites.
Within 6 months after the date on which this condition is imposed, the Applicant must provide evidence to the Respondent of the appointment of a suitably qualified person to the position of Executive Dean, based in Melbourne. The appointment must be made in accordance with the Applicant's position description dated 19 February 2018 and must be made with the agreement of the Respondent as to the identity of the appointee (which agreement is not to be unreasonably withheld).
The Applicant must:
- within 2 months after the date on which this condition is imposed, provide the Respondent with a plan for the enhancement of scholarly activity of the staff of the applicant. The plan must:
- be approved by the Applicant's Academic Board;
- include only activities or memberships which have scholarly or professional relevance to the individual's role with the Applicant;
- include a framework for collating, and reporting on, information about the scholarly activities of its staff. The framework must include a description of the steps taken by the Applicant to ensure that this information is consistently and appropriately categorised, having regard to the relevant guidance published by the Respondent in relation to scholarship.
- specify the resources to be made available to support staff scholarly activity and the basis on which the application of these resources is reported;
- specify the basis on which the policy will be reviewed by the Applicant.
- no later than 4 weeks prior to the commencement of each of trimester 1 and 2(i.e. excluding trimester 3) in the Applicant's courses, provide the Respondent with a report on its academic staff and the scholarly activities of those staff, which must include:
- the steps taken to implement the plan at (a), including the scholarly activities undertaken in the previous 6 months by each staff member with academic leadership or teaching responsibilities, and (where relevant)the amount spent by the applicant to support each of those activities; and
- the academic leadership and teaching responsibilities of each staff member of the applicant, whether the staff member is engaged on a full-time, part-time or casual basis, the units to be taught by each staff member in the subsequent teaching period, the location at which those units will be taught, and the relevant qualifications or professional experience of the staff member in relation to those units;
The Applicant must, every 2 years for the period in which the applicant is registered with the Respondent:
- engage a suitably qualified independent expert (with the agreement of the Respondent to the identity and terms of reference of the expert, which agreement is not to be unreasonably withheld) to prepare a report which contains an independent external review of the Applicant's Bachelor of Business and Bachelor of Accounting courses. The independent expert must:
- be suitably qualified to undertake the independent review;
- not be a past or present member of the Applicant's staff;
- not have been engaged as a consultant to the Applicant (and for the avoidance of doubt, this exclusion of 'consultants' is not to exclude any expert witnesses relied upon by the Applicant); and
- not have any conflict of interest.
- submit the independent expert's report to the Applicant's Academic Board, Board of Directors and the Respondent no later than one month after the independent expert provides their report (which must not be later than three months after the independent expert was engaged).
- provide the Respondent with a copy of the independent expert's report, together with a plan for the implementation of the recommendations in the report which has been approved by the Applicant's Board of Directors and its Academic Board, within six weeks after the independent expert provides their report to the Applicant.
The Applicant must provide the Respondent with reports on its moderation and benchmarking activities, including benchmarking of student performance data undertaken by the Applicant, in the preceding 12 month period. The Applicant must provide its first report by 15 May 2018 and a report by 15 May in each subsequent year.
The Applicant must complete its appointment of 3 new external members (consisting of 2 replacement members and 1 additional member) to its Academic Board within 6 months of the date of the decision by the Tribunal and report on those appointments within 1 month of the appointments being finalised.
The Applicant must:
- within 3 months after the date on which this condition is imposed, provide the Respondent with a comprehensive diagnostic analysis of the probable causes for observed rates and trends for student attrition, progression, grade distribution and minimum time completion rates, for each accredited higher education course it offers and each year, for the period from 2012 to 2016 inclusive. The analysis must include accurate data on student attrition, completion, progression and grade distribution rates and include analysis by:
- entry path (comparing students admitted under each entry pathway);
- credit awarded (comparing students admitted with no credit awarded with students admitted with credit for up to a third of the course and between a third and two thirds of the course);
- basis for assessment of the student's English language proficiencies) country of origin;
- referral to and uptake of student support (including participation in formal study support programs); and
- student achievement in similar courses at other higher education providers.
- develop and provide to the Respondent within 6 months after the date on which this condition is imposed, a detailed strategy, having regard to the comprehensive diagnostic analysis required under paragraph (a) above, which:
- includes specific targets for improvement of student attrition, completion and progression rates for each course and each year over the forward registration period;
- gives consideration to admission practices and standards, study load of students, the identification of students at risk of not progressing academically and the adequacy and effectiveness of student support;
- has been considered and approved by the Applicant's Corporate Board and Academic Board.
- revise the targets determined in accordance with paragraph (b) above if and as directed by the Respondent.
- demonstrate improvement, with reference to the targets to be established under paragraphs (b) and (c), overall and for each accredited higher education course of study, through annually reporting to the Respondent on these rates by 15 March each year (for the rates in the previous year)throughout the period of registration, with these reports to commence on 15 March 2019. The reports must be considered and approved by the Applicant's Corporate Board and Academic Board and be accompanied by evidence of this approval.