TEQSA smoothing initiative
1. What is the smoothing initiative?
TEQSA registers providers for a period of up to seven years and accredits courses for a period of up to seven years. This cyclical nature of applications has resulted in a peak volume of renewal workload for TEQSA as applications for re-registration and re-accreditation fall due.
TEQSA has initiated a project to smooth the volume of incoming re-accreditation applications in preparation for the next cycle (Cycle Two). The approach for smoothing involves:
- aligning and extending selected courses so that the re-accreditation due dates are the same as the existing re-registration due dates
- grouping selected courses with the same narrow field of education to have the same re-accreditation due date
- in limited cases, extending registration and course accreditation periods.
The providers we identify for smoothing will receive an invitation from TEQSA to provide feedback on a proposal to extend one or more of the provider’s course accreditation periods, and in limited cases, their registration period. This is permitted under the TEQSA Act, which permits one extension per accreditation period (section 57A of the TEQSA Act) and one extension per registration period (section 37A of the TEQSA Act).
TEQSA will pilot the smoothing initiative with selected providers to enable review of the materials, information provided and process, and take a staggered approach to implementation.
2. What are the benefits of smoothing?
Smoothing will enhance TEQSA’s ability to deliver timely outcomes for providers and, in turn, continue to increase the overall quality of higher education in Australia. This is achieved by creating a number of efficiencies which offer benefits for providers and TEQSA:
- a smoothed workload which will result in a better balance of volume and risk profile in TEQSA’s renewal workload and support improved assessment timeframes
- project efficiencies in assessing applications that arise from grouping courses and, where appropriate, aligning re-accreditation due dates with re-registration due dates
- efficiencies for the use of external discipline experts that arise from grouping courses with the same narrow field of education
- greater potential for the use of sampling for the concurrent submission of courses. As appropriate, TEQSA may select a number of courses to assess from a broader set, and use the findings on these to inform the overall decision.
For providers who receive an extension proposal, additional potential benefits may arise from the deferral of application workload and additional resource efficiencies from the consolidation of applications, given there can be overlap in requirements for applications.
3. How does smoothing fit with TEQSA’s existing policy on extensions to courses and registrations?
The purpose of the smoothing initiative is consistent with the principles set out in TEQSA’s policy on extensions to the period of provider registration or course accreditation, in particular:
- to provide efficient management of TEQSA’s workload
- to harmonise periods of registration and accreditation.
The policy sets out the relevant matters that TEQSA considers when granting extensions. These relevant matters have been considered as part of the smoothing initiative and those that are material have informed the scope and suitability for inclusion.
In particular, relevant matters included the provider’s latest annual risk rating, noting that:
- all re-accreditations were considered, irrespective of risk rating and conditions
- providers with a high risk rating to students were not considered for registration extension.
TEQSA will continue to monitor providers through the annual risk assessment process and its Compliance and Investigations function. Should unforeseen concerns arise, TEQSA can engage with providers and take action as necessary.
4. How have courses been selected for smoothing?
TEQSA has modelled various options for smoothing and selected the model that achieves the greatest benefit in terms of overall efficiencies.
The selection of courses deemed suitable for smoothing was based on the following approach:
- aligning and extending courses so that the re-accreditation due dates are the same as the existing re-registration due dates
- grouping courses with the same narrow field of education
- in limited cases, extending registration and course accreditation periods.
5. Have any re-registrations been proposed for smoothing?
Yes – a limited number of re-registrations have been selected. These providers will receive a proposal for an extension to their current registration period.
6. How does smoothing impact CRICOS re-registrations?
There is no change proposed to CRICOS re-registrations. The smoothing initiative focuses on TEQSA re-registrations and re-accreditations, given the volume of re-accreditations due in Cycle Two. There are only a limited number of TEQSA registrations selected for smoothing and therefore CRICOS re-registrations remain unchanged.
7. What options do providers have to provide feedback on an extension proposal?
Providers will be invited to provide feedback on an extension proposal. As part of their feedback, providers have the option of agreeing in full, partially agreeing or not agreeing with the proposal. Agreement is voluntary and at each individual provider’s discretion. The proposal that selected providers receive will set out the course/s (and registration if applicable) for extension, the proposed period of extension, and the timeframe for the provider to respond to the proposal. There is no fee attached to an extension.
8. What is the length of time for extensions in proposals?
The length of time for extensions in proposals is based on data modelling and dependencies on current re-registration dates, and therefore will vary for individual providers. However, most extensions will not exceed three years.
9. Can a provider choose to partially agree with a proposal e.g. opt for extension to selected courses?
Providers may opt to respond to an extension proposal by partially agreeing with the proposal. For example, providers may agree with an extension proposal for specific courses and not agree with others. TEQSA will consider each provider’s response on a case by case basis, to ensure that it remains consistent with the smoothing intent.
10. What if a proposal includes a course re-accreditation for ‘teach out’?
A provider should notify TEQSA if a course included in a proposal is for ‘teach out’ to ensure that these are exempt from the smoothing initiative, and instead undergo an expedited assessment.
11. What if a provider has already commenced scoping discussions with TEQSA for a renewal application?
Under the smoothing initiative, an extension may be proposed for courses for which the pre-scoping process has commenced. It is a matter for the individual provider to determine how to respond to an extension proposal in these circumstances.
12. Has TEQSA considered professional accreditation when selecting courses for the smoothing initiative?
TEQSA has not differentiated courses that are subject to professional accreditation in proposing courses for the smoothing initiative. It is a matter for the individual provider to consider any impact of an extension proposal on the professional accreditation process.
13. When will selected providers be contacted with a proposal?
TEQSA will take a staggered approach to implementing smoothing, first contacting those providers with re-accreditations due in early 2020, followed by those with re-accreditations due thereafter.
14. How much time will a provider be given to consider a proposal?
Formal proposals for extension will be made by TEQSA to selected providers in writing. Providers will be given two weeks from the date of the letter to respond. TEQSA will consider any requests from providers for additional time to respond.
15. What happens once feedback is provided on a proposal?
Once feedback has been received, TEQSA will make a decision on the extension and notify the provider in writing. The timeframe will vary, but ordinarily a decision on extension will be made within four weeks of receipt of the provider’s response.
16. What happens if a provider does not agree with a proposal?
If a provider does not agree with a proposal, TEQSA will not proceed with the proposed extension/s.
17. Can providers who do not receive a proposal express interest or volunteer?
TEQSA has specifically selected courses and registrations for extension under the smoothing model. Separate to an extension proposal from TEQSA, providers may express an interest in extending courses or registration periods to address their specific business needs. TEQSA will consider such requests on a case by case basis. Providers should contact their Case Manager if they wish to discuss this option.
Considerations for providers
18. What concerns might providers have?
Possible concerns for providers may include:
- cash flow management if course renewal dates coincide as a result of smoothing
- capacity to manage the workload for applications if courses are proposed for concurrent submission.
Whilst there is no fee for an extension, when an application is submitted, the application fee charged will be the fee that applies at that date. Note that the Australian Government has announced that TEQSA will transition to full cost recovery for its regulatory activities. TEQSA will consult with the sector on the proposed arrangements.
19. How will smoothing interact with the proposed Cycle Two changes?
TEQSA is undertaking a number of initiatives to streamline and improve workload efficiencies in preparation for Cycle Two. This includes an initiative which encourages providers to proactively source and submit their own independent expert review of courses when applying to TEQSA for renewal of course accreditation. Other initiatives will be progressively communicated to the sector as appropriate. Providers are encouraged to consider such initiatives when considering an extension proposal.
20. What does smoothing mean for any future extension?
TEQSA can only grant one extension of registration period (section 37A of the TEQSA Act) and one extension of accreditation period of courses (section 57A of the TEQSA Act). This means that an extension to an accreditation or registration period under smoothing will preclude future extensions for the same accreditation or registration period.
21. If submitted together as a result of smoothing, will applications for re-accreditation and re-registration be decided at the same time?
TEQSA will undertake assessments of re-accreditation and re-registration applications as efficiently as possible. Generally, applications will be decided separately, unless TEQSA determines that the assessment of applications from a provider should be decided together.
22. What are the implications of smoothing for future cycles?
The smoothing initiative is an adjustment to smooth the workload ahead of Cycle Two. Moving forward, there will be no implications for future cycles in relation to the period of registration or accreditation decided for applications submitted as part of smoothing.
23. Who can providers contact for more information?
Providers should submit any enquires via email to smoothing [at] teqsa.gov.au and cc their Case Manager.
Providers may also contact their Case Manager to discuss any questions in relation to a proposal.
These FAQS will also be updated throughout the smoothing initiative and made publicly available on this website.
|Beta||2 December 2019||
|1.0||18 December 2019||Addition of Question 16, minor update to Question 17 and 19 in response to feedback from peak bodies.|
|1.1||5 March 2020||Clarification that providers will be invited to provide feedback on an extension proposal, as at the time of the proposal letter, a decision is yet to been made by TEQSA/delegate on the extension.|