AUSTRALIAN INSTITUTE OF PROFESSIONAL EDUCATION

Transcription

1 AUSTRALIAN INSTITUTE OF PROFESSIONAL EDUCATION Education Provider Plan

2 Future directions for TEQSA s Regulatory Risk Framework Sector discussion paper Responding to this paper Consultation questions and responses: 1. Does the proposed approach reflected in Figure 1 offer an improvement to the current approach? If not, why and what changes would you propose? AIPE strongly supports the revision and simplification of key risk areas and the refinement of risk indicators by TEQSA. Further comments: There is a strong support for integration of Threshold Standards and the ESOS Act and National Code; The examples provided in Attachment B regarding risk assessments and key risk indicators are helpful; For new HEPs, when considering track record of delivery of recently registered CRICOS locations a good track record in education and training delivery must be taken into account, as opposed to a track record in higher education delivery only. With respect to attrition rate consideration could be given not just to transfer to another provider but also to transfer to another qualification within the same provider; Measures of student satisfaction and graduate destinations that are currently used e.g. GDS and CEQ are not appropriate for small private providers with small graduate cohorts, many of whom may be returning overseas. It should be clearer in Attachment B that alternative measures may be used by providers that are more suited to their individual contexts; With respect to senior academic leaders there should be scope for alternative models e.g. leaders on retainer who are sessional mentors/advisers to staff employed by the institution; In relation to the Staff Resources and Profile it would be helpful to remove ambiguity for non-university providers if the qualifying clauses in Items 8,9 and 10 were revised to indicate that In assessing risk consideration will be given to context rather than may be given. We would suggest that measures of Financial Viability and Sustainability be specifically reviewed by a small working party with strong knowledge of the business context of private and not-for-profit higher education provision. 2. Is the reduction in the number of risk indicators and the proposed selection of indicators at Attachment B appropriate for capturing key risks of non-compliance in the sector? If not, why and what changes would you propose? Page 2 of 11

3 Generally, the reduction in number of risk indicators and selection of indicators in Attachments B are appropriate for capturing non-compliances, however, the longterm real issue for a higher education provider is to provide quality higher education. Most survey questionnaires on average provide average information which does not discriminate well if one attempts to calculate standard errors, for instance, or to eliminate statistical outliers. Auditing is essentially about paperwork, not what actually happens in the classroom. More sophisticated benchmarking processes, independent of the Regulator, including systems of external examiners for final years of bachelor and masters coursework programs, may provide a conceptual framework in which to view long-term risk. 3. Should information about risk thresholds be released by TEQSA? AIPE would welcome any information that can reduce risk of misinterpretation and that would assist in understanding the risk framework. As a higher education provider, we are genuinely keen to provide quality teaching and learning opportunities to our students. 4. If yes, what information would strike an appropriate balance in supporting providers to understand risk assessments, while preventing the potential misinterpretation or misuse of the thresholds? It is impossible to prevent misuse of information, however, misinterpretation can be minimised with the provision of appropriate examples and scenarios. The assessment of risk in an education provider varies between obvious risks which would apply in any commercial enterprise and those which are peculiar to education because of the vulnerable nature of the consumers at formative stages of their development. The domino effects which can occur in the latter are where providers can learn from each other. 5. Apart from better information about the nature of information TEQSA takes into account in finalising risk ratings, are there other areas of the risk process and/or profile that would benefit from further explanation by TEQSA? While it is really a registration issue, scrutiny of the skill sets of the Governing Board and the Academic Board, and associated succession planning is essential if the financial viability of the provider as an educational venture is to be maintained. Page 3 of 11

4 Further comments: 2.1 Risk thresholds In general, it will assist providers to better understand the initial TEQSA assessment process and to, therefore, better represent their context. It will also assist providers to have a confidential report indicating how they perform on specified parameters in relation to the sector as a whole and to their specific subset of the sector e.g. small single discipline private provider or large multi-campus university. This should not be a numerical ranking but rather a graphical representation of clusters. The release of risk thresholds for financial indicators only is susceptible to greater misinterpretation than a broader cluster approach, especially given the special circumstances of public versus private providers and not-for-profits who may have subsidies built into their operations. In relation to financial risk it might also be worth considering more attention be given to track record as a VET provider. While the nature of the education process differs, the principles underpinning a viable business model are not widely variant. Several years successful operation as a VET and registered CRICOS provider should be considered as evidence in arriving at a risk rating for a new HEP. 2.2 Examples of information considered in finalising risk ratings Greater transparency is very welcome and will assist dialogue between the case manager and the provider. The key to the effectiveness of the approach however rests firmly with the development and maintenance of a culture in TEQSA that emphasises a desire to understand and mitigate potential risk by sharing information and advice with the providers. Several providers have experienced an attitude from some case managers that appears to stem from a presumption of high risk based in prejudice about certain categories of provider rather than consideration of the evidence before them. This leads to a confrontational approach in which proportionality and sometimes commonsense is sacrificed. Page 4 of 11

5 Future directions for TEQSA s regulatory processes Sector discussion Paper Responding to this paper Consultation questions and responses: Question A1: Do you agree with TEQSA s proposals for reforming renewal of registration processes? If not, why, and what would you propose instead? Yes, these are reasonably clear, though the depth of evidence required has seemed to be a matter of individual negotiation between a HEP and TEQSA. For example, in the area of risk management a private provider whose owner s assets are at risk is going to err on the side of conservative financial planning, yet sometimes the official TEQSA responses seem to disregard business processes that are different in kind and degree from those of a government entity. Question A2: Are the proposed core evidence requirements as listed at Attachment A appropriate? If not, why, and what would you propose instead? The removal of unnecessary duplication is to be applauded. Governance charts and delegation instruments which indicate well-balanced skill sets appropriate to the relevant terms of reference need to be monitored carefully as these can sometimes overemphasise one aspect of a provider s risks. Question B1: Do you agree with TEQSA s proposals for reforming course accreditation processes? If not, why, and what would you propose instead? Yes, because the proposals make the processes much clearer so that Providers can supply unequivocal responses. In addition, consideration could be given to the COPHE proposal A Modified Approach to Course Accreditation (20 August 2013), based on the former Queensland approach. Question B2: Are the proposed core evidence requirements as listed at Attachment B appropriate? If not, why, and what would you propose instead? Include Course and Unit Graduate Attributes; relate them to learning outcomes; map the latter against assessment tasks. There is no mention of external and internal benchmarking and moderation in Attachment B. Question C1: Do you agree with TEQSA s proposals for reforming renewal of course accreditation processes? If not, why, and what would you propose instead? Page 5 of 11

6 Yes, they simplify the process, particularly the outcomes and review and monitoring steps. More active and constructive cooperation between the HEP and the Case Manager should speed up the process too. It would help if experienced Case Managers had more delegated authority for decision making in relation to constructive advice. However, this would also necessitate an ombudsman type role where there is an avenue of appeal open to HEPs. Question C2: Are the proposed core evidence requirements as listed at Attachment C appropriate? If not, why, and what would you propose instead? They are generally appropriate; see comments below. Anything that helps to make the process transparent and unequivocal will be welcomed by providers. Page 6 of 11

7 Comments on Attachment A: Renewal of Registration Core evidence requirements RENEWAL OF REGISTRATION - CORE EVIDENCE REQUIREMENTS POLICIES AND PROCEDURES GOVERNANCE PRS 3.4 Risk Management PRS 3.7 Corporate and Academic Governance PLANNING AND PERFORMANCE OUTCOMES PRS 3.6 planning and review processes (focus on outcomes) PRS 5.6 performance of teaching, student learning outcomes, graduate outcomes, and (as applicable) research ACADEMIC QUALITY ASSURANCE PRS 3.8 QA and academic development, review and improvement systems, maintenance of academic standards with appropriate mechanisms for external input - Any policies, procedures or guidelines relevant to the Provider Registration Standards (PRS) listed below are to be provided, such as through a link to central repository - Constitution (except for universities constituted by Acts of Parliament) - Governance chart or similar - Delegation instruments * - Terms of Reference and membership of governing body and academic board or similar * - Minutes of governing body for last 12 months - URL link and access to any central policies and procedures repository or key documents for governance - Risk Management Plan or similar - Risk Register and status reports on risk and risk management reported to Risk Committee or similar - Audit & Risk Committee minutes for the past 12 months - Current Strategic Plan - Latest report on the progress of the Strategic Plan, as presented to the Governing body - Research Plan (where relevant) and most recent outcomes against plan - Teaching and Learning Plan and most recent outcomes against plan - Summary of benchmarking activity and outcomes - Sample reports of internal and external faculty, program and/or school reviews and evidence of use for improvement - Evidence of approach to course development and of its effectiveness (for example through minutes of academic governance committees such as course advisory, academic board, quality assurance, and/or teaching & learning committee minutes) - Evidence of approach to course approval and of its effectiveness - Evidence of approach to course monitoring and review and of its effectiveness AIPE response/comments Excellent suggestion for URL link rather than multiple paper copies. The Risk Register and status reports can easily be allowed to drift. Audit and risk committees may not always be in existence, particularly for a small provider where the function might be performed by an external auditor or similar rather than an official committee. It would be helpful if TEQSA could be a little more specific about the minimum components of a T&L plan especially when the provider is a single discipline small provider or dual sector institution. Benchmarking activities may sometimes be honoured in the breach, however, a necessary part of any good business practice. For a small HEP it might be more efficient if some of these committees performed dual roles. This should be explicitly acknowledged. It is unclear what evidence of approach would be considered sufficient. Is it a policy or is it samples of reports? Page 7 of 11

8 STUDENT EXPERIENCE AND SUPPORT PRS 6.4 grievance processes PRS 6.5 Transition, academic language and learning support - Internal and external audit/review of academic processes, and review outcomes - Recent student outcome data reports, as submitted to governance bodies, and evidence of consideration by those bodies - Examples of stakeholder feedback and provider response/action - Examples of student evaluation of teaching and (where applicable) research training, and use of this feedback - Effectiveness of quality assurance arrangements for any third party provision of education services (e.g. audit reports, moderation outcomes) - Evidence of provision of student support programs and take-up (for example students from an Aboriginal and Torres Strait Islander background, students with a disability, orientation programs, academic language and learning support for students at risk ) - Approach to student evaluation of support services and overall experience and use of feedback - Institutional response to student achievement and outcomes data - Evidence of student grievance processes in place, including the number of complaints over the past 12 months and analysis of nature of complaints - Latest report to governing body on student complaints and grievances Internal and external reviews are being done well by the more established HEPs. There is a delicate balance re student outcome data reports; however, micromanaging is to be avoided. Use of the feedback can be the missing link. Preparation for Higher Education & subsequent academic support are emerging issues for many HEPs including universities. This needs to be linked to correlating admission criteria with academic performance. This needs balanced roles and responsibilities among key committees. It is often difficult to get students to realise that there are no penalties for raising a grievance. The report should also include summary of actions taken in response to grievances. Page 8 of 11

9 Comments on Attachment B: Course Accreditation Core evidence requirements COURSE ACCREDITATION CORE EVIDENCE REQUIREMENTS COURSE DETAILS COURSE DOCUMENTATION ADMISSION, ARTICULATION AND PATHWAYS COURSE DEVELOPMENT, APPROVAL AND COORDINATION ASSESSMENT STAFFING LIBRARY AND INFORMATION RESOURCES CERTIFICATION DOCUMENTATION - Course title - Rationale - Proposed AQF level - Nested courses - Field of education - Delivery sites - Third party arrangements, if applicable - Professional registration/accreditation arrangements, if applicable - Course learning outcomes (mapped against qualification type descriptors) - Course structure and content, including rules of progression - Course information to students - Subject/unit outlines - Student information about pathways, credit transfer and recognition of prior learning - Sample of curriculum materials evidencing what is typically used in a subject - Admission (entrance) criteria, and evidence of how external benchmarks have been taken into account - Articulation and credit arrangements (internal and external) - Projected student numbers - Minutes of meetings of advisory committees, etc. To show course development process used - Evidence of external input into development of course - Assessment tasks and weightings - Internal and external moderation arrangements - Approach to integrity of assessment - Number and type of academic staff for the course - Abbreviated CVs for academic staff, including for those with an academic leadership role in the course of study. - Position descriptions for academic staff with leadership roles in the course of study - Position descriptions for academic staff who are not yet engaged at time of application - Policy and justification for staff who are not qualified to at least one AQF level higher than the course of study being taught - Library and learning resources, including support and access arrangements, to support learning outcomes for the course of study - Proposed testamur and record of results - Example statement of attainment AIPE Response/Comments Course Graduate attributes should be added to this list. Learning Outcomes should also be mapped against Unit Graduate Attributes. Comparison with peers and other HEPs. Benchmarking is mentioned in Section C. Assessment tasks and weightings mapped against relative weightings of learning outcomes. It is not clear what is meant by type of academic staff. Information resources should be mapped against Learning Outcomes would help the TEQSA Experts. Page 9 of 11

10 Comments on Attachment C: Renewal of Course Accreditation Core evidence requirements RENEWAL OF COURSE ACCREDITATION CORE EVIDENCE REQUIREMENTS AIPE response/comments COURSE DETAILS COURSE OUTCOMES UPDATED COURSE DOCUMENTATION COURSE MONITORING AND REVIEW ASSESSMENT - Course title - Professional registration/accreditation arrangements, if applicable - Summary of changes since last accreditation - Evidence of robustness of assessment - Results of moderation outcomes for most recent semester (or teaching period) - Performance outcomes data and analysis, including: cohort-based analysis of attrition, progress, completion, and student satisfaction - Results of benchmarking - Number of students admitted in the previous three years under each admission pathway and proportion given credit or exemptions into the course for the previous three years - Course learning outcomes for next accreditation period (mapped against qualification type descriptors) - Course structure and content, including rules of progression - Subject/unit outlines - Student information about pathways, credit transfer and recognition of prior learning for the course - Minutes of internal course governance bodies (such as course advisory committees, academic board or similar) showing consideration and response to monitoring of course quality - External course review reports and responses - Professional body reports/reviews (as applicable) - Assessment tasks and weightings - Internal and external moderation arrangements - Approach to integrity of assessment Is it unclear what changes can be made to the course during a period of accreditation. Many changes during a 7 year period will be required simply to keep a course up to date these may not all be regarded as material but the criteria need to be transparent and the case managers need to be well informed on this point. Particularly in relation to provisional admission and subsequent academic support. Assessment tasks and weightings should be mapped against relative Page 10 of 11

11 STAFFING - Number and type of academic staff for the course - Abbreviated CVs for academic staff not previously submitted to TEQSA - Position descriptions for academic staff with leadership roles in the course of study - Policy and justification for staff who are not qualified to at least one AQF level higher than the course of study being weightings of learning outcomes. Number and type of academic staff for the course and/or updated CVs? The policy and justification should only be required if it has changed since the original accreditation. Page 11 of 11