Changes to mode of delivery

1. How is TEQSA supporting providers with changes to mode of delivery?

TEQSA is supporting providers to be flexible and adaptive in how they deliver higher education and support students, both in Australia and offshore, to continue their study. We are not setting out particular approaches that providers should adopt. Providers are best placed to consider their individual context and determine the appropriate delivery solutions.

TEQSA appreciates providers have had to act swiftly to adapt to the current challenges and that they will be at different stages in terms of their online preparedness. We encourage providers to focus on ensuring that learning outcomes for courses are maintained, staff are adequately resourced to teach online, and that student wellbeing and safety continues to be a priority. This focus should be underpinned by clear, open, and accessible communication between students, teaching staff, and support staff.

So long as providers are able to demonstrate that they have taken into account relevant considerations and made a reasonable decision, in the best interests of students and the quality of learning, TEQSA is unlikely to draw negative conclusions about actions taken by a provider to change the mode of delivery to respond to COVID-19. It is important that providers report material changes and keep adequate records of decisions and reasons for their decisions.

2. Moving to online delivery

As a result of COVID-19 and in the interests of staff and student welfare, many providers are shifting to online delivery in short timeframes. There are a number of useful resources readily available on the topic of online learning and delivery. TEQSA has worked with peak bodies and experts to share a collection of resources that may assist providers. These online learning good practice resources are published on our website.

We also encourage providers to engage with their peak bodies as well as other providers as appropriate. There are many providers in the sector who have extensive experience in delivering online learning and they may be willing to share their expertise. For providers who don’t have online learning expertise within their own organisation, we encourage these providers to consider engaging the professional expertise required to assist them. 

3. Online delivery and the HES Framework

To assist providers, we have identified some key considerations, linked to obligations under the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) that providers should remain mindful of as they shift to online delivery.

The list of key considerations below do not reflect the full range of HES Framework and the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code 2018) requirements that relate to online delivery. Providers should ensure that there is appropriate governance in place to support online delivery and document key decisions and actions. These records are important to demonstrate that the provider has acted reasonably in the circumstances.

It is also important to recognise that there are immediate, upfront considerations to be addressed whereas responses to other considerations may be addressed over time.

1. Support for students in the new learning environment

A number of Standards are focussed on ensuring students are supported during their study. This includes Standards under Section 1.3 (Orientation and Progression), Section 2.3 (Wellbeing and Safety) and Section 3.3 (Learning Resources and Educational Support). 

Key considerations include:

• ensuring students have access to the resources they need to engage in online learning, including identifying and addressing barriers to accessing technology
• ensuring students are offered alternatives where there is significant change or disruption to delivery of courses, including processes for fee reduction, refunds or deferral
• checking existing contractual arrangements with students about mode of delivery, which may involve seeking and incorporating the views of students
• what additional learning, academic and personal support may be required in the online context. This includes ensuring students have the opportunity to contact and interact with academic and support staff and that student support is adequately resourced
• how student engagement will be maintained throughout the delivery of the course, including peer-to-peer interaction, staff to student interaction, and student support. This includes mitigating risks associated with social isolation.

2. Support services and training for teaching staff

It is a requirement under Standard 3.2.3 that teaching staff are equipped for their role. A move to online delivery may require nuanced approaches to course content, delivery and student engagement, noting that what works well for one course discipline may not be suitable for another. Staff are likely to require enhanced support and training. 

Key considerations include:

• what support services and training for staff are required for the changed delivery mode to ensure staff have the appropriate qualifications, knowledge and skills required to support the achievement of learning outcomes
• ensuring teaching staff have access to the tools to deliver online
• ensuring teaching staff have a common baseline for learning and teaching success
• how peer-to-peer interaction among teaching staff and support to teaching staff will be maintained.

3. Maintaining quality of education and learning outcomes

The quality of delivery and learning outcomes must be maintained to high standards irrespective of the mode of delivery. This focus on quality and learning outcomes is covered by a number of Standards, including Standard 3.1.4 which requires that each course of study is designed to enable achievement of expected learning outcomes regardless of a student’s place of study or the mode of delivery. Further, Section 1.4 deals with Learning Outcomes and Assessment and Section 5.2 deals with Academic and Research Integrity, which need to be applied in an online delivery context.

Key considerations include:

• assurance on how students will be able to meet the learning outcomes, and effective monitoring of student progression and the learning outcomes
• how student engagement and interaction will be monitored to ensure students are regularly logging in and undertaking the required learning
• quality assurance mechanisms tailored for the changed delivery mode, including how to review, measure and improve outcomes
• how academic integrity will be monitored and maintained. This includes ensuring risks that are particularly relevant in an online context are adequately mitigated e.g. academic misconduct, including cheating and plagiarism
• ensuring exams and assessments are fit for purpose, clearly communicated, effectively moderated, and allow students to demonstrate learning outcomes
• ensuring there are processes in place to maintain academic integrity of assessments, including proctoring/supervision of tests and exams
• how professional accreditation will be maintained (where applicable).

4. Other governance arrangements to support online delivery

The academic and governing bodies have ultimate responsibility for the provider’s operations to ensure that student interests and the quality of learning remain a priority with any shifts to new modes of delivery. Governance obligations are set out under Section 6.2 Corporate Monitoring and Accountability and Section 6.3 Academic Governance. 

Key considerations include:

• the internal decision-making and approval processes for developing, approving and implementing changes to delivery mode are clear and fit for purpose
• ensuring appropriate records are kept, including key decisions and actions, and reasons for decisions
• ensuring accurate records of changes to delivery mode on student files are maintained
• ensuring there is an appropriate communication plan for staff and students e.g. setting out key changes, how these apply to domestic and international students, and information relating to specific courses, classes, and programs
• oversight of key risks to operations in an online delivery context, including risks to academic integrity - how this will be monitored, reported, and acted upon.

In addressing key considerations and making decisions, providers should continue to act in the best interests of, and minimise adverse impacts to students, while maintaining the quality of learning. Providers should seek regular student feedback, particularly during this period of disruption, to inform continuous improvement of the student experience. 

Resources

Visit the TEQSA website for a range of online learning good practice resources from across the sector. Topics covered are:

1. Getting started: best practice for establishing online learning
2. Enabling staff to work with online learning
3. Student experience
4. Assessment integrity
5. International perspective

A student may enter a higher education course of study through a special arrangement involving the completion of an English Language Intensive Course for Overseas Students (ELICOS). This type of arrangement is called an ‘ELICOS Direct Entry’.

The main risk associated with ELICOS Direct Entry is that students will be admitted into a course of study without sufficient proficiency in English. To guard against this risk, the ELICOS Standards 2018 (P4.1 c (ii)) state that, where providers deliver ELICOS courses under a direct entry arrangement:

• formal measures must be in place to ensure that assessment outcomes are comparable to other criteria used for admission to the tertiary education course of study, or for admission to other similar courses of study.

The Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) also create corresponding requirements for higher education providers accepting students through Direct Entry arrangements. Both ELICOS and higher education providers have obligations to assure themselves that ELICOS Direct Entry applicants have achieved outcomes comparable to the admission criteria used by other applicants. The purpose of this guide is to outline how ELICOS and higher education providers can best meet these obligations.

Guidance for ELICOS providers

ELICOS providers must ensure that assessment outcomes for an ELICOS course with direct entry arrangements are comparable with other admission criteria for the course or similar courses.

A student’s ability to understand and communicate in English at a comparable level can be assessed using commonly accepted tests such as:

• CAE (C1 Cambridge English: Advanced)
• IELTS (International English Language Testing System)
• OET (Occupational English Test)
• PTE Academic (Pearson Test of English)
• TOEFL (Test of English as a Foreign Language). 

To demonstrate that a course for ELICOS Direct Entry satisfies the above requirements, providers should employ a variety of methods, including (but not limited to):

• external referencing through benchmarking
• benchmarking against valid frameworks for language proficiency
• tracer studies of student cohorts
• external testing.

External referencing through benchmarking

External review should include benchmarking of:

• assessment inputs (tasks, marking criteria/rubrics and processes)
• assessment outputs (re-examination of samples of student work and grades awarded)
• any other relevant measures. 

Benchmarking against valid frameworks for language proficiency

Content and assessment inputs and outputs may be benchmarked to an externally-validated framework for language proficiency including (but not limited to):

• Common European Framework of Reference (CEFR)
• International Second Language Proficiency Rating (ISLPR)
• Global Scale of English (GSE)
• Cambridge English Scale.

Tracer studies of student cohorts

A tracer study collects information about a cohort of students over time. Providers that offer ELICOS Direct Entry should conduct tracer studies that compare cohorts of students entering a course of study via ELICOS Direct Entry with those who enter via other means at the required English language level. Where applicable, compared cohorts should all be from the same (or similar) course of study.

Tracer studies may be supplemented with qualitative feedback from former students or higher education academic staff. The feedback should be about how well the Direct Entry program is perceived to have prepared students for their higher education studies.

External testing

External testing of the English proficiency level of students should adopt a test accepted by the higher education provider as the basis for entry for students who do not come through ELICOS Direct Entry. Any test involving a sample of students must:

• be large enough to be statistically robust
• be representative of the cohort as a whole
• minimise bias
• adopt a valid and transparent analysis of outcomes using established statistical methods.

Other methods of verification may be possible as agreed to on a case-by-case basis with TEQSA. Whichever method of verification is adopted, ELICOS providers should expect to undergo periodic review, with the frequency of review determined in part by the quality of evidence provided to TEQSA.

Guidance for higher education providers

Several standards in the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) are relevant for higher education providers accepting student through ELICOS Direct Entry arrangements. These include (but are not limited to):

• 1.1. Admission
• 1.2. Credit and Recognition of Prior Learning
• 1.3. Orientation and Progression
• 2.3. Wellbeing and Safety
• 3.3. Learning Resources and Educational Support
• 5.3 Monitoring, Review, and Improvement
• 7.2 Information for Prospective and Current Students

In the context of ELICOS Direct Entry, these Standards mean that a higher education provider should be able to:

• satisfy itself the students directly entering a higher education course through an ELICOS provider have comparable proficiency in English as students admitted based on other English language admission requirements
• show how it has satisfied itself that such claims of comparable proficiency are credible. 

Once students are enrolled through ELICOS Direct Entry, the higher education provider will also need to ensure students:

• have equivalent opportunities for success in relation to students who entered in other ways
• are provided with sufficient or appropriate post-entry language and learning support
• do not face impediments to progression and completion
• have their success rates monitored in comparison to other cohorts at a comparable English language level.

Processes for ELICOS Direct Entry should be formalised and transparent to all parties involved (including students) and should be periodically reviewed.

Related resources

• ELICOS Standards 2018
• Peer Review Portal: an (optional) online support mechanism which individuals, education providers, industry, networks and professional associations can use to meet national and international standards in external peer review
• Guidance Note: Admissions (coursework)
• Guidance Note: Credit and Recognition of Prior Learning
• Guidance Note: Wellbeing and Safety [under development]
• Guidance Note: Orientation and Progression [under development]
• Guidance Note: Learning Resources and Educational Support [under development]
• Guidance Note: Academic Monitoring, Review, and Improvement [under review]
• Guidance Note: Information for Prospective and Current Students [under development].

This discussion paper and toolkit have been prepared to stimulate new conversations about the quality assurance of online higher education in APEC economies.

Higher education is a global, mobile and growing sector, making higher education quality a priority area for policy makers, accreditation agencies, regulators and institutions. As online education increasingly becomes an integrated feature of educational delivery, it is important to ensure that it meets the same quality standards as other modes of education.

The Tertiary Education Quality and Standards Agency (TEQSA) is responsible for regulating Australia’s higher education providers to protect and enhance Australia’s reputation for high quality higher education. TEQSA has published a summary of its regulatory decisions from 1 July 2019 until 30 September 2019. 

What are TEQSA decisions?

Each week, TEQSA makes regulatory decisions. These may be on the registration of new providers or the reregistration of existing providers. For the providers that do not have the power to accredit their own courses, TEQSA also makes decisions whether to accredit or re-accredit their courses. There are many legal, compliance and quality assurance measures which a higher education provider must demonstrate in order for TEQSA to allow a provider entry to Australia’s higher education sector.

In order to make these decisions, TEQSA must be satisfied that a provider complies with the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) and the Higher Education Standards Framework, the standards framework underpinning the TEQSA Act.

TEQSA’s regulatory approach is standards and principles-based. It is guided by three regulatory principles: regulatory necessity, reflecting risk and proportionate regulation, when exercising its powers. TEQSA’s regulatory decisions are taken by its Commission, or by senior members of TEQSA staff under delegation from the Commission.

More information about TEQSA’s approach is available at Our regulatory approach page.

Where do I find more information about TEQSA’s decisions?

Detailed public reports on individual decisions are available on the National Register of higher education providers. 

For media interviews

Please contact comms@teqsa.gov.au

* This decision was made by agreement of the provider. Please see the public report on the National Register for further information.

Purpose

This guide is for registered higher education providers. It provides information about and explains the processes for making the following applications to the Tertiary Education Quality and Standards Agency (TEQSA):

• new course accreditation, and
• renewal of course accreditation.

Applications for course accreditation are considered under Part 4 of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act).

TEQSA may renew a provider’s course accreditation or accredit a new course if it is satisfied that the provider meets the relevant Standards in the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework).

TEQSA will use a range of information to reach its decision, including information submitted by the provider with its application. The minimum evidence for each application type is outlined in the tables in Appendix A of this guide.

In determining the scope of the information required, TEQSA will use the differentiated model (known as the ‘core+’ model) explained in Section B of this Guide. All applicants will be required to submit minimum evidence relating to a set of core Standards. The minimum evidence for each application type is outlined in general in the tables in Appendix A. Some providers will be asked to submit evidence against other selected Standards on a case-by-case basis, according to risk and regulatory track record. The specific evidence required for your individual case will be documented by TEQSA in the form of the Confirmed Evidence Table for the application (i.e. course accreditation or renewal of course accreditation), and sent to you.

For assistance in understanding the requirements of the HES Framework, new providers should refer to the guidance in TEQSA’s Higher Education Standards Framework 2021 section in the first instance, which includes an overview of each Domain of the HES Framework.

Detailed guidance notes can be found on the Guidance notes page.

Our annual report is also available on the Transparency Portal, the new central repository of publicly available corporate information for all Commonwealth bodies.

TEQSA's Annual Report for 2018-19 was tabled in Parliament on Monday 21 October 2019.

Purpose

The purpose of this policy is to establish a set of principles to inform TEQSA’s treatment of providers identified as high risk in relation to students or financial position—at the point of identification, and also in the course of accreditation, re-accreditation and re-registration assessments. It elaborates upon and further specifies the principle, published in TEQSA’s Risk Assessment Framework, that TEQSA may take various forms of action in relation to providers being identified as high risk. The principles that comprise this policy are intended to ensure that identified provider risk-levels drive differential treatment of providers, in line with established good practice in risk-based regulation, and consistent with the basic principles for regulation included in TEQSA’s establishing legislation.

Scope

This policy relates to providers identified as high risk through TEQSA’s annual risk assessment process. It does not relate to providers identified as low or moderate risk. Although the policy may to some extent describe TEQSA’s treatment of providers not identified as high risk, this is intended only to enhance clarity through contrast.

Principles

In-cycle monitoring

1. Where a provider is identified as high risk, the following activities are immediately triggered:
   
   1. a request for information to enable greater differentiation of risk type and extent, with the information requested to be determined on the basis of identified risk factors and other information available to TEQSA
   2. analysis of existing data, supplemented by additional information requested of high risk providers, to more precisely identify any potential areas of concern with the provider
   3. formulation of an action plan that will include consideration of the full range of available and appropriate regulatory options, including in relation to CRICOS applications, consistent with the principles for regulation described in the TEQSA Act
   4. TEQSA will provide advice to the relevant Australian Government department and portfolio Minister to support decision making under the Higher Education Support Act 2003.

Cyclical renewal of accreditation and renewal of registration assessments, and new accreditation assessments

2. In general, TEQSA differentiates the scope (of Threshold Standards tested), and the depth (of evidence required) of accreditation- and registration-related assessments on the basis of assessed risk.
3. For a provider that is not identified as high risk, an assessment will focus on a subset of standards and associated evidentiary requirements considered applicable to each case, and will expand this subset to cover areas of concern as appropriate to each case on the basis of available evidence.
4. Where a provider is identified as presenting a high risk to financial position, in registration- and accreditation-related assessments subsequent to the risk assessment, the starting point for the scope of assessment will include all financial- and resourcing-related standards, any standards related to planning and mitigation in case a provider ceases to operate, and any other standards that may be identified as relevant to the particular case given the financial risks identified, with this scope potentially reduced as appropriate in the context of the particular assessment.
5. Where a provider is identified as presenting a high risk to students, in registration- and accreditation-related assessments subsequent to the risk assessment, the baseline scope and evidence assumption will be reversed so that the starting point includes all standards appropriate to the application type, with standards subsequently excluded where not relevant to the provider or case in question, or where an assessment has recently determined the provider’s compliance, or otherwise where appropriate in the context of the particular assessment.

Contact

Any enquiries about TEQSA’s approach to high risk providers can be directed to: enquiries@teqsa.gov.au