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Effective from 1 January 2017

Providers should note that Guidance Notes are intended to provide guidance only. They are not definitive or binding documents. Nor are they prescriptive. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time.

What is TEQSA’s role in relation to the AQF?

The Australian Qualifications Framework (AQF) is a national policy document that includes overarching specifications for regulated qualifications in Australia. TEQSA has regard to the specifications and guidelines throughout the AQF.

TEQSA’s role is to register all higher education providers and ensure that providers and their courses continue to meet the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework). TEQSA applies the Standards in Part A of the HES Framework in the context of three regulatory principles: reflecting risk, regulatory necessity and proportionate regulation (section 13 of the Tertiary Education Quality and Standards Agency Act 2011 [TEQSA Act]¹). All of TEQSA’s regulatory activities must comply with these three principles. 

The HES Framework includes the requirement that the learning outcomes of all higher education qualifications at Levels 5-10 of the AQF must be consistent with the level of the course, which TEQSA will assess against the corresponding specifications for levels in the AQF. TEQSA will also take into consideration the relevant qualification type descriptors in the AQF.

The first of these requirements is located in Section 1.4 of the HES Framework on Learning Outcomes and Assessment:

‘1.4.1.  The expected learning outcomes for each course of study are specified, consistent with the level and field of education of the qualification awarded, and informed by national and international comparators’.

The second requirement is located in Section 1.5 on Qualifications and Certification:

‘1.5.3.  When an Australian Higher Education Qualification is offered, the course of study leading to the qualification is either self-accredited under authority to self-accredit or accredited by TEQSA and the learning outcomes for the qualification are consistent with the level classification for that qualification in the Australian Qualifications Framework’.

A further requirement is located in Section 3.1 on Course Design:

‘3.1.2.  The content and learning activities of each course of study engage with advanced knowledge and inquiry consistent with the level of study and the expected learning outcomes including:

a.Current knowledge and scholarship in relevant academic disciplines

b.Study of the underlying theoretical and conceptual frameworks of the academic disciplines or fields of education or research represented in the course, and

c.Emerging concepts that are informed by recent scholarship, current research findings, and, where applicable, advances in practice’.

Section 3.2 on Staffing also includes a requirement that academic staff and leaders have the qualifications and capacity needed to teach students in relation to the nature and level of expected learning outcomes (see Standard 3.2.2).

Domain 6 on Governance and Accountability includes the requirement that academic leadership must be consistent with the levels of higher education offered.

TEQSA does not determine the content of the AQF.

Stakeholders who wish to suggest amendments to the AQF should direct their suggestions to the Australian Government Department of Education and Training.

Stakeholders who wish to suggest amendments to the HES Framework should direct these to the Higher Education Standards Panel.

How does TEQSA assess whether the learning outcomes of a course are at the appropriate AQF level?

To assess whether the expected learning outcomes for a course meet the AQF level, TEQSA: 

• compares the expected course learning outcomes with the specified learning outcomes for the relevant AQF level
• assesses whether the design of all components of the course support achievement of the course’s learning outcomes as a whole.

TEQSA will also ascertain how effectively the course is designed to assess whether students will have achieved the course learning outcomes by the end of the course.

TEQSA may call on external academic discipline experts to assist in reviewing courses for course accreditation and re-accreditation applications from providers without Self-Accrediting Authority. TEQSA may also consult with or take account of the observations of professional accrediting authorities where relevant.

How much flexibility do providers have in assigning titles to AQF qualifications?

TEQSA will review qualification titles to ensure they accurately represent the nature of the course and particularly the qualification type, as required by Standard 7.1.1 in the HES Framework, with reference also to the AQF Qualifications Issuance Policy², which states that 'qualifications will have titles that unambiguously identify each qualification type, level and field of study/discipline’. For example, the title ‘Advanced Master of X’ is potentially misleading, implying that the qualification is of a type and level higher than Level 9. By contrast, it would be acceptable to use the title ‘Master of X (Advanced)’. However, providers would need to demonstrate that the course content was in some way more advanced than in other courses that do not have this designation.

Can Bachelor Honours Degrees be awarded solely on the basis of merit?

The AQF Level 8 criterion specifies that graduates will have advanced knowledge and skills for professional/highly skilled work and/or further learning. TEQSA assesses courses of study designated as honours-level courses through evidence that the course design, learning activities and assessment requirements are consistent with the Level 8 learning outcomes.

The past practice of awarding degrees with honours based only on meritorious performance (e.g. grade point average or weighted average mark) within a Bachelor Degree without evidence of additional honours-level study is no longer supported under the AQF or the HES Framework. A student cannot be awarded honours after completing the same course of study as a student who graduates with a pass degree. 

Under the AQF, Bachelor Honours Degrees are achievable either as part of an integrated course of study with embedded Level 8 honours components (e.g. a 4-year Bachelor Degree with an embedded Level 8 component) or as a separate honours year with Level 8 learning outcomes following a three-year Level 7 Bachelor Degree.

Can undergraduate units be included within a Graduate Diploma?

The AQF Level 8 criteria require graduates of a Graduate Diploma to have ‘advanced knowledge and skills for professional /highly skilled work and/or further learning’. 

It is doubtful if advanced knowledge at Level 8 could be developed within a one-year Graduate Diploma if the diploma made significant use of units from a Level 7 Bachelor Degree without adaptation, although one or two units from a Bachelor Degree could be included where they provide valid foundations as an introduction to Level 8 studies. It is more likely that some units from a Bachelor Honours Degree could be suitable for use within a Graduate Diploma, as both of these qualifications are at Level 8, however, this would be assessed by TEQSA on a case-by-case basis.

For any given Graduate Diploma, TEQSA will assess whether the course as a whole meets the specifications for Level 8 and whether the course enables students to achieve Level 8 learning outcomes by the end of the course.

How much research should there be in Masters Degree (Coursework) courses?

The Level 9 Specification criteria in the AQF include the following requirements:

• ‘Graduates at this level will have specialised knowledge and/or skills for research, and/or professional practice and/or further learning’, and
• ‘Graduates will have expert, specialised cognitive and technical skills in a body of knowledge or practice to independently:… research and apply established theories to a body of knowledge of practice’.

The descriptors for all qualification types at Level 9 require students to have knowledge of research principles and methods.

To meet these requirements and those of the HES Framework, a Masters Degree (Coursework) should include some form of learning activity that develops knowledge of research methods and principles appropriate to the discipline, field of work, or professional practice.

Learning activities to develop research skills would typically include one of the following:

• a research-based project
• a capstone experience and/or
• a piece of scholarship.

These three types of activities can be alternatives.

A Masters Degree (Research) by definition requires the planning and execution of a project that includes a substantial piece of research which makes a contribution to knowledge. By contrast, a Masters Degree (Coursework) does not require a graduate to make a contribution to knowledge.

Whilst this Note specifies the minimum elements of ‘research’ in a Masters by coursework (see above), this does not preclude individual providers including greater components of research such as independent research projects or the like.

How much flexibility is there in the volume of learning requirements for various types of Masters Degrees?

TEQSA will expect the learning outcomes of any course to be achievable by most students within the duration specified for the course, and assessed at the required level. 

TEQSA will have regard to the volume of learning guidelines for particular qualification types in the AQF as reference points. 

Where applicants are proposing a volume of learning substantially lower than those specified in the AQF qualification type descriptors, they should present an academically defensible case to the accrediting body (TEQSA, or their own course-approval body if they have Self-Accrediting Authority), citing credible reference points. Other reference points could include international comparators. 

TEQSA will pay particular attention to the interaction between the volume of learning and the level of assessment tasks. The level of assessment tasks should not be lowered to facilitate a shorter course duration.

The amount of time students require to complete a postgraduate course should be related to the level of their prior learning overall, and specifically to the level of prior learning in the relevant discipline. Admission requirements and volume of learning are inter-related in these cases and should take varying amounts of prior learning in different cohorts of applicants into account. Students with no background in the required discipline will need to undertake additional subjects introducing them to the discipline, which is likely to lead to the longer indicative durations in Table 1.

Particular issues can arise in relation to Masters Degrees (Coursework) in business fields, including the Master of Business Administration (MBA). It is common for substantial business experience to be one of the entry requirements into the MBA, substituting, to some extent, for formal qualifications. Providers need to consider the extent to which substantial business experience can be regarded as equivalent to experience in the academic discipline, in order to justify a shorter volume of learning (for example one year instead of two years). 

The issue here is whether applicants returning to study (or with no background in the discipline) will be able to achieve the course learning outcomes in the course duration, including acquisition of ‘advanced and integrated understanding of a complex body of knowledge in one or more disciplines or areas of practice’. 

Similar issues would apply in the case of Masters Degrees (Coursework) principally designed for professional conversion (for example a Master of Teaching or a Master of Accounting, for students with a Bachelor Degree in any field).

It may be more academically defensible to enrol students without prior experience in the academic discipline in a Level 8 qualification first, and allow them to articulate into the Masters Degree (Coursework) after demonstrating their ability to progress to achieving learning outcomes appropriate for a Masters Degree.

The volume of learning guidelines for Masters Degree (Coursework) in the AQF are summarised in Table 1 in Appendix A, for ready reference. In view of the myriad of possibilities, TEQSA will consider proposals on a case-by-case basis.

Credit, RPL and volume of learning

Prior learning (formal or informal) can be used either:

• to support admission into a course where the applicant does not have the standard criteria for admission, or
• for applicants who have met the standard criteria for admission, to support exemption form the need to complete some components of the course.

TEQSA does not expect that the same recognition of prior learning (RPL) would be used both for entry and for credit exemptions. Providers will need to ensure that where prior learning is used as a pathway into any course of study, the policies and course documents specify the extent to which prior learning can be used to gain admission into, or as contributing to credit (and therefore a shorter volume of learning) within, the course of study. 

The underlying principle, however, must still be observed; all students should have a sufficient basis of prior knowledge and skills to achieve the course learning outcomes and the learning outcomes for the AQF level in the time specified. This needs to be ascertained at the point of admission. 

TEQSA acknowledges that there are relationships between volume of learning and course duration that arise from differing models of participation. For example a course could be taught across three trimesters per year or in semesters for a longer period. Providers need to take care to present their models of delivery and participation accurately; to be clear to students and for CRICOS purposes for international students. 

When will changes to meet AQF specifications have consequences for CRICOS?

Part C, Section 7 of the National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2007³ (National Code) states that registering a course on CRICOS must include the expected duration of the course and ‘the designated authority must take into account the proposed course structure when determining the appropriate duration for registration on CRICOS’.

In accordance with the National Code, any changes to the registered duration of a course must be approved by TEQSA prior to the changes being made.

Whilst ELICOS and Foundation Programs are non-AQF courses, TEQSA also has regulatory responsibility for CRICOS registration of Foundation Programs and ELICOS courses linked to higher education programs. TEQSA will assess these courses against the relevant standards under the ESOS Act:

• ELICOS National Standards 
• Foundation Standards⁴

What is TEQSA’s role in assessing other courses for non-AQF qualifications?

Standard 1.5.9 in the HES Framework provides that:

‘Qualifications that do not align with a qualification that is recognised in the Australian Qualifications Framework are not described using the nomenclature of the Australian Qualifications Framework or implied to be a qualification recognised in the Australian Qualifications Framework’.

TEQSA will not assess courses that lead to non-AQF awards.

Can academic staff teach in a course if they do not have a qualification at least one AQF level higher than that of the course?

TEQSA will check that academic staff are appropriately qualified in the relevant discipline to at least one level higher than the AQF qualification level being taught, or that they have equivalent professional experience, as required in Standard 3.2.3 of the HES Framework. This is to ensure that the provider has the appropriate academic staff profile to ensure students receive a quality learning experience in a higher education environment. Consideration of the teaching staff will be done on a case-by-case basis, as TEQSA recognises that there are various combinations of qualifications and experience which would meet the requirements of the Standard.

There are four elements considered by TEQSA in assessing the suitability of the teaching staff for a particular course of study:

• qualifications and experience
• knowledge of contemporary developments in the discipline or field, informed by scholarship or research
• skills in teaching, learning and assessment relevant to the discipline
• relevance of the discipline.

If providers are relying to some extent on equivalent professional experience, this experience must be relevant to the course of study being taught and be equivalent to the required qualification level and specifications in the AQF. The provider should have a policy framework underpinning its approach to assessing equivalence. 

Please note that Standard 3.2.4 requires that teachers who teach specialised components of a course and who do not fully meet Standard 3.2.3 ‘have their teaching guided and overseen by staff who meet the Standard’. This might, for example, include tutors and higher degree students who are gaining teaching experience, or experienced practitioners.

For further detail, please refer to TEQSA’s Guidance Note on determining equivalence of professional experience and academic qualifications.

How will TEQSA interact with professional bodies and registration boards when assessing the same course?

In cases where both TEQSA and professional bodies are assessing the same course within the same timeframe, there are benefits for all parties in collaborating. TEQSA has been working with a number of professional bodies and its approach is under development.

For more information, refer to the Engagement with professional bodies page.

Such interactions could be beneficial:

1. to reduce duplication of activities and therefore reduce the regulatory burden on providers; and
2. to ensure a consistent and aligned approach to regulation and accreditation – i.e. TEQSA and professional accrediting bodies talk to each other and share relevant information.

Examples could include sharing of experts for course assessment, sharing of documentation or reports etc. 

TEQSA welcomes higher education providers to submit professional accreditation and other external review reports of its courses as part of applications for renewal of course accreditation and registration, as evidence of effective self-regulation and expert input. TEQSA also notes that a TEQSA accreditation of an institution may provide information on which a professional body may rely, even if not specific to a particular program e.g. evidence of effective institutional corporate and academic governance.  TEQSA also acknowledges that TEQSA’s work and the work of professional bodies have different levels of focus (institutional vs program) and purposes (regulation against the HES Framework vs e.g. public safety within the National Law for health professions).⁵

Notes

1. The complete TEQSA Act is available online.
2. See the AQF website.
3. The National Code was under review at the time of updating these FAQs.
4. The ELICOS National Standards and Foundation Standards are available online.
5. The Higher Education Standards Panel is considering the development of a Code of Practice for Professional Accreditation in Australian Higher Education, to further encourage the streamlining of accreditation processes.

 

Version #	Date	Key changes
1.0	February 2013
2.0	30 May 2014	Updated for volume of learning revisions in the AQF for Masters Degrees.
3.0	10 November 2016	Updated for the HESF 2015 and made available as beta version for consultation.
3.1	5 April 2019	Incorporation of consultation feedback.

 

 

Appendix A

Summary Table 1 – Masters Degree (Coursework) volume of learning guidelines

Previous Learning (Academic years)	Length of Masters (Academic years = 1 EFTSL)
Related Discipline
Bachelor Honours Degree/Degree with Honours	1 year
4-year Bachelor Degree	1 year or 1.5 years*
3-year Bachelor Degree	1.5 years or 2 years*
Different discipline
Bachelor Honours Degree/Degree with Honours	1.5 years
4-year Bachelor Degree	1.5 year or 2 years*
3-year Bachelor Degree	2 years

* Duration determined by entry requirements, structure and purpose of the Masters Degree, and demonstrated achievement of Masters-level outcomes.

 

 

 

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Definitions
“PIR providers”	Non-HESA-providers, and HESA-funded providers who report “Staff” data.
TEQSA	Tertiary Education Quality and Standards Agency
PIR	Provider Information Request
HEDC	Higher Education Data Collection
“the Department”	Australian Government Department of Education
TCSI	Transforming the Collection of Student Information
“the TEQSA Act”	Tertiary Education Quality and Standards Agency Act 2011
“the HESA Act”	Higher Education Support Act 2003
COPHE	Council of Private Higher Education
IHEA	Independent Higher Education Australia
ACPET	Australian Council for Private Education and Training
HEPCAT	Higher Education Provider Client Assistance Tool
NHF	Non-HESA-funded higher education providers
HEIMS	Higher Education Information Management System
ASD	Australian Signals Directorate
B2G	Business to Government API
API	Application Programming Interface
Packet	Interchangeable with ‘Flat File’; refers to a submission file in the context of the API submission method.
“Flat File”	Interchangeable with ‘Packet’; refers to a submission file in the context of the Portal submission method.
SMS	Student Management Solution

 

Revision History
Version Number	Date	Author(s)
1.0	14.05.2019	Jeremy Ong (Policy and Analysis, TEQSA)
0.9	24.04.2019	Timothy Howard (IM Program Officer, TEQSA)
0.8	16.04.2019	Timothy Howard (IM Program Officer, TEQSA); Joy Tan (Senior Risk Analyst, TEQSA).
0.7	05.04.2019	Timothy Howard (IM Program Officer, TEQSA)
0.6	03.04.2019	Timothy Howard (IM Program Officer, TEQSA)
0.5	28.03.2019	Timothy Howard (IM Program Officer, TEQSA)
0.4	18.12.2018	Timothy Howard (IM Program Officer, TEQSA)
0.3	30.10.2018	Timothy Howard (IM Program Officer, TEQSA)
0.2	03.09.2018	Timothy Howard (IM Program Officer, TEQSA)
0.1	16.08.2018	Timothy Howard (IM Program Officer, TEQSA)

 

 

Introduction

Background

The Provider Information Request (PIR) is undertaken to ensure key data is available for all higher education providers, to support a data-driven, risk-based approach to regulating the higher education sector. The Tertiary Education Quality and Standards Agency (TEQSA) utilises this data to minimise the reporting burden upon providers associated with regulatory processes, such as a renewal of registration.

The collection serves as a complementary collection to the Department of Education and Training’s (the Department) Higher Education Information Management System (HEIMS) data collection. It collects supplementary data that is otherwise not included in HEIMS, including the student data of 34 higher education providers and staff data of over 130 higher education providers not captured under subsection 19-70(1) of the Higher Education Support Act 2003 (HESA Act).

In 2016, TEQSA transitioned the formal administration of the PIR to the Department. The transition was a significant milestone towards creating an extensive, unified national collection for higher education data – an objective both TEQSA and the Department had worked to establish over several years. Under the transitioned arrangements, PIR student and staff data is reported through the Higher Education Provider Client Assistance Tool (HEPCAT) under separate submission files, due to scope differences in the specifications of the PIR and HEIMS data collections.

The Department is currently undertaking a major redevelopment of the Higher Education Data Collection (HEDC), named the Transforming the Collection of Student Information (TCSI) project.¹  Key objectives of the project include: direct reporting between provider systems and the Department; adoption of a unique student identifier for all students; and the reduction in size of the collection through the removal of duplicated data elements. 

The TCSI project will introduce a number of significant changes to how the PIR functions, specifically: HEPCAT will be replaced by a choice of two new submission methods; the scope of the PIR will be expanded and revised to ensure full compatibility with HEIMS, improving data quality and analysis; and, the collection period will be brought forward to earlier in the year to allow for earlier access to full-year datasets.

Purpose

This paper describes TEQSA’s approach to navigating the issues involved with streamlining the collection into the broader TCSI project, whilst minimising additional compliance burden upon providers. The requirement to examine the PIR, due to changes brought by TCSI, provides a valuable opportunity to re-evaluate and improve the collection against TEQSA’s regulatory principles and deliverables.

The alignment of data elements between the PIR and HEIMS will enhance data validity and reduce the possibility of data inconsistencies. To enable this alignment, the collection scope must be expanded to cover the minimum mandatory elements of the updated HEIMS specification. This expansion, alongside the streamlining of reporting periods, will allow TEQSA to draw upon a more comprehensive and timely source of data, allowing for more efficient and effective regulatory assessment processes, which in turn further improve the accuracy of assessment outcomes.² These actions will also serve to reduce information gaps in provider profiles, providing an improved evidence base to better inform policy development, good practice and student choice.³  

TEQSA is proposing the choice of two submission pathways to substitute HEPCAT. The Business to Government (B2G) application programming interface (API) permits a provider’s student management solution to establish a direct connection to the Department, enabling the real-time reporting of data to occur with minimal intervention. An alternative solution, the Provider Portal, will be available for smaller providers who are unable to implement a student management solution (SMS), allowing for the submission of data through an online form or spreadsheet (e.g. Microsoft Excel). This choice will be left to providers – should a provider choose to implement an SMS, the reporting of student data will become seamless; otherwise, spreadsheet reporting through the Portal will continue to be available. The reporting of staff data will continue as a spreadsheet submission through the Portal.

The objectives of this project are to:

• streamline and align TEQSA and Department data collections, wherever feasibly possible
• audit the current data schematic for informational gaps and improve data quality and breadth
• determine how PIR providers will report, access and utilise data
• align the timing of the TEQSA and Department data collections.

The outcome of this project will be a single, unified reporting system for universities, higher education and vocational institutions. PIR providers will benefit from the technological advances of the TCSI project, primarily through the implementation of the new B2G API which will generate significant savings in time and effort for providers who choose to utilise the solution. Those who choose to utilise the alternative Provider Portal will still benefit from the removal of ineffective and duplicated data elements from the collection scope, reducing compliance burden. Moreover, the alignment to HEIMS will support improved insights into how their operations are tracking compared to other non-HESA-funded and HESA-funded providers.

Consultation process

TEQSA has established a comprehensive consultation process to ensure that all feedback is considered as the Agency re-evaluates the PIR data collection. The discussion points contained within this paper are a starting point to guide stakeholder feedback. Stakeholders are encouraged to use the consultation process to raise any further ideas or commentary that might help improve the implementation plan.

Guiding this consultation is TEQSA’s commitment to working with all PIR providers to continually improve the collection process, and to ensure that the most effective, relevant dataset is produced.

Process

Throughout the outlined process, TEQSA will provide regular updates using the Agency’s e-News, social media accounts and website to keep the sector informed of progress on the re-evaluation and transition.

Step One: Consultation paper and proposed schematic distributed

To begin the consultation process and seek feedback, this consultation paper will be distributed to the two peak sector bodies who represent the majority of PIR providers – the Australian Council for Private Education and Training (ACPET) and Independent Higher Education Australia (IHEA) – alongside a proposed data schematic, to seek feedback. This paper will also be presented to individual PIR providers.

Step Two: Consideration of submissions

TEQSA will consider all submissions received before the closing date of 20 September 2019 and will attempt to incorporate any relevant recommendations into the implementation plan.

Step Three: Stakeholder discussion and information forums

A number of forums will be held with interested provider representatives to inform and discuss the implementation plan. PIR providers are welcome to nominate representatives for these forums by sending a request to collections@teqsa.gov.au.

Step Four: Final schematic and documentation distributed

The consultation process will conclude with the release of a final data schematic and data element dictionary, to ensure all PIR providers are ready to migrate to the new system in time for the 2020 PIR.

Making a submission

Format

Your submission should clearly state the following information:

• the name of the organisation and/or individual who is making the submission (if an organisation, please provide details of a contact person)
• your contact details, including at a minimum the following:
  • an address
  • an email address
  • a telephone number.

Submission

Submissions and other enquiries can be sent electronically or by post using the following details. Submissions must be received before the closing date of 20 September 2019 to be eligible for consideration.

Electronic submission
Email address: collections@teqsa.gov.au 
Subject: PIR TCSI Integration Project Submission

Postal submission
Information Management Team
Tertiary Education Quality and Standards Agency
GPO Box 1672
Melbourne VIC 3001

Confidentiality

TEQSA will not accept submissions that are provided on a wholly confidential basis. If you consider that information in your submission should be treated as confidential, please provide this information as a separate attachment and clearly indicate this in your submission.

For more information on TEQSA’s Privacy Policy, including the Agency’s collection of information and use or disclosure of personal information, please view our Privacy page on the TEQSA website.

Further guidance

If you have any enquiries regarding the content of this consultation paper, or alternatively the consultation process, you are welcome to contact us by email at collections@teqsa.gov.au. 

Summary of changes

This section outlines the challenges and opportunities in implementing changes to the PIR data collection process, including the rationale for these revisions in line with TEQSA’s regulatory principles, and how the changes will benefit providers.

Reporting process

Issue

A key objective of the TCSI project is to establish direct reporting between provider systems and the Department. The current submission pathway used by providers, HEPCAT, is not equipped to handle this functionality and also suffers from a number of other deficiencies. For example, HEPCAT validates submissions on a file-level rather than a record-level, and will decline the entire file submission even if there is only one failed record. Moreover, HEPCAT must be installed locally and is currently only compatible with Microsoft Windows 7, meaning that submissions cannot currently be made using Apple Mac, Linux or modern Windows 10 systems.

Any replacement submission pathway must balance the technological advancements of TCSI with the level of transitional impact upon providers, whilst delivering an improved front-end experience for the user.

Proposal

To reduce transitional burden upon providers, TEQSA is proposing the choice of two submission pathways to replace HEPCAT:

• The B2G API permits a provider’s student management system to establish a direct connection to the Department, enabling real-time reporting of data to occur with minimal human intervention
• The Provider Portal, designed for smaller providers who are unable to implement a student management system, allows for the submission of data through an online form or spreadsheet (e.g. Microsoft Excel).

The PIR is currently composed of 5 submission files, although this will be expanded to 10 files to maintain referential integrity and consistency with the TCSI project. This change will reduce duplication and limit the likelihood of data reporting errors. Providers choosing to utilise the Provider Portal will be most impacted by this change, as the B2G API will handle this process in the background.

All providers, regardless of what method they choose to utilise in the reporting of student data, will be required to use the Provider Portal to submit staff data through a spreadsheet submission.

Further information on the restructuring of the file structure can be found in the accompanying Provider Information Request Data Schematic and Provider Information Request Data Dictionary contextual documentation.

Benefits

• A singular reporting process for universities, higher education and vocational institutions, achieved through the streamlining of the PIR into the broader HEIMS data collection
• The choice of two user-friendly submission pathways – the preferred B2G API, which achieves significant time savings for providers by enabling real time data feeds through the establishment of a connection between provider systems and the Department, and the alternative Provider Portal
• Reduced learning curve in comparison to the training required with HEPCAT, as your student management system would handle an API submission, and the Department’s backend infrastructure would automatically interpret and translate the data fields of a Provider Portal submission to those of TCSI, reducing any transitional impact on providers.

 

Discussion
For PIR providers who choose to utilise the ‘Provider Portal’, what other benefits or unforeseen implications that might impact your institution do you see arising with this proposed transition? How can these complications be mitigated and what viable alternatives might be a better solution?

Data scope and TCSI alignment

Issue

PIR providers currently report against a maximum of 45 data elements, whilst HESA-funded providers report against a maximum of 137 data elements. If PIR providers were to directly transition over to the HEIMS data collection, they would be subject to a 72 per cent increase in data elements to report against. Out of these 45 data elements, only 9 do not have a direct equivalent within the HEIMS data scope, meaning that the PIR could be otherwise streamlined into the broader HEIMS collection relatively easily.

Many duplicated elements currently exist within the PIR data scope, while other existing elements have been identified as ineffective, producing information gaps within provider profiles. Specifications of PIR data elements also sometimes differ from their equivalents in HEIMS, producing data inconsistencies when comparative analyses are undertaken.

Proposal

TEQSA proposes to expand the scope of the PIR with a view to improve the quality of data and to align the collection to become fully-compatible with the TCSI project, whilst attempting to minimise compliance burden.

It is envisaged that an additional 41 new data elements be added and 10 existing data elements be removed or superseded. These additional elements will likely have little impact on providers, as they are primarily demographic in nature, and will already be captured by providers. Duplicated elements will be removed wherever feasible. In addition, 22 existing data elements will also be revised in an effort to improve the effectiveness of the collection, with some of these elements being split in two for clarity and simplicity.

Expanding the scope of the PIR will also further strengthen the validity of risk indicators and measurements by allowing TEQSA to draw upon a more comprehensive and detailed dataset, reducing information gaps in provider profiles and improving general data quality and breadth which serve to inform improved analysis and regulation of the higher education sector. An expansion is also necessary to align data elements between the PIR and HEIMS data collections.

An alignment of these data elements will reduce the possibility of data inconsistencies, allowing for strengthened comparative analysis between NHF and HESA-funded providers. Moreover, it will allow providers to exploit the many technological advances and front-end improvements brought about by TCSI, reducing the time and effort spent reporting. As TCSI will also provide a singular reporting process for all types of higher education institutions, it will also grant a straightforward transitional path for providers who aspire towards gaining FEE-HELP accreditation.

A proposed data schematic, including an overview of the changes outlined, can be found in the accompanying Provider Information Request Data Schematic contextual document.

Benefits

• Data elements will be standardised and aligned between the PIR and HEIMS data collections, reducing the possibility of data inconsistencies and allowing for more effective and efficient regulatory processes
• New areas of analysis possible with the availability of an expanded evidence base, whilst overall data quality will improve with the removal of unnecessary data elements and the revision of existing elements.

Discussion
What do you think of the proposed data schematic? Do you see any weaknesses in any of the data elements presented? Are there further things we could do to make the collection more user-friendly and efficient?

Submission period alignment

Issue

The HEIMS data collection will transition to direct reporting with the HEDC redevelopment, enabling real-time reporting of data on an ongoing basis. Once this occurs, there will be no set reporting period for the collection. Rather, data will flow on a continual basis between provider systems and the Department. One of the primary objectives of the redevelopment is to make a full-year of verified student data available earlier in the year, meaning the PIR will need to be brought forward to allow this objective to eventuate.

Proposal

TEQSA proposes a move of the PIR submission period from its current August submission window to March, to allow a full-year of verified student data to be made available earlier. The change in timing would make the processing of data more efficient, as data from HEIMS and the PIR could be verified concurrently, removing unnecessary overheads by essentially merging two disparate processes into a singular, streamlined process. 

Benefits

• A full-year snapshot of verified student data will be made available earlier in the year, with a single submission period in March to align with the HEIMS data collection
• Removal of unnecessary overheads by allowing HEIMS and PIR data to be verified concurrently, streamlining two processes into one, thereby allowing the HEDC to become more efficient
• Allows TEQSA to better plan cyclical regulatory activities and assessments, providing more certainty around the timing of data availability, in turn further ensuring the accuracy of assessment outcomes.

Discussion
How will the change in timing to March impact upon your institution’s operations? How might these impacts be further mitigated?

 

Data security, integrity and privacy

Issue

The Department’s transformation of the HEDC will mean that the centralised data repository will begin using new technologies (i.e. cloud-based ‘Data Lake’). These technologies bring a number of distinct advantages, including the futureproofing of the platform to be compatible with new and emerging technologies. 

There are a number of privacy implications that will need to be considered in a transition to using cloud-based technology. Under the proposal, data that falls under the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) will be stored alongside other data collected by the Department that falls under the HESA Act. Under existing arrangements between the Department and TEQSA, the Department collects PIR data pursuant to the TEQSA Act and releases it directly to TEQSA for the purposes of undertaking its regulatory functions. With the transition to cloud-based technology, TEQSA will undertake work to ensure similar safeguards around data separation and segregation are in place to protect personal information from unsolicited use. 

Further work will need to be undertaken in consultation with the Department and the Office of the Australian Information Commissioner to determine whether it is appropriate to obtain consent from individuals to store their personal information on cloud-based technology, and if so, potential disclosure arrangement options. 

Proposal

While data legislated under both the TEQSA and/or the HESA Acts will be stored together within the Department’s central data repository, access to TEQSA-legislated data will continue to be limited to TEQSA officers for the purposes of the agency’s regulatory functions. All personal information collected by TEQSA is protected by the Privacy Act 1988 (the Privacy Act). TEQSA is committed to protecting personal information and will undertake a review to ensure adequate safeguards for the protection of personal information under the proposal against requirements contained within the Privacy Act, the Privacy (Australian Government Agencies – Governance) APP Code 2017 and the Guidelines for Federal and ACT Government World Wide Websites, issued by the Privacy Commissioner.  

The Department’s central data repository will be secured using best practice tools and techniques, whilst the cloud infrastructure that will be hosting the data will be Australian Signals Directorate certified, approved for Commonwealth Government use and audited by the relevant agencies to ensure that data security and integrity will be maintained.

Benefits

• Future-proofing the infrastructure of the Department’s central data repository, allowing it to make use of new and emerging technologies
• Centralisation of inter-agency data into one singular repository will reduce costs and overheads, whilst being hosted on an expandable, load-balanced and secure cloud environment
• Data security and integrity is ensured, with access to records being limited by their relevant legislative act, whilst the data infrastructure itself is approved and audited by the relevant government agencies following due process.

Discussion
Are there any further data security and privacy issues around the storage of student/staff personal information collected by your institutions on cloud-based technology that you believe TEQSA should consider?

Notes

1. More information on the Transforming the Collection of Student Information (TCSI) project is available in the discussion paper, Redevelopment and Audit of the Higher Education Data Collection.
2. See 'Action 1.4: Enhance TEQSA’s approach to monitoring, assessment and management of risks' in the TEQSA Corporate Plan 2018-22.
3. See 'Action 3.2: Provide information about the sector to inform policy development, good practice and student choice' in the TEQSA Corporate Plan 2018-22.

 

Body

The consultation closed on 16 December 2022. Feedback is available on the Consultations page.

Register Guidelines

The Tertiary Education Quality and Standards Agency (Register) Guidelines 2017 (Register Guidelines) is a legislative instrument that sets out the information that TEQSA must enter on the national register in respect of each registered higher education provider.

• View the Register Guidelines and the National Register

Currently the Register Guidelines require TEQSA to include information about regulatory decisions under the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) (see section 9 of the Register Guidelines) and, for each registered provider, “trading name/s used for the provider’s higher education operations” (see section 4(b) of the Register Guidelines).

Proposed amendments to the Register Guidelines

Reason for proposed amendments

Requiring the national register to include information regarding the decisions TEQSA makes about higher education providers under the ESOS Act, and to include the relevant legislative provision(s) which were the subject of findings that informed TEQSA’s decision(s) under either the TEQSA or ESOS Acts will promote transparency and align with TEQSA’s approach to public reporting.

Requiring the national register to state only the current trading names for registered providers’ higher education operations will remove any doubt in relation to which trading names for these providers the Register must contain, in circumstances in which providers’ relevant trading names can change over time.

Consultation process

This paper is being made available on TEQSA’s website (www.teqsa.gov.au) and has been sent directly to peak bodies for providers regulated by TEQSA under the TEQSA Act.

TEQSA requests that feedback on the proposed amendments to the Register and Information Guidelines, along with any other relevant feedback, be submitted via email to review@teqsa.gov.au.

Submissions close at 5:00pm on Friday 16 December 2022.

Interested parties can also email review@teqsa.gov.au with queries about this consultation, or to seek clarification regarding the proposed amendments.

Please note that TEQSA intends to publish a summary of submissions received. If you do not wish for your submission (or part of your submission) to be published, please indicate this in your response. TEQSA may alter the format or content of submissions before they are published, or decline to publish particular submissions, having regard to the requirements for Australian Government websites.