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This report is the second release of financial information held by Tertiary Education Quality and Standards Agency (TEQSA). It provides a snapshot of selected key financial metrics across the Australian higher education sector. Data in this report has been sourced from TEQSA’s 2015 data collection and relates to financial years ended 31 December 2014 until 30 June 2015. 

TEQSA is committed to ensuring that stakeholders in Australia’s higher education sector have access to relevant information to enable and better inform decision making. TEQSA works closely with the Department of Education and Training and other agencies to collect data on the sector and to minimise the regulatory burden on providers. As part of its ongoing monitoring and quality assurance role TEQSA collects and then analyses this data.

The first edition of this report was released in April this year following a period of consultation and was well received by the sector. TEQSA intends to release this report on an annual basis using data from the latest available collection year. 

About this report

Assessing the financial position and performance of a provider is a complex process which involves analysing a number of quantitative metrics and understanding the provider’s operating context, mission, governance and management structures. TEQSA conducts an annual financial assessment of each provider, which analyses ten commonly-accepted financial metrics reflecting the key business drivers critical to financial viability and sustainability. TEQSA consulted with the sector prior to adopting these financial metrics in 2013, and received broad support for their adoption.

This report provides a snapshot of selected key financial metrics across the whole sector. The metrics have been selected for their importance in measuring the capacity and capability of providers to deploy financial resources in a way that supports quality in the delivery of higher education. Importantly, the selected metrics are reasonably comparable across all providers and also provide visibility of financial position and performance at sector and sub-sector levels.  The definitions and calculation methodology for each measure is available in the Glossary section of this report.

A copy of the report is available above in MS Word and PDF formats.

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In July 2016, TEQSA released a consultation paper on proposed extensions to TEQSA’s external reporting program, seeking submissions in relation to proposals for future reporting, particularly in relation to assessment outcomes and compliance with the Higher Education Standards Framework (the Standards).

Submissions were broadly supportive of high level analysis of areas of the Standards in relation to which issues were regularly encountered and of risk assessment outcomes and their relationship to the outcomes of assessments. In its summary report on the consultation process, TEQSA indicated it would subsequently publish a report on assessment outcomes. It is now timely, given the change to the 2015 Threshold Standards for applications submitted from 1 January 2017, to reflect on outcomes of applications submitted up to 31 December 2016.

This report provides an overview of assessment outcomes, organised by five themes: 

• assessment outcomes by year and application type
• prevalence of particular sets of issues leading to adverse assessments
• differences in assessment outcomes by provider type
• the time TEQSA takes to complete assessments 
• the relationship between risk assessments and regulatory outcomes. 

The provider categories used in the analysis are, as proposed in the consultation paper¹:

• universities
• higher education providers — for-profit
• higher education providers — not-for-profit (divided by TAFE, faith-based and ‘other’ providers).

A range of regulatory outcomes are characterised as ‘adverse’ in this paper. Around 25 per cent of adverse decisions are outright rejections of an application — the remainder involve some combination of conditions and reduced period of provider registration or course accreditation. This means that, in around 75 per cent of adverse cases, TEQSA has approved the application with some form of sanction. This approach gives providers notice that TEQSA considers some form of improvement to be necessary, while allowing reasonable opportunity for providers to make improvements.

A copy of the report is available above in MS Word and PDF formats.

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Overview

The Higher Education Provider Roundtables (held in Melbourne on 25 June 2018 and Sydney on 6 July 2018) were convened as an opportunity for TEQSA to receive feedback directly from independent and TAFE higher education providers about how the agency can improve its performance and its engagement with these provider groups.  

Approximately 60 participants attended the Melbourne event and 80 participants attended the event in Sydney.  

The roundtable events commenced with Anthony McClaran, TEQSA Chief Executive Officer, providing an update on the agency’s recent performance, changes in budget position and key data from the most recent Stakeholder Survey results submitted by independent and TAFE higher education providers. 

Simon Finn, Chief Executive Officer of the Council of Private Higher Education (COPHE), presented some of the key issues identified by COPHE members in relation to TEQSA’s performance, provider interactions and communication with the agency and experiences in fulfilling TEQSA’s Course Accreditation and Risk Assessment processes. 

Dr Paul Whitelaw and Ili Pelletier, on behalf of TAFE Directors Australia (TDA) provided an overview of some of the key characteristics unique to TAFE higher education providers, and how both TEQSA and the sector could better understand these providers and support TAFE higher education students. 

At the Sydney event, Rod Camm, Chief Executive Officer of the Australian Council for Private Education and Training (ACPET), discussed some of the challenges faced by ACPET members in their interactions with TEQSA, and a vision of how providers and the agency can continue to build a stronger relationship in the future. 

Participants then took part in small group discussions facilitated by a representative from the sector and observed by a Commissioner or member of TEQSA’s Senior Management Team. Participants were asked to note the legal framework and Government policy environment in which TEQSA is required to operate, and to focus the discussion on the operations of the agency and how it can improve its interaction with independent and TAFE higher education providers.   

The main points arising from each group were later presented to all attendees for broader discussion. Common themes, issues and ideas for improvement were identified. 

Overall, there is a strong desire from providers for TEQSA to act as a quality assurance agency, not just as a regulator, and help to guide providers to achieve excellence in higher education. 

Major Themes Identified

The following themes were identified as part of the small group discussions and appeared consistently across both events. Additional issues raised are also listed below. 

Many of the themes identified were consistent with the views presented by ACPET, COPHE and TDA in the opening remarks and with the results of TEQSA’s 2017 Stakeholder Survey.

Melbourne

Timeliness of Decision Making

Many participants expressed concern about the significant time lapse between the submission of applications and a decision by TEQSA, particularly for decisions regarding course accreditation applications. 

It was stressed that waiting for a course to be accredited, without having an indication of the estimated completion date, may have financial implications for providers in relation to not being able to market the course or recruit students. This may also affect operational decisions around facility and property leases, staffing and other resources. Many participants believed that this put the non-self-accrediting providers at a disadvantage compared to self-accrediting providers. 

Some concerns were raised that, while TEQSA requests information and responses from providers within relatively short timeframes, this is inconsistent with the time in which the agency itself takes to provide feedback on applications, respond to risk assessments or to routine enquiries from providers, who would like more timely communication.  

Future increases and stability in TEQSA’s resources should assist in reducing the time taken to complete assessments and improve the consistency and timeliness of communication with Case Managers, which was welcomed by participants. 

Case Manger Performance

Participants provided varying accounts of their interactions with Case Managers. Many providers confirmed that their dealings had been extremely positive, while others believed the communication and relationship with their Case Manager could be improved. 

Communication

From the feedback provided by some participants, a balance needs to be struck as to the right amount of communication between TEQSA and providers – and this may vary between providers. The majority of participants indicated a preference for more regular and consistent communication with Case Managers,  particularly in relation to feedback on applications, progress of assessments, updates to guidance material and changes in Case Manager. These comments are consistent with the feedback provided in TEQSA’s 2017 Stakeholder Survey.   

Some participants indicated a desire to meet more often and face-to-face with their Case Manager. Other participants requested greater transparency around provider meetings initiated by TEQSA as these can be daunting when issues have not previously been communicated and discussed.

Culture

A number of participants raised concerns about the high turnover of Case Managers, which may contribute to a loss of corporate knowledge in, and inconsistent experiences with, TEQSA. 
There was also a concern raised by some participants that the agency does not understand or take into account the differences of independent and TAFE higher education providers and, in extreme cases, there is a perception that TEQSA may appear biased against these provider types. For example, small-scale providers are not able to compete with larger providers, including universities, in terms of resources and yet TEQSA is seen by some to apply a one-size fits all approach in regards to policies, procedures and regulation. 

The suggestion was made that this could be improved through diversifying TEQSA’s workforce by recruiting Case Managers with more experience in the private sector, industry or business. 

These comments are consistent with feedback provided in the 2017 Stakeholder Survey.  

Risk Indicators and Assessments

Generally, participants indicated that the TEQSA Risk Assessment was a helpful document and that the communication with the agency in collecting and validating the data was a positive experience. 

Participants indicated varying levels of understanding of the risk indicators and there was a strong desire that TEQSA gives greater consideration to the context of the provider when developing the risk assessment – particularly regarding calculating attrition data and conducting financial analysis. Similarly, the context of the provider should be taken into account when developing International Activity Profiles.

For a number of providers, more transparency on risk thresholds and the weighting that is applied to different indicators would be beneficial. 

In regards to organisational risk, many participants indicated that changes in Government policy is identified as one of the most significant risks for their institutions. 

Guidance Notes

Generally, participants indicated that TEQSA’s Guidance Notes were helpful for interpreting the Higher Education Standards Framework. However, the consensus was that more communication is required to alert providers when Guidance Notes are released or updated, and to explain what changes have been made and why. 

Some providers also sought clarity about the process for consulting with providers in developing guidance material and on whether the information published in Guidance Notes is a suggestion, a recommendation, an expectation or a ‘must do’.

Confidentiality and Protection of Information

Concerns were raised by a small number of independent and TAFE higher education providers as to the security and confidentiality of information once submitted to TEQSA. Clarity was sought as to how the agency ensures the protection of sensitive information and intellectual property, through confidentiality agreements with its staff, and how the agency would act in the event of a breach by either current or former staff.

Other Issues Raised

The following issues were also raised by participants during the small group sessions:

• Tailoring course accreditation processes and evidence requirements to better meet the business needs of the provider.
• Continue to streamline assessment processes: less burden for low risk providers/courses or new courses already within a providers’ scope of delivery; running internal and external reviews of material concurrently; and working more cohesively with peak and professional bodies to ensure that these accreditation processes are not impacted by TEQSA’s timeframes for decision making.  
• Responses from Case Managers in a more timely and consistent manner to all enquiries, to strengthen relationships and ensure providers receive feedback on applications so that necessary improvements can be made. 
• Give providers more information on their options for internal review and increase communication from Case Manager’s so that providers understand the circumstances around conditions imposed. 
• Take into account the context of the provider when collecting data; for example, graduate outcome data for international students is hard to collect once the student leaves Australia, which may affect the ability to report data accurately. 
• Give greater focus to employability as a student outcome. 
• Collaborations between independent and TAFE providers to diversify the sector and create more choices for students. 
• Increase independent and TAFE provider representation at TEQSA events, including the annual TEQSA conference.
• Ensure appropriate levels of consultation with the sector around upcoming changes to TEQSA’s cost recovery model, taking the scale of providers and the potential impact of providers passing on costs to students into account in developing the model.  

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Sydney

Reputation of Private Providers: Rocognising and Valuing Uniquness

Some participants expressed a belief that the distinctiveness of independent and TAFE higher education providers, and the benefits that this brings to sector, is not recognised or valued highly enough by TEQSA. They believed that this is seen through experiences with some Case Managers and in the way the Higher Education Standards Framework can be applied. There was also concern that, in a few cases, there is a perceived inconsistency in TEQSA’s decision making for independent and TAFE higher education providers.

The comment was made by some participants that TEQSA could do more to ensure its regulatory processes are tailored to take into account the different contexts of providers and ensure that the Higher Education Standards Framework and TEQSA’s expectations of evidence requirements do not stifle diversity and innovation – particularly in niche and specialist areas. 

Some participants indicated a belief that independent and TAFE higher education providers are perceived by the broader community as providing poorer quality education (than universities). There was a desire for TEQSA to assist in dispelling this perception.

Generally, participants disliked the “for-profit” categorisation and terminology often used to describe independent providers. It was commented by some that profit is not a bad thing, as providers need to make profit to be financially viable, but it is what providers do with the profit that is important for example, re-investing back into the business.

Similarly, there was broad aversion to the use of ‘non-university higher education provider’ as it was believed this suggests a lack of credibility and defines a part of the sector by what it is not, rather than by placing value in what those providers contribute to the sector. The term ‘independent providers’ was generally considered more appropriate for describing this group of higher education providers.

Overall, participants believed that TEQSA can assist in creating a more equitable view of all providers by promoting examples of good practice from independent and TAFE higher education providers and continuing to engage with these providers, guiding them to not only meet, but exceed the Higher Education Standards Framework.  

Case Manager Performance

Participants provided varying accounts of their interactions with Case Managers. Some participants confirmed that their dealings had been extremely positive and that they had been able to seek advice and work well in partnership with their Case Manager. However, other participants believed the communication and relationship with their Case Manager has been hampered by the significant turn-over of TEQSA staff in recent years, creating inconsistencies in knowledge and expertise. Some participants indicated that they were unsure of who their current Case Manager was, which does little to build relationships with the Agency.

Inconsistency in Case Manager approach was a concern voiced by a number of participants, and three areas in particular were identified for further consideration with regard to improving Case Manager performance:

• Induction
• Calibration and consistency of decision making
• Monitoring of the performance of case managers.

Expertise

Some participants believed that TEQSA should be more diverse in its workforce, seeking staff with more a greater experience and understanding of the independent and TAFE higher education sector. 
Participants were generally supportive of the Case Management Model but expressed concern at what they saw as the variability of expertise of the Case Managers. Some also noted that the discontinuity of Case Managers had impacted on the ability to build relationships between TEQSA and provider contacts. This is consistent with the results of the Stakeholder Survey 2017.  

Engagement

There was strong commentary that Case Managers would gain a better understanding of individual providers if they worked towards a partnership with provider contacts, where communication is strengthened and there is more direct and regular dialogue. Overall, participants were keen to develop stronger relationships with their Case Managers, with some calling for Case Managers to take part in regular site visits, and attend provider events and TEQSA provider forums.

Agency Performance and Timeliness of Decision Making

Some participants were concerned about the time TEQSA can take to reach a regulatory decision, particularly for decisions around revoking conditions, which are in the public domain and may impact on a provider’s ability to attract students.

Other participants noted that in many cases they are given a fixed period of time to respond to requests, but felt that TEQSA does not hold itself to the same standards.

Overall, participants indicated that the Agency should reflect the same behaviours it expects from providers with some participants suggesting that performance indicators be considered, and others indicating that TEQSA needs to be more responsive to the sector in general. 

Risk and Data

Many participants expressed the view that TEQSA needs to take into account individual provider contexts when defining risk. A one-size fits all approach does not work, as small or specialist providers, particularly in areas such as the use of casual and sessional staff, calculating attrition and financial sustainability and viability, may be at a disadvantage as statistics do not always accurately reflect reality. The lag in the data being used in Risk Assessments may also not be an accurate reflection of what is occurring at the provider at the time TEQSA is making a decision.  

There was support for the Risk Assessment Framework and the process. However, many participants believed that more communication and greater transparency of the TEQSA thresholds was required to ensure all providers understand how they are being assessed, and can use the information for benchmarking activities.

TEQSA’s Role in Quality Enhancement

There was strong support for TEQSA adopting a greater focus on quality enhancement and playing a larger role in helping the sector exceed the threshold standards of the Higher Education Standards Framework.

Some participants expressed a view that TEQSA can behave “like a bully”, and that the agency’s approach is “not to help, only to regulate”. There was also a suggestion that Case Managers sometimes act more like “Case Prosecutors”. 

Generally, participants believed that a more collaborative approach, where TEQSA worked in partnership with providers, would be more effective in enhancing quality.  

There was very strong support for TEQSA’s good practice note on contract cheating and a desire that more examples of best practice be published for other providers to learn from.  

External Experts

Many participants felt that the TEQSA Register of Experts would benefit from more private sector experience and that all experts should undergo training to ensure they have an appropriate level of knowledge and understanding of the Higher Education Standards Framework, as well as up to date experience in a modern teaching environment.

Other Issues Raised

The following issues were also raised by participants during the small group sessions:

• Ensuring guidance material from TEQSA and ASQA is not contradictory to assist dual sector providers who must meet requirements of both regulators. 
• Continue to look for opportunities for cohesion between TEQSA, other regulators and professional accreditation bodies.  
• Consider the way condition information is displayed on the National Register to ensure it is not misleading, particularly for those providers who have a reliance on the international student market.  
• The perception that independent and TAFE higher education providers have been tarnished by what occurred in the VET sector regarding VET FEE-HELP. 
• The types of information TEQSA requests as part of a course accreditation application can be vast and cumbersome. 
• Greater transparency around TEQSA’s decision making processes and the judgements being made when setting evidence requirements for accreditation processes.
• Greater collaboration between TEQSA and providers to engage students in the private sector. 
• Improving communication between TEQSA and providers with an aim to reduce adversarial and legal action.  

Next Steps

An improvement plan will be developed, in consultation with TEQSA’s Senior Management Team and Case Managers, to implement actions to improve the Agency’s engagement with independent and TAFE higher education providers.  

The following questions, based on the feedback received from participants of these roundtable events, will assist in the development of the improvement plan and be considered as part of TEQSA’s forward planning, including the Corporate Plan for the next four years: 

1. How can TEQSA classify higher education providers more appropriately to reflect all organisations, including independent, not-for-profit, TAFE and pathway providers? 
2. Why is there a difference in TEQSA’s performance rating and feedback from universities compared with other providers? How can this be addressed and can TEQSA be more transparent around how it does business?  How can TEQSA receive feedback (both positive and negative) from providers on a more regular basis? 
3. How can TEQSA play a greater role in quality enhancement to support ‘excellence, innovation and diversity’ and support the growth of the higher education sector effectively? What can providers do to assist in building a more collaborative partnership with the regulator? 
   1. TEQSA sees itself as a regulator based on a partnership model but this needs to be conveyed to the sector to remove a roadblock in improving relationships. 
   2. Providers need to have a strong understanding of the relevant legislation to gain an appreciation of the environment that TEQSA is required to operate within. 
4. As industry, the market and the sector continue to evolve, how can TEQSA ensure it is also evolving as a regulator? 
5. How can TEQSA further streamline the course accreditation assessment process? Could the internal and external review of material occur concurrently? Could the process for new courses within a provider’s existing scope of delivery and expertise be accelerated? 
6. How can the relationship between case teams and providers be improved? 
   1. Can Case Managers be more engaged with the sector and conduct site visits to gain a greater understanding of individual organisations?  
   2. What does good provider liaison look like? What should be the KPIs and training for Case Managers? How can TEQSA ensure a consistent approach by all Case Managers? 
   3. Can a tiered approach to partnership and risk be implemented whereby high risk providers have far greater interaction and work more closely with Case Managers? 
7. How can TEQSA improve its communication to providers around the following matters?
   1. The status of assessments – can this be tracked through the Provider Portal? 
   2. The process for requesting an internal review of decisions, including decisions made about conditions
   3. The status of Guidance Notes and ensuring the relevant people within providers are aware of and understand any changes. What innovative systems could be used to support this?
8. How can TEQSA increase transparency of metrics/data in relation to risk thresholds, attrition and financial analysis? Could a dashboard report be developed for each provider, indicating how they are tracking? 
9. How can TEQSA increase the areas of expertise of its Register of Experts and ensure adequate representation from the independent, TAFE and business sectors? Can there be more cooperation between professional accreditation and TEQSA processes?

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Background

On 12 November 2014 the Fairfax media reported allegations of cheating by students at a number of Australian higher education providers through the purchase of assignments, particularly through the MyMaster website. The Honorable Christopher Pyne MP, Minister for Education and Training, referred the matter to the Tertiary Education Quality and Standards Agency (TEQSA) to investigate further.

TEQSA wrote to all registered Australian higher education providers. Those providers identified in the media were requested to report to TEQSA on action taken to investigate the allegations and remedy the matter should it prove necessary. All higher education providers were asked to share best practice approaches to minimising student misconduct in assessment and promoting academic integrity amongst students. This report is drawn from the responses received.

Response by providers to Media allegations regarding the MyMaster website

Responses were received from all the higher education providers identified in the Fairfax media, including 15 public universities and two non-university private providers.

It appears that activities relating to the MyMaster website were focused on providers with Sydney CBD locations (including regional New South Wales and interstate universities, and pathway-to-university providers). At many of these locations, MyMaster “services” were promoted by the unauthorised distribution of leaflets and posters on campus. Many providers were aware of this activity and had taken action to destroy the promotional material and to warn their students not to contact MyMaster well before TEQSA wrote on 24 November 2014.  At least one provider had also contacted the principal of MyMaster to threaten legal action if they persisted with this activity.

The majority of providers identified in the press have sought specific information about students enrolled at their institution from Fairfax Media. A couple have already taken action against identified students and others are planning to take action once legal issues have been clarified, including those relating to Fairfax’s access to the information. One provider has reported using its IT security system to identify students who have accessed the MyMaster website and is keeping a watching brief in addition to placing a general warning on the system should attempts be made in the future to access the site.

It appears from providers’ preliminary investigations that only a very small number of students have been involved in this fraud, even at providers where Fairfax reported the highest level of activity.  All affected providers reported taking specific action immediately they became aware of the MyMaster website to discourage contract cheating by students and heighten surveillance by academic staff during the forthcoming assessment period.

Contract cheating – the purchase of another person’s work to present as your own – has a long history. Recently, the ready availability of sophisticated communication technology and the rise of social media have increased the opportunity to access and/or repurpose another’s work to present as your own.  Availability of essay writing services is pervasive with both local and international websites advertising their services. A number of assessment strategies have been devised to minimise the opportunity for such fraudulent activity by students and to detect it when it occurs.  However it should be noted that the efficacy of such strategies has not been established and the favoured way to combat such behaviour is by the promotion of academic integrity in the student body. Approaches to assessment and promotion of good student conduct are discussed in the next section of this report.

Policies and procedures to promote academic integrity and deal with student academic misconduct in Australia’s higher education sector

TEQSA pays particular attention to issues of academic integrity during provider registration and course accreditation. The Higher Education Standards Framework (Threshold Standards) 2011 has a number of standards relevant to academic integrity, including Provider Registration Standards 3.4, 3.8, 4.3 and 6.5 and Provider Course Accreditation Standards 3.1, 3.2, 4.4, 5.1 and 5.3.

Among the providers identified by Fairfax Media, TEQSA is confident that all that have been reviewed by the Agency over the last three years have appropriate academic integrity policies and practices in place and meet the relevant Standards. It is noteworthy that all Australian public universities have their academic integrity policies and procedures available publically through their websites and through the website of the Asia Pacific Forum on Educational Integrity (see below).

The responses received by TEQSA show that considerable effort has been spent by higher education providers in the last decade to promote academic integrity among students and staff.

1. Strengthening corporate and academic governance of student academic integrity

All providers report regular consideration of academic misconduct matters by their Academic Board (or equivalent body), systematic analysis of findings and development of plans of action. Many providers report annually to their corporate governing body on student academic misconduct and on the outcome of strategies to promote a culture of academic integrity. A number of providers (eg University of Newcastle) enclosed a copy of their most recent academic integrity report to their governing body, which were exemplary. 

2. Appropriate policies and procedures

All providers report that they regularly review their policies and practices to: promote academic integrity; minimise opportunity for fraudulent assessment conduct by students; detect academic misconduct; and impose appropriate penalties. Many examples (eg University of Wollongong, La Trobe University) were provided to TEQSA which show thoughtful development of policies as teaching practices and delivery methods have changed.  Virtually all providers that responded with a written report to TEQSA report the use of plagiarism detection (text-matching) software in the assessment of student assignments.

A number of providers (eg Griffith University, University of Western Australia) have revised their policies recently to make specific reference to contract cheating.

3. Staff development

The evidence collected by TEQSA shows that Australian higher education providers have invested significantly in increasing staff understanding of and capability in promoting and assuring student academic integrity (eg University of South Australia, University of Western Sydney). This includes: how to recognise and report suspected academic misconduct, including how to recognise non-original work such as purchased or repurposed work of others; being familiar with the provider’s policies and procedures relating to student academic misconduct; the appointment and training of academic integrity officers at Faculty /School level to promote an appropriate student culture and to investigate and deal with cases of suspected misconduct; the use of plagiarism detection software for educational purposes as well as for misconduct surveillance; promoting an understanding of the learning needs of particular student cohorts, including academic learning support and English language needs; and the appropriate design of student assessment.

4. Assessment design

Evidence was provided to show that many providers are making a concerted effort to improve the quality of student assessment, both to better assess the learning outcomes achieved by students and to minimise the opportunity for fraudulent activity and academic misconduct.  Some of the recent emphasis on assessment redesign has been driven by the requirement for all providers to be compliant with the Australian Qualifications Framework by 2015.

Good assessment design features (eg University of Wollongong, Macquarie University, University of Technology Sydney) include:

• setting new assessment tasks each time the subject is taught
• requiring analysis and synthesis rather than simply factual recall and explanation
• using a variety of assessment tasks that are staged throughout the subject
• requiring group work on some assessment items
• requiring an invigilated component (or other form of face-to-face assessment ) and, in the case of some providers (eg Melbourne Institute of Technology), requiring the student to pass this component in addition to passing the subject overall
• using learning analytics to assess student engagement with the provider’s learning platform
• using early formative assessment and other mechanisms to identify students at risk of failure so that learning and language support can be offered
• directly assessing student performance in the workplace and other “authentic” assessment designs
• negotiating assessment tasks with students by encouraging them to participate with staff in the design of assessment tasks that are aligned with their specific learning experience and outcomes (eg RMIT, UTS).

With regard to the deterrence of “contract cheating”, the following assessment principles have been advanced as good practice:¹

• “just in time” announcement of written assignments in order to limit the time available to purchase the work of others (although there seems to be significant redundancy in the essay mill business and turn-around times can be very fast)
• encoding or electronic watermarking of assignment submissions
• emphasis on face-to-face (physical or virtual) assessment, including in-class essay writing
• personalisation of assessment by building in requirements that are specific to the student’s experience (eg linked to a guest speaker presentation).

It is often considered that essays purchased through essay mills are less likely to be detected by anti-plagiarism software because they are kept behind firewalls and are supposedly bespoke products. However, this is not the experience of all providers (eg University of Sydney). Purchased work is usually detected because the quality of the academic content and/or language is significantly superior to the student’s usual performance in class or because the answer provided has a generic quality rather than addressing the specifics of the assignment task. It is widely regarded that the best way to detect and deter contract cheating is to “know your students”.

5. Student activities to promote academic integrity

Most providers include the promotion of a culture of student academic integrity as a key aspect of their policy.  Approaches to achieve this include:

• enacting a Student Charter or Code of Conduct which sets out expectations of student behavior, including honesty and integrity.  Many providers have such a document and in New South Wales this has been enacted at State level for international students, with the Council of International Students Australia being a signatory
• requiring all undergraduate commencing  students to successfully complete a module on academic integrity as a foundation requirement for progression in their degree program
• encouraging students to run their written assignments through plagiarism detection software (such as Turnitin) as an educational exercise before assignment submission
• students establishing Academic Integrity Societies (eg Macquarie University) to promote and support appropriate behavior in the student body.

Asia Pacific Forum on Educational Integrity (APFEI)

The APFEI was established in 2001 to promote academic integrity and best practice among university staff and students.  Australia has played a leading role in the establishment and ongoing activities of the APFEI.  The current Chair is Dr Ruth Walker of the University of Wollongong and six Australian Universities are institutional members (Adelaide, Deakin, Macquarie, Newcastle, Tasmania and Wollongong).

The Forum has sponsored a well-attended conference on academic integrity every second year since 2003, covering areas such as plagiarism, culture and values, inclusive approaches and bridging the gap between policy and practice.  The most recent conference was held at La Trobe University’s Melbourne CBD campus just two weeks ago on the topic of Engaging Designs of Academic Integrity Modules.  TEQSA has been informed that the conference was fully subscribed within 24 hours of the call for registration.

The APFEI website provides links to a variety of helpful resources, including those held and funded by the Office for Teaching and Learning in the Department of Education.

The Academic Integrity Policies of all Australian universities are available on the APFEI website. 

Office for Learning and Teaching funded projects (OLT)

• The OLT (and its predecessor body the Australian Learning and Teaching Council) has been very active in funding projects to promote academic integrity. These projects have created broad engagement and collaboration across Australian universities and more recently have involved the private higher education sector.  The nature of projects funded since 2010 runs from student responsibility to teaching and assessment to the design and implementation of policy.  Recent project titles include:
• Academic integrity in Australia – understanding and changing culture and practice (led by Macquarie University, to be published in early 2015)
• Plagiarism and related issues in assessment not involving text (led by the University of Newcastle, to be published in early 2015)
• Working from the Centre: supporting unit and course coordinators to implement academic integrity policies, resources and scholarship (led by Victoria University, 2014)
• Web 2.0 authoring tools in higher education: new directions for assessment and academic integrity (led by the University of Melbourne, 2011)
• Investigating the efficacy of culturally specific academic literacy and academic honesty resources for Chinese students (led by Victoria University, 2010) 
• Academic integrity standards: aligning policy and practice in Australian universities (led by the University of South Australia, 2013)
• Embedding and extending exemplary academic integrity policy and support frameworks across the higher education sector (led by the University of South Australia, 2014)

The last project in the list is notable for the involvement of the private sector through the Queensland Institute of Business and Technology, which is owned by the large private provider Navitas and is a pathway college for Griffith University.  The project also has a relationship with another Navitas owned pathway college, La Trobe University International College.

Project reports and resources flowing from these projects are freely available from the OLT website and individual university websites with links across from the APFEI website.

 

1. Newton, PM and Lang, C: Custom essay writers, freelancers and other paid third parties (forthcoming), preview provided by Dr Tracey Bretag; and Rogerson, A (2014):  Personal communication.  

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Assessing the financial performance and financial position of a provider is a complex process which involves analysing a range of quantitative metrics and understanding the provider’s operating context, mission, governance and management structures.

TEQSA conducts an annual financial assessment of each provider, which analyses ten commonly-accepted financial metrics reflecting key business drivers critical to financial viability and sustainability. TEQSA consulted with the sector in developing these financial metrics in 2013, and received broad support for their adoption.

This report provides a snapshot of selected key financial metrics across the whole sector. The metrics have been selected for their importance in measuring the capacity and capability of providers to deploy financial resources in a way that supports quality in the delivery of higher education. Importantly, the selected metrics are reasonably comparable across all providers and also provide visibility of financial position and performance at the sector and sub-sector levels. Definitions and calculation methodologies for each measure are available in the Glossary section of this report.

A copy of the report is available above in PDF format.

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This application guide is currently being revised (as at January 2023).

Background

TEQSA Act

Registered higher education providers must comply with conditions of registration set out in Division 2 of Part 3 of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act). TEQSA may impose other conditions on registration in accordance with subsection 32(1) of the TEQSA Act.

Other conditions imposed on registration may be varied or revoked by TEQSA either:

• on the agency’s own initiative in accordance with subsection 32(2) of the TEQSA Act, or
• upon application by the higher education provider in accordance with subsection 32(3) of the TEQSA Act.

A registered higher education provider must also comply with any conditions imposed by TEQSA on the accreditation of a course of study in accordance with subsection 53(1) of the TEQSA Act.

Conditions imposed on accreditation of a course of study may be varied or revoked by TEQSA either:

• on the agency’s own initiative in accordance with subsection 53(2) of the TEQSA Act, or
• upon application by the higher education provider in accordance with subsection 53(3) of the TEQSA Act.

Subsections 32(4) and 53(4) of the TEQSA Act provide that:

‘The provider’s application must be:

a. in the approved form; and
b. accompanied by any information, documents and assistance that TEQSA requests; and
c. accompanied by the fee determined under section 158 for an application under this section.’

TEQSA has developed the Application Form for Variation or Revocation of a Condition for use by higher education providers when applying to TEQSA to vary or revoke one or more conditions in accordance with the provisions of subsections 32(3) and 53(3) of the TEQSA Act.

TEQSA will consider applications for variation or revocation of a condition against the requirements of:

• the TEQSA Act
• the Threshold Standards, which include the Provider Standards and the Qualification Standards.

Completing the Application Form

There are four sections to the Application Form:

• Section 1 Provider details
• Section 2 Condition details
• Section 3 Revocation of condition(s)
• Section 4 Variation to condition(s).

The Application Form contains sections requiring free-text responses. Where the same responses are appropriate for more than one section, or where attachments contain relevant information for more than one section, cross-references to the relevant pages and/or information can be made.

Where the Application Form or any attachments refer to information or evidence on the applicant’s website, the weblink reference (url) should be noted in full, together with the exact location of the relevant information – for example, the name of the document and page number or section number that is being referred to. The url reference should hyperlink to that url. If information is referred to on a website, ensure that:

• the system is accessible to TEQSA
• appropriate checks have been made to ensure that access is not hindered by internal firewall protection
• there is facility to print documents
• there is facility to save and download documents.

If special provision needs to be made for TEQSA to access the provider’s intranet in order to retrieve information, these arrangements need to be made with TEQSA prior to formal submission of the application. Failure to do so will have an impact on TEQSA’s ability to assess the application.

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

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Department of Education and Training and TEQSA webinar

Q. The minimum ATAR required for consideration and minimum ATAR to which an offer is guaranteed are optional, is that correct?

Yes, a provider can decide whether to use the ATAR as a factor in determining eligibility. If admission is based on ATAR, Minimum ATAR required for consideration and Guaranteed Entry ATAR are optional for publication in the program/course admission information set in 2017. If relevant, they will need to be published from 2018.

Q. Will universities be compelled under these changes to publish data on "forced offers" below the published ATAR, which have traditionally gone unreported publicly?

From 2017, where ATAR was a factor in determining eligibility of a recent secondary education leaver, the lowest ATAR to receive an offer should be published in the program/course admission information set. If ATAR was not a factor in the offer being made, the student’s ATAR would not be included in the ATAR profile.

Q. In regard to reporting ATARs for forced offers, we were told that whether to report them "would be up to the institution".  Surely the whole system of transparency falls apart if this is the case?

If an offer is made to a recent secondary student that is not based on ATAR the institution is not required to report the ATAR of that applicant. If an offer is made that is based wholly or partly on the applicant’s ATAR, then the institution is required to report the ATAR of that applicant.

Q. Will universities be required to provide student profile/enrolment data for each program/course or is the university student profile sufficient?

Both are required. The student profile in the whole-of-institution gives a picture of commencing students across the whole institution. But this would not provide an applicant with information specific to the program or course they are applying to, unless the provider only offered one program or course.

The student profile in the program/course admission information set (Appendix D to the Implementation Plan) illustrates the peer cohort that commenced in in the specific course of interest in the most recent relevant intake period.

Q. Can both sets be combined? As some of the information required in both sets is the same

In general, information in the program/course admission information set should not repeat information that applies to all applicants and is covered in the whole-of institution information set.  However, it should be clear to the applicant that the information is the same for both. For example, the program/course admission information could provide a link to the whole of institution information where it is the same.

Q. If all student profile information at course level falls into the 'low number' category, is a provider required to publish a table that effectively has no data

If the course is being offered for the first time, there is no need to publish a table. If the course has previously been offered and the number of students in the most recent intake was less than 5 the table should be published using L/N to indicate low numbers.

Q. When will the desktop snapshots be taken in 2017?

The snapshots of provider websites will be taken between September and October 2017.

Q. Will we be notified of the snapshots?

Providers will not be notified of the snapshots. TEQSA may contact a provider for the purposes of clarification.

The evaluation that TEQSA will undertake is formative, not summative. That is, we are using the information to consider how best to support the sector in providing improved transparency in admissions information.

Q. We are providing Semester 1 2017 data for 2018 admissions. We expect to then update and provide Semester 1 2018 data for 2019. We do have a mid-year intake. Are we expected to update to full year in the future?

Data should be provided for the most relevant recent intake period. If you have updated full-year data ready to go by the time you are publishing information to support the mid-year intake, you could consider using that instead of data from the first semester of the previous year. But it is up to institutions to determine the most relevant data to use.

Q. Will we be told what level of compliance TEQSA considers occurred with the implementation for this year?

During the implementation process, TEQSA’s assessment of compliance with sector admissions transparency commitments will not affect providers’ registration. It is being used to assess the progress of the sector as a whole and to determine how TEQSA can best support providers to achieve best practice. Therefore a ‘level of compliance’ will not be reported to each provider. A whole of sector assessment and evaluation is the initial goal.

Q. Are we required to provide an explanation of what the data means?

The implementation plan details the minimum amount of information that is required to be presented. A provider may choose to provide further explanation or information.

Q. Are there going to be some public communications so that students understand the new information? There is now so much information there is the potential for more confusion among the transparency.

The Department of Education and Training has a communication strategy to support implementation and this includes providing students, schools and career educators with information. To support the phased implementation, the information communicated to stakeholders will also be staggered – with more information appearing in 2018 to support full implementation.

In 2017, some existing terminology like “ATAR cut-off” and “clearly in ATAR” will be used alongside the new agreed common terms and data definitions. While this may be a little confusing, it may also help users to understand the transition to the new approach.

Q. How would you recommend educating prospective students on how to interpret data, to make a decision about their likely competitiveness for entry into a course?

See above. A communication strategy is in place, with information products tailored to different stakeholders being developed.

Q. The student profile table distinguishes between students admitted on the basis of ATAR and international students. What is the preferred method of categorising international students admitted via an ATAR score?

The main focus of the information sets is admission requirements and data for domestic undergraduate students. The ATAR profile table and all except one line of the student profile table should only include data on domestic students.

The only data on international students, regardless of selection method, should be in the “international students” line of the student profile tables. International students admitted on the basis of an ATAR should not be included in the ‘recent secondary education’ data.

Q. When we say offshore students, does it mean international students studying in Australia or Domestic students studying in other countries under specific arrangement?

‘Offshore students’ refers to students studying in other countries. The current implementation relates to domestic undergraduate students studying in Australia.

Q. Is it recommended we publish ATAR thresholds after each TAC offer round?

Data should be provided for the most relevant recent intake period. Based on stakeholder feedback during consultation it seems likely that, to inform applicants for the following semester one intake, most providers would use data covering the most recent entire semester one intake period – including all offer rounds that were part of that intake period. The data would likely be needed at the latest by mid-year to support publication timelines so full-year data would be unlikely to be available for the current year; and using full year data from the previous year might be considered out of date.

To support mid-year intake rounds, some providers may be in a position by then to have data for the previous full calendar year available. Updating the data used in information sets would be a choice for the institution.

Q. Where we only have students, who are not included in the datasets (e.g. only postgrad) is there a specific way we should note or clarify this to our applicants?

At this stage, the admissions transparency information plan only applies to courses available for domestic undergraduate applicants. If you do not offer courses for domestic undergraduate students, you do not have to provide information in the ‘information set’ format.

Q. Can you clarify requirements if all our students are UG and internationals?

If you have courses that have both domestic and international undergraduate students, the international students should be included in the data for ‘international students’ in the student profile.

Q. Do we need to publish data sets for 1-year Honours programs (i.e. a 1-year add on after completion of a UG degree)

If the honours program is offered as a postgraduate course, the ‘information set’ approach to publishing admission requirements and student data is not required. An institution may use the ‘information set’ approach to publish postgraduate course information if they wish.

Q. What about a Graduate Diploma which is equivalent to an Honours year course?

A Graduate Diploma is a postgraduate course; therefore the ‘information set’ approach to publishing admission requirements and student data is not required. An institution may use the ‘information set’ approach to publish postgraduate course information if they wish.

Q. Where an applicant was accepted on the basis of secondary studies at school two years previously and then deferred a year would they still be including in the 'recent secondary school' applicant group?

In accordance with the HEIMS data definitions, commencements data in the student profile covers students admitted in the most recent intake period who have passed the course census date. Offer data in the ATAR profile covers all offers made in the most recent relevant intake period.

As a general principle, the offer made to the recent secondary student would be included in the ATAR profile data soon after the offer is made. The commencement would appear in the student profile after the deferment has concluded, and once the student has commenced and passed the census date.

Q. Do we need to publish information sets for pathway students leading to undergraduate studies?

The information sets are not required for enabling, bridging or other non-award courses; only undergraduate programs open to domestic students.

Q. Is it still okay to include international students in the data profile now?

Data on international undergraduate students should be included in the student profile in both the whole-of-institution and program/course admission information sets. Admission requirements for international students are not required in the information sets as the initial focus is on domestic undergraduate students studying in Australia.