Australia's independent national quality assurance and regulatory agency for higher education

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 academic leadership?

Academic leadership is central to the educational purpose of higher education providers and, as discussed later in this Note, its importance is reflected in its prominence throughout the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework). TEQSA sees ‘academic leadership’ in higher education providers as a subset of the overall institutional or corporate leadership of the provider, differentiated mainly by its focus on ‘academic matters’ in particular. For the purposes of this Note, ‘academic matters’ include teaching, learning, research, scholarship and related matters. 

For regulatory purposes, TEQSA sees academic leadership as a complex system of interrelated and interdependent elements that, together, support leadership of academic matters. Before considering the elements of successful academic leadership, it is helpful to consider its intended outcomes. 

TEQSA identifies the following (non-exhaustive) list of important potential outcomes arising from successful academic leadership:

• agreed institutional directions on academic matters within a provider (e.g. policy frameworks, institutional academic benchmarks such as desired grade standards, admission criteria)
• established continuity of academic cultures and values within the provider (e.g. commitments to scholarship, academic freedom and improvement)
• consistent adherence to agreed academic directions and policies (e.g. acceptance of institutional academic directions and consistency in application of policies) 
• positive student learning experiences and quality academic outcomes 
• academic influence and innovation through dissemination of ideas about higher education, whether within a provider, across the sector or more generally (e.g. in the literature) 
• intended academic positioning of the provider in its sector (e.g. at the forefront of distance learning, an overt commitment to professional education, specialisation in innovative technology or creativity)¹.

The elements of the academic leadership system that assist in realising such outcomes include:

• organisational leadership structures (e.g. as shown on an organisational chart)
• defined leadership roles and accountabilities (e.g. as set out in board leadership charters such as an academic board, individual position descriptions for leadership roles [such as Deans, for example] and academic staffing policies)
• particular enabling organisational functions and processes (e.g. academic planning, academic quality assurance, policy development processes)
• periodic reflection and thought leadership by academic leaders and leadership groups about academic directions 
• leadership within academic disciplines (e.g. in teaching, research, HDR supervision, mentoring, scholarship)
• individual leadership (e.g. through personal academic achievements and related contributions).

In large part, these elements of institutional academic leadership rely on corresponding enabling management functions to bring the direction-setting aspects of leadership to fruition. Some observers find it helpful to conceive of leadership as the ‘what’ that is to be achieved, as distinct from enabling management/executive functions, which can be seen as the ‘how’ of achieving desired outcomes.

In summary, TEQSA sees academic leadership as the system of interdependent elements that together allow a provider to achieve (or at least support) and monitor its intended academic outcomes.

A presupposition of this definition is that providers have a clear view on the intended academic outcomes they are seeking.

Particular features of higher education

Higher education traditionally enshrines several distinct characteristics that may need to be accommodated in various ways by a provider’s model of academic leadership (and are reflected in the HES Framework), as set out below.

Collegiality

Higher education is characterised by a reliance on bringing a diversity of views and perspectives to academic decision making. This is typified, for example, by academic boards, faculty boards, course advisory committees and communities of scholars, which provide mechanisms to bring a diversity of academic opinion to bear on an issue. A reliance on peer review is another way that diverse perspectives are utilised.

Academic Freedom and Freedom of Speech

Higher education is also characterised by a great deal of freedom in what individual academics or teams choose to be involved with in their academic pursuits, e.g. through research and scholarship. Such freedom is acknowledged in the HES Framework; the governing body is required to take steps to ensure that academic freedom is upheld and protected (6.1.4). Likewise, the governing body must ensure that freedom of speech is upheld and protected (6.1.4).

Individual Competence and Autonomy

The academic workforce is generally highly qualified (a higher degree is typical) and individuals are typically highly skilled and experienced in their particular field/discipline. As a result, academics are well placed to decide how to deal with their academic endeavours, at least in relation to their discipline (e.g. via their research, scholarship, teaching and professional development). Academics are also likely to identify with communities outside of the provider as strongly as they do within (e.g. as part of a national or international scholarly community). This too, needs to be considered by a provider’s model of academic leadership. 

Multiple Leadership Models

Higher education is characterised by a range of different leadership models, as addressed in the HES Framework. There are corporate leadership approaches as may be typified in any organisation via its governing board. However, academic leadership traditionally holds a privileged and significant position in higher education providers. This may lead to tensions between corporate and academic directions and such tensions must be managed. Corporate leadership is typically supported by a model of executive leadership (e.g. a Vice-Chancellor, CEO, Executive Dean or equivalent), which may bring other perspectives to academic leadership initiatives. Because of the expert nature of staff within disciplines, much of what academic staff do may be determined locally or even individually, potentially with varying regard to institutional leadership and executive models. This tendency may be exaggerated according to the extent of research culture within a provider, where individual researchers have considerable standing as experts in their field and may favour a model that emphasises self-determination. A provider will be expected to manage its particular flavour of leadership models. Ideally, a provider will realise a constructive synergy among the various types of leadership, leading to a well-developed and continuing culture of academic integrity, innovation, scholarly activity and creativity within the provider. 

Diversity of Leadership Models and Culture

TEQSA recognises that the sector is characterised by a variety of approaches to the delivery of higher education, which may include differences in employment conditions. For example, providers whose staff are employed under the Education Services (Post-Secondary Education) Award 2010 are unable to formally employ staff at Academic Level D (Associate Professor) and above. This potentially affects the notion and categorisation of ‘senior’ staff roles across different types of providers.

Relevant Standards in the HES Framework 

The processes/outcomes of academic leadership permeate most aspects and levels of the HES Framework. Some Standards address academic leadership directly (e.g. academic governance), while others imply underpinning academic leadership, such as through institutional academic policy development and consistent implementation of those policies. 

All aspects of Student Participation and Attainment (1.0) are subject to academic policies derived from academic leadership, including Admissions (1.1), Credit and Recognition of Prior Learning (1.2), Orientation and Progression (1.3), Learning Outcomes and Assessment (1.4) and the issuance of credible Qualifications and Certification (1.5). Similarly, academic leadership is fundamental to all aspects of Teaching (3.0) through the design of courses (3.1), academic staffing [both collective and individual] (3.2), and provision of learning resources and educational support (3.3). The standards for staffing make particular reference to academic leadership; requiring the academic staff in each course of study to have ‘the level and extent of academic oversight and teaching capacity needed to lead students in intellectual inquiry suited to the nature and level of expected learning outcomes’ (3.2.2).  Academic leadership is also crucial to research training (4.0), both at an individual level and through research policies, including creation of an appropriate learning environment for research training (4.2.2).

At the institutional level, academic leadership is pivotal to the design and development of effective quality assurance systems (5.0) encompassing course approvals (5.1), academic integrity (5.2), monitoring and improvement (5.3) and relationships with other parties (5.4). Peak direction and oversight of academic leadership is enshrined in the requirements for academic governance (6.3) including, in particular, setting institutional benchmarks for academic quality and outcomes (6.3.1b) and establishing and maintaining academic leadership at an institutional level (6.3.1c). The corporate governing body has critical roles in academic leadership, including taking academic advice to inform its corporate decisions (6.1.3a), creating and protecting a culture of freedom of intellectual inquiry (6.1.4), setting educational directions (6.2.1b) and ensuring that mechanisms for competent academic governance and leadership have been implemented and are effective in maintaining the quality of the education that is offered (6.2.1f). 

Intent of the Standards 

The general intent of the Standards related to academic leadership is to ensure that higher education providers have all of the elements of an academic leadership system in place and that this leadership system will, collectively and in concert, be effective in achieving the provider’s intended academic outcomes; whether at an institutional level, in individual academic disciplines and in the quality of student experiences, and educational outcomes for graduates. The monitoring, reporting and quality assurance elements of the Standards provide the means for providers to determine, at an institutional level, whether their chosen academic leadership system is indeed effective. 

Because of the central role of academic leadership in a higher education provider, most structures, roles and individuals are likely to be involved in some way, whether in setting directions and/or in delivering outcomes. The Standards of the HES Framework are largely outcome focused and tend, with some notable exceptions (such as the attributes of teaching staff), to focus on the outcomes of academic leadership, rather than the behaviour of ‘leaders’ who perform leadership roles.

Typical expectations of leadership roles include strategic thinking, ‘standard setting’, team building, innovation, reflection, policy leadership, peer review, consensus, mentoring and leadership of scholarly activities such as research, disciplinary scholarship, the scholarship of teaching and learning and professional development. Leadership behaviours include leadership by example and guidance and direction (e.g. academic supervision), especially within academic units such as schools or departments.

Risks to quality

Given the pervasive and critical nature of academic leadership in higher education, failures in the leadership system may have far reaching effects on the quality of education. Because of the importance of academic leadership to a provider’s success, TEQSA has included the concept of academic governance/leadership as one of the indicators in its Risk Framework, which is subject to annual risk assessments. TEQSA has found that effective academic leadership in each of a provider’s fields of education (and disciplines within fields) to be one of the critical factors that determines whether a provider or prospective provider is able to maintain compliance with the HES Framework relating to academic quality. The Standards relating to academic governance and academic leadership are commonly referenced by TEQSA in adverse registration and accreditation decisions².

Effective academic leaders will be experienced in a wide range of academic issues, bringing their expertise and judgement to such matters as academic policy development and review, as well as being leaders in their disciplines. Without this leadership, there are major risks to effective academic governance and academic standards that could result in decisions made having an adverse effect on the quality of education and on student experiences. As noted in the TEQSA Guidance Note on Academic Governance, academic leadership is important for setting academic benchmarks, developing policy frameworks, scrutinising and approving courses of study, ensuring the meaningfulness of academic grades, and determining admission requirements. An absence of academic leadership places all these at risk, with potentially serious implications for the institution and its students.

There is a significant risk that, without effective academic leadership across all levels, there will be an inadequate policy framework, resulting in unclear expectations for staff and students; that high level decisions may be made without taking account of the impact on the quality of the courses being offered; that issues of equity and maintenance of standards are not addressed; and that engagement in scholarship by staff and students will either not develop or decline. A further and major risk from this will be the negative impact on learning outcomes for students. 

What TEQSA will look for

This part of the guidance note covers the full extent of the Standards and corresponding evidence that TEQSA may require, in relation to academic leadership.
 

For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards. 
 

For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.  
 

The evidence required for particular types of application is available from the application guides on the TEQSA website.
 

Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

TEQSA will expect a provider to be able to demonstrate an effective³ academic leadership system. The provider will need to show that the system operates effectively in providing senior academic leadership within the fields of education taught, as well as in research and research training, if applicable. The provider will also need to demonstrate that overarching leadership mechanisms are in place at the institutional level (corporate governance, academic governance and quality assurance) to provide academic oversight and monitoring at that level, as required under the HES Framework. 

TEQSA will also look closely at the membership of corporate and academic governing bodies to determine whether they include competent academic leaders, including external appointments, who are able to contribute to the overall leadership of the institution above the level of individual disciplines. TEQSA will need to be satisfied that the leadership structures and roles that support academic leadership are accompanied by a comprehensive academic policy framework that addresses the academic matters encompassed by the HES Framework and codifies academic effectiveness. TEQSA will also want to see that policy frameworks and other leadership systems, such as the roles of key academic decision-making bodies, are subject to regular monitoring and review. 

At the course level, TEQSA will need to see that academic leadership underpins judgments about the courses and curricula to be offered; the development of those courses and curricula; the students to be admitted to the courses; academic staff to be employed; the deployment of these staff to best effect; the development of learning resources and systems; the appropriate academic policy framework and its implementation; student assessment; the leading, supervision and development of staff; the monitoring and improvement of the quality of courses;  how stakeholders will be assured of academic standards; and the development of an environment of scholarship and (where applicable) research. 

TEQSA will look to see that nominated academic leaders, whether in disciplinary or institutional leadership roles, are experienced academics who are recognised leaders in their fields of study (e.g. through publications, research and scholarship) and, where they hold institutional roles, bring to the provider a breadth of academic leadership experience at a level that can function across disciplines (e.g. as demonstrated in previous overarching appointments such as academic leadership at faculty, school or institutional level) and cover the range of academic leadership activities encompassed by the HES Framework at institutional level. At least one senior academic leader (at least associate professor or equivalent) must be in place for each field of education taught (and for disciplines within that field as well, if the disciplines are recognised as non-cognate). TEQSA’s observations of leadership at a disciplinary level will be informed by its annual risk analyses, particularly of academic governance/leadership. This will be informed by the likely continuity of disciplinary leadership arrangements.   

TEQSA will also look for evidence that academic decisions are informed by external academic leadership (e.g. external appointees to boards, external appointees to course advisory committees) and that academic decisions are subject to effective academic scrutiny. TEQSA will need to be satisfied in particular that the requirements for academic leadership in staffing arrangements are appropriate for the level of study being undertaken (Staffing 3.2.1 – 3.2.4). TEQSA accepts that some aspects of academic leadership may be ‘outsourced’ through, for example, advisory boards or the like, and welcomes such external input in accord with the HES Framework, particularly where such mechanisms can demonstrate continuity of academic leadership. 

TEQSA acknowledges that there are a variety of business models operating in the sector, along with considerable variation in the scale of providers and the nature of their particular missions.  TEQSA welcomes models of academic leadership that meet the requirements of the HES Framework in different ways according to the circumstances of individual providers, provided the chosen model achieves strength and continuity of leadership consistent with the requirements of the HES Framework. TEQSA will not accept that leadership as a whole can be outsourced, either institutionally or within disciplines. A sustainable and effective core of academic leadership within the provider is regarded as essential and will need to be evident to TEQSA.

For applicants seeking initial registration, TEQSA accepts that all elements of a leadership system may not yet be in place. However, TEQSA will need to see that all elements of an effective academic leadership system have been addressed in planning. Where leadership appointments have not yet been made, TEQSA will need sufficient detail on the elements of the system, the position descriptions for leadership roles (e.g. discipline leaders) and outlines of leadership structures (e.g. charter and membership categories an academic board or equivalent) to evaluate the likely effectiveness of academic leadership. Where academic leadership has been required at the time of an application (such as in presenting a course design or planning the academic leadership system), TEQSA will expect to see that such matters have been overseen and scrutinised by senior-level academics with extensive experience of both academic leadership and the disciplines involved. These academics may be part of a temporary arrangement (e.g. an interim course advisory committee) or the inaugural staffing arrangement of the proposed provider, or a mix of both.  

As noted earlier in this document, TEQSA does not seek to prescribe in detail how a particular provider might go about setting up its academic leadership mechanisms, but TEQSA will wish to see that the outcomes and processes that are required by the HES Framework, at various levels of the organisation, are met in any chosen arrangements.  In reviewing the effectiveness of academic leadership, TEQSA may draw on the observed outcomes of academic leadership through feedback from staff and students, together with the outcomes and responses to periodic organisational reviews. 

Resources and references

Higher Education Private Providers Quality Network (HEPP-QN) (2019), Higher Education Private Provider Quality Network (HEPP-QN) Academic Leadership Statement.

Scott, G., Coates, H., & Anderson, M. (2008), Learning leaders in times of change: Academic Leadership Capabilities for Australian Higher Education.

Southwell, D., and Morgan, W. (2009), Leadership and the impact of academic staff development and leadership development on student learning outcomes in higher education: A review of the literature.

Risk Assessment Framework (Version 2.3) Tertiary Education Quality and Standards Agency.

Assessment Insights (12th September 2018) Tertiary Education Quality and Standards Agency.

Independent Review of Freedom of Speech in Australian Higher Education Providers (2019).

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact TEQSA’s Enquiries Management team at providerenquiries@teqsa.gov.au. 

Notes

1. This outcome is a potential corollary of successful academic leadership that looks outside of the provider. It is included here for completeness. It is not generally of regulatory significance, unless a provider’s claims are inaccurate or misleading (see HES Framework at Part A 7.2.1).
2. See TEQSA Assessment Insights September 2018.
3. Achieving the types of outcomes listed earlier in this Note, referenced against the relevant Standards of the HES Framework.

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 academic quality assurance?

Broadly defined, academic quality assurance is a demonstration or verification that a desired level of quality of an academic activity has been attained or sustained, or is highly likely to be attained or sustained. ‘Academic activities’ generally include teaching, learning, scholarship, research and research training for higher degrees by research. The mechanisms (systems, processes, activities) employed to verify such attainments are typically known as quality assurance systems, quality systems or even just ‘quality assurance’. In the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework), academic quality assurance is called Institutional Quality Assurance. While quality assurance processes are equally applicable to any aspect of a provider’s operations, not just academic activities, this note is primarily concerned with academic activities.

There are at least two essential prerequisites to quality assurance. The first prerequisite is that the characteristics of quality that are being sought need to be defined. These may be inputs (e.g. entry standards, staff qualifications), processes (cycle time for an enrolment process or time to get feedback from assignments), outputs (completion rates) or outcomes (knowledge and skills acquired, including life-long learning skills). The second prerequisite is that a judgement of attainment needs to be made. This may involve quantitative measures or qualitative judgements or both. A presupposition of academic quality assurance is that judgements about academic quality are made by someone (or some process) that is competent to do so. Many types of quality assurance are used in higher education.

Although not necessarily a feature of quality assurance as defined above, the higher education sector generally sees ‘continuous improvement’ as an integral part of academic quality assurance. Continuous improvement is typically based on an on-going reflective feedback cycle involving monitoring, review and consequent evidence-based improvements both of courses and of major controls on academic quality such as assessment policies and procedures. ‘External referencing’ is another widely accepted feature of quality assurance in higher education. This means the provider comparing internal courses and quality controls with others within or beyond the institution. ‘Benchmarking’, ‘moderation’ and ‘peer review’ are common methods of external referencing used for particular purposes.

The effectiveness of a provider’s academic quality assurance processes is seen by many to be an important determinant of a provider’s reputation in the sector. It is certainly a key determinant of TEQSA’s confidence in a provider’s operations.

Relevant Standards in the HES Framework

In essence, the entire HES Framework and the Standards contained therein are concerned with the quality assurance of a provider’s higher education operations. Most of the Standards are concerned directly or indirectly with academic matters. Some of the Standards are quite detailed and technical (e.g. staffing qualifications and learning outcomes and assessment), some are overarching (institutional quality assurance) and others are higher level still and even more overarching (corporate and academic governance).

This guidance note is concerned primarily and specifically with the Standards for institutional quality assurance (Sections 5.1-5.4). These relate closely to the Standards for academic governance, and to those for corporate governance in so far as the governance Standards are concerned with monitoring and accountability for the quality of higher education at corporate level. There are links to enabling information management systems as well (see Standard 7.3.3). The Standards for course approval and accreditation (5.1.1-5.1.3) cross refer (via 5.1.3a) to the more detailed Standards that are applicable to course accreditation (see ‘Threshold Standards - Provider Course Accreditation Standards’ as defined in the preamble to the HES Framework 2015 Legislative Instrument).

Intent of the Standards

The Standards encompass four particular areas of academic quality assurance of a provider’s operations:

• Section 5.1 Course Approval and Accreditation
• Section 5.2 Academic and Research Integrity
• Section 5.3 Monitoring, Review and Improvement, and
• Section 5.4 Delivery with Other Parties.

The intent of Section 5.1 is to ensure that all courses of study leading to a regulated higher education qualification are subject to a rigorous internal approval process (whether or not the provider has self-accrediting authority from TEQSA). The approval process is to be applied consistently by the provider for all approvals and re-approvals. In the case of a provider without self-accrediting authority, the internal approval process is an essential prerequisite for an application to TEQSA for an external course accreditation. TEQSA will not accredit a course of study that has not first been subject to a rigorous and credible internal approval process.

The Standards require that a provider’s internal approval processes involve rigorous oversight of course proposals by participants in the provider’s organisational academic governance processes, at arm’s length from those involved in delivery of the course of study. Demonstration that a proposed course of study will meet the requirements of the HES Framework and that sufficient resources will be available is also required. In essence, Section 5.1 constitutes an organisational framework for a consistent internal course approval process. As a consequence, 5.1 invokes (via 5.1.3a) the Provider Course Accreditation Standards that outline the detailed requirements of the HES Framework in relation to quality assurance of a course of study.

Section 5.2 encompasses potential risks to academic and research integrity[1] by focusing on maintaining an effective policy framework, taking preventative action in relation to predictable risks, guiding students toward good practices and preventing lapses in integrity in any delivery arrangements with other parties. This section links to institutional monitoring of any lapses and consequent corrective actions in relation to academic and research integrity (see 6.2.1j, 6.3.2d, 7.3.3c).

The intent of Section 5.3 is to focus on a provider’s mechanisms for monitoring and reviewing its higher education activities, and engaging in consequent reflection to bring about evidence-based improvements (i.e. continuous improvement). The Standards require a fundamental, comprehensive review of courses and course delivery at least every seven years, and speak to the scope of such reviews. These periodic overall reviews of courses of study are expected to be informed and supported by more frequent monitoring of course performance at unit level, and a provider’s review activities are expected to encompass external referencing against comparable courses (including student performance data) and to be informed by student feedback. The Standards in Section 5.3 link to the Standards for academic and corporate governance in so far as there is an expectation that a provider’s monitoring and review activities related to Domain 5 will inform corporate awareness and decision making.

The intent of Section 5.4 is to place an explicit requirement on the primary registered provider for quality assurance of delivery arrangements with other parties. A registered provider must be able to demonstrate how it ensures that course delivery though third parties meets the Standards.

Risks to quality

Effective quality assurance systems help a provider to validate any claims it may make about the quality and standing of its educational offerings. Without such mechanisms, courses of study may not be subject to sufficient rigorous scrutiny to be credible, they may not be refreshed for the contemporary environment and it will not be possible to make credible evidence-based claims comparing offerings with other courses and providers. Without adequate monitoring and data gathering, evidence-based improvement will be precluded and courses will be subject to ad hoc changes and/or lapsing into irrelevance or obsolescence. Failure to attend sufficiently to feedback from students will lead to adverse student experiences and raise potential reputational and market risks. Insufficient attention to the integrity of a provider’s operations will call into question the credibility and authenticity of any qualifications issued. In larger providers, monitoring, review and improvement of course quality and course delivery will need to occur at multiple levels, including at course, academic unit and provider levels.

Providers who fail to pay sufficient attention to maintaining academic and research integrity place their entire operation at risk. Without continuing due diligence in this respect, lapses are inevitable with, at best, attendant reputational risk to the provider and to Australian higher education more generally, which TEQSA is bound to protect and enhance. A reputation once lost may be difficult to regain; so too might a financial position.

Section 5.4 addresses and seeks to avoid two particular areas of potentially serious risk concerning arrangements with other parties. The first is where students undertake temporary experiences with another party, such as on a work placement, where without exercise of care by the registered provider, the students could be unreasonably isolated from the provider or its learning system and/or subject to indifferent supervision in the placement, resulting in poor learning outcomes and/or loss of wellbeing. The second set of risks concerns arrangements with other parties to deliver a more substantial part of a course or even an entire course, e.g. via a third party with a remote campus, if the primary provider intends to defer all responsibilities for quality assurance to the delivery partner. This too represents an unacceptable risk to students; the primary registered provider must be able to demonstrate that it maintains quality assurance of all of its operations, including assuring itself of continuing compliance with the requirements of the HES Framework, irrespective of the involvement of other parties.

What TEQSA will look for

This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to institutional quality assurance.

For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.

For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.

The evidence required for particular types of application is available from the application guides on the TEQSA website.

Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

TEQSA acknowledges the diversity of providers and offerings in the higher education sector and will vary its approach to assessment of the quality assurance mechanisms of providers accordingly. Nonetheless, the Standards are applicable to all providers and for the most part the requirements are largely self-evident and are expected to be reflected in a provider’s normal operations.

In relation to course approvals, TEQSA will need to be satisfied, irrespective of the scale and nature of the provider, that there is a rigorous process for scrutiny of course proposals that is applied consistently, is at arm’s length from those who deliver the course of study, and is capable of competent relevant academic judgement appropriate to the level of study. This should involve external experts and input from industry and/or professional bodies where relevant, for example through a course advisory committee. A demonstrated capacity to conduct course approvals across a range of fields of study, at different levels of qualification and through a number of cycles of review, will build TEQSA’s confidence in the provider’s processes.

In so far as the internal course approval process canvasses the Provider Course Accreditation Standards, TEQSA will take into account the provider’s track record of meeting those accreditation standards in determining the scope of its assessment.

The Standards for academic and research integrity (Section 5.2) require a number of specific elements to be addressed. TEQSA will need to see evidence that those elements are in fact addressed (unless they are not applicable to a particular provider, e.g. research is not carried out). The more those elements are being addressed in a coherent, systematic way and the more a strong culture of maintaining integrity is evident across a provider’s operations (whether through predicting risks and/or establishing preventative measures), the more confidence TEQSA will have in this respect.

As with the other Standards for quality assurance, there are specific requirements for monitoring, review and improvement in the Standards that TEQSA requires to see demonstrated. As a provider becomes more experienced, TEQSA would expect to see more examples of completed cycles of review with implementation of demonstrable improvements arising from the reviews; i.e. a developing culture of continuous improvement. Providers should note that the Standards require certain types of external referencing of performance and TEQSA will need to see that this is occurring and how it informs improvement cycles and, where relevant, the marketing and representation of the provider. In particular, TEQSA will want to see how a provider is referencing its performance externally, especially in relation to student performance and outcomes, whether via peer review, benchmarking or similar mechanisms (including peer review of assessment, the results of which should also be considered within course reviews). TEQSA will also want to see how the findings of reviews and external referencing lead to improvements in teaching and learning, how these findings feed back to corporate decision making and monitoring (i.e. corporate and academic governance) and that consequential changes are traceable to revised corporate positions e.g. in changed policy frameworks, admission criteria, marketing information.

Where TEQSA is required to consider delivery arrangements with other parties, the provider must be able to demonstrate to TEQSA that it remains fully accountable for quality assuring those arrangements and that there are effective mechanisms in place to do so. TEQSA may modulate its approach in this respect based on a provider’s record of success.

Scope of assessments

The effectiveness and maturity of a provider’s internal quality assurance mechanisms, in combination with their links to effective academic and corporate governance, are essential to TEQSA’s confidence in the quality and integrity of a higher education provider’s operations.

If, as a result of looking at the provider’s internal academic quality assurance arrangements, including the requirements of relevant related Standards, (e.g. academic governance, corporate governance, Provider Course Accreditation Standards), TEQSA is satisfied that the provider’s institutional quality assurance arrangements are robust, effective and sustainable, this may allow TEQSA to reduce its evidence requirements for other Standards or for subsequent regulatory activities. On the other hand, if concerns are raised in relation to the provider’s internal assurance mechanisms, this may require TEQSA to probe other areas of the provider’s operations in more detail where the provider is not already doing so effectively as part of its own routine quality assurance.

The adequacy and maturity of a provider’s internal quality assurance processes for approval of courses will also have a direct bearing on any application the provider may make for self-accrediting authority (see Part B2 of the HES Framework: Criteria for Seeking Authority for Self-Accreditation of Courses of Study). Among other things, the criteria for self-accrediting authority will look for maturity of cycles of review in the provider’s monitoring and review processes. This would also be true of a provider seeking ‘University’ status.

[1] ‘Research integrity’ has come to be identified separately from other academic integrity in common parlance.

Resources and references

AUQA Occasional Publication (2004), Quality Frameworks: Reflections from Australian Universities.

Office for Learning and Teaching Resource Library^[2].

Quality Assurance Agency (2014), UK Quality Code for Higher Education^[3].

Resources for enhancing quality available on the Academic Quality Agency (New Zealand) website.

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact TEQSA’s Enquiries Management team at providerenquiries@teqsa.gov.au. 
 

Providers should note that guidance notes are intended to provide guidance only. The definitive instruments for regulatory purposes remain the TEQSA Act and the Higher Education Standards Framework as amended from time to time.

What does admissions (coursework) encompass?

The Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework) sets out the admissions standards for all registered higher education providers. The National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) includes admissions standards where higher education providers offer courses of study to overseas students.

Admissions policies, requirements and procedures (the admissions framework) should ensure students:

• have the academic preparation and English language proficiency to participate in their intended study
• are admitted with no known limitations that would impede their progression and completion (except those who may require reasonable adjustments to complete their course)
• are not disadvantaged in achieving the expected learning outcomes for their course of study where credit through recognition of prior learning has been granted.

An effective admissions framework requires transparency, is applied consistently and fairly, and accommodates student diversity and contributes to creating equivalent opportunities for academic success.

Once students are admitted, regular monitoring and analysis of student performance is critical in reviewing and improving the admissions framework. Providers must be able to demonstrate that governance oversight and the management of the admissions framework, and the corresponding monitoring and review arrangements are effective.

What TEQSA will look for

The HES Framework requires TEQSA to consider the following aspects of a provider’s admissions framework:

The HES Framework requires admissions policies, procedures and requirements to be clearly documented. Further, requirements for implementing an admissions framework include:

• the admissions framework must be applied fairly and consistently. Decisions on admitting students must not be arbitrary, nor should such decisions result in potential students being disadvantaged because of personal characteristics that are not related to the academic preparation and English language proficiency required to be eligible for admission (noting the need to accommodate student diversity and equity, as detailed below)
• the admissions framework takes into account, accommodates and considers student diversity including the under-representation and disadvantage experienced by identified groups. The admissions framework should be designed to ensure admitted students have no known limitations that would be expected to impede their progression and completion, and creates equivalent opportunities for academic success regardless of students’ backgrounds
• accurate and current admissions information is made available to prospective students in a timely manner to enable an informed decision about educational offerings and experiences. Further information regarding admissions information and transparency can be found in Good Practice Note: Making higher education admissions transparent for prospective students
• reviews of and improvements to the admissions framework are informed by regular monitoring of students’ performance, including but not limited to, the performance of student cohorts and identified groups and regular external referencing of students’ performance. Further information about monitoring and reviewing student performance can be found in Guidance Note: Monitoring and analysis of student performance
• corporate and academic governance arrangements provide effective oversight of the approval, implementation, and the monitoring and review of the admissions framework. This includes oversight of the admissions framework for courses of study delivered wholly or in part by a third party.

TEQSA will also consider, with reference to the National Code, a provider’s ability to demonstrate:

• appropriate coverage in the admissions framework of English language proficiency, educational qualifications, and work experience
• appropriate documentation and recording of recognition of prior learning, and the integrity of prior learning assessments in the admission framework.

Identified issues

TEQSA has identified a range issues which are indicative of potential deficiencies in a provider’s admissions framework. These include, but are not limited to:

• admissions decisions made without sufficient documentation of English language proficiency, work experience or the basis for granting credit for recognition of prior learning. This includes inadequate record-keeping in relation to exemptions or waivers, especially waivers granted against English language proficiency requirements (see TEQSA’s communiqué covering English language waivers for more information) (Standard 1.1.1)
• poorly specified or a lack of arrangements to identify student subgroups and cohorts which limits the capacity of a provider to ensure students are admitted with no known limitations, and creates difficulties in monitoring and reviewing the efficacy of the admissions framework by student subgroups and cohorts
• limited use of student performance monitoring to inform reviews of and improvements to a provider’s admission framework
• inadequately specified governance arrangements including lack of clear delegations for admissions decisions, especially in relation to decisions to grant exemptions or waivers, and insufficient monitoring of delegated decision making
• a lack of systematic reporting on the monitoring and review of the admissions framework to relevant governing bodies causing ineffective oversight of a provider’s admissions framework
• insufficient oversight of the application of a provider’s admissions framework in third party arrangements.

When providers systematically admit students via poor admissions practices, students may struggle or fail to succeed in their studies as a result, and, more broadly, the integrity and reputation of Australia’s higher education sector may be undermined.

There are also risks to the students themselves. If an admissions framework is inadequate, a provider’s student support services may be overwhelmed by demand for support from students who do not have the academic preparedness or English language proficiency needed to participate effectively in their course of study.

In contrast, a robust admissions framework, and its consistent and equitable application, contributes to safeguarding the quality and reputation of Australian higher education and the quality of the student experience.

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HES Framework can be met in different ways according to the circumstances of the provider. Provided the requirements of the HES Framework are met, TEQSA will not prescribe how they are met. If in doubt, please contact TEQSA’s Enquiries Management team at providerenquiries@teqsa.gov.au.

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. 

Purpose of this note

TEQSA expects that courses of study will evolve over time as providers make improvements as part of their quality assurance processes and/or respond to changing circumstances in the educational and workplace environments. Some changes may be relatively minor, some may be more significant (see the Material Change Notification Policy available on the TEQSA website), while others may change the course so fundamentally that it amounts to a ‘new’ course. A ‘new’ course will need to be accredited as such, whether internally if the provider has authority to self-accredit the new course, or externally by TEQSA. In the case of accreditation by TEQSA, accreditation as a new course of study may arise as a result of:

• a provider’s own initiative to replace a previously-accredited course of study with a new course of study, or
• TEQSA determining that the proposed changes to a course of study will change the course sufficiently to warrant accreditation of the course as a new course of study.

The aim of this note is to indicate some of the major factors that TEQSA may have regard to in reaching a decision on whether accreditation of a course can be renewed under its existing identity or whether it needs to be accredited as a new course of study.

Because of the variety of factors that may affect a determination by TEQSA, providers are advised to discuss proposed significant changes to a course of study with TEQSA. These discussions will help to resolve whether or not the proposed changes fundamentally change the nature of the course of study and/or likely expectations of it from students and the community, to the extent that TEQSA will require accreditation as a new course.

Factors that may affect TEQSA’s determination

Many factors may influence TEQSA’s decision making in particular circumstances. Some key factors that may lead to a requirement for accreditation as a new course are outlined below. Many of these are somewhat interdependent, e.g. changes to learning outcomes and course design, but for the purposes of this guidance note they are considered separately. The discussion largely follows the matters raised by the requirements of the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework).

Representation of the course of study

From time to time, providers may wish to change the orientation of a course to match new or emerging opportunities, such as innovative employment opportunities or marked changes in technologies. This may cause a provider to structure the course differently and change the title. For example, a Bachelor of Science (BSc) may be recast as a BSc (Environmental Sciences) or BSc (Emerging Technologies). Where the new title of the course is likely to suggest to prospective students that the course may lead to markedly different employment prospects or opportunities for further study, TEQSA may form the view that the course should be accredited as a new course. This could also apply to broadening or narrowing a field of education, e.g. changing a Masters of Business Administration (MBA) to a more specialised course of study, e.g. to MBA (Health Management), or vice versa. TEQSA would also consider whether the new title, if not accredited as a new course, may cause confusion with existing courses or be misleading to the community and potentially affect the reputation of Australian higher education.

Level/type of qualification

Where a change to a course is proposed to lead to a different qualification at the same AQF level, e.g. Bachelor (Honours) degree to a Graduate Diploma at Level 8, or to one at a different level, from a Bachelor to a Masters Degree, the course will need to be accredited as a new course. This will also include postgraduate courses, e.g. Masters, Doctorate, that are proposed to change from coursework (or predominantly coursework) to a research degree (i.e. including at least two-thirds research work). A change to a research degree would also involve meeting the Research and Research Training Standards (Domain 4 of the HES Framework) if that has not already occurred.

Where a provider that offers a Diploma accredited as a vocational education and training (VET) course proposes to convert this to a higher education course, or to offer a Higher Education Diploma with the same title and content, the Higher Education Diploma will need to be accredited as a new course. Higher education providers should have regard in such cases to the over-riding requirement to deliver teaching and learning that engage with advanced knowledge and inquiry (HES Framework Category Criterion B1.1).

Learning outcomes

TEQSA expects the learning outcomes of courses to evolve with time, and such evolution is unlikely to have an impact on re-accreditation of a course. However, from time to time, marked changes may occur in expected learning outcomes, e.g. to provide training for a different (broadened or specialised) scope of professional practice, such as a new major or course solely addressing forensic accounting instead of management accounting. In such cases TEQSA will consider accreditation as a new course in the interests of clarification and avoidance of confusion about what can be expected of graduates. Providers may well also see this as advantageous in proposing a new field of study.

Course duration/volume of learning

A marked change in the duration of a course of study or the volume of learning may lead to a need for accreditation as a new course. This may occur particularly if:

• there has been a marked reduction in the volume of learning without other corresponding changes to other factors, and/or
• a marked and unsubstantiated departure from the broad guidance of the AQF is proposed.

A marked change in volume of learning would be expected to be accompanied by various other changes, such as changes to the:

• level or qualification type
• scope of the expected learning outcomes
• prerequisites or other aspects of academic preparedness
• course design, or
• delivery methods.

If these types of accompanying changes have not occurred, TEQSA would be concerned about the credibility of the proposed changes to the volume of learning. Where accompanying changes are being proposed to support a change in volume of learning, TEQSA will form a view on whether, in aggregate, they change the fundamental nature of the course to the extent that it amounts to a ‘new’ course.  

Entry requirements

Changes to entry requirements may cause TEQSA to see the changes as a new course. This would occur where the changed entry requirements are likely to change the consequent type and level of learning experiences that flow from the change, e.g. a change from undergraduate entry to graduate entry, or new and substantial requirements for prerequisite professional or workplace experience that is expected to be advanced in the course of study. Changes in entry requirements that may require additional support, e.g. admitting an educationally disadvantaged cohort, but do not otherwise change the fundamental nature of the course or its outcomes, are less likely to require accreditation as a new course. 

Course design/delivery

Providers are expected to change the design and delivery of courses over time as part of their internal monitoring and quality assurance. TEQSA will consider such changes as part of re-accreditation of a course of study. Provided that the changes do not markedly change the expected outcomes of the course for students or the community, TEQSA is unlikely to require accreditation as a new course of study. For example, progression to more emphasis on online learning is likely to be seen as part of a natural evolution in a provider’s educational management, provided the changes are accompanied by corresponding relevant changes to the provider’s monitoring and quality assurance. Adopting a solely online mode of delivery would be a material change, but not necessarily change the course to such an extent that it would require accreditation as a new course.

However, where the design and delivery of a course is changed fundamentally and such changes to its design and delivery are claimed to engender markedly different graduate capabilities and/or a capacity to meet new community expectations, TEQSA may form the view that accreditation as a new course of study is warranted. For example, if a provider introduced an unprecedented predominance of ‘best-practice’ work-integrated learning, TEQSA may form the view that the interests of all parties may be better served by accreditation as a new course.  

Research and research training

As mentioned above, offering a research degree(s) requires a provider to meet the standards of the HES Framework for both Research and Research Training. Changes to a course of study that are intended to convert it to a research degree will require accreditation as a new course of study.

Institutional quality assurance

If a provider proposes changes to a course of study that would require capabilities that have not been previously been demonstrated, TEQSA will need to consider accreditation as a new course. For example, a provider may wish to incorporate new fields of education into a course for which it has not previously demonstrated a capacity for sufficient academic leadership, staff expertise, learning resources or dedicated expertise in institutional quality assurance (e.g. in the academic board or equivalent) in that field to meet the requirements of the HES Framework prima facie. As discussed above, this would apply to new research degrees but it would apply in any area where the provider is proposing significant involvement in new fields of education or markedly different modes of delivery, e.g. adding significant STEM content to a humanities program.

Delivery partners

The HES Framework sets out specific requirements in relation to delivery with other parties. A proposal for a new delivery partner would require consideration by TEQSA at least as a material change, and, depending on the nature of the delivery arrangement and its likely impact on the design of course of study, may lead to accreditation as a new course. So too may a change of delivery partner, however TEQSA would take into account the provider’s previous record of managing and quality assuring delivery partners.

International students

Providers may propose changes to a previously accredited course to meet the needs of one or more cohorts of international students (whether onshore or offshore). TEQSA will have regard to the matters discussed elsewhere in this guidance note in considering whether the course amounts to a ‘new’ course and warrants accreditation as such. TEQSA will also have regard to any potential impact on the reputation of Australian higher education. 

Resources and references

TEQSA (2016), Material Change Notification Policy (HES Framework 2015).

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact TEQSA’s Enquiries Management team at providerenquiries@teqsa.gov.au. 
 

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 corporate governance?

Broadly defined, corporate governance is the framework of structures, rules, relationships, systems and processes of an entity through which:

• corporate directions and targets are set
• authority is delegated
• organisational performance is monitored
• risks are identified, managed and controlled
• organisational accountability is maintained
• corporate culture is developed and influenced.

The centrepiece of corporate governance is a formally constituted governing body (e.g. a board of governance) that is collectively accountable for the governance and performance of the entity overall, including, in the case of registered higher education providers, meeting and continuing to meet the requirements of the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework).

In higher education providers corporate governance is typically part of a governance framework that also includes academic governance. Together these elements of governance guide and monitor the executive and academic functions of the provider.

Relevant Standards in the HES Framework

The principal Standards concerned with corporate governance are in Part A, Sections 6.1 (corporate governance) and 6.2 (corporate monitoring and accountability) of the HES Framework. These in turn have links to other related Standards concerning academic governance (6.3), representation of the entity (7.1), policy frameworks (7.2), information management systems (7.3) and institutional quality assurance (5.1-5.4), which together address a variety of mechanisms that enable and support effective corporate governance. Standards concerning wellbeing and safety (2.3) and student grievances and complaints (2.4) are also indirectly related to the corporate governance, through the oversight responsibilities of the governing body.

Intent of the Standards

The overall intent of the corporate governance Standards is to establish a corporate governing body that has certain specified characteristics, such as the inclusion of independent[1] members (directors), and that is competent to undertake its governance roles. The governing body is accountable for the direction setting and oversight of the provider as a whole. This makes the Standards for corporate governance the highest and most overarching level of the Standards in the HES Framework. The Standards require the governing body to address particular aspects of the governing body’s own performance and behaviour, including obtaining advice as needed to make informed decisions and formally delegating authority (e.g. to the provider’s executive) as it sees fit. The Standards also encompass a series of specific corporate requirements (e.g. financial sustainability, maintaining the quality of higher education) that the governing body must be able to demonstrate and assure itself about as part of its corporate accountabilities. The governing body is also accountable for periodic independent reviews and improvement of the effectiveness of the provider’s governance systems.

The corporate governance Standards are designed to ensure that the matters encompassed by all other Standards in Part A of the HES Framework are intended to have a traceable accountability pathway to the governing body and Standard 6.1, via Standard 6.2. For example, the next layer of overarching Standards (academic governance and institutional quality assurance) requires the provider to generate performance monitoring information from various aspects of its operations and to report that information through its management information systems to the governing body. In this way, the governing body should be well positioned to understand and monitor any aspect of the provider’s performance, at least at aggregate level.

Where a provider is a wholly-owned subsidiary of another provider, the governing body of the owner may be designated as the governing body of the subsidiary as well, provided that the governing body of the owner exercises all the responsibilities and meets all the requirements outlined in Sections 6.1 and 6.2.

Risks to quality

The role of the governing body has a fundamental influence on the operations of a provider. It is involved in setting corporate directions, setting and monitoring performance targets, proactively identifying and mitigating risks, monitoring financial viability and sustainability, and influencing corporate culture. For higher education providers it is also accountable for the quality of education delivered, the validity of qualifications issued, compliance with the HES Framework and the way it represents its offerings to prospective students and others.

Any shortcomings in governance expose a provider to significant risks. The concern of the governance Standards, and of TEQSA, is that higher education providers have a focus of responsible overall monitoring and accountability, which collectively prevents the realisation of significant risks such as not meeting the requirements of the HES Framework, unrealistic or unsustainable resourcing to deliver quality higher education, irresponsible representation of the provider or development of a culture that is inconsistent with quality higher education.

Some potentially serious shortcomings in governance that TEQSA will want to see obviated include a governing body:

• having insufficient collective competence to understand and undertake a governance role in a higher education provider
• failing to obtain advice as required to make informed decisions, particularly about the nature and quality of higher education offered
• not being well enough informed, and not diligently making itself sufficiently informed, to identify and address likely risks to the provider’s viability, sustainability and educational offerings
  • this may particularly be a risk in corporate groups where the group board acts as the governing body for multiple entities
• not taking steps to assure itself of compliance with the HES Framework and not demonstrating how it knows the provider is meeting the Standards required
• not delegating authority to achieve effective management and accountability of the executive, and not monitoring that those delegations are effective
• allowing a provider to represent itself or its offerings in an inaccurate or misleading manner with consequent damage to students and Australian higher education, or
• failing to keep adequate records of its activities and decisions.

At worst, failures of corporate governance may lead to major organisational failures that disadvantage students and/or damage the reputation of Australian higher education, including corporate collapse arising from ignorance or mismanagement of preventable risks by the corporate governing body, whether directly or through its delegations of authority.

What TEQSA will look for

This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to corporate governance.

For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.

For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.

The evidence required for particular types of application is available from the application guides on the TEQSA website.

Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

Higher education providers are legal entities established by one of a number of possible legal avenues of incorporation, e.g. the Corporations Act. TEQSA will need to see the instrument formally establishing the provider and its governing body (see also Standard 7.3.1) such as the constitution. TEQSA will wish to confirm from the provider’s constitution or related documentation (e.g. the strategic plan) that: the entity has a primary purpose of higher education, the governing body’s accountabilities are specified (e.g. board charter, constitution or equivalent) and the membership of the governing body meets the requirements of the HES Framework. This will include declarations from members of the governing body concerning the independence of at least two members, residency and fit and proper persons.

The background of all of the members of the governing body will need to be available in sufficient detail for TEQSA to form a view of their collective and individual competence and the experience of the members to undertake governance roles (see also Section 7.3) in a higher education provider. TEQSA will wish to confirm that the governing body collectively has (or has ready access to) the range of expertise and governance experience necessary to undertake the overall roles specified by its charter (or equivalent) and the HES Framework (such as financial monitoring, planning, risk management, oversight of the quality of higher education).

In relation to Standard 6.1.3, TEQSA will wish to see the mechanisms that the governing body has adopted to obtain independent advice and academic advice as is necessary to carry out its governance roles diligently and competently. TEQSA will also want to see the governing body’s delegations of authority and the mechanisms it adopts to assure itself that such delegations are implemented and are operating effectively. Standard 6.1.3d requires the governing body to undertake periodic independent governance reviews and TEQSA will wish to see (in the evidence submitted for renewal of registration) the results of such reviews (or plans for such reviews in the case of a new provider) and the consequent actions taken.

Section 6.2 outlines a set of key matters that the governing body must assure itself of and be able to demonstrate that they are being attended to responsibly and effectively. A provider is required to keep a true record of the business of the governing body (Standard 6.1.3e). TEQSA will wish to examine the record of the governing body’s work (e.g. agendas, meeting minutes, actions arising) for a significant period (at least a year) to confirm the scope and detail of the governance activities involved and that they have been undertaken diligently. TEQSA does not prescribe the format of meeting minutes. However, minutes should record not only the decisions taken, but also the basis on which the decision was made (key documents considered and key points that were taken into consideration by the governing body in making its decision), as well as actions arising. The Governance Institute of Australia and the Australian Institute of Company Directors have issued a Joint statement on board minutes (August 2019) which gives definitive guidance.

In particular, TEQSA will need to be satisfied that the governing body’s work encompasses all of the requirements of its charter, that the relevant Standards have been met, and that the governing body is able to demonstrate how it knows that they have been met.

If the evidence that is used and relied on to give assurance to the governing body is not already incorporated in the governing body’s records, TEQSA will wish to see that evidence. This may include:

• internal audit reports or the like, showing that the entity is meeting its obligations for legislative compliance (Standard 6.2.1a)
• performance reports that demonstrate that the provider is meeting its planning targets as set out in its strategic plan (or equivalent) (Standard 6.2.1b)
• financial reports and audited statements, internal audit reports and reports from the audit committee (or equivalent) that show that the provider’s financial position and projection are sustainable and controls are in place (Standards 6.2.1c, d)
• risk management plans showing that risks have been identified tenably and credible mitigation strategies have been implemented (Standard 6.2.1e)
• academic governance reports demonstrating that the provider’s higher education operations are operating as planned at the level of quality intended (Standard 6.2.1f)
• equity/diversity reports that are relevant to the provider’s operations (Standard 6.2.1g)
• evidence that effective controls for the secure issue of qualifications are in place (Standard 6.2.1h)
• evidence that tenable contingency plans are available to deal with unexpected events (Standard 6.2.1j)
• records of incidents and complaints that are maintained and used to inform risk management and prevent recurrences (Standard 6.2.1j, see also Standard 7.3.3)
• evidence that mechanisms for identifying and managing lapses in meeting the requirements of the HES Framework are effective (Standard 6.2.1k, see also Standard 7.3.3).

TEQSA will need to be satisfied that the governing body’s mechanisms to assure itself that the requirements of the HES Framework are continuing to be met are both credible and effective.

Scope of assessments

If, as a result of looking in detail at the governing body’s activities, TEQSA is satisfied that the governing body is:

•  competent, diligent and effective in attending to the breadth of its governance responsibilities as required by the HES Framework, and
• able to demonstrate that it is well informed about the provider’s operations, risks and sustainability through its internal assurance mechanisms,

this will build TEQSA’s level of confidence in the provider overall.

This confidence may allow TEQSA to reduce its evidence requirements for other Standards or for subsequent regulatory activities. On the other hand, if concerns are raised in relation to the provider’s capabilities in corporate governance or its internal assurance mechanisms, this may require TEQSA to probe other areas of the provider’s operations in more detail where the provider is not already doing so effectively as part of its own routine governance and monitoring work.

[1]           Broadly speaking, an independent member (director) of a governing board is someone who does not have a material personal, financial, business or other interest in the provider.

Resources and references

ASX Corporate Governance Council (2014), Corporate Governance Principles and Recommendations, 3^rd edition.

Committee of University Chairs, Higher Education Funding Council for England (2009), Guide for Members of Higher Education Governing Bodies in the UK.

Governance Institute of Australia and Australian Institute of Company Directors (2019), Joint statement on board minutes.

Hénard, F. and Mitterle, A. (2010), Governance and quality guidelines in Higher Education: A review of governance arrangements and quality assurance guidelines, OECD.

OECD (2015), G20/OECD Principles of Corporate Governance.

Quality Assurance Agency (2014), UK Quality Code for Higher Education.

TEQSA (2016), Explanations of terms in Part A of the HES Framework 2015.

Universities Australia (2018), Voluntary Code of Best Practice for the Governance of Australian Public Universities. 

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact TEQSA’s Enquiries Management team at providerenquiries@teqsa.gov.au. 
 

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 course design?

Course design can be defined structurally as the content, duration and sequencing of the elements (units) of a course of study[1]. This structural definition is broadened by the Higher Education Standards Framework (Threshold Standards) 2015 (HES Framework) to include various other design characteristics including entry requirements and pathways, the nature of the content, the expected learning outcomes, their sequence of attainment and assessment, and professional accreditation if required. For the purpose of meeting the requirements of the HES Framework, the Framework effectively defines course design through the scope of the relevant Standards.

Relevant Standards in the HES Framework

The principal Standards concerned with course design are at Section 3.1. Learning outcomes and Standards concerned with their assessment are at Section 1.4. These are linked to various elements of Domain 7 in relation to the publication of information about courses of study to inform prospective students and other stakeholders. There are also links between learning outcomes (Standard 1.4.1) and the level of an AQF qualification awarded (Standard 1.5.3).

Intent of the Standards

The overall intent of the course design Standards is to identify what is required in the design of a course of study that leads to a higher education qualification. Standard 3.1.1 outlines the items that constitute the specification of the design. This specification gives an overall picture of the course of study in sufficient detail for an expert in the field to undertake an initial assessment of the scope and nature of the course and for prospective students to make an informed choice about the course (see Section 7.2). Section 3.2 focuses in detail on the nature of the content required of a higher education course, including its consistency with the level of study concerned and the expected learning outcomes. How the design of the course is intended to enable progressive and coherent achievement of the expected learning outcomes is encompassed by Standard 3.1.3, and it is expected that this should occur irrespective of the mode of participation or delivery (Standard 3.1.4). The design of the course of study also needs to address accreditation of the course of study by a professional body where this is required for registration to practise (Standard 3.1.5).

The Standards for learning outcomes require a provider to specify the learning outcomes for a course, including demonstrating their consistency with the field of education and level of qualification awarded. The Standards also require a provider’s specification of learning outcomes to be informed by national and international comparators, without specifying how a provider chooses to achieve this requirement. The Standards require achievement of different classes of learning outcomes (see Standard 1.4.2) including specific, generic, employment-related and life-long learning outcomes, and that all learning outcomes are assessed prior to completion of the course of study, irrespective of how and where they are assessed (Standard 1.4.4). Methods of assessment also need to provide students with timely feedback on their progress towards achieving course learning outcomes (Standard 1.3.3).

There is a specific requirement to demonstrate the appropriateness, fitness of purpose and effectiveness of all methods of assessment for all providers (Standard 1.4.3) and there is specific detail on the requirements for and assessment of learning outcomes for research training by higher degrees, if undertaken by a provider.

Risks to quality

In addressing course design and learning outcomes, the HES Framework seeks to prevent a series of important risks to the quality, outcomes and reputation of higher education. Failure to adequately and publicly specify the design of a course inhibits comparisons of courses and informed choice by students. It also indirectly potentially diminishes the standing of Australian higher education if international comparisons cannot be made, as do learning outcomes that are not informed by international comparators.

Failure to meet the requirements of the HES Framework leads to risks of learning outcomes and course designs not being fit for higher education, particularly in relation to the level of advanced inquiry involved, with a consequent degradation of qualifications. There is also a risk that learning outcomes are poorly defined or not defined at all, and that they may be narrowly focused rather than embracing specific, generic, employment-related and life-long learning outcomes as expected of contemporary higher education. Inadequate consideration of different modes of participation or delivery may lead to disadvantage for some individuals/cohorts.

If the achievement and assessment of expected learning outcomes are not aligned for the course of study overall, there is a risk of learning outcomes not being achieved or not being adequately assessed, or of some outcomes being assessed excessively to the detriment of others that are given little attention or ignored. Insufficient diligence in selecting methods of assessment may result in invalid or otherwise unreliable assessment, to the extent that students may graduate who have not in fact achieved the learning outcomes of the course.

What TEQSA will look for

This part of the guidance note covers the full extent of the Standards, and corresponding evidence that TEQSA may require, in relation to course design, learning outcomes and assessment.
 

For new applicants seeking initial registration and course accreditation, TEQSA will require evidence to be provided in relation to all relevant Standards.
 

For existing providers, the scope of Standards to be assessed and the evidence required may vary. This is consistent with the regulatory principles in the TEQSA Act, under which TEQSA has discretion to vary the scope of its assessments and the related evidence required. In exercising this discretion, TEQSA will be guided by the provider’s regulatory history, its risk profile and its track record in delivering high-quality higher education.
 

The evidence required for particular types of application is available from the application guides on the TEQSA website.
 

Providers are required to comply with the Standards at all times, not just at the time of application, and TEQSA may seek evidence of compliance at other times if a risk of non-compliance is identified.

When providers apply to TEQSA for course accreditation, they are required to provide detailed course documentation. In other circumstances (i.e. if an issue arises outside the scope of a formal application) TEQSA may be in a position to readily form a view on the basis of the publicly available information (required under Standard 7.2.2). Such an issue may also prompt a request for further information, which in turn may also be influenced by the provider’s previous record of meeting the requirements of the HES Framework in course design for cognate or different fields of education.

Broadly speaking, the specification of the design of the course provided to TEQSA for a course accreditation application should allow a peer to form a view on the standing and quality of the course, and allow prospective students to compare comparable offerings from different providers.

TEQSA requires that a provider be able to demonstrate that the content and learning activities of the course are of a sufficiently advanced level and otherwise appropriate to higher education, and are consistent with the field of education and the level of qualification involved. TEQSA will probe these aspects intensively in relation to the requirements of Standards 3.1.2 and 3.1.3. A provider may wish to advance credible national or international comparators in support of the course design (note that this is required for learning outcomes at Standard 1.4.1). Reference may also be made to the specifications of the AQF for the level of qualification concerned. In the case of ‘nested’ course designs, TEQSA will pay particular attention to entry and exit pathways and to the integrity of course design and learning outcomes for each exit point.

Where the provider’s intention is to offer a course of study in different locations or by different modes of participation or delivery, TEQSA will need to be satisfied that the design of the course is such that students have equivalent opportunities to achieve the expected learning outcomes irrespective of their mode of participation. As for external accreditation of the course by a professional body (Standard 3.1.5), providers are encouraged to review the application guides on the TEQSA website.

Just as TEQSA will be concerned that a course of study and its content are fit for higher education, it will be similarly diligent in relation to the nature, quality and level of the expected learning outcomes for the course (Standards 1.4.1-1.4.2). This will include an assessment of the credibility of comparators advanced by the provider (Standard 1.4.1) and may involve expert/peer review. Similarly, TEQSA will wish to be satisfied that the methods of assessment of learning outcomes that are used throughout the course are credibly capable of valid assessment of the various outcomes concerned for the level of qualification offered (see also Standard 1.5.3). The Standards require that all specified learning outcomes are assessed before completion of the course of study (Standard 1.4.4) and that progressive and coherent achievement of learning outcomes is planned in the design of the course (Standard 3.1.3).

TEQSA will expect some clear information demonstrating where course learning outcomes are taught, practised and assessed, whether at unit level or at course level (e.g. via a ‘capstone’ assessment and/or an assessment against a set of occupational or professional standards) or a combination of these (Standard 1.4.4). TEQSA may require an appropriate demonstration that the learning outcomes that are assessed at individual unit level (and/or within a capstone unit) reasonably demonstrate achievement of overall course learning outcomes on graduation. The Standards also require that any grades awarded reflect the level of student attainment (Standard 1.4.3). TEQSA will expect providers to be able to advance credible evidence (such as moderation exercises, peer reviews, benchmarking studies) that will satisfy TEQSA in this respect.

For those providers that offer research training by higher degrees, TEQSA will need to be satisfied that the additional requirements for the specification and assessment of learning outcomes for research training are met (Standards 1.4.5-1.4.7). This may involve an assessment of the relevant policies and procedures governing assessment for research degrees, and their implementation, as exemplified by assessment of actual reports from examiners for a sample of relevant assessments. The details of this will be covered in the assessment request for information. Providers are encouraged to review the application guides on the TEQSA website.

Scope of assessments

If, as a result of looking in detail at the provider’s capabilities in course design and assessment of learning outcomes, TEQSA is satisfied that the provider’s processes meet the requirements of the HES Framework and that there is evidence of continuing sustainability and effectiveness of these processes, this may allow TEQSA to reduce its evidence requirements for other Standards and/or for subsequent regulatory activities for other courses of study. On the other hand, if concerns are raised in relation to the provider’s capabilities, this may require TEQSA to probe the design and assessment of other courses in more detail.

Resources and references

Australian Qualifications Framework Council (2013), Australian Qualifications Framework Second Edition January 2013.

FLIPCurric website.

Office for Learning and Teaching project, Assuring Graduate Capabilities.

Office for Learning and Teaching, Assuring Learning.

Publications developed by the Assessing and Assuring Graduate Learning Outcomes Project.

Quality Assurance Agency (2014), UK Quality Code for Higher Education, Chapter B1: Programme Design, Development and Approval.[2]

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its guidance notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the HESF can be met in different ways according to the circumstances of the provider. Provided the requirements of the HESF are met, TEQSA will not prescribe how they are met. If in doubt, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au. 
 

[1] A course of study is a coherent sequence of units of study leading to the award of a qualification. The use of ‘course of study’ in the Standards includes both coursework and higher degree by research programs unless otherwise specified. Courses of study are sometimes known as ‘programs’ and units of study are sometimes called ‘modules’ or ‘subjects’.

[2] This document sets out expectations for providers of UK higher education.