Re-registration and re-accreditation 21 September 2016

Provider: ParaPharm Pty Ltd

Course: Bachelor of Health Science (Naturopathy)

Renewal of registration

Report on the application for renewal of registration of ParaPharm Pty Ltd

TEQSA has agreed to orders made by the Administrative Appeals Tribunal under which the registration of ParaPharm Pty Ltd trading as Paramount College of Natural Medicine as a higher education provider will be renewed until 31 December 2019 under subsection 36(1) of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act) in the provider category of 'Higher Education Provider'.

These orders also involve the imposition of conditions on the registration of ParaPharm Pty Ltd under subsection 32(1) of the TEQSA Act. A copy of the conditions is available at Attachment 1.

TEQSA has also agreed to orders made by the Administrative Appeals Tribunal under which:

  • the accreditation of the following courses of study offered by ParaPharm Pty Ltd is renewed until 31 December 2019 under subsection 56(1) of the TEQSA Act:
    • Bachelor of Health Science (Naturopathy)
    • Bachelor of Health Science (Nutritional Medicine)
    • Bachelor of Health Science (Western Herbal Medicine)
  • pursuant to section 57A of the TEQSA Act, the deemed accreditation of ParaPharm Pty Ltd' Bachelor of Health Science (Homoeopathy) course of study under item 18 of Schedule 3 of the Tertiary Education Quality and Standards Agency (Consequential Amendments and Transitional Provisions) Act 2011 (Cth) is extended until 24 February 2017, and
  • pursuant to section 57A of the TEQSA Act, the deemed accreditation of ParaPharm Pty Ltd's Bachelor of Health Science (Mind Body Medicine) course of study under item 18 of Schedule 3 of the Tertiary Education Quality and Standards Agency (Consequential Amendments and Transitional Provisions) Act 2011 (Cth) is extended until 31 July 2017.

As a result of these orders the Bachelor of Health Science (Homoeopathy) and Bachelor of Health Science (Mind Body Medicine) will cease to be offered by ParaPharm Pty Ltd as at 25 February 2017 and 31 July 2017 respectively.

These orders also involve the imposition of conditions on the accreditation of the Bachelor of Health Science (Mind Body Medicine) under subsection 53(1) of the TEQSA Act. A copy of the conditions is available at Attachment 2.

Background to Decision

ParaPharm Pty Ltd applied to TEQSA for registration in the category of Higher Education Provider under Part 3 of the TEQSA Act.

TEQSA considered ParaPharm Pty Ltd's application and sent ParaPharm Pty Ltd a draft summary of findings with details of the assessment of ParaPharm Pty Ltd's application by the responsible case management team. TEQSA's Commission considered ParaPharm Pty Ltd's response to the draft summary of findings and made a decision to not grant ParaPharm Pty Ltd's application for registration and the renewal of accreditation of five courses of study on 24 June 2015 on the basis that it was not satisfied that ParaPharm Pty Ltd met the Threshold Standards.

TEQSA's reasons for not granting ParaPharm Pty Ltd's application included, but were not confined to, TEQSA's lack of satisfaction that ParaPharm Pty Ltd:

  • Ensured its course design was appropriate and consistent with the Qualification Standards and that assessment ensured learning outcomes were achieved;
  • Ensured that staff who teach in the course of study were appropriately qualified
  • Had the financial resources and financial management capacity to sustain higher education operations
  • Showed sound corporate and academic governance
  • Managed its higher education operations and its human resources appropriately
  • Ensured there are safe, well-maintained physical and electronic resources and infrastructure sufficient to enable the achievement of its higher education objectives

ParaPharm Pty Ltd applied for review of TEQSA's decision in the Administrative Appeals Tribunal (AAT). In the course of the proceedings, ParaPharm Pty Ltd made submissions and provided further information and evidence about the matters raised in TEQSA's decisions.

TEQSA engaged external experts to review the further material.

It is well established that absent a specific legislative provision to the contrary, the AAT is generally required to make a decision on review based on the evidence available at the time of the AAT's decision on review, and that the AAT is not confined to the evidence available at the time of the primary decision. Accordingly, TEQSA accepted that the AAT was required to take account of the further material submitted to TEQSA after TEQSA had not granted ParaPharm Pty Ltd's application.

Main Reasons for Decision

After reviewing the further material submitted by ParaPharm Pty Ltd and participating in mediation with ParaPharm Pty Ltd, TEQSA was satisfied that ParaPharm Pty Ltd meets the Threshold Standards. However TEQSA considered that there remained a number of risks related to ParaPharm Pty Ltd's capacity to meet the Threshold Standards in the future. On this basis, TEQSA agreed that it was appropriate to substitute TEQSA's initial decision to not grant the application with decisions to register ParaPharm Pty Ltd until 31 December 2019 and to impose a number of conditions on that registration.

The conditions are designed to address the following risks:

  • The effectiveness of ParaPharm Pty Ltd's corporate and academic governance of its higher education operations and ParaPharm Pty Ltd's capacity to manage and effectively quality assure those operations in accordance with Provider Registration Standards (PRS) 3.7 and 3.8 and Provider Course Accreditation Standard (PCAS) 6.1;
  • The quality of the courses of study in accordance with PCAS 1.1, 1.3, 1.7 and 5.1 and Qualification Standard 1.1; and
  • The application of sufficient and appropriate resources to ensure the numbers, qualifications, experience and expertise of staff is appropriate to teach the courses of study in accordance with PCAS 4.1 and 4.2; and
  • The adequacy of physical and information resources in accordance with PRS 2.1, 2.2, 7.1 and 7.2 and PCAS 2.1, 2.2 and 2.3,

TEQSA is satisfied that the conditions will provide a framework for TEQSA to oversee the key risks associated with ParaPharm Pty Ltd's corporate and academic governance arrangements and the quality assurance of its higher education operations. The conditions will also enable TEQSA to closely monitor the effectiveness of ParaPharm Pty Ltd's response to expert findings in relation to its courses of study.

In accordance with subsections 32(2) and 32(3) of the TEQSA Act, TEQSA may vary or revoke a condition imposed on the registration of a higher education provider, either on its own initiative, or upon application by the provider for variation or revocation. Accordingly, TEQSA will have the capacity to vary or revoke the conditions as ParaPharm Pty Ltd addresses the risks identified above., particularly in relation to the course design and arrangements for clinical practice, The adequacy of physical and information resources and the corporate and academic governance practices of the College.

Attachment 1

Conditions imposed on the registration of ParaPharm Pty Ltd trading as Paramount College of Natural Medicine:

i. ParaPharm Pty Ltd must review the following three courses of study:

  • Bachelor of Health Science (Naturopathy)
  • Bachelor of Health Science (Nutritional Medicine)
  • Bachelor of Health Science (Western Herbal Medicine).

    and its information resources in light of the matters described in the 2016 expert reports and, within three months of the date of these orders, provide TEQSA with the following:

    1. a list of the changes to be made to each of the courses;
    2. evidence that the changes have been considered and approved by ParaPharm Pty Ltd's Academic Committee; and
    3. evidence from an independent expert (approved by TEQSA prior to his/her appointment) that the revised courses and information resources will allow students to achieve the learning outcomes of the courses (Condition 1);

ii. ParaPharm Pty Ltd must not enrol any new students in the following three courses of study:

  • Bachelor of Health Science (Naturopathy)
  • Bachelor of Health Science (Nutritional Medicine)
  • Bachelor of Health Science (Western Herbal Medicine).

    until A and B of Condition 1 are met (Condition 2);

iii. ParaPharm Pty Ltd must, within one month of the date of these orders and, at least one month prior to the beginning of each financial year in which it is registered, provide TEQSA with the following:

  1. a budget describing ParaPharm Pty Ltd's planned expenditure on staffing, facilities and educational resources for the financial year, which includes details on how ParaPharm Pty Ltd intends to address the concerns raised in the 2016 expert reports in relation to the currency of ParaPharm Pty Ltd's information resources and the adequacy of ParaPharm Pty Ltd's physical facilities (particularly its specialised facilities); and
  2. evidence that the budget has been considered and approved by ParaPharm Pty Ltd's Board of Governors, with the benefit of advice from the ParaPharm Pty Ltd's Academic Committee (Condition 3);

iv. For six months from the date of these orders, ParaPharm Pty Ltd must provide TEQSA with a copy of the minutes of each meeting of its Board of governors and Academic Committee (minutes) no later than 21 days after the meeting takes place. After the initial six month period, ParaPharm Pty Ltd must provide the minutes no later than two weeks after the date the meeting takes place. The minutes must:

  1. demonstrate a process consistent with the TEQSA Guidance Notes for the relevant bodies on the matters the subject of discussion;
  2. include consideration of the matters required to be considered by the relevant bodies under the Higher Education Standards Framework, including risk management, delegations, course review, student performance, financial sustainability, facilities and staffing; and
  3. specify the extent to which the discussion took account of external advice or input(Condition 4);

v. Within one month of the date of these orders, ParaPharm Pty Ltd must provide to TEQSA revised position descriptions for its Faculty Manager and another person or other persons, which set out the specific responsibilities of those staff to guide and support students to access library and information resources (Condition 5); and

vi. Within six months after the date of these orders, ParaPharm Pty Ltd must provide TEQSA with a report from an independent external expert (approved by TEQSA prior to his/her appointment), which reviews ParaPharm Pty Ltd's clinic arrangements and confirms that those arrangements provide for appropriate supervision, resources and student experiences to prepare students for practice in the field of their course of study (Condition 6).

Attachment 2

Conditions imposed on the accreditation of the Bachelor of Health Science (Mind Body Medicine) offered by ParaPharm Pty Ltd trading as Paramount College of Natural Medicine:

i. ParaPharm Pty Ltd must not enrol, or allow to be enrolled, any new students in the Bachelor of Health Science (Mind Body Medicine) course (Condition 1);

ii. any students currently enrolled in the Bachelor of Health Sciences (Mind Body Medicine) course who are scheduled to complete the course by 31 July 2017 may continue studying the course (Condition 2); and

iii. any students currently enrolled in the Bachelor of Health Sciences (Mind Body Medicine) course who are not scheduled to complete the course by 31 July 2017 must be transferred to another appropriate course or be provided with an appropriate refund within three months of the date of these orders (Condition 3).