Registration Renewal 26 October 2016

Renewal of registration

Report on application for renewal of registration of Cambridge International College (Vic) Pty Ltd

TEQSA has agreed for the registration of Cambridge International College (Vic) Pty Ltd (Cambridge) as a higher education provider to be renewed for the period until 1 November 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'.

TEQSA has also agreed for the accreditation of the following courses of study offered by Cambridge to be renewed for the period until 1 November 2019 under subsection 56(1) of the TEQSA Act:

• Bachelor of Business
• Bachelor of Business (Accounting)
• Bachelor of Business (Management) and
• Bachelor of Business (Marketing).

Decisions on registration and accreditation have been made accordingly and conditions on the registration of Cambridge have been imposed under subsection 32(1) of the TEQSA Act. A copy of the conditions is available at Attachment 1.

Background to Decision

Cambridge applied to TEQSA for renewal of its registration as a higher education provider under Part 3 of the TEQSA Act and for renewal of the accreditation of its four higher education courses under Part 4 of the TEQSA Act.

Main Reasons for Decision

After reviewing the evidence relating to Cambridge's current and historical compliance with the Threshold Standards, TEQSA considered that there were a number of risks related to Cambridge's capacity to meet the Threshold Standards. In particular, Cambridge's history of delivery of higher education raises substantial concerns about Cambridge's corporate and academic governance, arrangements to protect academic integrity, staffing, course admission practices and course assessment arrangements.

However, in the course of the assessment of Cambridge's application, Cambridge provided some evidence that it is addressing, or has addressed, these issues. On this basis, TEQSA agreed that it was appropriate to for Cambridge's registration to be renewed for a period until 1 November 2019 and to impose a number of conditions on Cambridge's registration.

The conditions are designed to address the following risks:

• The effectiveness of Cambridge's corporate and academic governance of its higher education operations and Cambridge 's capacity to manage and effectively quality assure those operations including arrangements to protect academic integrity in accordance with provider registration standards (PRS) 3.7, 3.8 and 4.3;
• The need for Cambridge to ensure that it has appropriately qualified personnel, including teaching staff qualified to at least one AQF qualification level higher in the relevant discipline than the course being taught, to manage and to provide academic leadership at all locations at which its courses are delivered as required by PRS 5.2 and 5.3 and Provider Course Accreditation Standard (PCAS) 4.4;
• The need for Cambridge to effectively quality assure the admission criteria for its course in accordance with Provider Course Accreditation Standards (PCAS) 3.1, 3.2, 3.3 and 3.4; and
• The need for Cambridge to ensure the effectiveness of assessment and achievement of expected student learning outcomes for students in its courses in accordance with PCAS 5.1, 5.2, 5.3, 5.4, 5.5 and 5.6.

TEQSA is satisfied that the conditions will provide a framework for TEQSA to oversee the key risks associated with Cambridge's corporate and academic governance arrangements and its responsibilities to students. The conditions will also enable TEQSA to closely monitor the effectiveness of Cambridge's quality assurance arrangements for systematic monitoring, review and improvement of its higher education operations and robust process for the review of its courses.

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 Cambridge addresses the risks identified above.

Attachment 1: Conditions imposed on the registration of Cambridge International College (Vic) Pty Ltd

Condition 1: External independent audits

1.1. The College will engage at the College's expense suitably qualified independent experts (with the agreement of the Agency to the identity and terms of reference of the experts, which agreement is not to be unreasonably withheld) to review and make recommendations to the College (independent audits) in relation to the following matters:

(a) the College's Academic Integrity Framework incorporating the content and implementation of Academic Integrity Policy, Academic Misconduct Policy and Procedure and Plagiarism Policy and Procedure;

(b) the content and implementation of the College's Academic Progress Policy and Procedure, including the identification and management of students at risk;

(c) the content of the College's courses, particularly the course design, course review and assessment approaches; and

(d) the College's compliance with the Education for Overseas Students Act 2000 (Cth) and the National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2007.

1.2. The independent experts will:

(a) be suitably qualified to undertake the independent audits;

(b) not be a past or present member of the College's staff;

(c) not have been engaged as a consultant to the College; and

(d) not have any conflict of interest.

1.3. The outcomes of the independent audits are to be reported to the College's Academic Board, Board of Directors and the Agency by 30 April 2017.

1.4. The College is to prepare an implementation plan for each of the recommendations in the expert reports, approved by the Academic Board and Board of Directors, to be provided to the Agency no later than 31 May 2017.

1.5. The College is to report to the Agency on the implementation of the outcomes of the independent audits on:

(a) 31 July 2017; and

(b) such further dates as the Agency may require after the 31 July 2017 report.

Condition 2: Student to academic staff ratio

2.1. Commencing from 1 January 2017, the College must endeavour to maintain a maximum student to academic staff ratio of 30:1, calculated using the methodology set out on page 18 of the TEQSA Risk Assessment Framework document.

2.2. The College must notify the Agency if its student to academic staff ratio increases above 30:1 for a period longer than 5 business days.

Condition 3: Assessment moderation

3.1. The Director of Higher Education must prepare a report to the Academic Board by 31 November 2016 regarding amendments to the College's External Moderation and Benchmarking Policy and Assessment Policy in relation to:

(a) including minimum qualifications and experience for internal and external moderators of the College's assessment items; and

(b) the regularity with which such moderation is conducted.

3.2. The College must report to the Agency on the outcome of that report by 31 January 2017.

Condition 4: Student performance analysis and reporting obligation

4.1. The College is required to:

(a) provide the Agency, no later than 31 January 2017, with a comprehensive diagnostic analysis of the probable causes for observed rates and trends for student attrition, progression, minimum time completion rates and absent failure rates, for each accredited higher education course it offers and each year, for the period 2014 to 2016 inclusive. The analysis must include accurate data on student attrition, completion, progression, grade distribution and absent failure rates and include analysis by:

(i) entry path (comparing students admitted under each entry pathway);

(ii) credit awarded (comparing students admitted with no credit awarded with students admitted with credit for up to a third of the course and between a third and two thirds of the course);

(iii) education agent;

(iv) basis for assessment of the student's English language proficiency;

(v) country of origin;

(vi) referral to and uptake of student support (including participation in formal study support programs); and

(vii) student achievement in similar courses at other higher education providers.

(b) develop and provide to the Agency by 31 March 2017, a detailed strategy, having regard to the comprehensive diagnostic analysis required under 4.1(a) above, which:

(i) includes specific targets for improvement of student attrition, completion, progression rates and absent failure rates for each course and each year over the forward registration period; and

(ii) gives consideration to admission practices and standards, study load of students, the identification of students at risk of not progressing academically and the adequacy and effectiveness of student support.

(c) revise the targets determined in accordance with 4.1(b) above if and as directed by the Agency.

(d) demonstrate improvement, with reference to the targets to be stablished under 4.1(b) and 4.1(c), overall and for each course of study, through annually reporting to the Agency on these rates by 31 January each year (for the rates in the previous year) throughout the period of registration, with these reports to commence on 31 January 2018.

Condition 5: General reporting obligations

5.1. By 31 July and 31 January each year, the College must provide to the Agency copies of the following for the previous six month period:

(a) each report to the Board of Directors on student performance, including progress, attrition and completion rates;

(b) minutes of meetings of the Board of Directors

(c) minutes of meeting of the Academic Board, which:

(d) demonstrate a process consistent with the TEQSA Guidance Notes for the relevant bodies on the matters the subject of discussion; and

(e) specify the extent to which the discussion took account of external advice or input.