Renewal of Registration 25 October 2023

Renewal of registration

Report on renewal of registration of Think: Colleges Pty Ltd

On 25 October 2023, TEQSA:

• renewed, under section 36 of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act), the registration of Think: Colleges Pty Ltd in the category of Higher Education Provider, for a period of 3 years until 25 October 2026.

On 15 November 2023, TEQSA:

• imposed, under section 32 of the TEQSA Act, 2 conditions on the registration of Think: Colleges Pty Ltd.

Condition 1. Corporate monitoring and financial viability

In order to address concerns with regard to paragraphs c, d, and e of Standard 6.2.1 of the Higher Education Standards Framework (Threshold Standards) 2021, within 12 months from the date of re-registration, Think: Colleges Pty Ltd (Think) must submit to TEQSA one or other of the following:

EITHER

1. if the planned corporate restructure has been completed:
   
   1. an outline of the revised corporate group structure, identifying the identities and positions for all board and leadership roles
   2. evidence that Think's governing body is regularly assured that the revised Australian corporate group has sufficient financial resources for its Australian operations to remain financially viable, and
   3. an updated copy of related party balances, with summaries of amounts owed and associated commentary, as previously provided in Think's response to REQ06114 on 13 April 2022

OR

1. if the planned corporate restructure has not been completed, by 28 February each year of its registration period until the restructure is completed:
   
   1. a status update on the restructure, including a timetable for completion and an overview of causes and implications for any delays
   2. evidence that Think's governing body is regularly assured that the Australian corporate group has sufficient financial resources for its Australian operations to remain financially viable, and that the net asset deficiency of its Australian holding company has been addressed.

Condition 2. Academic quality assurance

In order to address concerns with regard to Standards 5.3.4, 5.3.5, 5.3.6 and 5.3.7 of the Higher Education Standards Framework (Threshold Standards) 2021, by 30 June of each year of its registration period, Think must submit to TEQSA evidence of regular and routine reporting to its corporate and academic governing bodies on how Think is maintaining effective academic quality assurance, which includes at a minimum:

1. current and projected external referencing and benchmarking arrangements
2. an analysis of actual and target student outcomes (attrition, progression, completion and grades distribution)
3. an analysis of student satisfaction ratings and any plans for improvements to these ratings
4. a review of unit and course learning outcomes over the previous 12 months
5. a review of assessment modes and weighting towards the constructive alignment with unit and course learning outcomes
6. evidence of grading/assessment moderations
7. a timetabled plan for course modifications or rectifications based on review and analysis in items a - f above, including a strategy for gauging the effectiveness of course modifications.

Main reasons for the decision

TEQSA renewed the registration of Think: Colleges Pty Ltd (Think) because TEQSA is satisfied that:

1. Think continues to meet the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards); and
2. Think, and each person who makes or participates in making decisions that affect the whole, or a substantial part, of Think's affairs, is a fit and proper person.

However, TEQSA renewed Think's registration for a period shorter than 7 years with conditions because TEQSA considers there is a risk that Think may not continue to meet, the following provisions of Part A of the Threshold Standards:

1. Paragraph c of Standard 6.2.1: TEQSA has concerns about Think's capacity to continue to apply sufficient financial resources to maintain its viability and business model, to meet the requirements of the Threshold Standards and to achieve its higher education objects and performance targets.
2. Paragraph d of Standard 6.2.1: TEQSA is concerned about the adequacy of Think's governing body oversight of its financial position and future directions.
3. Paragraph e of Standard 6.2.1: TEQSA is concerned about the appropriateness of Think's management of risk.
4. Standards 5.3.4, 5.3.5, 5.3.6 and 5.3.7: TEQSA is concerned about the adequacy of Think's academic quality assurance in terms of its scope and depth. Further, TEQSA is concerned that Think's monitoring, review and improvement mechanisms may not sufficiently incorporate regular external referencing and student feedback.
5. Therefore, TEQSA imposed Condition 1 to address concerns that Think is at risk of not meeting the requirements of Paragraphs c, d and e of Standard 6.2.1, due to the lack of transparency, certainty and appropriate risk management regarding Think's financial position and future directions.
6. Additionally, TEQSA imposed Condition 2 to address concerns that Think is at risk of not meeting the requirements of Standards 5.3.4, 5.3.5, 5.3.6 and 5.3.7, due to deficiencies in Think's institutional monitoring, review and improvement processes. This finding has taken into account the challenges faced by Think in developing external referencing and benchmarking activities given the absence of other higher education providers delivering a Myotherapy course at a Bachelor level.

Application to withdraw conditions

In accordance with section 32 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.