Guidance note: Academic monitoring, review and improvement

TEQSA’s guidance notes are concise documents designed to provide high-level, principles-based guidance on interpretation and application of specific standards of the Higher Education Standards Framework (Threshold Standards) 2021. They also draw attention to other interrelated standards and highlight potential risks to compliance. They do not introduce prescriptive obligations.
 

The definitive instruments that set out providers’ obligations in delivering higher education remain the Threshold Standards (as amended on advice from the Higher Education Standards Panel to the Minister for Education from time to time) and the TEQSA Act.
 

In August 2023, TEQSA consulted stakeholders with a draft version of the Academic Monitoring, Review and Improvement guidance note, and considered all feedback.
 

This guidance note was finalised on 19 March 2024.
 

The purpose and intent of the guidance note about academic and research integrity is to support providers in ensuring they have the relevant policies, processes, training, oversight, and culture to protect and maintain the integrity of their academia and research.
 

• Full list of guidance notes

1. What does monitoring, review and improvement encompass?

In the context of the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards) monitoring, review and improvement are key elements of institutional quality assurance.

The Threshold Standards provide that all higher education providers (providers) carry out ongoing monitoring and review to improve their operations, and that providers comprehensively review all their registered courses of study (courses) at least every 7 years. For each course of study, a comprehensive review should encompass:

• design and content
• expected learning outcomes – their methods of assessment and student achievement
• emerging developments in the relevant field of education
• mode of delivery
• changing needs of students
• identified risks to quality
• trend analyses over a range of factors (e.g. completion rates) for different student cohorts and subgroups. 

Alongside student feedback, such continuous monitoring and reviews should also inform ongoing improvement activities. As the Explanatory Statement of the Threshold Standards notes, the purpose of monitoring and review is “to maintain and enhance [the] quality and effectiveness” of the provider’s educational offerings.¹

To ensure a provider’s improvement cycle both maintains and enhances its offerings, the Threshold Standards place 2 quality assurance conditions upon comprehensive reviews.

The first condition is that comprehensive reviews involve benchmarking activities such as external referencing. Although the Threshold Standards do not define ‘external referencing’, TEQSA understands this term to describe activities wherein a provider assesses an aspect of their operations against an external comparator. Examples of external referencing include, but are not limited to:

• peer review
• moderation of courses
• course accreditation by professional bodies
• engagement with and feedback from industry groups
• comparisons with identified good practices in the sector
• comparisons grounded in publicly available information or market intelligence
• comparisons developed through collaboration with other providers, peak bodies, employers, or industry.

The second condition placed upon comprehensive reviews is that they are overseen by peak academic governance processes. Such oversight aims to ensure a provider’s monitoring, review and improvement activities are not ad hoc but instead reflect a systematic approach to quality assurance.

At the same time, oversight by academic processes should also serve to ensure the systematic approach a provider adopts to monitoring, review and improvement is appropriate to the specific character of the provider. For example, the Threshold Standards describe more developed processes of review, monitoring, and improvement for providers granted self-accrediting status, and for those who seek to enter ‘higher’ provider categories. But across any such variations, TEQSA holds all providers to a common expectation of being able to demonstrate an understanding of how their own monitoring, review and improvement operations provide an appropriate form of ongoing and systematic quality assurance.

2. What TEQSA will look for

TEQSA considers relevant standards from the Threshold Standards in the context of academic monitoring, review and improvement, among which most notably are:

Obligations applying to providers of education to overseas students in Australia

Where it applies to a provider, TEQSA considers the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) and the Education Services for Overseas Students Act 2000 (ESOS Act).

The sections of the National Code relevant to monitoring, review and improvement are 4.1, 4.2.3, 8.1, 8.3, 8.6 – 8.8.

Sections 4.1 and 4.2.3 require providers engaging an education agent to enter into a written agreement that outline processes for monitoring the agent’s activities, particularly regarding whether the agent is giving students accurate information on the provider’s offerings. The agreement should also include corrective action to be taken if it is determined that the agent is not complying with the terms of the agreement.

Sections 8.1 and 8.3 require providers to monitor student’s attendance and progress to ensure they are on track to complete their studies in the duration specified by their Certificate of Enrolment. Sections 8.6, 8.7 and 8.8 provide for more detailed requirements for monitoring the attendance and progress of students enrolled in ELICOS, Foundation Programs and higher education programs, and for having intervention strategies to support students when necessary.

3. Identified issues

Within the context of the Threshold Standards, TEQSA has identified a range of issues which may indicate potential problems in a provider’s approach to monitoring, review, and improvement:

Monitoring and data gathering

• Lack of investment in adequate time, staff, or resources to effectively complete monitoring, data gathering or data analysis, or a lack of focus on areas that pose the greatest risk to students and the integrity of the provider, which may lead to:
  • insufficient data being available to identify problems and engage in evidence-based improvement in areas such as academic integrity, progression, completion, and admissions
  • a failure to monitor or provide support to students with equity backgrounds
  • insufficient oversight of education agents and other third parties, increasing the risk to the students of being misled or receiving a poor quality of education
  • courses being subject to ad-hoc changes.
• Not monitoring cohorts of students who are more likely to be at risk academically, i.e. students with a low socio-economic status background.
• Not monitoring English language skills as a risk factor that may impact on students’ successful completion of courses.

Quality assurance systems

• Quality assurance systems are absent, too complex, or poorly enacted, which may result in:
  • a provider being unable to validate the quality of its educational offerings
  • courses of study not being sufficiently reviewed or updated.

Student feedback

• Lack of timeliness or neglecting student feedback in monitoring and improvement processes, resulting in:
  • failing to adequately address barriers and risks to sub-groups of student cohorts progressing through courses of study
  • the hinderance of course improvement based on the end users’ (students’) experience
  • constraining improvements of other aspects of the student experience including campus and facilities, course enrolment and student information systems, and issues of student wellbeing and safety
  • elevated reputational and market risks.
• Declining responses to student feedback, which may impact on providers’ approaches to monitoring and review.
• Lack of mechanisms to screen student feedback to identify abusive or discriminatory comments or feedback that indicates that there may be a risk of harm, resulting in:
  • teachers and supervisors failing to review student feedback due to concerns about psychosocial hazards or harms
  • providers failing to identify students at risk of harm
  • providers failing to protect staff from abusive or discriminatory feedback.

Integrity of operations

• Insufficient attention to the integrity of a provider’s operations, including the academic integrity of its offerings, that raises concerns about the credibility and legitimacy of any qualifications issued.

External referencing

• A lack of external referencing within an institution limiting the awareness of advances in a particular field of education, leaving a provider ‘reinventing the wheel’ or providing outdated education.
• A lack of stakeholder perspective via external referencing jeopardising claims about the quality and standing of courses, providers, and the Australian higher education sector more broadly.
• No involvement of industry stakeholders and advisory boards or other stakeholders external to the institution in benchmarking to ensure graduates are best placed to succeed in their industries.

Lacking the general capability to monitor, review and improve in a way expected given the character of the provider

• Absence of any systematic policies and approaches to an ongoing improvement cycle.
• A lack of mature and advanced processes appropriate to the provider category in which the provider is registered.
• Failure to systematically collect and analyse data for trend analyses on student progress and success across different cohorts and student subgroups.

Related resources

• Guidance note: Academic governance
• Guidance note: Course design (under review)
• Guidance note: Diversity and equity (in development)
• Guidance note: Wellbeing and safety (in development)
• Guidance note: Learning outcomes and assessment (in development)
• Guidance note: Work-integrated learning

Notes

1. Explanatory Statement Higher Education Standards Framework (Threshold Standards) 2021, p.11.

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