Compliance in focus: Professional accreditation
The circumstances
In 2021 TEQSA investigated several concerns relating to courses that require professional accreditation. These included instances where providers were delivering courses that were not accredited by the relevant professional accreditation bodies and delivering courses in breach of conditions imposed on the course accreditation.
This is a significant concern for TEQSA as the absence or loss of course professional accreditation may prevent a student from progressing in a course or practising in their chosen profession upon graduation.
Our role
Professional accreditation of courses is specifically referenced in the HES Framework:
- Standard 1.4.2c requires that the learning outcomes of a course of study include knowledge and skills required to be eligible to seek registration to practice where applicable
- Standard 3.1.5 requires that courses are professionally accredited by relevant bodies if such accreditation is required for graduates to be eligible to practise
- Paragraph 6.2.1i requires providers to have credible business continuity plans and adequately resourced financial and tuition safeguards to mitigate disadvantage to students who are unable to progress in a course of study due to unexpected changes such as the loss of professional accreditation
- Standards 7.1.1, 7.1.2 and 7.1.5 require that the representation of a course is accurate and not misleading, for example, not describing a course as accredited for the purpose of professional registration until such accreditation has been obtained.
In addition, section 29(1) of the TEQSA Act requires providers to notify TEQSA of an event that happens or is likely to happen that will significantly affect the provider’s ability to meet the HES Framework. The loss of, or failure to obtain, professional accreditation would trigger this notification requirement, as the provider is no longer compliant with the HES Framework and there is a heightened risk to students and possible reputational damage.
The cases
When TEQSA becomes aware that a course does not have, or loses, professional accreditation, we actively engage with the provider. The level of engagement varies according to the willingness and capability of providers to identify risks to their higher education operations and demonstrate that material risks are managed and mitigated effectively.
- Case 1: The provider informed TEQSA through a material change notification that a course they were offering was provisionally re-accredited with conditions by the professional accreditation body. The provider subsequently informed TEQSA that, after addressing the concerns set out in the conditions, the course had been granted full accreditation. No students were disadvantaged and TEQSA did not take further action.
- Case 2: TEQSA was informed by a professional accrediting body that it had conducted a re-accreditation assessment of a suite of courses and one course had not been re-accredited. The provider had not informed TEQSA of this outcome. TEQSA engaged with the provider and it submitted a material change notification with information about course assurance arrangements for affected students, including transfers to other providers and refund of fees. TEQSA was satisfied the provider had suitable arrangements in place and did not take further action.
- Case 3: TEQSA became aware that a provider was delivering a course that required, but did not have, professional accreditation, with students graduating or about to graduate. TEQSA engaged with the provider intensively, because of our significant concerns about the impact on affected students. The provider voluntarily suspended all new admissions into the course while the application for professional accreditation was resolved. TEQSA asked for detailed arrangements to mitigate any disadvantage for all affected students. In response, the provider submitted a tailored solution for each student, including transfer to another provider, coverage of tuition fees if extra study was required, refund of costs for lost units and financial support where necessary. TEQSA was satisfied suitable arrangements had been put in place and did not take further action.
What providers can do
Providers should have robust governance processes in place to ensure that courses of study have the required professional accreditation and are not misrepresented. This includes:
- robust course development and review processes to ensure the course design meets the relevant professional body requirements
- periodic external referencing and other benchmarking activities
- the risk register clearly identifies the risk to reputation and the potential disadvantage to students if professional accreditation of a course is not obtained or is lost
- adequately resourced financial and tuition safeguards are in place to mitigate disadvantage to students if professional accreditation is not obtained or is lost
- all representations of a course in respect to professional accreditation are accurate and not misleading, particularly for those courses that require professional accreditation for graduates to practise. Where professional accreditation is pending, students should be clearly informed of this status and understand the impact if professional accreditation is not successfully obtained
- regular and transparent communication with professional accreditation bodies to keep abreast of any changes to requirements and ensure continued compliance
- if the status of professional accreditation changes, fully inform affected students of the potential impact on their studies and future employment outcomes.
Compliance monitoring approach