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Issues for Consideration in the Review of Australian Higher Education
April 2008
Vision
As a peak body of established private providers of longstanding in the higher education sector our vision for higher education in Australia includes:
· a diversity of courses and institutions
· equity in student access irrespective of whether an institution is public or private; and,
· support for student choice such that a student can elect to study wherever he or she can best achieve success that equips them for life and work.
Steady expansion of the private higher education sector to continue
Over the past five years there has been a 50% increase in student load in non-Table A providers approved as HEPs by the Commonwealth and since the introduction of Fee HELP started to impact in 2005 and 2006. This approximates 5% of total higher education student load in Australia or the equivalent of a mid-sized university. We anticipate this may increase to about 10% of student load over the next decade. Some of the growth can be attributed to a transition of courses from VET to higher education and improved retention.
Multiple pathways
The trend is for students to undertake more than one course of study, and study in more than one institution before settling into a career. Some institutions will be public universities and others private providers or TAFE colleges. The range of pathways will continue to expand. The term private provider is probably no longer helpful as the range of types of provider, the extent of “private arms” of public entities and collaborative arrangements has multiplied, reflecting an ongoing expansion of diversity and choice.
Need for recognition of contribution
We would hope that the contribution of non-Table A providers, often with their distinctive missions, is recognized, much in the same way that small and medium business enterprises are recognized for achieving outcomes in flexibility, customisation and price effectiveness that large corporations cannot. We also recognize that the scale of large enterprises enable them to serve mass markets and undertake activity that is beyond the scope and capacity of the smaller or medium enterprise. Effectiveness is maximised with SMEs and large corporations working cooperatively.
Broader understanding of what “university”means
We wish to see a broader understanding of what a “university” is. The new MCEETYA protocols for Higher Education Approval Processes introduce important developments in defining higher education, including more diverse forms of university in Australia, however the insistence that research intensive is the only model for a university is unrealistic and unaffordable. We would want all opportunities for quality research to be encouraged and maximised wherever there is capacity and for new models of achieving this to emerge. Currently the research active students and staff of private providers are disadvantaged.
Introducing a new understanding of university college
We also see the need for a new understanding of the term “University College” (or similar) so that it means an institution that teaches at university level. Currently, under the MCEETYA Protocols, which are not due for revision until 2013, the term can only be applied to “proto-universities”, reflecting a status that historically applied in the establishment phase of many universities in Australia. It is difficult to see that approach to the establishment of a university applying today or in the future.
Strategies
Greater investment required – both public and private
We believe that further developing a higher education environment with outcomes that meet the expectations of Australian society calls for higher levels of both public and private investment. This investment should be directed to teaching and research activities and also must address critical infrastructure needs.
Towards a single student loan scheme
COPHE believes that a single income-contingent loan scheme to replace HECS HELP and Fee HELP, and following consistent rules, needs to be considered.
Expanding scholarships to ensure equity
The Commonwealth Scholarships program assisting students from low socio-economic backgrounds, regional and remote areas, and indigenous students, should be made available through any institution that can serve the needs of those students.
Compacts enhance diversity
The introduction of compacts between universities and government is a positive development that should enhance diversity of institutional mission.
Expanding the compact scheme to private HEPs
We will be watching how the compact process develops, and, noting that the first compact developed was in fact with a private university, would be interested in an examination of how compacts between government and private providers could enhance higher education and encourage additional non government support. This could commence with HEPs that currently have publicly funded load, and then possibly more widely to any approved HEP where students can access Commonwealth support.
Student entitlement schemes
A student universal entitlement or scholarship scheme for tuition, available to all Australians and across all providers in concert with institutional compacts needs to be considered. Effective compacts together with enhanced student choice will increase equity and encourage diversity as well as mitigating any unintended policy impacts on public universities.
Providing incentives for investment in higher education
We have noted with interest that public spending on higher education as an investment in human capital achieves a high rate of return for a country and would want to affirm what seems obvious, that in addition to public expenditure, encouraging and providing incentives for individuals, investors and private providers would generate an even greater dividend. Measures that provide such an incentive should be considered a priority for government.
Incentives for students to invest in their education
The experience of private providers suggests that students make rational choices in their spending on higher education tuition and should be encouraged to invest in their own education. We recognize the importance of ensuring equity in the treatment of those unable to make a significant contribution. The success of the HECS scheme and associated income contingent loan schemes as equity measures is widely acknowledged.
Barriers
Misunderstanding about accreditation and quality assurance of private providers
Ignorance and misunderstanding about accreditation and quality assurance of non-Table A providers is widespread in public universities. In fact private HEPS are subject to rigorous state accreditation of their courses, as well as state registration based on a detailed review of capacity, and Commonwealth approval as a HEP (for those institutions accessing Commonwealth programmes) that follows an exhaustive approval process. Institutions are then subject to quality audit following an AUQA or similar model. The quality of higher education awards from private providers in Australia is comparable to those of Table A providers. The misunderstanding impacts providers in a variety of ways but primarily through a view that somehow student support and other measures should be applied differently.
Issues of compliance cost and complexity
Compliance cost and complexity is an increasing concern for private providers who are regulated in multiple jurisdictions. Duplication of process and reporting remains an issue.
Concern about lack of integration of planning and policy
During the past decade the private higher education provider component of the sector has become more visible and grown rapidly, but beyond the introduction of Fee HELP, there has been a lack of integration of policy and planning at both Commonwealth and State levels, taking into account the increasingly significant role and potential contribution of the private sector. By the end of the decade, which is the scope for this review, a number of private providers, both domestic and foreign, will be of equivalent size to some public institutions. The review should take note of the investment, aggregation and integration processes currently underway in the private sector, the longevity of many providers, the increasing number of partnerships between public and private providers and the growing presence of successful public university-owned private providers.
Unworkable consumer protection policies
There has never been a failure of a higher education institution where students were displaced. The current requirements for consumer protection, though well intentioned, have produced policies that are simply unworkable in the higher education environment. It is accepted practice in higher education that institutions must “teach out” when a course is not to be offered for any reason and provision needs to be made for an industry response if required. The unique nature and content of most higher education courses needs to be recognized with any two students rarely undertaking an identical course of study.
Conclusion
We appreciate the opportunity to make these initial comments for the review; and look forward in due course to participating in the detailed process.
COPHE has been collecting student data from private providers since before the introduction of Fee HELP and is in the process of collating and assessing data collected over five years.
CONTACT DETAILS
Council of Private Higher Education Inc.
Suite 244
813 Pacific Highway
Chatswood NSW 2067
Executive Officer – Adrian McComb
Phone (02) 8021 0841 Fax (02) 8021 0843 email amccomb@cophe.edu.au
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