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Submission to the Review of Australian Higher Education
July 2008
Introduction and Summary
The Council of Private Higher Education (COPHE) welcomes the opportunity to make this submission to the Review. Much has changed in the past five to ten years for higher education in general and private providers in particular.
As an organisation representing established and longstanding private providers in the higher education sector our vision for higher education in Australia is for:
· a diversity of courses and institutions;
· public assurance of high quality and accreditation standards;
· equity in student access, funding and support 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.
We appreciate the recognition in the discussion paper of private providers and the challenges presented in understanding them and their part in what has traditionally been considered an essentially public system. In point of fact private higher education providers have a long history in Australia and it is really an accident of history as to why some institutions are private and others public. With public universities and other government entities operating “private arms” and partnerships, professional bodies providing higher education programs, and TAFE entering higher education provision, the dichotomy is increasingly meaningless.
While acknowledging that the term private is problematic, for the purposes of this submission we are focused on private providers defined as accredited higher education institutions that are not Table A providers in the HESA, while affirming the need for and collaboration between all types of institution, as well as public policy that maximises the contribution made by all providers.
Access to FEE-HELP for students enrolled with approved Higher Education Providers (HEPs) is a very important measure, as is provision of funded places for national priorities in nursing and teacher education. Though still a small part of the sector, the past five years have witnessed significant development and change with domestic student load in non-Table A providers approved as HEPs increasing from around 2.4% in 2004 to 4.1% in 2007. With the inclusion of overseas student enrolments as well as higher education providers that are not HEPs (public data are not available for the latter) the figures are probably double. The reporting required as part of the regulation of HEPs has also raised the profile of private providers where hitherto no data were available.
Notwithstanding the major reforms introduced in the HESA, there are still many areas where current policy settings place students enrolled with private providers at a disadvantage.
Looking forward to 2020, we believe that achieving the vision for a competitive world class higher education sector and one that meets the many expectations for higher education in Australian society will call for increased investment, both public and private. No enterprise can operate in an environment where the price of its product is capped but its costs are uncapped without damaging its future prospects yet this is the situation faced by public universities. There is a need for deregulation of the public sector but also for additional public funding. It is our contention that, subject to higher education course accreditation, funding should follow student choice irrespective of where the student decides to study.
The sector needs to be primarily driven by student choice, underpinned by a universal entitlement or scholarship scheme linked with income contingent loans and universities free to set their tuition fees. There is both a public and private benefit in higher education and it is the national interest to encourage people to invest in their own education as well as drawing further private sector investment. There is also a requirement and legitimate role for government to provide for the public good in funding areas of need and provide incentives for addressing regional and labour market requirements.
We would hope that the contribution of non-Table A providers, with their distinctive missions, is becoming better recognized. Broadly speaking, COPHE does not consider that private providers compete directly with public universities in what they offer. We would draw some parallels with the business world where small and medium business enterprises achieve outcomes in flexibility, customisation and price effectiveness that large corporations cannot. The scale of large enterprises enables them to serve mass markets and undertake activity that is beyond the scope and capacity of the smaller or medium enterprise. Effectiveness and the contribution to the economy is maximised with each contributing in accordance with their strengths.
Response to the Discussion Paper
Higher Education in Australia
The first questions posed on the functions and characteristics of higher education in Australia are fundamental as they establish a definition that underpins the framework for the Review.
While clearly much of what goes on in higher education prepares people for work, we believe the statement as to the first core function seems unnecessarily restricted to the individual and addressing labour markets and needs a third point: - to serve the needs of Australian society and the professions.
This is sufficiently important that we would want to carry this statement of function through into the characteristics by making the first characteristic: - Meet the needs of the labour market, Australian society, the professions and industry for high level skills and knowledge.
As to providing opportunities for all capable students, we would add that we want them to participate and succeed in areas or disciplines of their choice and this must include the options offered by private providers, made available in a non-discriminatory way.
The meaning of “operate internationally” is unclear. Higher education must serve to produce global citizens and the economic and educational benefits of international students are obvious, as is the need for contemporary international curricula.
Section 3.1 Meeting labour market and industry needs
Early in the life of our organisation when graduate unemployment was a growing concern we sought data from COPHE members on employment outcomes of their graduates. We found unemployment concern had never been an issue as there was high demand for graduates. The nature of private providers is such that they have to be closely attuned to the needs of students and employers, and addressing those needs is central in their varied missions. Indeed many private providers have direct links with employers.
More broadly across the sector, meeting the needs of the labour market and industry will be improved by maximising choice for students through the measures proposed elsewhere in this submission. Meeting labour market needs calls for further alignment of policy for both the VET and higher education sectors so as to open up pathways between both sectors of tertiary education.
Providing incentives to students
Where there is a particular labour market need identified, government and industry must combine to provide incentives that might include tuition fee support incentives and work experience. It is not productive to attempt to force students to choose in certain areas of study where there are labour needs by restraining student choice. Students do not achieve when they are studying subjects they are not interested in.
The labour market and the needs of industry do not form the only framework for considering social and economic wellbeing. For example, many graduates of private providers are employed in not-for-profit or non-government organisations, a major sector in the Australian economy that is possibly overlooked in discussion of labour market needs. The sector employs some 600,000 people, that is, around 10% of the workforce, and has an economic turnover estimated to be around $10 billion with faith-based organisations amongst the largest service providers.
Section 3.2 Opportunities to participate in higher education
Private providers help increase low-SES participation through privately funded scholarships, less restrictive entry requirements and delivering a learning environment that is nurturing. Private providers, even those that are large enterprises by Australian standards, can offer smaller class sizes and a strong sense of community. No detailed research data is available; however responses from COPHE members to questions raised in the Review reveal extensive support and encouragement for disadvantaged students.
Private providers provide these access opportunities with little or no government support.
Low-SES, mature-age and pathways
One COPHE member exemplifies the role of many private providers in providing study opportunities for mature-age students and those who might struggle in large higher education environments:
“We estimate our average student age is 40. We provide learning opportunities for students from ethnic groups that have traditionally struggled in public university situations including those from the Pacific Islands and Africa (Sudan/Nigeria). Those ethnic groups make up about 10% of our student population.”
Another smaller COPHE member noted that nine per cent of their cohort had special needs (two are on humanitarian visas) arising from trauma, psychiatric problems and learning difficulties that called for additional specialized support.
Equity in access to government assistance to students
Currently however, students of HEPs not listed in Table A or B under HESA (2003) do not have access to:
- Commonwealth Accommodation Scholarships
- Indigenous Access Scholarship
- Indigenous Enabling Scholarships
- Higher Education Disability Support Program including ASSD, ADCET and Performance-Based Disability Support Funding
- Commonwealth Education Costs Scholarships
Equity in access to scholarships to encourage students from disadvantaged backgrounds to undertake pathways programs would seem to be a particularly helpful approach but here again assistance is restricted to students enrolled in Table A and B providers. We note however that distribution of scholarships to Table A and B providers is on the basis of SES scores attributed to postcode, which seems a flawed and limited allocation methodology for higher education support. A better approach would be administration through Centrelink with secondary schools identifying and encouraging students that might benefit. Though beyond the scope of this review we would express the view that most areas of disadvantage have to be addressed long before a student is even considering higher education, and COPHE applauds the government focus on early childhood education.
We submit that 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 and increase participation. Whether the institution is public or private is immaterial and the only consideration should be what best assists the student to succeed in higher education.
A challenge for private providers and their students in addressing disadvantage, is the limited support and administrative infrastructure generally available to smaller institutions. To expand capacity in this area private providers need access to additional Commonwealth services or funding support to outsource or establish a private industry administrative facility.
Section 3.3 The student experience of higher education
While the majority of private providers have not to date participated in the GCA surveys on student satisfaction, the statement in the discussion paper that there is no data available on student satisfaction for private providers is not correct. The survey data available present a very positive picture.
It is clear from this chart that private providers give students a course experience that usually exceeds the satisfaction levels in public universities. This is to be expected from smaller classes and the experience of a close-knit learning community which characterises private providers. While the strong CEQ results for private providers should be acknowledged, it also gives rise to an opportunity and a concern.
In terms of opportunity, it is clear that private providers might be well suited to providing access to mature-age and disadvantaged students.
In terms of concern, while private providers give students excellent course experiences, they don’t have access to the learning and teaching awards and information/skills sharing available (the Commonwealth Learning and Teaching Performance Fund) to public universities. Again, there is no good reason or basis for different treatment of providers.
[Note: data sourced from those COPHE member institutions participating in the CEQ, and information which is publicly available. Participation in CEQ by private providers is fairly recent. The measure used is the CEQ overall satisfaction with course index. Percentage is calculated by summing “Agree” and “Strongly Agree” responses.]
Section 3.4 Connecting with other education and training sectors
Most COPHE members operate solely or primarily in the higher education sector though some are dual sector. Members report a wide range of articulation arrangements and linkages with the VET sector. As an organisation however the focus has been on higher education issues and policy.
The distinctive missions of the VET and higher education sectors, the vastly different funding arrangements, the variety of policy positions adopted by the states and the challenges posed by developing articulation pathways between sectors make for a very complex environment for policy development. While there is need for further discussion regarding a tertiary education sector, we would welcome the establishment of a national policy body with the objective of drawing VET and higher education closer together. However there is concern that the need for reform in higher education may be overwhelmed by the breadth of the current agenda.
As to whether there should be distinctive or converging missions in VET and higher education, this raises very important issues that call for an in depth review of VET and input from VET professionals in a manner that is beyond the scope of a review where the parameters are established within a higher education framework and the input is primarily from a higher education sector perspective.
COPHE welcomes the extension of FEE-HELP for VET as an important development in ensuring seamless links by introducing a similar funding arrangement and incentive for articulation between the sectors. There is an educational challenge in establishing appropriate credit transfers between different types of courses with some universities demonstrating little understanding of the AQTF or even the National Protocols. In the experience of some of our members, universities tend to underestimate the skill levels of diploma and advanced diploma students.
Even with improved and clearly understood articulation, expansion of the variety of acceptable models of educational institution would be absolutely necessary, as would a reengineering of the funding system to allow for the sort of articulation one finds in Europe in the polytechnic system, and in the United States with the liberal arts system of general education prior to professional education at postgraduate level. The current restriction on type of university to research intensive militates against variety and the ability to unify all forms of tertiary education into a single system.
The importance of 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, TAFE colleges or VET providers. The range of pathways will continue to expand. A national body could provide a more active role in encouraging and facilitating the movement not just of students, but also of staff, learning materials, programs, research, knowledge, and resources across providers.
In another form of pathway amongst private providers many non-English speaking people use VET programs in order to develop English language competence before progressing to higher education. Close linkage between VET and higher education is essential for skill provision, underpins employment and social integration.
Section 3.5 Higher education’s role in the national innovation system
Broader understanding of what “university” means
There needs to be a broader understanding of what “university” means. The MCEETYA protocols for Higher Education Approval Processes in their revised form this year, 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. As a society we need to see all opportunities for quality research to be encouraged wherever there is capacity and for new models of achieving this to emerge. Under the current National Protocols, in order to become a university, a private provider would need to demonstrate a research performance that exceeds that of the lowest quartile of existing Australian universities.
Teaching intensive universities
COPHE prefers the term teaching intensive within the broader understanding of scholarship advocated elsewhere in this submission. Teaching intensive reflects the reality of most university activity and to stress research across the entire sector only serves to diminish the value and importance of good teaching and the other elements of scholarship.
Overseas there are many examples of teaching intensive universities and furthermore it is difficult to see how Australia can afford for all universities to be research intensive.
Private providers believe it unreasonable that public universities are currently able to establish teaching only operations, typically in the CBD of capital cities, while still enjoying university branding. We also note that accredited foreign universities that are teaching only can be registered under the MCEETYA Guidelines.
The need for a new understanding of university college
We also see the need for a new understanding of the term “University College” (or similar such as University Institute) referring to an institution that is accredited to offer courses at university level without implying that it is a large and comprehensive institution. 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 in today’s climate.
The application of the term could readily be regulated by higher education providers undergoing quality audits and meeting self-accreditation standards. Under the current MCEETYA protocols there is a quality audit requirement for Higher Education Providers that is undertaken by AUQA or an accredited agency on a five yearly cycle. The old suspicions about differing values of qualifications depending on origin are no longer valid (if they ever were). There is a solid basis upon which a new category of “University College” can be established and understood in the community.
In countries where the systems are more diverse, prospective students clearly understand the differences between institutions carrying the title “University”.
Current narrow definitions of “University” confuse students when the qualification they receive is the same. From the student perspective the work they have done to achieve the award is comparable. When approaching employers, students may be disadvantaged because of uninformed suspicions about the validity or quality of awards from private providers. Definitions, such as “university” applying to higher education providers should take into account the broader concepts of higher education for a public purpose, rather than being based on historical developments, legislative requirements or how the institution is funded.
Equity in resourcing research and research training
While COPHE is not advocating that all should be research intensive, those institutions with research capacity should have access to resources to support research. Currently Commonwealth funds for research such as Research Infrastructure Block Grants and the Institutional Grants Scheme are only able to be accessed by Table A and B providers. All HEPs should have the opportunity to apply directly for grants, with grants awarded in terms of research capacity, and the perceived public good, rather than how the organisation is accredited or funded.
Research training has to be supervised by active researchers but should be available to any student who has the intellectual capacity and the research skills. Currently the Research Training Scheme and the Australian Postgraduate Awards Scheme are only open to students with Table A and B providers under HESA (2003). All postgraduate students should have the opportunity to apply for grants and scholarships, with grants awarded according to the ability of the student and the perceived public good of the research. How the organisation providing research training is accredited or funded is irrelevant.
The impact on HEPs is that their research-capable staff members are disadvantaged and institutions lose post-graduate research students because of the absence of research training places. These initiatives would also increase the possibilities for collaboration with the public sector universities, maximising exposure for talented students, and building on the potential of research initiatives.
A broader understanding of scholarship where research is but one form
The current model of higher education in Australia is biased in allocation of resources and recognition toward research-intensive higher education providers and while we are not advocating any reduction in research activity, rather expansion, it needs be to acknowledged that many academics are not research active but are primarily teaching and engaged in other forms of scholarship or professional practice.
It should also be acknowledged that much research in Australia is carried out in privately-funded laboratories and research facilities.
If we were to view it through the lens of the original Carnegie Classification system in the USA, Australia has ended up with a focus on a single type of university, Doctoral-Granting Institutions. There is however a move toward embracing more diversity. For example, the Melbourne Model is embracing inclusion of a US-style Liberal Arts College model. However there is a general lack of recognition in an Australian context of Professional Schools and Other Specialised Institutions. This is the classification level the bulk of private providers fall under which is helpful in adding to diversity in Australian higher education.
Under the Carnegie Model there is not a drive to make Liberal Arts Colleges or Professional/Specialised Institutions into Doctoral-Granting Institutions. The latest version of the classification is much more complicated, reflecting the diversity of higher education options in the United States; especially with the rise of community colleges. Higher education public policy in Australia has focused on a more homogenous model which does not reflect the diverse higher education options available.
Even within this focus on research-intensive institutions in Australia, there is a narrow interpretation and appreciation of research. A broader definition of research, such as the Boyer Model of Scholarship (Ernest L. Boyer, Scholarship Reconsidered: Priorities of the Professoriate, 1990), which recognises outputs rather than simply input, would be welcomed not just by smaller institutions; but by those that utilise those outputs, including students, employers and industry.
The Boyer Model recognises scholarship of teaching, integration, application and discovery. Discovery is the pure research which we submit is given undue focus and resourcing. Research which is focused on teaching, integration, and applying new knowledge also needs to be embraced and recognised.
While there are some private providers who are capable of discovery research; most providers are capable of other forms of scholarship, and this should be recognised and resourced, wherever a public good is able to be demonstrated.
Other groups have advocated expansion of the Boyer Model to incorporate elements such as presentation of creative work as a form of scholarship (plays, dance, stories, songs); or engagement with the community (Rod St Hill, Engaging Communities as Scholarship, University of Southern Queensland). These also deserve to be recognised.
Section 3.6 Australia’s higher education sector in the international arena
Private providers enrol considerable numbers of overseas students, though amongst COPHE membership the proportion of foreign students varies dramatically between different institutions. While some have established or are establishing off-shore campuses, this is a fairly recent development for most.
For many COPHE members, enrolling overseas students is not commercially driven, but undertaken to further the mission of the provider or expand the cultural milieu of the student body. Typically this can mean enrolling five to ten students, sometimes from disadvantaged backgrounds, who are commonly on scholarships. The compliance costs and complexity for small numbers of overseas students is an ongoing issue.
Providing all students with an overseas study experience
The opportunity to study overseas is clearly important in the development of globally-minded graduates, however, there are impediments to providing Australian students with a study experience in another country. The main impediment to establishing linkages with overseas institutions for most private providers is simply lack of resources.
OS-HELP is a loan scheme to assist eligible undergraduate students to undertake some of their course of study overseas. This loan scheme is primarily offered to Table A providers under HESA (2003) with Commonwealth-supported places. Students studying with private providers that don’t have Commonwealth-supported places do not have access to OS-HELP. We submit that all higher education students should have equal opportunity to access a loan scheme that enables overseas study experience.
We have determined that, with funding support to establish an administrative facility, COPHE would be able to build the capacity for our HEPs to administer OS-HELP. We have member institutions looking to provide opportunities for students to study overseas and we have overseas institutions keen to provide the experience. If these provisions were opened up our initial focus would be teacher education where we believe we have the capacity to build a cohort of students.
One COPHE member has students who would be keen to take advantage of OS-HELP expressed it in the following way:
“We have students studying education who would like to experience teaching English in an international context. Not only would this provide them with useful exposure to other cultures, it would give them an opportunity to refine their TESL skills. Unfortunately, our students cannot access the OS-HELP scheme and therefore do not have the resources to undertake such an opportunity.”
Section 3.7 Higher education’s contribution to Australia’s economic, social and cultural capital
COPHE asserts that it is not just universities that play a part in knowledge transfer and community engagement in Australian society. Private providers, in quite diverse ways, must maintain very close links to the communities from whence they derive their support. One example is that many not-for-profits or faith-based private providers relate particularly closely to cultural groups, faith communities and others may link into the sports, art or music communities. In these cases they may offer the key connection with the higher education sector.
Section 3.8 Resourcing the system
Private providers make a significant contribution to the provision of higher education, without public investment in infrastructure. In advocating that more encouragement needs to be given to private providers we would want to ask the question as to why competitive neutrality policy is not applied in the higher education sector as it is in the VET sector? The reasons for university teaching activity not being considered as having a commercial character were established in another era. When public universities can identify private providers as competitors, as some do, and export of education is such a significant business, as it is, the commercial character of university teaching is obvious and competitive neutrality policy must apply so that private providers and their students are no disadvantaged.
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.
Given there is a public good in higher education teaching and research we propose that investment should be encouraged through tax incentives following the same rationale advanced for benefits that accrue from research and development expenditure.
Access to funding from the Education Innovation Fund
Where a proposal can demonstrate a contribution to tertiary education that delivers a public good it should be considered for funding on the value of the contribution irrespective of the nature of the “ownership” of the institution. Competitive Neutrality Policy needs to be applied.
Universal entitlement or scholarships
Universal student entitlement or scholarship where funding follows the student, is the most effective and equitable allocation mechanism for scarce resources. Students are investing significant time, effort and resources into their education. In addition to making a major financial commitment, and provided they have appropriate preparation for entry, students deserve to undertake the course of their choice with the provider of their choice. We welcome increasing recognition within the public university sector of student choice as the key driver in allocation of places.The current environment where overall domestic demand is flat and there is even evidence of oversupply, provides an opportunity to introduce some form of universal entitlement without the perceived problem of capping demand.
We believe the following quote from Seizing the Opportunities: A Group of Eight discussion paper, 6 June 2007 (p.34) makes the point clearly:
“Student choice in pursuit of their own study interests is limited in this supply-driven system to what the institutions choose to supply. An alternative approach is to empower student choice through the direct allocation to them of portable national scholarships. Under such a scheme, the individual higher education institutions would retain their prerogatives in student admission but they would have stronger incentives to respond to student needs in the design and delivery of their courses.”
Universal entitlement deals with barriers to access, by empowering the student. There is an increasing move in public policy toward personalisation of public resources. This is applied in primary and secondary education, health services and transport. Individuals have a right to choose how their component of public services is allocated.
Providing incentives for investment in higher education
We have noted with interest the research that indicates 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, employers and private providers would generate an even greater dividend. Measures that provide such an incentive should be considered a priority for government.
Full-fee places
It is the view of COPHE that removal of the ability for public universities to offer full-fee places to domestic students, supported by FEE-HELP is poor public policy, as it reduces choice and encourages public universities to offer more full-fee places to overseas students in an effort to limit losses to their revenue. Furthermore it reduces the ability of the public sector to provide access to university from full-fee pathways courses offered by providers either private or public. We fail to see the logic in denying places to domestic students that are offered to foreign students. A system of universal entitlement could overcome this issue.
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.
Towards a single student loan scheme
COPHE proposes that a single income-contingent loan scheme to replace HECS-HELP and FEE-HELP, and following consistent rules irrespective of the nature of the provider, must be introduced. Currently different rules apply between undergraduate and postgraduate with the former subject to a 20% surcharge.
Section 3.9 Governance and regulation
Recognition of accreditation and quality assurance of private providers
Ignorance and misunderstanding about the extensive accreditation and quality assurance requirements for non-Table A providers is widespread in public universities. Non-self-accrediting institutions 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 programs) 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 ongoing compliance cost, duplication and complexity
Compliance cost and complexity is an increasing concern for private providers who are regulated in multiple jurisdictions, state and Commonwealth. In consultations with COPHE members this is repeatedly the key issue that needs to be addressed and a constant source of frustration with poor service levels in some state jurisdictions.
This translates to multiple layers of regulation, duplication of reporting, and the need for repeat work in compliance across jurisdictions. The result is that over-regulation of the private sector is costly (in terms of resourcing as well as upfront direct costs), time-consuming and increasing. The overall process is inconsistent and often takes too long, preventing providers from quickly meeting student/employer demand.
This month the state and federal education and training ministers received a MCEETYA report on the desirability of a National Higher Education Accreditation Body. It has not yet been made clear whether it will be made public. This report needs to be as it will inform the Review process.
COPHE has expressed support for a national body to develop and monitor the implementation of standard processes and arbitrate between state agencies on matters affecting registration and accreditation under the National Protocols. We had expressed great hope that the new National Protocols would usher in improved processes and that mutual recognition would actually mean mutual but thus far the improvements appear to be at the margins. Currently the states cannot agree on a standard form of annual reporting.
COPHE submits that the burden of higher education regulation and the cost and time taken to comply stifles innovation, results in missed opportunities, and reduces resources that could otherwise be put into improving access for students, and learning and teaching resources.
The unequal burden of regulation for private providers
One COPHE member has calculated compliance costs and writes:
“While compliance costs are meant to be only $10-20K per degree, the requirement that colleges require university-level performance with existing staff and facilities, effectively means that accreditation costs colleges in the vicinity of $200K per degree. For smaller colleges, this cost is exorbitant, and acts as a brake for entry into new markets and innovation.
Multiple levels of site visits, and compliance for registration, accreditation CRICOS, ESOS and so forth; combined with the disconnection between various national registers, leading to state-specific requirements undermining national frameworks, leads to compliance costs which are crippling even for medium-sized colleges.”
Another COPHE member on escalating compliance costs:
“The multiple (and increasing) layers of governmental regulation has rendered the whole process of operating more cumbersome and more costly in financial and human resources. As a direct result of its accreditation as an HEP, the college has increased its administration personnel by 30%. The recent move to national standardization of registration and accreditation has resulted in a significant escalation of accreditation fees in the state. The requirements of the various layers of government are not integrated and often demand information that is not consistent or in very different forms. There is not even coordination of time frames among the government agencies. For example, a new course submitted for accreditation needs to be forwarded to the regulator nine months before implementation, while DEEWR requires Course and Campus Profiles by August of the preceding year, which effectively brings the state submission time ahead by four months.”
Regulation barriers to innovation and response to demand
A COPHE member provides one example of the impact of state-federal regulation issues:
“The college wished to commence a masters program accredited in one state in another state, and made application. However, one of the two higher education officers in the state was absent. The application was caught up in the backlog for more than six months. By the time it was considered, legislation had changed and a new application had to be compiled and submitted.
After 18 months a review committee sat to consider the application, but by then their was only six months left on the term of accreditation in the primary jurisdiction, meaning that approval in the other sate was suspended until reaccreditation was completed.
It took 24 months before the application of the Masters program was successful. The college has calculated that this delay cost it $200K in foregone income.”
Another COPHE member provides an example of the difficulties:
“In our last round of accreditation we found that the review panel’s reference points were drawn from large universities. They had little regard for part-time students, and did not fully comprehend the students accessing higher education at various life-stages, rather than in a linear fashion from school to undergraduate to postgraduate to employment.”
Then there is the situation where a long-established leading provider wanted to offer one subject of 15 days duration that is part of a course accredited in one state and was to be delivered in another state in intensive mode. Rather than have the eight students travel interstate for ten days it was proposed that the lecturer travel interstate and deliver the subject in a public hospital facility. The second state regulator in this case applied a fee of $3,850 and indicated approval would take six weeks. Unfortunately this is not an isolated example.
An independent regulation review body required
COPHE recommends appointment of an independent body to review higher education regulation with a goal of ensuring that regulation is “proportionate, transparent, targeted and accountable” (Higher Education Regulation Review Group, Department for Innovation, Universities and Skills, UK). Unnecessary burden from government and external organisations should be reduced. Regulations should be based on the principles of proportionality and simplicity, and systems should focus on outcomes, not process. Where possible, the number of statutory regulatory bodies should be reduced. This places a greater burden on all higher education accreditation bodies to have more transparent structures and more accountable governance.
Unworkable consumer protection policies – Tuition Assurance
The current requirements for consumer protection through tuition assurance schemes, though well intentioned, have produced policies that are simply unworkable in the higher education environment. They have their origins in arrangements for the protection of foreign students in English language colleges where there is a level of homogeneity of course offering that does not exist in higher education.
Tuition assurance (TAS) provision is also a major burden and cost for most private providers.
There has never been a failure of a higher education institution where students were displaced, which is not surprising, given the barriers to market entry in the cost of establishing accredited higher education and the resulting value of students. It is accepted practice in higher education that institutions must “teach out” when a course is not to be offered for any reason and consumer protection provision needs to focus primarily on placement of students rather than reliance on a type of insurance cover for tuition fees. Ensuring that the governing bodies of HEPs are committed to students completing what they have started and providing an industry response to student placement is required. The unique nature and content of most higher education courses needs to be recognized with the understanding that any two students rarely undertake an identical course of study.
The solution has to be provided by the higher education sector through an industry-managed entity with institutional governing bodies being bound to provide courses that enable students to complete what they have started and a commitment from the sector to accept students in the event of displacement. The approach, which is currently the most common, based primarily on insurance cover that provides a refund for fees paid in the current semester is not a genuine solution and as such is inadequate.
Conclusion
This Higher Education Review has an historic opportunity to propose policy that enhances the diversity of the sector and provide a solid platform for the future. We encourage the Review to have the courage of its convictions and to make bold recommendations for change.
We also hope that the Government has the imagination and fortitude to follow through with the public policy initiatives recommended.
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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