by MICHAEL TOMLINSON
For outsiders who want in to one of the new categories the Tertiary Education Quality and Standards Agency website provides copious guidance on the types of evidence they expect to see.
Institute of Higher Education
In a way, this one is simple – you have to show that you meet all the base-level standards in the Higher Education Standards Framework (Threshold Standards) 2015. Some of these are marked for TEQSA to consider when assessing an application for registration, and some are marked for consideration when assessing an application for accreditation of one or more courses. It is an integrated framework, not separated into two sets, so some standards apply to both registration and to course accreditation, but in different ways.
Admission Standard 1.1 is an example which applies to both. For the registration decision, TEQSA will want to know you have an overarching policy framework governing student admissions that is fair and transparent. Students must know what they are letting themselves in for before they sign on the dotted line and agree to pay fees and charges.
For the accreditation decision, TEQSA will want to know the admissions criteria for the particular courses you are applying for. No-one can guarantee that all students can succeed once they embark on a course, but they should be positioned to succeed. They must have the level of prior knowledge and skills they need as a foundation for good progress. They should be given enough credit (so that they do not have to repeat topics they have already learned) but not too much so that they are exempted from topics they really need to learn in order to start new ones at the next level.
By the way, you can only be registered if you have at least one course accredited. Don’t go with a single innovative course that experts might find too far removed from generally accepted models especially for a novice provider – plain vanilla will do. If you sail through your registration assessment and flunk the course assessment, you end up with nothing.
By all means seek assistance from consultants, but make sure TEQSA realises you are not dependent on outside assistance. TEQSA will want to be confident you have enough internal capability to start operating if they give you the green light. You will not be expected to hire a complete workforce before you have regulatory approval, that would be unreasonable. But at an absolute minimum, engage an experienced academic director to guide the development of your application. Academic leadership is a critical success factor for new providers.
Self-Accrediting Authority (SAA) is not a category, but it is the next step along the development path, and these criteria are being modified along with the category criteria.
Only a handful of providers have been able to gain SAA during the TEQSA era. This is because the outgoing (but still in force) criteria require great track-records for both applications for course accreditation and student completion rates, attrition rates and graduate employment, over at least three cohorts of graduates. Not many providers can pass both these tests.
But the requirement for outstanding “evidence of student success” now applies to the new University College category.
This is arguably because the only relevant test for SAA is the ability to reliably accredit a course. In reviewing a course, a provider should obviously consider the track-record of student success and make adjustments for variations, but this is relevant to assessing the internal process of course review and renewal, and will no longer be a test in itself.
This was originally called ‘National Institute of Higher Education’ and was re-named by the minister, recycling the name that has traditionally been used for a university on training wheels. It fills the slot that was needed for a provider able to demonstrate that it significantly exceeds the threshold for quality. It is largely based on the criteria for unlimited Self-Accrediting Authority (i.e. not limited to specific fields or levels).
The former University College category was designed only to be a staging post on the way to university status, although nothing would prevent a provider remaining in the category if they didn’t make the transition. However, they had to demonstrate credible planning to achieve university status within five years.
The new category leaves it completely open – you can use it as a staging post or you can apply with the overt intention of staying in this category indefinitely, and you don’t need to develop plans to progress to university status. There are no requirements to conduct research, but at the same time you are free to do so and to build your research profile if you are intending to progress to the next category.
The criteria are quite demanding – don’t even think about applying unless you are well positioned. They include the requirement carried over from SAA for a five-year track record of strong student outcomes, measured by indicators such as attrition rates, student experience ratings and graduate outcomes. Your student success numbers should look like those of a successful university, which will be difficult for providers in fields where the gig economy prevails and high rates of conventional full-time employment are not attainable.
You should also be able to demonstrate a track-record of responsible use of SAA in at least 70 per cent of your courses. TEQSA will look for evidence that these courses have been through at least one cycle of comprehensive course review and meet the extensive requirements in the Monitoring, Review and Improvement section of the HESF. Robust quality assurance and course accreditation processes are also required
You will also need to show evidence of extensive staff scholarly activity and support. This needs to be more than just professional development, (TEQSA issued a discussion paper last year suggesting ways of defining the distinction). For this category, many staff should be evidently contributing in some way to the advancement of knowledge, engaging in the collegial dialogue about their discipline and/or teaching and learning. It should not be onerous to demonstrate this if required, building on the information gathered about staff publications and maintained by many staff members for Continuing Professional Development programs required by their professional associations. Get the staff to add a few points about how the activities contributed to their teaching or to curriculum development in case TEQSA audits this.
A University College should not be an island, looking inwards, and this extends to a need for extensive engagement with industry and the professions.
Overall, you need to show that you are providing an advanced and scholarly learning environment, and to build this you will of course need superior and experienced academic leadership.
If you thought getting into the UC category was hard, university status will be even harder to attain, and challenging even for some existing universities to maintain.
Research will be the major criteria distinguishing universities from university colleges. TEQSA is being given new specifications to help it assess the quantity and quality of research appropriate to university status.
Providers delivering predominately in one field will be able to occupy a niche intended for universities with a specialised focus, but others will have to demonstrate a reasonable quantity of research over at least three broad fields and at least 30 per cent of those delivered. This could amount to four out of 11 in the case of universities offering all broad fields.
And the research will need to be “at or above world standard” (the concept used in the Australian Research Council’s ‘Excellence in Research for Australia’ ratings). Clearly, we would not want research at Australian universities to be generally below world standard, but it will be a difficult test to meet for fields that have mainly local relevance, such as Australian history or Australian literature. And it will become harder, in 2030, with the requirement to conduct research at or above world standard in at least 50 per cent of the fields a university delivers, which could amount to five out of eleven.
The current established universities should have no difficulty meeting the initial test, and almost all already meet the 2030 requirement. But the existing Table B private universities will be challenged.
Even more challenging will be the scenario of anyone seeking to establish a “greenfield” university, i.e. an entirely new organisation going for registration in the Australian University category. They will face a technical speed hump because the standards have traditionally been written in terms of current capability, so TEQSA should assess providers on the basis of where they are at the time of application. A greenfields university will clearly not be conducting research in three fields which it is delivering at the time of application, because it will not be delivering at all. Building research activity and demonstrating that it is at world standard will take time. So, a greenfields development needs five years at least from the time it commences delivering to come up to speed with the research requirements. TEQSA pointed this out to the Coaldrake Review of provider categories, which recommended the government find a solution.
The days in which state governments established new universities appear long passed, but we would not want to exclude the possibility that a government might want to establish a university in a fast-growing area of the country at some time in the future, or outsource this to a private organisation.
For the foreseeable future, it seems the only realistic pathway towards (non-specialised) university status will be using University College as the staging post, and building research capability over time without the pressure of having to meet any of the research requirements. The time-honoured strategy for doing this is to poach research leaders from universities, but success is not guaranteed – you need to select well! Will University Colleges get listed on Table B and so get access to research funding, despite not being required to undertake research? It would be hard for them to progress to University status otherwise.
As a parting message – let us nurture and value all the roses in the garden, and keep studying the evolving body of knowledge about rose-growing!
Dr Michael Tomlinson FGIA FCS is a higher education quality and governance consultant, and the director responsible for TEQSA’s input into the review of the Category Standards during its formative stages.