TDA policy position papers on tertiary education - TAFE Directors ...

TEQSA – National VET Regulator AlignmentThe evolution of a national tertiary regulator and a separate VETregulator has arisen primarily as a result of recommendationscontained in the Bradley Review. The Review recommended thatnational regulation was appropriate for an expanded tertiary sector andthat the interim <strong>position</strong> of two regulators should transition into oneregulator by 2012.There are many legal and constitutional impediments to achieving atimely transition but just as importantly as these, <strong>TDA</strong> considers thatthe existing provider categories in the National Protocols for HigherEducation do not accommodate the variety of institutional types thatexist now in that sector. Moreover, in the VET sector, there is nodifferentiation between 5,000+ existing providers. <strong>TDA</strong> maintains thatclarifying the provider categories in Higher Education and establishingprovider categories in the VET sector are essential steps to enable thetransition to occur. Without these steps being taken, there would beno commonality of approach to this issue.The Australian Qualifications FrameworkThe advent of a single qualifications architecture in the revisedAustralian Qualifications Framework (AQF) is further impetus for thetertiary sector. According to the Communiqué for a recent MinisterialCouncil for Tertiary Education and Employment (MCTEE) Meeting,the AQF will ‘result in an increasingly integrated tertiary sector, withstronger pathways between VET and Higher Education’. 8 The TEQSAlegislation has already incorporated the revised AQF as a vehicleto clarify the definition of Higher Education courses. As it becomesmore widely known across all education sectors, the revised AQF willprovide a clear and consistent basis that providers can use to publicisethe level of qualifications offered.8Communiqué for the MCTEE Meeting, 19 November 2010, p. 2.4 THE CASE TO REVIEW PROVIDER CATEGORIES IN HIGHER EDUCATION

PROVIDER CATEGORIES IN HIGHEREDUCATIONProvider Categories Proposed under TEQSAAccording to the April 2011 consultation draft of the TEQSA ProviderCategories, the former National Protocols will be replaced by thefollowing six Provider Categories:> > Australian University> > Australian University College> > Australian University of Specialisation> > Higher Education Provider> > Overseas University> > Overseas University of Specialisation.These latest categories still reflect the former National Protocols,however, the last category is new.Overview of Higher Education ProvidersThe range of HEPs has gradually evolved over time in line withperceived demand and commercial potential and with little by way of aplanned approach. The variation is wider than the provider categoriesabove would imply. HEPs can now be loosely grouped in terms of:University or non-UniversityBroad-based, General or SpecialistResearch intensive or not research intensivePublic or PrivateAustralian or International/OverseasRegistered Training Organisation(RTO) in the VET sectorornot an RTOBox 1 provides an indicative overview of how these groupingscurrently apply.TAFE DIRECTORS AUSTRALIA5

Box 1: An Overview of Australian Higher Education Providers(HEPs)BROAD-BASED/GENERALUNIVERSITYQUADRANT 1:UNIVERSITY/BROAD-BASED33% of all HEPs39 Australian universities(inc. 14 RTOs)> 37 public> 2 private3 other approved uses of‘University’> Open UniversitiesAustralia> Carnegie MellonUniversity> University CollegeLondon0 designated ‘AustralianUniversity College’OTHER (NON-UNIVERSITY) HEPQUADRANT 2:OTHER HEP/BROAD-BASED12% of all HEPs17 HEP providers (inc. 14 RTOs)> 9 TAFE institutes + TAFENSW> 2 large private providers> 4 attached to universitiese.g. Monash College,Deakin Prime> 1 indigenousSPECIALISTQUADRANT 3:UNIVERSITY/SPECIALIST0% of all HEPs0 designated ‘AustralianUniversity of Specialisation’0 designated ‘OverseasUniversity of Specialisation’The 39 universities in Quadrant 1have 95% of all HE provisionQUADRANT 4:OTHER HEP/SPECIALIST55% of all HEPs70 HEP providers (inc. 33 RTOs)> 67 private> 2 public (AFTRS, NIDA)> 1 TAFESpecialising in:> Theology – 17> Business/IT – 16> Creative Industries – 15> Health – 12> Hospitality – 6> Other – 4Quadrants 2 and 4 share 5% of allHE provisionSources:www.goingtouni.gov.au – DEEWR website ‘Going to Uni’ – Higher Educationfor Students in Australia – All Australian Providers.www.ntis.gov.au/ – National Training Information Service (NTIS) – All RTOs.Note that listings are not consistently compiled and may be understated,particularly in Quadrant 4. For example, some universities have separateregistration for their associated (predominantly international) colleges (as inQuadrant 2), while others do not.6 THE CASE TO REVIEW PROVIDER CATEGORIES IN HIGHER EDUCATION

CommentaryExamining Box 1, a number of observations can be made:> > The two most populated quadrants are 1 and 4, quadrant 1because of its dominance in provision (95% of student load) andquadrant 4 because of its dominance in provider numbers (55%of all HEPs).> > There are three examples of institutions other than the 39universities using the name ‘university’, one of which is aconsortium of Australian universities and the other two areoverseas universities operating in Australia.> > There are no examples of ‘Australian University College’,‘Australian University of Specialisation’ or the proposed newcategory of ‘Overseas University of Specialisation’.> > In all, five categories using the title ‘university’ are now proposedfor 42 HEPs, with only two of these categories populated inpractice, while the remaining 86+ HEPs are relegated to thenondescript category of ‘Higher Education Provider’.> > Fourteen of the 39 universities are also RTOs in the VET sector –three times more than would be accounted for by the dual sectoruniversities. In total, 48% of all HEPs are also RTOs.> > Apart from the universities and their associated (oftenpredominantly international) colleges, there are relatively fewbroad-based HEPs, with most of these being drawn from the 59TAFE institutes.> > The 70 non-university specialist HEPs (quadrant 4) are, relativelyspeaking, small, with 47% also being RTOs. Sixty-six of the 70are accounted for by five specialist areas, the dominant one ofwhich is Theology/Faith-based.> > With the overwhelming preponderance of providers in quadrant 4being in the private sector, there are no non-university specialistHEPs operating in the skill shortage areas such as building andconstruction, electrical/electronics or engineering/manufacturing.<strong>TDA</strong> members have extensive VET expertise in these as well asother areas.The proposed six categories of HEPs are unduly weightedtowards universities, maintaining or creating categories forinstitutions that do not even exist yet.No attention has been paid to clarifying the distinctionsbetween the remaining HEPs, for which there is still onlyone category. This ignores the fact that this category has thepotential to generate diversity and to contribute to nationalproductivity by addressing skill shortages.TAFE DIRECTORS AUSTRALIA7

study offered, not the level of qualifications or any other features.All categories involve offering Masters (Research) and Doctoraldegrees. This does not foreshadow a more diverse sector.> > The intent of the new Criterion 2 appears to be to create furtherbarriers to entry into the Australian university category and tocurb further diversity of organisational type by imposing a timeframeand quantum for self-accreditation, effectively preventingany further universities being established domestically for theforeseeable future. 9> > The potential for the ‘Australian University College’ category tobe used as a transition category to full university status has beenre-introduced 10 (in Criterion 2) but since this potential has existedand was not used in the past, the title may well continue toremain superfluous or redundant.> > The research requirement in all three categories is problematicfrom a number of points of view:> The recent report on Excellence in Research for Australia 11shows that the current research output varies widely acrossthe university sector with some universities having onlysmall pockets of research excellence.> It unnecessarily reinforces exclusivity in an increasinglydiverse tertiary education market.> It is not consistent with international practice.> It leads to already scarce research dollars being potentiallyspread even more thinly..The latest changes to the Provider Categories have donenothing to foster diversity in tertiary education.The intent has been to strengthen the exclusivity of thecategories where the title ‘university’ is used, even thoughthere are currently no providers in these categories and thereis only limited distinction between them.There is no provision for a teaching-only category of universityalthough, in practice, some universities appear to be moving inthis direction.9It is noted here that while the April 2011 consultation draft of the TEQSA ProviderStandards has changed the basis for self-accreditation from a course-by-coursebasis to a more holistic programmatic approach, thus loosening the requirementssomewhat, this does not change the restrictiveness of Criterion 2.10The previous Protocol D contained provisions that: ‘This title (University College)will be … reserved for use by new universities, which at point of establishment,need only undertake research and research training in one field. It may also be usedby provisionally approved ‘greenfield’ institutions based on a plan, which wouldnormally be mentored by an existing university’.11Excellence in Research for Australia 2010 – National Report, 2010, AustralianResearch Council, Australian Government, Canberra.TAFE DIRECTORS AUSTRALIA9

THE NEXT STEPSTo progress the issue of Provider Categories in the VET sector, <strong>TDA</strong>proposes that the following actions occur within the next 12 months:Higher EducationA working group be convened of the key stakeholders to recommendpossible revised provider category standards and nomenclature forTEQSA to consider once that body is established. The stakeholders toinclude, but not be limited to:> > TAFE Directors Australia (<strong>TDA</strong>)> > Universities Australia (UA)> > Council of Private Higher Education (COPHE)> > Australian Council for Private Education and Training (ACPET)> > Department of Employment, Education and Workplace Relations(DEEWR)> > A sample of representatives from the States and Territories.TertiaryA timeline be set for a tertiary working group consisting of thecombined Higher Education and VET stakeholders and the tworegulatory authorities to develop integrated provider categories,associated standards and nomenclature across the tertiary sector.TAFE DIRECTORS AUSTRALIA15

16 THE CASE TO REVIEW PROVIDER CATEGORIES IN HIGHER EDUCATION

Charles Darwin UniversityBatchelor Institute ofIndigenous Tertiary EducationTropical North Queensland TAFEKimberely TAFEBarrier Reef Institute of TAFEPilbara TAFECentral Queensland TAFESunshine Coast TAFESouthern Queensland Institute of TAFEMetropolitan South Institute of TAFEBrisbane North Institute of TAFEThe Bremer Institute of TAFESouthbank InstituteSkillsTech AustraliaGold Coast Institute of TAFEDurack Institute of TechnologyCurtin University of TechnologyTAFE NSW New England InstitutePolytechnic WestCentral Institute of TechnologyChallenger Institute of TechnologyWest Coast Institute of TrainingC.Y. O’Conner College of TAFESouth West Institute of TechnologyGreat Southern TAFETAFE SA – Adelaide NorthTAFE SA – Adelaide SouthTAFE SA – RegionalTAFE NSW North Coast InstituteTAFE NSW Western InstituteSunraysia Institute of TAFECanberra InstituteTAFE NSW Hunter Instituteof TechnologyTAFE NSW Riverina InstituteTAFE NSW Illawarra InstituteGoulburn Ovens Institute of TAFE Wodonga TAFEBendigo RegionalUniversity of BallaratInstitute of TAFEChisholm Instituteof TAFECentral Gippsland Institute of TAFESouth West TAFEEast Gippsland Institute of TAFEGordon Institute of TAFETAFE NSW Sydney InstituteTAFE NSW Northern Sydney InstituteTAFE NSW South Western Sydney InstituteTAFE NSW Western Sydney InstituteSwinburne TAFEVictoria University (TAFE Division)Kangan InstituteWilliam Angliss Institute of TAFEBox Hill InstituteHolmesglen Institute of TAFERMIT UniversityNorthern Melbourne Institute of TAFECentre for Adult EducationTasmanian Polytechnic