Accreditation and Accountability Beyond the comfort zone Shirley Stokes Manager, Quality and Regulation Higher Education Directorate NSW Department of Education & Training

Current Australian Context Universities (mostly public) Non self-accrediting higher education institutions Small number of self-accrediting institutions 39 Unis Approximately 130 NSAIs (Area of most involvement, + any new applications for university or self-accrediting status) 3 SAIs (none in NSW) My role is managing applications from institutions to become HEIs, including new universities) Accrediting courses of NSAIs.

Universities Established or recognised under state or territory legislation Established in perpetuity (existing) Funded by and accountable to Commonwealth & State/Territory governments Significant student contribution Self-governing Self-accrediting Audited by the Australian Universities Quality Agency Definition of university under National Protocols. My role not concerned with universities except for some responsibilities under the Commonwealth ESOS Act: interstate unis want approval to offer courses to overseas students in NSW monitoring compliance of all universities in NSW with the requirements of the ESOS Act, includes investigating complaints

Non Self-Accrediting Sector Approximately 130 institutions across Australia Small but growing niche of higher education students Sector has grown significantly in the last decade: In NSW seven years ago there were 29 non self-accrediting institutions delivering approximately 140 courses today there are 57 registered higher education institutions (including one overseas university) and 381 courses accredited by the Department. Types of institutions: theological colleges those meeting needs of specific professional or industry groups (e.g. institute of chartered accounts; advertising federation of Australia; college of law. those catering for niche markets (primarily for profit). Biggest growth has been in this sector (Business & commerce; creative & digital media; counselling; tourism and hospitality) Reference to morning discussion. Accreditation: Require a focus on scholarship and a commitment to academic integrity. Courses evidence of scholarship. Teaching quals and experience..

Accreditation (non self-accrediting sector) Institution must be approved by relevant State or Territory accrediting agency Each course must be accredited against Australian Qualifications Framework Requires separate approval in each State/Territory Approval for five years Separate approval to deliver courses to overseas students There are ‘mutual recognition’ agreements in place. Perhaps the least effective aspect of current accreditation. It frequently works as intended, but when it doesn’t its because a jurisdiction has different requirements or chooses to undertake excessive re-assessment of local delivery. Also need to work with professional accreditation bodies. Experience with NSWIT.

Accountability (non self-accrediting sector) Annual reports If approved for Commonwealth-funded student loans: reports also to the Commonwealth subject to an audit by the Australian Universities Quality Agency Must seek re-approval every five years Considering how to leverage the re-approval off the AUQA audit, esp if close in time.

Recent Developments Revised National Protocols National Guidelines Allows for more diverse types of higher education institutions Common criteria for all higher education institutions National Guidelines For the first time, common requirements and procedures for institutions applying for higher education approvals National Protocols Self-accrediting authority for institutions with a good track record University College with 5 years to build to full university status. Specialised universities. Overseas institutions able to offer overseas awards. Protocols nationally agreed, but required changes to State legislation. National Guidelines Commenced implementation. Outcome of considerable national collaboration and agreement. For NAIs, also nationally produced application forms,

Strengths of Current System A Quality Assurance Framework comprising: Accreditation arrangements (National Protocols and Guidelines allow common and agreed criteria, requirements and processes across Australia) Australian Qualifications Framework (Describes the characteristics of each qualification. Includes a public register of approved institutions and courses) Australian Universities Qualities Agency (Audits institutions. Current cycle will more explicitly address performance, standards and outcomes)

Issues Concern at the amount of regulation and ‘red tape’ imposed on institutions Legislative responsibility shared between Commonwealth and state and territory governments and among states in some cases creates complexity, inconsistency and duplication and replication Results in regulatory incoherence Regulatory arrangements across the whole sector are complex. Gradual accretion over time, esp the last decade Institutions increasingly seek to operate across state boundaries, in more than one education sector (VET) and a growing number want to operate offshore. The current arrangements comprise: nine state, territory and Commonwealth agencies are registering institutions and accrediting courses a separate regulatory system for overseas students studying in Australia also administered by nine agencies different arrangements relating to offshore approvals, all involving nine agencies a separate regulatory system for non self-accrediting institutions accessing FEE‑HELP student loan system various professional registration requirements that individual courses may also need to satisfy.

Issues (Cont.) Inadequacies of the Australian Qualifications Framework Provides insufficient guidance to institutions and accrediting agencies Often ignored by Universities Challenges for panels and institutions: If AQF does not provide guidance, panel look to what happens in the university sector for guidance on standards; often the variation is large.

Issues (Cont.) Adequacy of the quality audit regime to provide assurance about standards? Too early to assess the efficacy of the Australian Universities Quality Agency second cycle of audits Query about one size fits all approach. No allowance for a risk-based approach where particular institutions or operations within institutions can be targeted, if required, more immediately than is possible within the current cyclical audit program

Issues (Cont.) Accountability discourse is chiefly about reporting to regulators Less attention on reporting to consumers (students, parents, public) Personal viewpoint. Focus on NSAIs How to choose between institutions. All we can say is that an institution is registered, a course has met accreditation requirements. Once accredited they are all on the same page. Consumer protection however is strong in terms of how institutions advertise, contract with students and they must have sound grievance procedures. Require institutions to survey their students. Accountability is through the market.

Challenges The underlying framework is in place Accreditation (Protocols & Guidelines) Australian Qualifications Framework Audit program But requires strengthening and more rational implementation Look to what the Bradley review might recommend.

Challenges Rationalise and streamline the regulatory system to make it more efficient and transparent (reduce ‘red tape’ without sacrificing quality) Establish environment and expectations for institutions to better ensure quality (less dependent on the regulator) Sometimes concerned that institutions rely too much on the regulators for quality. Some regulators may encourage this dependency. Comfort when the accreditation process verifies the quality of an institution. Too often, the accreditation process is used to assist an institution to reach the required standard. Need to think more laterally about how our processes may foster the former. Education? More collegial development work within the sector, with peers.

Thank you! Shirley Stokes shirley.stokes@det.nsw.edu.au