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Education and Employment Legislation Committee
Tertiary Education Quality and Standards Agency

Tertiary Education Quality and Standards Agency


ACTING CHAIR: Welcome Professor Saunders. I believe congratulations are in order for your appointment. Welcome. Would you like to make an opening statement before we go to questions?

Prof. Saunders : No, I have no opening statement to make.

Senator KIM CARR: I take it you have had an opportunity to read the Teacher Education Ministerial Advisory Group report, Action Now, dated December 2014.

Prof. Saunders : I read a summary of that and the government's response.

Senator KIM CARR: I understand you have also been charged with re-accrediting the 400 courses across 48 separate institutions within two years. Is that your understanding?

Prof. Saunders : No, my understanding is that I am to cooperate with the Australian Institute for Teaching and School Leadership and that we are yet to sit down and work through how that cooperation between—

Mr Cook : The state accreditation body is actually—

Senator KIM CARR: The courses themselves, what will you actually have to do?

Prof. Saunders : There are 15 providers on our register, remembering that most teacher education goes on in the universities and TEQSA does not accredit university courses. They are self-accrediting institutions. There are 15 providers on our register that provide 53 courses that relate to teacher education. They are from providers that are some faith based colleges, some TAFEs or ex-TAFEs and a smattering of other providers, like Montessori. Our job will be to—

Senator KIM CARR: You are really doing the 15 non-university trainers of teachers. Is that what you are saying?

Prof. Saunders : That is the routine at the moment. We do not accredit university programs. What we do though, when we come to re-register universities, is we have the opportunity and take the opportunity to look at some of the courses they are offering. We generally look at those courses from the point of view of academic governance and quality assurance rather than the content of the courses. But in the course of us re-registering universities, there will be a chance—if it is deemed appropriate, and we will obviously consult on this—for TEQSA to have a role in looking at teacher education, specifically.

Senator KIM CARR: What is the additional cost involved in this extra work you have been asked to undertake?

Prof. Saunders : I do not believe we have been asked to do any extra work, at the moment, so I cannot give you an answer to that.

Senator KIM CARR: You normally would be reviewing these particular institutions, would you?

Prof. Saunders : Yes. For re-registration of universities, as I have said, it is our routine to look at about five courses from the perspective of academic governance. And, as I say, we negotiate with the universities which courses we would look at. It is quite feasible that, over the next year or two, one of those courses that we would look at within each of the universities would be their teacher education programs.

Senator KIM CARR: Only five courses?

Prof. Saunders : We only look at five courses in universities, by and large, yes. It is a small aspect of our re-registration activities.

Ms Paul : The government's response said that the government asks this and that of AITSL, and:

Additionally, a closer working relationship between AITSL and the Tertiary Education Quality and Standards Agency (TEQSA) will be established to make sure the two complement each other and together address any courses identified as a concern.

So it is a quality perspective. But AITSL has the key role, as we spoke about with them, in their accreditation and reaccreditation. You will recall that Ms Evans said that, arising from the TEMAG review, she expected to be required to accelerate the reaccreditation or the reassessment.

Senator KIM CARR: Professor, there is a reference in the report that goes to the issue of entry standards. Is that a matter that TEQSA would look at?

Prof. Saunders : With all our providers we are interested in looking at admission criteria, and entry standards is one of those criteria that we would look at.

Senator KIM CARR: Does TEQSA have a view on the question of academic entry requirements?

Prof. Saunders : As you know, we re-accredit courses and we re-register or register providers on the basis of looking at their performance or their plans against the Higher Education Standards Framework, and there are standards that relate to admission. What those standards require are for the admission standards of the particular institution or the particular course to be quite clear and unambiguous, and we need to see that the institution is paying regard to its own policies in that regard, but as well as that there is a review of how the students are proceeding in the course and then there is action taken depending upon the findings of that monitoring.

Senator KIM CARR: So would you look at noncompletion rates?

Prof. Saunders : Part of our annual information gathering is to look at completion rates, progression rates, attrition rates—those sorts of things.

Senator KIM CARR: Is that on the basis of what the universities tell you, or do you have any independent—

Prof. Saunders : We use the information from universities from the HEIMs data collection, which is what they submit to the department.

Senator KIM CARR: The report here tells us:

… the total proportion of students admitted to teacher education programs on the basis of an ATAR of 60 or less remains low across the board, at approximately seven per cent for regional universities in 2013 and about six per cent for all universities.

I would have thought that is quite a significant number, but the question I put to you is: do you have any insight into what a 60 ATAR actually looks like? For instance, are you aware of any bonus schemes that operate by universities or other providers that build upon a raw ATAR so that it gets up to 60?

Prof. Saunders : I am not sure that this is actually relevant to TEQSA's role in the functions that we play in quality assurance of the higher education sector. My answer, if you want me to answer, would be based really on an opinion from my prior experience rather than speaking as an official from TEQSA.

Senator KIM CARR: I will not press you on this, but in your experience how does it work?

Prof. Saunders : It works by students getting entry via a variety of pathways, some of which indeed do not involve an ATAR at all, some of which involve a raw ATAR, some of which involve entering into pathway programs run by the institution, some of which have bonus points added to them for disadvantaged background, geography—there are a whole range of reasons why bonus points might be added.

Senator KIM CARR: My interest goes to how the bonus scheme works. It is not apparent from this report how it works.

Ms Paul : That is I think the purpose of recommendation 11 that we spoke about before from TEMAG, to have universities make all that transparent.

Senator KIM CARR: I understand what the report says. Professor Saunders is particularly experienced in universities. I am wondering if he could provide any advice on what his experience tells us about how the bonus scheme works when it comes to the establishment of an ATAR? I think there is a substantial difference between an ATAR of 60 and a raw ATAR, which may be considerably less than 60.

Prof. Saunders : What you are talking about there is what some universities might call an adjusted ATAR, some would call it their entry score rather than the ATAR itself. Most universities are transparent about that in terms of making it quite explicit as to what they offer points for and how many points are offered. But it is a bit of a mystery for many people, I think, trying to unbundle this from the point of view of what is published in the UAC guides, for example, those sorts of things, which often do not take into account the bonus point scheme. It is a confusing and somewhat opaque thing for—

Senator KIM CARR: I would agree entirely with your assessment. But where would I find an assessment of the bonus schemes that operate? You said some institutions are transparent about it. Where do I find advice on those that are transparent about it?

Prof. Saunders : I think you would find them on the university websites under information for students. We should make the point that bonus schemes are not just applied to teacher education programs, as you know; they are for every course in the country.

Senator KIM CARR: Absolutely. I have just seen the cut-offs and the university admission schemes for main rounds 2014. Just glancing through this, I see a number of institutions have an entry ATAR of 60. That is not a raw 60; it is actually an adjusted 60—is it not?

Prof. Saunders : I do not know the document that you are referring to.

Senator KIM CARR: It is the Universities Admission Centre's cut-off for main round offers, which is published twice a year, I think. It lists the entry scores for just about every course that is operating. If I take the Catholic University, as an example since it has been given some interest in the press this morning, the teaching program there for the first list here of about nine teaching courses have ATAR entries of 60. That is not a raw entry score, is it, as a rule?

Prof. Saunders : I do not know what the Australian Catholic University do about bonus points or indeed their entries into the UAC. If they are cut-off scores run by UAC, they will include bonus points.

Senator KIM CARR: That is my point.

Prof. Saunders : What we are concerned about at TEQSA is that regardless of the admission processes that a provider has, be it public or private, university or non-university, is that they have adequate support for their students, they monitor what is happening and they make sure that there is a continuous cycle of improvement with regard to the success of their students. We are interested in student outcomes here, the welfare of the students and the quality of their experience.

Senator KIM CARR: Is it true that you are finishing up your acting CEO role this week?

Prof. Saunders : Friday—I am still acting.

Senator KIM CARR: I see. Then you will be replaced with an interim appointment—is that right?

Prof. Saunders : I am staying on as a part-time chief commissioner, so I am staying on in the role as chief commissioner but there will be an interim CEO appointed—

Senator KIM CARR: That is Mr Ben Johnson, is it?

Prof. Saunders : That is correct.

Senator KIM CARR: He is formerly branch head of the VET FEE-HELP? Is that the same fellow?

Prof. Saunders : My colleagues in the department—

Mr Griew : He is not just formerly; he is substantively VET. He is going to temporarily fill the position as interim CEO while—

Senator KIM CARR: So he would have some experience about how the VET system operates?

Mr Griew : He is extremely knowledgeable about the whole tertiary education system.

Ms Paul : He has worked in the tertiary education area for a long time.

Mr Griew : And he has also been responsible for a significant period of time for the liaison with TEQSA.

Senator KIM CARR: What is the plan to appoint a permanent CEO? Can you help me on that score?

Prof. Saunders : That process is underway. There is a search firm that has been engaged, and there are applications that have been received. That process will roll out in the next month or two.

Senator KIM CARR: Is it intended to fill the position by June?

Prof. Saunders : It would be my hope that it would be filled by June.

Senator KIM CARR: But there is no formal time line for that?

Ms Paul : It is a process run by us, and it is the department that commissions the search firm et cetera. Of course, we want to try to fill the position substantively, permanently, as soon as we can.

Senator KIM CARR: But you are not expecting to complete it by June?

Ms Paul : I would hope we would, yes, absolutely. We are already out in the market.

Senator KIM CARR: Has an advertisement been placed?

Ms Paul : Yes.

Senator KIM CARR: Whereabouts are you in the appointment process then?

Mr Griew : We have had a report from the search firm. We have a selection panel ready to go. We are looking at potential candidates and moving towards short-listing.

Senator KIM CARR: That is an appointment by government, is it not?

Ms Paul : Yes.

Mr Griew : That is right.

Senator KIM CARR: So it will be a cabinet appointment?

Ms Paul : I think it is a ministerial appointment.

Mr Griew : We will take that on notice.

Senator KIM CARR: Surely that goes to cabinet?

Ms Paul : I will check that; it could well.

Senator KIM CARR: Thank you, if you could. Can you confirm that the funding cut for TEQSA in the current year has been $3.428 million?

Mr Griew : The appropriation in 2013-14 was $18.5 million. It is $15.5 million this year, so it is $3 million during this financial year, and then it is planned to go down by another $4 million in 2015-16.

Senator KIM CARR: And the staff numbers—we have discussed this on previous occasions. How are we going with the staff numbers?

Prof. Saunders : Fifty-six at the moment.

Senator KIM CARR: How many is that down?

Prof. Saunders : That is down 10 from the last time I reported to Senate estimates. What I have been doing in the meantime is filling those positions with contract staff, not permanent staff, simply because of the budget changes that will be happening in July this year.

Senator KIM CARR: What savings measures have you been able to identify to manage the efficiency dividend?

Prof. Saunders : You mean the changes in our budget?

Senator KIM CARR: Yes.

Prof. Saunders : I think I spoke about that last time. We have done our utmost to try and reduce non-salary costs, and we have done a good job there. We have been able to outsource some of our processes, backroom office corporate functions, to the Productivity Commission, who share the same building as us. We have shrunk in size, we have got space to sublet and we are in discussions with a range of organisations to help us sublease some of our space, which will help us with our accommodation costs. But the reality is that, in an organisation like ours, which service organisations heavily dependent upon staff, it is inevitable that there will be staff reductions, and that has been happening over the last couple of years.

Ms Paul : You will recall this is caused by a narrower focusing of TEQSA on what is regarded as its core business, particularly arising from the former reviews of TEQSA and then the subsequent legislation.

Senator KIM CARR: Let me be clear about this. To what extent has the reduction been a result of the efficiency dividend and to what extent has it been a result of a reduction in function?

Prof. Saunders : There is no way that the agency could have achieved what it is achieving—we are very busy, the staff are working very hard, but we are keeping up to date with the workload as it comes in—without us actually having changed our processes. We have streamlined our processes quite significantly, and we will continue to streamline our processes going into the next financial year.

Ms Paul : The reduction was due to the refocus—for example, moving away from the theme reviews—not due to any sort of random efficiency—

Senator KIM CARR: So the agency does not need any more money. Is that what you are saying?

Ms Paul : No. That would be an opinion.

Senator KIM CARR: Professor, would you see it that way?

Ms Paul : I am sure everyone would always like more money, but the fact is that the reduction was due to the moving away from some activities which arose from the Braithwaite-Kwong Lee Dow review.

Senator KIM CARR: I understand that. Professor, you do not need any more money?

Prof. Saunders : Everyone needs more money. I think that at the moment, as I said, we are very busy and the staff are working hard, but we are keeping our head above water. With the levels of staff that we have at the moment, I think we will manage next financial year, but it will be difficult and I cannot guarantee that we will be as timely as we are at the moment. But we are managing.

Senator KIM CARR: What other effects will you have apart from timing?

Prof. Saunders : I think that is about it. I think that you can be assured that what we do will be done at very high quality and that we will certainly have a focus on the moderate- and high-risk providers, people that our annual risk assessment identifies as possibly being at risk of not complying with the higher education standards. So I think the work that we do will be as good a quality as ever has been done, but we will have to be more focused about that—so reducing the scope of the assessment and reducing the evidence requirements in support of examining those standards. But at the moment I can assure you that very high-quality work is continuing to be done. We have reduced very, very significantly the scope of re-registration, for example.

Senator KIM CARR: At what point do you say that reductions in your budget affect the ability to actually fulfil your functions?

Prof. Saunders : I do not think our quality is impaired at the moment. As I said, it has reduced the scope and the scale of the assessments that we are doing, but I think those providers that one might have concerns about are having due attention paid to them.

Senator KIM CARR: The 10 reductions that you mentioned—was that more than you anticipated?

Prof. Saunders : No. In fact, it is what needed to occur for us to manage our budget this year and going into next year. Actually 20 people have left the agency. Four commissioners have left the agency. We had a couple of short-term projects being done, and those contracts were not renewed. And we have had about 19 people leave the agency, about half those on voluntary redundancies as part of the corporate rationalisation, and the other people have left because they have found work in other places.

Senator KIM CARR: In the regulation and review area, how many staff have you lost?

Prof. Saunders : I will have to take that on notice because I can only tell you about the last six months. They are operating at the moment with 25 people plus eight contractors, so a total of 36 people. That is the level of budget that they were allocated in the 2014-15 financial year.

Senator KIM CARR: But there is a question here of whether it is function fitting budget or budget fitting function. Is this not a core area for the agency?

Prof. Saunders : It is.

Senator KIM CARR: So have you reduced the budget to accommodate the fact that you have 28 people or do you need a further amount of money to actually fulfil the functions in regard to regulation and review?

Prof. Saunders : This year we can afford to backfill some of those positions with contractors. As I said, we have 33 people working there at the moment, but going into next year obviously we have to find savings—our budget is going down $4 million—so the numbers will go down at that stage. At the moment, though, as I said, good quality work is being done.

Senator KIM CARR: Are you preparing a draft of a new structure document?

Prof. Saunders : Yes, and I am meeting with the staff tomorrow to present that to them tomorrow afternoon.

Senator KIM CARR: It is in a completed form, then?

Prof. Saunders : Well, it is a consultation paper, so it is there for the staff to read and respond to. It has been seen by and amended by the senior management team in TEQSA. It has also been seen by the commission. So what is going out has high level endorsement but consultation needs to be genuine, as you know, Senator, and therefore if people come back—

Senator KIM CARR: I think that is a reasonable approach if you are going to have this. But you would not be presenting it as a fait accompli, would you?

Prof. Saunders : No, absolutely not.

Senator KIM CARR: That is good to hear. When do you expect this matter to be concluded?

Prof. Saunders : There is a month's consultation period. That is part of the process. So we will be having meetings with individual staff and groups of staff over the next couple of weeks and then a decision will be taken based upon the feedback and consultation as to whether the plan needs to be amended and then the final plan will be put to the staff. I think the date for putting the final plan to the staff is 13 April.

Senator KIM CARR: I am hearing this term 'streamlining' in regard to the R&R area. What does that mean?

Prof. Saunders : It is really shorthand for describing what I was saying to you before. When TEQSA first began its operations, for example for reregistration it would have taken the provider registration standards—and there are about 40-plus of those standards—and examined each and every one of those against the applicant. About 12 months ago, there was a revision of that approach and now we use a core set of seven standards. So there is a very substantial reduction in the number of standards, but those standards, one would anticipate, go to the heart of appropriate academic governance, academic standards and student outcomes in an institution. What we have been doing is, by and large, unless there is a reason not to apply the reduced number of standards—what we call the core standards—then that is what a provider has to respond to. So the burden on them is less, the evidence that they are required to produce is less, the amount of work that we are required to do is less. At the moment, that has worked very effectively and it has worked effectively with private providers; we have done it for the first time with a public university and we were able to do the registration of that public university within three months. So it was a very efficient process. We are confident that the standards are being represented in such an appropriate way that we could be confident of the outcome. If the risk assessment that we do each year was to flag concerns that sit outside those core standards, we would include other standards in the assessment.

Senator KIM CARR: So you have dropped your core standards from 40 to seven. What are the 33 standards you have left out?

Prof. Saunders : I would have to go to my trusty Higher Education Standards Framework booklet and take you through it page by page, if you like. The other way around it would be to tell you that the core standards that we have applied, the seven that we apply—

Senator KIM CARR: The problem I have with this is that it all goes really well until you get a dodgy college that blows up in your face. Is this a tick-and-flick operation?

Prof. Saunders : No, it is not a tick and flick operation. As I say, we collect information about every provider every year. So we have information about those providers—about how long they have been operating, what their completion rates are like, what their attrition rates are like, what their staff-student ratios are, how many academic leaders they appear to have per field of education, what their financial viability and sustainability is and what their student perceptions in terms of student surveys say. We have got a very good basis upon which to look at annual performance by providers.

Ms Paul : You will remember this came out of the Kwong Lee Dow-Val Braithwaite review, towards a misplaced and proportionate approach.

Senator KIM CARR: I know that. I know where it has come from.

Senator Birmingham: A review commissioned by the previous government.

Senator KIM CARR: Oh no; in fact, I released it. Let me be clear about this. I released it because they would not.

CHAIR: Senator Carr, we might just go to Senator Rhiannon, who has been waiting patiently for 25 minutes.

Senator KIM CARR: Before Professor Saunders thinks he has got away with this matter, I would like to know the substance of the 33 areas that you are no longer surveying.

Prof. Saunders : I will take it on notice and I am happy to tell you what standards are included and what ones are not.

Senator RHIANNON: Thank you, Professor Saunders. I noted you said that the staff numbers are currently 56, down 10. What were the staff numbers when TEQSA started?

Prof. Saunders : We had a staff level of about 100—not when we started, but we built up to staff level of about 100.

Senator RHIANNON: In what year, please?

Prof. Saunders : We started in 2012, so it would have been sometime during 2012 that those numbers built up.

Senator RHIANNON: So it was in the year that TEQSA started?

Prof. Saunders : Yes, when TEQSA started. I think that would have included—I would have to go back and check—the five commissioners and other sorts of staff that were brought on in the start-up phase.

Senator RHIANNON: So about 100 full-time positions?

Prof. Saunders : About 100 full-time positions.

Senator RHIANNON: So we are now down to 56?

Prof. Saunders : No. I have not counted in my 56 the commissioners, the public office holders, people on leave without pay, people who are on maternity leave. Those 56 staff are people on the ground, working in the agency at the moment.

Senator RHIANNON: Could you give us comparable figures, even if you have to take it on notice, of what it was initially, what you built up to and then maybe on a yearly basis—it is not that many years—to see what the changes are, for full-time positions?

Prof. Saunders : Sure, I would be happy to take that on notice.

Senator RHIANNON: Thank you very much. Could you also explain to me the relationship between core and threshold standards?

Prof. Saunders : The threshold standards are the standards that make up the framework, and there are close on 100 standards. They were promulgated in 2011 and are still the standards today. They cover provider registration, course accreditation, provider categories—whether a university or a non-university, those sorts of things—and the qualification standards, which relate to the Australian Qualifications Framework. They are the threshold standards. The core standards are what I was talking to Senator Carr about—

Senator RHIANNON: They are the ones that have gone from 40 to seven?

Prof. Saunders : The provider registration standards, which we have reduced down to a core set of seven standards.

Senator RHIANNON: Sorry, I thought you just said provider registration was in the threshold standards?

Prof. Saunders : Yes, they are.

Senator RHIANNON: And they are also in the core standards?

Prof. Saunders : Yes, some of them are in the core standards.

Senator RHIANNON: What is the difference? Can you explain why that is the case, please?

Prof. Saunders : So, for example, in the provider registration standards we have 42 threshold standards in the provider registration standards, and seven of those 42 have been chosen to be the core. That is what we apply to all low-risk providers unless there is something in their prior history or in their risk assessment that suggests we should have a broader examination.

Ms Paul : And this is what comes out of the review, which is not letting poorer providers off the hook, but taking a risk managed approach.

Prof. Saunders : Yes, exactly.

Mr Griew : So it is not just the core.

Ms Paul : So you are not abandoning all these other standards.

Prof. Saunders : No, absolutely not. What we are saying is that, if you are low-risk provider and we do not have any flags against you, then we believe—in fact we know—that those seven standards will give us a fair and accurate assessment of the quality and will give us confidence then that you would complying with all the other provider registration requirements.

Senator RHIANNON: So, if you are confident in this provider, do you always look at the seven that come under the core standards, but you would not look at the 35 provider standards that come under threshold? Is that correct?

Prof. Saunders : We would routinely, or can?

Senator RHIANNON: You would not. I thought you were saying that if you have got a provider and you are confident in them and you have not had any trouble, you have seven standards that you would look at, but there are 35 that make up the 42 that would not look at?

Prof. Saunders : Would not? That is correct.

Senator RHIANNON: Thank you. What else comes under core standards, please?

Ms Paul : I think the phrase that was used arising from the review was 'risk based and proportionate', wasn't it?

Prof. Saunders : Yes.

Ms Paul : So you might look at all 42 for a provider that was not rated risk-free, but rather rated as higher risk.

Prof. Saunders : That is correct. Indeed, for initial registrations—this is for a new provider we have no experience with; they are coming in to seek registration—we apply all 42 standards to the assessment of that provider. We are just talking here about reregistration.

Senator RHIANNON: Right. Can we get back to core standards. We have provider registration. We have seven for that. What are the other ones please?

Prof. Saunders : That is all the core we use at the moment.

Senator RHIANNON: That is the only core!

Prof. Saunders : We are only using the core for reregistrations at the moment. We have a process in place, which we are taking out to consultation next month, about course accreditation and reaccreditation. And there we are going to be taking a similar approach whereby we will take the provider course accreditation standards, of the threshold standards, and we will use a core of those—roughly one third of those standards—when we look at individual courses for accreditation or reaccreditation.

Senator RHIANNON: With regard to staffing standards, we do not have any staffing standards under core standards. Is that—

Prof. Saunders : No. Staffing standards are under 3.8.

CHAIR: It is in a public document—available.

Prof. Saunders : It is in a public document and we do have staffing considerations in that.

Senator RHIANNON: In the core standards?

Prof. Saunders : Yes.

Senator RHIANNON: So that is within the provider registration—those seven. And part of that covers staffing standards?

Prof. Saunders : Yes.

CHAIR: Any further questions?

Senator RHIANNON: Yes; sorry. In the threshold standards section relating to ensuring teaching and learning of a high quality, the term 'equivalent professional experience' is used.

Prof. Saunders : Yes.

Senator RHIANNON: You would know that term because it is used a number of times. I picked that up in 4.2 in chapter 3. How is equivalent professional or research experience determined?

Prof. Saunders : That comes from the Australian Qualifications Framework, which requires a provider to have teachers who are qualified one level above the course that they are teaching. If they are teaching a bachelor's qualification they need to have a master's qualification to teach it, or professional experience that is equivalent to achieving what you would expect from a master's graduate. There are no hard and fast definitions about what that professional experience must be. The agency requires, first of all, to see that the provider has a policy in place and that the policy looks to be reasonable. It would require somebody to be performing in the workplace at a level that would give you confidence that they have outcomes and experience equivalent to a relevant graduate certificate or graduate diploma qualification. That experience might include prior teaching experience.

We require the provider then to demonstrate not only that they have a policy that looks reasonable but that they also have evidence that they apply the policy. For example, when we seek information about staff we require abbreviated CVs or some document that shows the person and their qualification, and, if they are claiming professional equivalence, what that professional experience is and the level of the courses they are teaching.

Senator RHIANNON: Is that something that would vary from provider to provider?

Prof. Saunders : There would be variation from provider to provider.

Senator RHIANNON: Are you saying that what constitutes equivalent professional experience at one university is difference to another?

Prof. Saunders : It may well be, in minor shades; yes.

Senator RHIANNON: But how does that constitute a threshold standard, with that variation? You have a variation between institutions. How does it constitute a threshold standard? 'Threshold', in people's minds, is that you have a threshold, and that is where you work it out from.

Prof. Saunders : I think one has to accept, though, that policies across higher education providers vary. The minimum expectation is about five years equivalent experience in work for a masters qualification.

Senator RHIANNON: I suppose I am still trying to understand how that would vary, considering you are saying we have these threshold standards. It seems as though the argument falls down when you get to that point.

Prof. Saunders : Some would say three years professional experience and seeking a qualification at that level. So if you are enrolled in a masters or a doctorate degree and you have three years professional experience that would be considered acceptable to teach a bachelors course. Don't forget that, for example, quite a lot of tutoring and that sort of thing in universities goes on by PhD students, so there is some flexibility, and that will vary from institution to institution.

Senator RHIANNON: I totally understand that range within institutions, but we have the variation in standards between institutions.

Prof. Saunders : I do not think they are variations in standards. We are talking about the equivalence of a variety of different experiences.

Senator RHIANNON: Okay, I will have a think about that one. Are these standards meant to apply to all staff, including those employed on a casual basis?

Prof. Saunders : Yes, they are. But one has to be realistic—for example, students studying in professional courses, say, in the health sciences, will often be tutored in the clinical experience by tutors who do not have postgraduate qualifications but have lots of professional experience.

Senator RHIANNON: In an earlier comment I think you were talking about 'risk based and proportionate', that they came out of the review.

Prof. Saunders : No, 'risk based and proportionate' is in our legislation.

Senator RHIANNON: Yes, it is. I thought so. Going back to the numbers: you spoke about how it has reduced the 'scope and scale'—that was the term that you used when you spoke earlier. Is that correct?

Prof. Saunders : Yes.

Senator RHIANNON: Obviously, when you hear about the reduction in numbers that illustrates that. Therefore, reduced scope and scale, less work is being done, but you are saying that it is concentrating on certain areas. Ms Paul, you said that it is a refocus of the work—that was the word you used?

Ms Paul : It may have been. What I was talking about was the fact that the—

Senator RHIANNON: It was.

Ms Paul : Yep, that is probably true. The work that TEQSA now undertakes arises from the former government's review into TEQSA undertaken by Val Braithwaite and Kwong Lee Dow, which had many recommendations which this government accepted, including a move to the risk based and proportionate approach. What I was talking about when I used the word refocus was—I think I said narrower focus—to a narrower focus on its core business and, for example, moving away from doing their thematic reviews which they had been doing before. Some activities ceased—we have moved away from them—but of course Professor Saunders can talk about this more than I. The remaining activities were recommended by the review to be done in a more risk based approach, which is what Professor Saunders has been describing: some providers might have only seven standards supply; some might have all 42 in that particular area.

Senator RHIANNON: My question was specifically about that word refocus that you used. Clearly, refocus means that you are going back to a focus one had before. With everything I have heard, even your answer then, you seem to be trying to move away from the word refocus, so I ask you: will you withdraw the word refocus so we are not misled? The professor's description, as it has been before, is that it is about reducing the scope and scale. That is not refocusing.

Ms Paul : Okay, I am happy to withdraw if you think it is confusing.

Senator RHIANNON: It is not what I think; if you are to be accurate, surely that is not the word that is consistent with what has happened and what the professor has just described.

Ms Paul : Well, I have withdrawn it.

Senator RHIANNON: Thank you.

Senator KIM CARR: Could I turn to the question of homeopathy—one of my favourite topics, as you know, Professor. I would like to deal with a specific case. I understand that Dr Ken Harvey has sought by FOI matters relating to the reaccreditation report for homeopathy offered by ParaPharm in Western Australia. Do you have any detail of that matter?

Prof. Saunders : I have some detail of that matter, yes.

Senator KIM CARR: As I understand it, there are two degree courses offered in homeopathy, one in Western Australia by ParaPharm, and there is one on the east coast as well, is there?

Prof. Saunders : By the Australian College of Natural Medicine, yes.

Senator KIM CARR: Is it the case that the NHMRC has released a finding of the committee reviewing homeopathy which has found that there is no good evidence to actually support the discipline?

Prof. Saunders : That is correct.

Senator KIM CARR: Do take any note of that?

Prof. Saunders : Absolutely, I take note of that. It was conducted by somebody I have a great deal of respect for.

Senator KIM CARR: Who is that? Can you refresh my memory.

Prof. Saunders : Paul Glasziou, from Bond University.

Senator KIM CARR: There was no trick question there.

Prof. Saunders : It was a very thorough examination of the evidence at hand.

Senator KIM CARR: There was also a committee chaired by the Chief Medical Officer. Is that the case?

Prof. Saunders : I think that relates to something else. I think it relates to the funding of these.

Senator KIM CARR: The Review of the Australian Government Rebate on Private Health Insurance for Natural Therapies.

Prof. Saunders : Yes, that is correct.

Senator KIM CARR: Not an unrelated topic, I would have thought. I understand that the report of the committee chairman has been with the government for some while. Are you aware of that.

Prof. Saunders : No, I am not aware of the delays or whether there have been delays.

Senator KIM CARR: I understand the two homeopathy programs that I have referred to were in fact accredited by state authorities originally. Is that the case?

Prof. Saunders : Originally; that is correct, yes.

Senator KIM CARR: They are now up for reaccreditation with your agency. Is that correct?

Prof. Saunders : Yes.

Senator KIM CARR: In fact, the Western Australian course was up for reaccreditation at the end of last year—

Prof. Saunders : Yes.

Senator KIM CARR: and I understand the Sydney course—the Endeavour college course—comes up for reaccreditation in a couple of months time.

Prof. Saunders : Yes.

Senator KIM CARR: What is the process you will be using to reaccredit this particular program?

Prof. Saunders : It is the process that we would use for all course accreditations. It is a mixture of our own assessment as well as sending the courses to external experts.

Senator KIM CARR: How many external experts?

Prof. Saunders : It would depend, but in general terms we would send a course to two experts. If there is a suite of courses we might actually send it to more experts than that. Sometimes we do not use experts at all.

Senator KIM CARR: If you do not use experts at all, who does the assessment?

Prof. Saunders : We sometimes have internal expertise, the background of people within TEQSA; sometimes we are assessing the fifth course in a single field of, say, a business field and we have confidence in what the external experts have said previously.

Senator KIM CARR: Am I correct in saying that while a course is under the process of reaccreditation it is entitled to continue?

Prof. Saunders : That is correct.

Senator KIM CARR: Have you made a decision in regard to the Western Australian course?

Prof. Saunders : No, we haven't. We are in the process of making that decision, and it would not really be appropriate for me to say much more.

Senator KIM CARR: No, but you have not made it.

Prof. Saunders : We have not made a decision on that.

Senator KIM CARR: And the provider can continue while that process is underway.

Prof. Saunders : That is correct.

Senator KIM CARR: The second course—I have a date here of 2 April 2015 for reaccreditation—have you commenced the process for that?

Prof. Saunders : I would have to take that question on notice. The submission usually has to be made six months prior to the expiry of the date, so yes we would have at least received that.

Senator KIM CARR: So it is a reasonable expectation that that has commenced as well. Are there any courses in alternative therapies that you are examining at the moment?

Prof. Saunders : At the moment, we have courses from Study Group Australia. To my knowledge, that is the only other application coming from providers we have not already mentioned.

Senator KIM CARR: How many students are involved in Study Group?

Prof. Saunders : I would have to take that question on notice.

Senator KIM CARR: That is based where—in Melbourne?

Prof. Saunders : I would have to take that question on notice. I think Study Group has multiple campuses, but I will have to take that on notice.

Mr Griew : You may be interested that there are also nine complementary medicine degrees at universities.

Senator KIM CARR: Yes, there are some issues there too, I am sure. When will you get to look at those?

Prof. Saunders : If it is relevant, we will look at those at the time of reregistration.

Senator KIM CARR: Dr Ken Harvey has sought advice from you in regard to the re-accreditation report. Is that correct?

Prof. Saunders : The re-accreditation of?

Senator KIM CARR: ParaPharm in Western Australia.

Prof. Saunders : That is correct.

Senator KIM CARR: Did the document provided back to Dr Harvey under FOI include the name of the external reviewer—who, I am told, is a naturopath—used by TEQSA?

Prof. Saunders : The response to Dr Harvey had to be considered in the context that this was an application that was still under assessment. There had to be processes that were fair to the provider. There were also commercial-in-confidence considerations in that what we were considering was the intellectual property of the provider, and there were a range of other matters that had to be taken into account. So the material released to Dr Harvey was very limited.

Senator KIM CARR: How long would you sit on a report of this type?

Prof. Saunders : We do not sit on reports.

Senator KIM CARR: When was the report finalised?

Prof. Saunders : We have not finalised the report for this particular provider. As I said, this is a process that is ongoing. It would not be appropriate for me to talk about any particular stages.

Senator KIM CARR: But you did provide Dr Harvey with a document concerning the process that TEQSA was using, including the name of the external reviewer?

Prof. Saunders : Yes.

Senator KIM CARR: You have indicated that you are mindful of the NHMRC review?

Prof. Saunders : Yes.

Senator KIM CARR: Have you adopted a policy of prioritising the commercial interests of private providers over the public's right to know what the bases of accreditation decisions are?

Prof. Saunders : Absolutely not.

Senator KIM CARR: Why is that?

Prof. Saunders : We believe there needs to be a balance between considering the interests of both the provider and the public. All our FOI decisions are based on those considerations.

Senator KIM CARR: That is in regard to the FOI decision. I am asking you in regard to your accreditation process.

Prof. Saunders : We do not take commercial considerations into account at all in assessing a course or a provider. As I said, the assessment is done against the standards. The standards refer to matters to do with financial viability but not to the commercial interests of the provider.

Senator KIM CARR: In regard to the re-accreditation of ParaPharm, why did only a single person—not a panel—undertake the review of the course?

Prof. Saunders : That relates to a technical issue with regard to the FOI request.

Senator KIM CARR: How does that work?

Prof. Saunders : We were assessing a number of courses. Dr Harvey asked for information about one course. So we gave Dr Harvey the relevant information about one particular course, but we had other people involved in the assessment of the other complementary—

Senator KIM CARR: The other things at the institution—I see. Can you indicate to me why it was that your expert witness—who I would prefer not to name at this point, but you know the person I am referring to. Is that right, Professor? You are aware of the details of that expert—

Prof. Saunders : I would have to take that on notice. I have seen the report; I just cannot carry the name of the person in my head at the moment.

Senator KIM CARR: All right. Can you indicate what was the basis of the appointment of that particular individual—who as I say, is a naturopath—to examine the operations of this particular college.

Prof. Saunders : That person would be on the TEQSA register or we would have had advice from people who were on the TEQSA register of experts as to who we might approach in this particular circumstance. Finding assessors who are experts in the field of complementary medicine is not easy. We have a range of people that we can go to. We have taken steps in the last six months to try and expand the range of people that we can choose to do those assessments, and I think I will leave it at that. If I may make a comment about the whole issue here—

Senator KIM CARR: I look forward to your comments.

Prof. Saunders : I think it is important that we separate out assessment against a set of educational standards against the recognition, registration and regulation of clinical practitioners. Unfortunately, or fortunately, TEQSA has no role to play in the latter. What we have to do is take a course and look at it from the point of view of the standards, and nowhere in the standards does it talk about the need for material or the course to be scientifically based. Nowhere does it have any content-specific standards. What it says is that the body of knowledge upon which this is drawn has to be coherent and it has to actually have scholarship associated with it, and there are other standards in there about intellectual inquiry of students and promoting those sorts of critical appraisal skills and the like. So, when we apply the standards to something like a course in homeopathy, we are not asking the question as to whether the science or the clinical outcomes of homeopathy are appropriate. What we are asking is: does this course position homeopathy in the field such that students who are studying this understand that there is a controversy and that there is strong evidence that it is in fact not an effective clinical regime? We are expecting students to understand the criticisms of homeopathy, not just simply to study in a modular sort of way the tenets of homeopathy. We would use our judgement applying those standards to the accreditation of courses like this.

Senator KIM CARR: Yes. Thank you for that. Do I take it from that there is a degree of discomfort about the way in which this now operates?

Prof. Saunders : No, I do not think there is. If there is discomfort, it would be the same discomfort about accrediting bachelors of theology. We use educational standards about the experience of the student, the coherence of the course, the build, the framework, the learning outcomes that are being achieved and whether it fits with the Australian Qualifications Framework. These are educational standards.

Senator KIM CARR: In terms of publishing the accreditation report for homeopathy, what are you doing about that? When will you be publishing this report?

Prof. Saunders : What we do is that, once we have done our assessment, we then publish the decision of the assessment. We would then be declaring whether or not the assessment has led to a reaccreditation of the course; if it is reaccredited, what are the conditions that are applied on that course; and whether the course has been accredited for a maximum period of 7 years or a shorter period of time. And there is a public notice that we always publish as a part of the national register that actually explains why we have taken those decisions.

Senator KIM CARR: Yes. Now the difficulty here is—and this particular issue has been experienced with regard to ESOS registration and it has been experienced with regard to VET registration—in this particular case, with students that are being enrolled in 2015—given that I take it you have had this process underway for at least six months?

Prof. Saunders : Yes.

Senator KIM CARR: I take it that you must have completed your work, your—

Prof. Saunders : We are in the final stages of discussion with the provider about provisional findings, yes.

Senator KIM CARR: So what do they do about enrolments for 2015?

Prof. Saunders : They are free to make enrolments until a decision is taken by TEQSA, and if the decision—

CHAIR: Senator Carr—

Senator KIM CARR: I will just—

CHAIR: Senator Ruston has one quick question.

Senator KIM CARR: Yes, sure. My concern, though, is that I take it you have actually decided to allow them to continue?

Prof. Saunders : No, we have not made that decision at all.

Senator KIM CARR: So what do you do with the students, then, if you choose to close them down?

Prof. Saunders : Then they have to have a planned and supervised teach-out of that. Now that would require them to transfer their students to another provider—

Senator KIM CARR: There is only one other provider.

Prof. Saunders : Yes.

CHAIR: All right, can we continue this after dinner if you have more questions for TEQSA, Senator Carr? Senator Ruston, you have a quick question?

Senator RUSTON: Just one.

CHAIR: But I will just double check. Sorry, Minister? Hello, Minister? We just have a question from Senator Ruston.

Senator Birmingham: Sorry, Chair. I was just confirming one point there with Professor Saunders about the course that Senator Carr was asking about the provider for. Being a bachelor course, it is a multi-year course. So the phase-out-type provisions that Professor Saunders was just talking about would have had to apply regardless of the timing of when a decision is made, where a decision has been made in that type of area.

Senator RUSTON: Professor Saunders, I am just wondering in the discussions about the accreditation whether there were any alternative medicine courses already being offered at public universities?

Prof. Saunders : Yes, certainly. Alternative medicine courses are offered by a number of public universities: Central Queensland University, Charles Sturt University, Macquarie University, Murdoch University, RMIT, Southern Cross University, University of New England, University of Technology Sydney and the University of Western Sydney. Chiropractic is the most common course that is being taught in the public universities, but as well as chiropractic they cover naturopathy, traditional Chinese medicine, acupuncture, osteopathy and western herbal medicine, and a couple of those public universities offer a Bachelor of Health Sciences with a generic complimentary medicine stream.

Senator RUSTON: And one assumes that the process of accreditation is exactly the same?

Prof. Saunders : They are self-accrediting institutions, so they would have put these courses through their own proper academic governance processes.

Senator RUSTON: Okay, thank you, Professor Saunders.

Senator KIM CARR: I would like to ask you about Avondale College of Higher Education.

Prof. Saunders : Yes.

Senator KIM CARR: TEQSA has provided Avondale College with self-accrediting status, is that correct?

Prof. Saunders : That is correct.

Senator KIM CARR: The power to grant self-accrediting status on one or more levels of study in one or more broad fields of study—is that the case?

Prof. Saunders : There is a set of standards that applies to the authorising of self-accrediting authorities. There are, in fact, a number of standards, in the order of 10—

Senator KIM CARR: So with regards to this decision, what is the basis for which Avondale College is now able to be self-accrediting in terms of broad fields of study? Is it all broad fields of study or specific areas?

Prof. Saunders : No, all their current fields of study.

Senator KIM CARR: All current?

Prof. Saunders : Yes. And they have broad offerings.

Senator KIM CARR: You have said that it meets the criteria set out in chapter 2, section 7 of the standards frameworks. Is that correct?

Prof. Saunders : Yes.

Senator KIM CARR: How did you make that decision?

Prof. Saunders : First of all, Avondale has been going for a long period of time, so it is a well-established provider. We have had a lot of experience with Avondale over the last three years in terms of its courses; we must have seen in excess of 20 of their courses. So we actually know their academic governance arrangements, we know the quality of the monitoring of their student outcomes and the like. It is that accumulated knowledge over the last three years of working with Avondale—and recognising that, where they were falling a bit short of the mark, they were able to demonstrate that they took that on board and had appropriate mechanisms in place to self-improve—that, when they applied for re-registration and self-accrediting authority, we had confidence that they could be given that status.

Senator KIM CARR: Do you have any other applications before you for self-accreditation?

Prof. Saunders : Yes, we do. We have three being actively considered at the moment. That assessment is almost finished. And we are expecting a number of other providers to apply for self-accrediting status during this year.

Senator KIM CARR: What are the names of the three?

Prof. Saunders : I will have to take that on notice, I am sorry.

Senator KIM CARR: These are not confidential, are they?

Prof. Saunders : Sorry?

Senator KIM CARR: There is no reason why these would be confidential?

Prof. Saunders : No, the reason I take it on notice is that I cannot tell you the names offhand.

Senator KIM CARR: It is just a memory question.

Prof. Saunders : Yes, it is a memory question.

Senator KIM CARR: There is no other issue. Are you required to provide public notice of an intention to grant self-accreditation?

Prof. Saunders : You mean in terms of a heads-up, letting people know? No, we are not.

Senator KIM CARR: There is no requirement in the act?

Prof. Saunders : There is no requirement in the act for us to go out for public consultation before we grant self-accrediting authority.

Senator KIM CARR: Avondale is the first time you have done this, isn't it?

Prof. Saunders : It is the first time we have done it through this sort of thorough process. We did actually grant self-accrediting authority to the overseas universities and Torrens University, which we inherited from the state government processes.

Senator KIM CARR: But they were established institutions with an international reputation; is that correct?

Prof. Saunders : The two overseas universities, yes. Torrens is, as you know, a branch of Laureate.

Senator KIM CARR: Yes. Surely, it is arguable that this is an entirely different circumstance?

Prof. Saunders : Yes, it is. We applied the process really from go to whoa here in terms of that assessment.

Senator KIM CARR: Is this a disallowable instrument?

Ms Paul : I do not think so.

Mr Griew : I do not believe it is, no.

Ms Paul : We will check it out.

Senator KIM CARR: You said 'a number of others'. Are you able to indicate how many others you expect?

Prof. Saunders : As I said, we have three underway and we are expecting possibly two or three more by the end of the year.

Senator KIM CARR: Right. That obviously requires more attention, I would say. Thank you.

CHAIR: Thank you very much, Senator Carr. The committee now stands suspended till approximately 7.30 pm.

Proceedings suspended from 18:23 to 19:32