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Discussion Paper: Next steps on improving the transparency of higher education admissions

Extension to postgraduate courses and international students

Improving the transparency of ATAR reporting in course profiles

Professor Kerri-Lee Krause
HESP Deputy Chair and
Chair of the HESP’s Advisory Committee on Admissions Transparency

The Group of Eight (Go8) welcomes the opportunity to make a submission to the Higher Education Standards Panel (HESP) consultation on the Discussion Paper: Next steps on improving the transparency of higher education admissions: Extension to postgraduate courses and international students: Improving the transparency of ATAR reporting in course profiles.

Please note that this submission represents the views of the Go8 as a whole and member universities may choose to provide their own submission. We are happy for this submission to be published in full.

The Go8 comprises Australia’s world-leading research-intensive universities, with seven of our universities in the top 100 globally. Our total economic impact is some $66.4 billion each year and we enrol 425,000 students, educating more than one quarter of all higher education students in Australia.  Go8 universities also enrol over one third of all postgraduate students, and almost half of all students in higher degrees by research. We educate over 160,000 international students on and offshore or one in three international students.

The Go8 is broadly supportive of efforts to improve the consistency and comparability of information on admission requirements for postgraduate courses and international applicants, and, with some caveats, the inclusion of student ATAR data profiles of recent secondary education students.

Our universities already publish extensive information on admission standards for postgraduate domestic courses and for international students. Entry requirements for postgraduate courses and for international students do vary between institutions and each of our institutions apply considerable care in framing their information for these cohorts ensuring, of course, full compliance with the Education Services for Overseas Students Act 2000 for international students. As queried by the Go8 during phase one of HESP’s consultation on this issue, are additional reporting, data and publication requirements warranted or is a central web location that links to every university’s relevant information a sensible alternative?

There remains an untested and unanswered question as to whether the proposed changes will in fact deliver any real benefit for prospective students. For example, will providing prospective postgraduate and international students historical statistical information on how many students commenced last year disaggregated by their previous qualification status really be helpful for those cohorts when they are deciding what courses to apply for? Do students feel under-served by the information currently provided? Is HESP imposing additional burdens on the sector to address a limited number of institutions that may be trying to subvert existing admissions transparency standards when a more sensible approach would be dealing directly with those institutions?

Regulatory Burden

Notwithstanding our in-principle support for improved consistency and comparability in admissions information, we urge the HESP to consider the burgeoning regulatory and administrative impost faced by Australia’s universities, which is a significant handbrake on our productivity – adding additional costs with often questionable ‘benefits’.

In our recent publication, Essential decisions for national success: reducing the regulatory overload on our universities[1] the Go8 outlines the clear lack of coordination between Government agencies in developing and oversighting legislative, administrative and reporting requirements on the higher education sector. Despite successive Australian Governments pledging to rid the higher education sector of unnecessary red-tape and regulation, each year the list of new imposts grows without any corresponding attempt to remove obsolete, duplicative and unnecessary requirements. This latest set of proposals from HESP must be seen in this wider context of increasing administrative burden faced by our universities. We are not only concerned about this new impost on our universities, but also the potential for the proposed reporting requirements to increase over time.

We therefore recommend that the HESP  consider carefully three threshold questions in relation to these new ‘transparency’ measures:

  1. Can the desired objectives be achieved without creating additional reporting and burdensome compliance load?
  • Will the suggested mechanisms to achieve increased transparency genuinely serve the interests of postgraduate and international student candidates and therefore achieve the stated objectives?
  • Is there a way of achieving the stated objectives that adjusts the existing means by which admissions requirements are published by universities that does not create additional administrative/reporting load?

The Go8 and our member universities are willing to contribute to further consideration of these fundamental questions and provide feedback on more detailed examples of what reporting and data sets are envisaged by HESP, the exact timing and scope of proposed reporting – as all of these will have resourcing and capacity impacts. Ongoing engagement on any changes to admissions information requirements will be important to ensure their workability. Certainly, greater clarity on the detail of proposals is sought by our universities.

Additionally, we are concerned about the proposal to require all affected course information to be produced in the updated format by ‘around the end of May 2023’. This timeline does not consider the other new requirements placed on universities as a result of the Job Ready Graduates package. Nor does it recognise the significant lead time involved in marketing and recruitment phases for international admissions. As reported by one Go8 member, marketing material for international entry in 2024 is about to be released to market. The HESP will no doubt be aware of the importance of rebuilding Australia’s international education reputation and the need to ensure that any changes to terminology or other requirements are introduced with sufficient lead-time for universities to implement without detriment. Again, we recommend working closely with our universities to identify a more appropriate timeline for implementation.

The Go8’s responses to the specific consultation questions posed by the Discussion Paper are in the Appendix.

Thank you for the opportunity to provide advice on this issue. Please feel welcome to contact me directly about this submission on 0417 808 472.

Yours sincerely



Inclusion of postgraduate courses

  1. Do you agree with the proposed two applicant grouping to target admission information to prospective postgraduate students?
  2. Completed higher education study, bachelor degree level or above
  3. Work, study and/or life experience.

In broad terms, these two groups are workable for our universities, but clarification will be required where there is overlap between the two groupings.

Most students admitted at Go8 universities will fall within category (a). This is particularly so for international students applying for postgraduate studies. However, there are also instances among our universities of postgraduate courses that require a combination of higher education qualifications and relevant work experience.

The consistency in the assessment of work and life experience across degrees, as well as the communication of that to prospective students is likely to be an issue across universities. This is particularly relevant in the postgraduate space. Clear messaging will be required where a prospective student can gain entry to a graduate certificate with work and life experience and from there progress onto a Masters. Being able to explain the number of years and the parameters of professional relevant experience, as well as the use of the GMAT (including what evidence is required to demonstrate the work experience level) would need to be a key area of focus when looking to implement these proposed changes.

Further consultation with universities around the precise terminology and requirements is required if this proposal is to be pursued.

  • What are your views on the proposed inclusion of information about the availability and allocation of Commonwealth Supported Places (CSP) in postgraduate courses, which some students have indicated may assist in choosing the best course for their needs?

In general terms, the Go8 is supportive of the proposal to include information about the availability of CSPs and fee-paying places. Several our members already provide this information online and certainly when offers are made for domestic postgraduate courses it is made clear to the applicant whether they are being offered a CSP or fee-paying place.

However, as the HESP may be aware, there is now greater flexibility available to universities around the allocation of CSPs for postgraduate programs and their availability can change from semester to semester – even quite late in the preceding semester. This can be driven by receiving late changes in funding agreements or identifying changes in demand that mean more places can be filled than originally anticipated. The requirements that may be imposed in relation to this proposal must consider this reality for universities.

Inclusion of information for international students

  • Do you agree with the proposed approach of integrating the minimum required admission information to enable course comparisons for international students without creating a separate applicant grouping?

As noted, Go8 universities are committed and do publish detailed admissions information for international applicants. There could be challenges with implementing this proposal given the variations that exist between members in terms of the differences in weighting when converting international qualifications to the local equivalent. Because of these differences, requiring the publication of minimum entry requirements may not actually lead to greater transparency and accurate comparisons between providers’ requirements. We therefore query whether the additional administrative costs for providers of complying with this proposal on an ongoing basis would be worth the benefit of the outcome that would be achieved.

  • Is it appropriate and workable to separate out different cohorts of international students in the student profile tables on the same applicant grouping basis as domestic students (higher education, VET, Recent Secondary, work and life experience, etc.), rather than a single figure for international students as in the current information sets?

NOTE: If you are a provider, does your institution have data that would enable this approach?

While this proposal would be achievable for Go8 universities, for those with larger international student numbers it will be a significant administrative burden to fulfil on an ongoing basis. The HESP is asked to consider whether the additional administrative effort and associated cost is worth the intended result.

  • What are your views on the proposed:

a) inclusion of offshore students in enrolment profiles where they are studying and engaging with onshore students on an equal basis; and

b) exclusion of purely offshore course offerings, for instance courses offered at an overseas campus, as out of scope for this exercise?

We support the inclusion of offshore students in profile tables where those students are enrolled in a program that is based in Australia and subject to Australian admissions standards.

We support the exclusion of offshore students and programs that operate in an overseas regulatory environment, even where the program is identical to one offered in Australia but is managed by offshore admissions teams.

Enhancing the reporting of ATARs for places offered to recent secondary students

  • Do you see any difficulty with including the ATARs of all recent secondary students offered a place in the ATAR profile table for a course?

We recommend against the inclusion of all recent secondary students in the ATAR profile tables, where ATAR is not a basis for admission, or where it applies differently to parts of the population. For example, all our universities offer a range of equity programs that have a lower minimum ATAR for certain student cohorts and publishing these could be misleading and confusing rather than helpful. Instead, we support the current practice of publishing the “lowest ATAR before adjustment processes” with appropriate exclusions that ensure the number is meaningful for applicants.

Additionally, it is important to remember that in the Queensland context this proposal may not actually improve transparency. Almost half of the students completing the Queensland Certificate of Education do not receive an ATAR. How is it proposed that these non-ATAR admissions be reported?

Overall feedback on admissions transparency initiatives

  • Are there any other aspects of either the previously agreed common terminology definitions or information set specifications or the implementation of admissions transparency that you wish to provide comment on?

While the Go8 appreciates the additional work undertaken by the HESP following the first consultation round, as we have noted, there are outstanding questions that need to be carefully thought through and upon which further consultation with providers is required if the stated objectives of this phase of ‘increased admissions transparency’ are to be achieved.

We recommend that the HESP give particular consideration to the issues we have raised regarding the increased regulatory, reporting and administrative burden faced by our universities which are responsible for increased costs and diverting much-needed resources from our core business of teaching and research. Most importantly, will the proposed changes benefit students by significantly improving their decision-making process or at least to the extent that justifies the additional burden placed on universities?

[1] https://go8.edu.au/report-reducing-the-regulatory-overload-on-our-universities