July 26, 2024
Mr Tony Cook PSM
Secretary
Australian Government Department of Education
The Group of Eight (Go8) states up front that it is absolutely committed to a fair and well managed tertiary education system positioned to achieve the long-term aspirations for the nation as articulated in the Universities Accord Final Report (Accord).
The Go8 consents to this submission being published in full and notes that Go8 members may make individual submissions.
The Accord set out an ambitious vision for a dynamic and efficient tertiary education system that underpins a strong, equitable and resilient democracy, and drives national economic and social development and environmental sustainability.[1]
It positioned diversity in higher education providers as key to meeting new attainment targets – i.e. 80% of the working aged population with at least one tertiary qualification and a more than doubling of students in Commonwealth supported places (CSPs) in higher education to 1.8 million by 2050.[2]
It recommended establishing an ATEC – a sector steward – to help realise these goals.
At the same time the Accord also warned about damage from decades of underfunding of universities – particularly in relation to research – and the failure of the Job Ready Graduates (JRG) reforms. What it could not have foreseen was the perfect storm looming for the sector through ill-conceived and economically destructive international student caps just at the time it was proposing its new direction and vision.[3]
This clearly demonstrates the need for Australia’s higher education sector to be underpinned by independent, transparent, consultative and long-term policy advice provided to government.
The ATEC – as the designated system steward – must have the capability to provide independent policy advice. It can only do this as an independent body, similar to the Productivity Commission or the Australian Law Reform Commission.
The model proposed in the consultation paper, where the ATEC is housed within the Department of Education to take advantage of “organisational efficiencies”, will not have the independence nor the scope to provide this capability.
The Government must rethink its approach to the ATEC and ensure that independent, transparent, consultative long-term policy advice to government is a core function.
Failure to do so, on the basis of managing costs and leveraging organisational efficiencies, risks the success of the intended Accord outcomes, and will cost the nation dearly.
| Recommendations: 1. The ATEC should have as its primary function the transparent provision of independent and long-term policy advice to government. 2. The ATEC should include or be linked to the establishment of a National Equity Data/Evidence Institute to ensure a research and data driven approach to increasing equity of access and success in higher education. 3. In its role as a system steward the ATEC should not be overly interventionist and not unduly constrain institutional autonomy. |
Discussion
The ATEC should have as its primary function the transparent provision of independent and long-term policy advice to government.
The Accord sets an ambitious but appropriate goal of a tertiary education system that meets Australia future needs through a target of 80% of working aged population with at least one tertiary qualification and a more than doubling of students in CSPs in higher education to 1.8 million in 2050.
This represents generational reform in higher education of the order of the “Dawkins’ reforms”, including the introduction of the Higher Education Contribution Scheme (HECS) of the late 1980s, and of the full Demand Driven System in 2012. Both periods saw a substantial increase in participation in Australia’s university system.
Common to both reforms were the key questions at the heart of expanding participation:
- Who will teach the increased number of domestic students?
- How will the expansion in participation be paid for?
Broadly speaking, for the Dawkins’ reforms this included the creation of new universities and the introduction of HECS. For the Demand Driven System, universities were freed up from previous caps on domestic student numbers to enrol additional students. This was accompanied by a commitment from the government to fully fund these additional enrolments.
Despite proposing a significant expansion of the tertiary and higher education system, the Accord does not address either of these challenges. Yet the goal of growing CSP students from 860,000 (in 2022) to 1.8 million by 2050 represents an uninterrupted growth rate of approximately 2.7 per cent per year.
This will be a significant challenge. Currently, domestic demand for university places is soft. Even if demand increases, the capacity of universities to expand may not be able to match the challenging but required annual 2.7 per cent growth rate.
Even during the full Demand Driven System – when universities had an uncapped ability to enrol students – the annual growth rate (for domestic bachelor degree) students did not consistently meet this benchmark.[4] Underscoring these capacity constraints is the introduction of the JRG reforms in 2021, which has resulted on average in a 6 per cent decrease in funding for undergraduate teaching with a disproportionate impact on universities offering high-cost courses in science and engineering – which have suffered cuts of 16 per cent.
Universities are increasingly required to cross-subsidise the education of domestic students in these courses from other revenue sources. As government funding has declined, universities have had to rely on international student fees to make up the shortfalls. However, the ability to do so – and to fill additional funding gaps in research – will be curtailed by the proposal to introduce institutional caps on international student numbers and associated reputational damage to the sector. It is therefore very concerning that the legislation to implement caps has been rushed into Parliament without due consultation.[5]
The JRG has also had a disproportionate impact on students studying a range of humanities, arts, and social science degrees – often a pathway for students from underrepresented backgrounds to enter higher education. These students have seen their student contribution more than double and are now paying 93 per cent of the cost of their degree.
The Accord seeks to increase participation of students from equity and underrepresented backgrounds who may require additional financial and other support to succeed at university studies. However, the New Managed Growth Funding and Needs-Based Funding consultations have left reform of the JRG and funding amounts off the table – running the risk of ignoring the lessons of the JRG that rushed policy with little consultation once implemented is difficult to unwind.
Given the extent of the challenges of complex system redesign, that must address current deficits in the system and plan for a sustainable expansion to 2050 Accord targets, the proposed ATEC model housed within the Department of Education as a statutory authority[6] cannot deliver the breadth and depth of policy reform that is needed.
The ATEC should include or be linked to the establishment of a National Equity Data/Evidence Institute to ensure a research and data driven approach to increasing equity of access and success in higher education.
One of the core drivers of the Accord is to ensure that the increase in participation and attainment at universities is accomplished by increasing the rate of participation and attainment by currently under-represented groups, aiming for population parity by 2050.
As Minister for Education Jason Clare put it:
We want to make sure more Australians get a crack at going to university. That’s what the Universities Accord is all about.[7]
What is already clear through consultations on the New Managed Growth Funding and Needs-Based Funding policies is that for these programs to be successful it is essential to obtain better data on underrepresented groups to identify and address actual student need.
More broadly, the targeted, long-term solutions and focused strategies developed to ensure equity of access and success, which will be implemented across Government agencies, the tertiary sector and individual tertiary institutions, must be research and data driven. We must know what works, what hasn’t worked and why, if we are to evolve our tertiary system and maximise access across the population. This will be critical to the successful implementation of the Accord. Without this, we risk embedding the potential for failure into the policies themselves.
A National Equity Data/Evidence Institute could bring together, in a single or federated structure, the research and evidence remits of the Australian Education Research Organisation (AERO), the National Centre for Vocational Educational Research (NCVER) and the National Centre for Student Equity in Higher Education (NCSEHE). A core part of the Institute’s research agenda could be enabled by developing an advanced data capability (a National Education Evidence Database) built from integrated public sector data assets, including provider data. It is data and data systems that will help the sector know what success looks like, track progress and measure it. A National Equity Data/Evidence Institute would enable tertiary education providers to understand where and how they can have the most impact, and in collaboration with Government, industry, communities and other sectors create mission relevant targets and strategies designed with maximum potential for real and tangible impacts.
In its role as a system steward the ATEC should not be overly interventionist and not unduly constrain institutional autonomy.
The Go8 is absolutely committed to being accountable for the investment of all Australians in the research and education they provide to Go8 members. This is both accountability to our students that they receive a world class education, our staff, and to the Australian community to evidence that public investment delivers research and education outcomes directly aligned with the national interest, contributing to the prosperity of the nation.
However, accountability must not be conflated with a command-and-control approach by government. The vision of the Accord is for a diversity of education providers and offerings that allow all Australians the opportunity of lifelong education across a seamless tertiary education sector. If this vision is to be realised, providers must have the institutional autonomy to pursue different ways of delivering education that fits within their distinctive mission.
It has already been proposed that the ATEC will be given oversight of international student profiles for public universities[8] – which may include course level international student enrolment limits if the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024 currently before the Parliament is passed.
In addition, the current New Managed Growth Funding and Needs-Based Funding consultations are considering a role for the ATEC in determining Managed Growth Targets (MGT) for each institution which would prescribe the number of CSPs allocated to each institution – as a hard cap.
In combination this would result in the ATEC controlling the majority of places at Australian universities. Rather than looking forward 25 years to the aspirations of the Accord for a flexible, diverse system this would seem to be looking back 25 years to a more constrained, command-and control system.
[1] From the National Tertiary Education Objective in Recommendation 1 of the Accord
[2] From the Attainment Targets in Recommendation 2 of the Accord
[3] Contained in the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024 currently before Parliament.
[4] Figures included with the Productivity Report The Demand Driven University System: A mixed Report Card indicate that the year-on-year rate of increase in domestic bachelor degree students for the final three years of the Demand Driven System 2015-17 were 2.6%, 1.5% and 1.2% respectively. See https://www.pc.gov.au/research/completed/university-report-card
[5] Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024
[6] A secondary statutory structure in the Australian Government Organisations Register with other bodies such as the Productivity Commission and the Australian Law Reform Commission are primary bodies.
[7] House of Representatives, 25 March 2024.
[8] See page 6 of the ATEC consultation paper
