May 7, 2018
I am writing on behalf of the Group of Eight (Go8) universities to comment on the release of advice from the Higher Education Standards Panel (HESP) on the impacts of professional accreditation in higher education.
Please note that what follows are the views of the Go8 network; member universities may make their own, more detailed submissions.
The Go8 is very pleased to be able to provide brief input in response to the HESP advice that has been provided to Government. The views of the Go8 remain consistent with our earlier submission to the review undertaken by Emeritus Professor Christine Ewan. In that context, the Go8 acknowledges that the HESP appears to have recognised many of the concerns and issues raised by the Go8 in that submission.
In respect of the HESP advice to Government following the review process, the Go8 is broadly supportive of the key recommendations made by the Panel. Comments against each of the three headline recommendations follow.
Recommendation 1: that Government consider requiring professional accreditation bodies to only assess or raise matters that are profession-specific and not already assured by accreditation against the Higher Education Standards Framework under the TEQSA Act, whether that accreditation is undertaken by TEQSA or by a self-accrediting provider.
In making this recommendation, the Panel canvassed four possible options. The Go8 considers that a full legislative regime that would prevent professional bodies considering matters already covered by the Standards Framework would be an onerous process for all concerned and one that would likely be overly intrusive on both accreditation bodies and universities in particular. Further, it is unlikely to send a message of mutual respect between universities, professional associations and Government.
The proposal to instead manage this though a code of practice that is given legislative authority through the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) offers substantial positive benefits and the Go8 supports this option.
The Go8 is supportive of the option as it is capable of actively dealing with the recommendations made in our 2016 submission in an effective manner. Those recommendations from the Go8 submissions are:
- Accrediting bodies should work proactively to remove or at least minimise any duplication or administrative overlap in accreditation practices, consistent with the 2016 Joint Statement from Universities Australia and Professions Australia.
- Accrediting bodies should work to configure processes such that they align with the 2016 Joint Statement from Universities Australia and Professions Australia.
- Accreditation processes should focus on outcomes rather than the inputs that might be required to achieve them: the knowledge, competencies, skills and attributes required for the relevant profession.
- Any conflict of interest – real or perceived – in accreditation practices should be avoided wherever possible and steps taken to mitigate those that may already exist.
- Professional accreditation must not encroach on discipline development, internal quality review, the work of the Tertiary Education Quality and Standards Agency and the operation of the Higher Education Standards Framework.
- Accrediting bodies should develop processes that allow institutions to be viewed in their context rather than in a uniform manner.
To enable the development of a code of practice to be most effective, it is important to ensure input from relevant stakeholders is included and embraced from across the university and professional associations sectors, and not let this important opportunity be restricted to a small number of groups. This is particularly important in the context of the need to develop dispute resolution protocols.
This approach would act as a compulsory code of practice and require a level of compliance that other possibilities such as a voluntary code or self-regulatory approaches do not offer. In developing a code of practice, it is imperative that mechanisms for compliance align closely with those in the Standards Framework with respect to accreditation and to reduce, to the maximum extent possible, the chance of any increase in regulatory burden for universities.
Recommendation 2: that TEQSA work collaboratively with accrediting bodies to build capacity by developing additional guidance notes and participating in relevant workshops on the proposed changes to encourage a focus on outcomes‑based quality assurance, and promoting best practice regulation.
The Go8 supports this recommendation and agrees with the Panel that it is crucial this process be incorporated into the work that informs the code of practice under Recommendation 1. In doing so, however, it will be important to ensure that any engagement between TEQSA and the professional bodies is ongoing and founded with an intention to develop and lead professional capacity building across the sector.
The Go8 would also like to highlight that there can be significant issues with respect to international accreditation bodies that Recommendation 1 is unlikely to address to any effective degree. For example, international accrediting bodies (in the discipline of business and management for instance) can seek to exert pressure on staffing and other resources (mandating minimum staff-student ratios and the like) require. These issues may be better managed though collaborative engagement from TEQSA and institutions and the Go8 will seek to work with TEQSA in this context.
Recommendation 3: that a stakeholder forum is held to discuss the future of professional work and the ways to further streamline professional accreditation.
This is an essential outcome for the Go8 and also reflects recommendations made in 2016. This should not, however, be restricted to a single, one-off event. While the Panel recommends the Department convene a stakeholder forum for this purpose, it is possible that such a forum may be restrictive and as a result not achieve its intended purpose.
The Go8 suggests that an effective and broadly representative forum could be woven into other events, possibly as a part of the annual TEQSA National Conference to ensure that momentum is maintained. This would enable stakeholders – including institutions and associations – to engage through TEQSA and the Department and for TEQSA to leverage their growing global engagements to inform best practice in Australia.
Yours sincerely