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Go8 Submission to the Australian Government Department of Education, Skills and Employment on the Draft Higher Education Support (Student Learning Entitlement) Guidelines 2021

4 November 2021
Michael Jones
Assistant Director
HESA Modelling and Performance | Funding and Students Branch Higher Education Division
Australian Government Department of Education, Skills and Employment

The Group of Eight (Go8) welcomes the opportunity to make this submission to the consultation on the Draft Higher Education Support (Student Learning Entitlement) Guidelines 2021 (SLE Guidelines).

Please note the following represents the views of the Go8 which leads policy and advocacy for Australia’s world-class research-intensive universities with seven members consistently ranked in the world’s top 100 leading universities.

Go8 universities may make their own submissions.

In addition to being Australia’s leading research-intensive universities, Go8 members also educate over 250,000 domestic students – almost a quarter of all Australian students in higher education. The Go8’s undergraduate retention and success rates are higher than other Australian university groups, delivering over 100,000 quality graduates each year. In post graduate education, Go8 universities enrol over one third of all post-graduate students.

Noting that this is now a legislated measure, we provide the following input on the draft Guidelines with a focus on two important cohorts of students: those who undertake two degrees (sequentially) one of which is a medical degree, and secondly, those students who, as a result of disruptions beyond their control, may be impacted by the 50% pass rule – a measure introduced as part of the Job Ready Graduates (JRG) package.

The COVID-19 pandemic has highlighted the critical importance of the medical workforce and the contribution of science-based disciplines such as epidemiology, virology, immunology and public health to the well-being of our society has never been more evident. These are the people qualified in both of these knowledge domains that have led our public health efforts during COVID-19 and have been at the forefront of our national clinical care response. The accessibility of a highly educated and readily available medical workforce is essential to Australia’s future. Given that a medical degree is typically 6 or 4 years in length – depending on whether it is an undergraduate or postgraduate course – and a science degree is 3 or 4 years, it is in the national interest that additional SLE criteria allow full Commonwealth support for the education of this student cohort.

In addition, the Go8 recommends that a further category for additional SLE – a ‘special circumstance’ for the recrediting of SLE be created for those students who, for a number of reasons (including the 50% pass rule) may review and change their course enrolment after their first year of study. This measure would provide equity to certain student cohorts who might otherwise not be able to complete a tertiary qualification.  This supplementary category could either be introduced as an ‘automatic’ additional SLE or require the student to apply for consideration under the ‘special circumstances’ provisions.

It is worth noting that the Go8 has separately recommended that the Government postpone the introduction of the 50% pass rule until January 2023. This is particularly important in the current environment as evidence is emerging that student outcomes are being impacted by the pandemic.  At the University of Sydney, for example, we are seeing higher fail rates in 2021 than in 2020 or prior years, especially in disciplines such as science with significant practical components.  It is likely therefore, that the commencing 2022 cohort will need additional support given the disruption to their schooling.

There are a number of other issues related to the SLE which require further clarification.

  • In relation to the calculation of additional SLE for an honours degree it is not clear if the Guidelines are referring to an honours that is added on to the end of a bachelor degree or an entire embedded honours degree. This should be made clear in the Guidelines.
  • The SLE will run in parallel to the operation of the HELP lifetime limit and clarity would be useful as to the circumstance in which the HELP limit will be reached without exhausting the SLE and whether the Government contribution under the SLE will continue.
  • The Guidelines should stipulate how the SLE calculation will be managed, not just with a focus on the responsibilities of universities but also on those of the Government. If the TCSI report will provide the data required by universities then the Government’s role in ensuring that this platform is operational for this purpose should be stipulated in the Guidelines.

We note that there is scant information in the Guidelines about the compliance and reporting mechanisms that the Government will establish to support the reintroduction of this system. It may be intended that these will be revealed as part of the implementation information process, but we seek early engagement in the design of these to ensure maximum operability.

Finally, the Go8 is concerned about the very short timeframe available for universities to develop systems and processes to administer and report on this measure. Australian universities have had significant new administrative, reporting and regulatory activities imposed upon them in the last few years while simultaneously experiencing a significant drop in the revenue and resources required to undertake these new responsibilities. We therefore urge the Department to engage with the university sector as a matter of priority on the implementation process and trust that the Government will ensure information systems, training and support are available to universities well in advance of the commencement of the SLE in January 2022.

As this is a new iteration of the SLE in Australia and the full impact of the implementation of the Guidelines may not be immediately obvious the Go8 recommends that the Department build in a regular review process and seek input from stakeholders. The Go8 would be pleased to contribute to this process.

If you have questions regarding the Go8 submission, please do not hesitate to contact me.

Yours sincerely,