December 16, 2020
Introduction
The Group of Eight (Go8) welcomes the opportunity to make a short response to the TEQSA discussion paper Making and assessing claims of scholarship and scholarly activity to inform the review of TEQSA’s Guidance Note on Scholarship. Please note that this submission represents the high-level views of the Go8, and our members may make their own, more detailed submissions.
The Go8 has seven members in the top 100 ranked universities globally and collectively graduates over 115,000 students annually, all educated in research-intensive environments with a commitment to both research and scholarship informing teaching.
In general, TEQSA guidance notes are very helpful to the sector. They are clear and describe well the intent of elements of the Threshold Standards in the Higher Education Standards Framework. For large research-intensive institutions such as the Go8 members this facilitates a more efficient process of evidencing compliance with the Threshold Standards without having to continually seek clarifications from TEQSA.
There is, however, the inevitable tension between providing clarification as to what constitutes evidence in demonstrating compliance and effectively prescribing the nature and form of evidence presented. While there is no doubt some utility for TEQSA and also for smaller institutions in taking more of a “template approach” to providing evidence in support of compliance, there is the danger that a level of prescription leads to the establishment of de facto additional Threshold Standards – outside the formal Threshold Standards and the intent of the Higher Education Standards Panel in drafting the standards.
In this regard, the Go8 does have concerns with the tone and language of the discussion paper in that it is significantly more prescriptive than the current version of the Scholarship Guidance Note. This prescription appears both in the definitions of scholarship and in the mechanisms to demonstrate compliance with standards concerning scholarship.
This is most evident in the Principles 1-4 of the discussion paper which are also seemingly somewhat at odds with the final Principle 5 which speaks to institutions adopting different approaches to scholarship that reflect the nature of the provider.
The Go8 recommends that the tone and language of a revised Guidance Note on Scholarship be less prescriptive than that of the discussion paper – particularly Principles 1-4 – and more in keeping with the tone of the current Guidance Note.
Discussion
As laid out in the TEQSA Act 2011, part of the role of TEQSA in (re)-registering Higher Education Providers (HEPs) is to ensure that the provider (continues to) meet the Threshold Standards as established in the Higher Education Standards Framework (Threshold Standards) 2015. TEQSA is also charged with reviewing/examining ongoing compliance with the Threshold Standards.
The 29 TEQSA Guidance Notes – which do not form a part of the TEQSA Act – provide guidance in areas identified as relevant to the operation of HEPs under the Threshold Standards, and that inform the task of providers to evidence compliance with the Threshold Standards in a way that is consistent with their institutional context and arrangements.
As noted on the TEQSA website[1] Guidance Notes are not instructional or ‘how to’ documents for compliance with the new HES Framework, and TEQSA publishes guidance notes, to provide greater clarity for providers in the interpretation and application of selected standards.
The Go8 is entirely supportive of this approach and acknowledges the utility of the provision of guidance notes in assisting the sector in evidencing compliance with the Threshold Standards.
Scholarship – the focus of the Guidance Note under review – is an important element in informing the delivery of both teaching and research in Higher Education.
The Go8 agrees that it is important and appropriate for institutional concepts of scholarship to be informed by scholarly work on the topic. However, in the discussion paper, there is a lack of clarity on how formal models of scholarship are to be used, how the credibility of models is to be recognised and indeed when a model is to be considered “established” – as seemingly mandated in Principle 1 of the discussion paper.
The Boyer model is identified in the discussion paper, and although influential there does seem to be scope for other frameworks to be used, as well as institutional adaptations of frameworks to allow institutional definitions of scholarship that are evidently consistent with some other credible typology of scholarship that embraces similar principles – as suggested on page 3 of the discussion paper.
It is also noted on page 3 of the discussion paper and again as one of the two points of summary of TEQSA’s proposed approach on page 10 that claimed scholarly activity should be consistent with an established typology of scholarship that is “acceptable” to TEQSA.
This seems to suggest either that TEQSA will produce a list of acceptable typologies or that somewhat recursively that there needs to be further guidance on what is meant by “acceptable” in the guidance note.
It should also be noted that definitions of and criteria for research and scholarship are also specified by other agencies and the TEQSA guidance note should aim for consistency with these definitions.
Given the above, the Go8 believes that the appropriate solution is to encourage the application of scholarship typologies as useful references without being prescriptive.
In general terms, the Go8 is also concerned with the narrowing of the concept of scholarship for TEQSA assessment purposes in Principles 2 – 4 to activities where that scholarship must be linked specifically to intended outputs or outcomes of that scholarship and that TEQSA would not regard a ‘scholarly’ activity (an input) as an end in itself (page 5 of the discussion paper).
This would seem to be much narrower than the description in the current Scholarship Guidance Note that describes scholarship as activities concerned with gaining new or improved understanding, appreciation and insights into a field of knowledge, and engaging with and keeping up to date with advances in the field. In the view of the Go8 this broader description is more representative of the intent of the Threshold Standards, formal typologies such as the Boyer model, and the mission of a modern research-intensive university.
Of course, the Go8 believes in and practises the delivery of outputs/outcomes such as the advancement of curriculum, teaching and learning, and knowledge transfer to academic colleagues through scholarly activity (including research). It is also important in a regulatory sense that evidence is provided linking these outcomes to scholarly activities and the institutional strategies that underpins this.
However, in doing so it is important to be mindful of the administrative load that imposing too granular an institutional reporting regime of the outcomes of scholarly activity represents, particularly given the different nuances in the practice of scholarship across the range of disciplines in a comprehensive, research-intensive university.
I hope that this brief submission will be of use for TEQSA in considerations of scholarship and in reviewing the Guidance Note on Scholarship. The Go8 looks forward to an ongoing engagement in the important work of TEQSA and should you have any further questions regarding the Go8 submission, then please do not hesitate to contact Dr Matthew Brown at the Go8 Directorate at matt.brown@go8.edu.au or 0422 937 663.
Yours sincerely,
VICKI THOMSON
CHIEF EXECUTIVE
[1] https://www.teqsa.gov.au/guidance-notes