WHAT’S

NEW IN THE
NEW HIGHER
EDUCATION
STANDARDS
FRAMEWORK?

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 [NOTE: The purpose of this paper is to describe some of the more substantial or
interesting changes introduced with the Higher Education Standards Framework
(Threshold Standards) 2015 as compared to the 2011 Threshold Standards. It is not
intended as an exhaustive summary of the 2015 Threshold Standards. Additionally, it
is not intended as a replacement for TEQSA’s published advice on the new standards.
The intent is rather to supplement the TEQSA advice with a paper focused more closely
on changes in the character of the standards, hopefully to help clients think about the
changes they may need to consider for their own organisation.]

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OVERVIEW

The change to the Higher Education Standards Framework

most people will notice irst up is its structure. The old
standards were organised into chapters relating to provider
registration, provider category, course accreditation and
qualiication. That is, they were organised according to
categories of regulator activity. The new standards, on
the other hand, are organised around categories more
relevant to higher education providers—that is, into
categories of provider activity. This should help providers
and prospective providers to use the standards for their
own internal quality assurance purposes.

Although the material has been substantially reorganised,

the fundamental sense of what components comprise
a good higher education provider remain the same. A
provider that met the intent, as distinct from the letter, of
the old standards is likely to meet the new standards in
all but a few areas. The new standards do, nonetheless,
contain signiicant shifts in focus if not substantive meaning.
For example, there is a greater focus on implementation,
rather than mere possession, of policies and processes.
Additionally, there is a signiicant focus on tailoring of
higher education delivery to individual students and
cohorts. Overall the orientation of the new standards is
towards principles rather than speciics, which means
fewer pages of standards overall (ifteen versus twenty-
four). The changes in focus have the potential to catch out
providers whose practice has not necessarily matched their
documented policies and whose efforts in supporting their
student cohorts have been limited, but the new standards
may also make demonstrating compliance easier for
providers working to provide good quality education to
their students.

While it is not possible to know in advance exactly how

changes to the standards will affect TEQSA’s regulatory
decision making, the nature of the changes does seem to
point towards a major pivot towards outcomes. Given the
dificulties inherent in actually regulating against outcomes,
it’s not clear this will result in a substantial change to
TEQSA’s regulatory approach.
In addition to the change in structure and focus, there are
some completely new additions, as well as some substantial
changes to existing requirements—some expansions, some
contractions and some total omissions.
 NEW ELEMENTS

For the most part the new additions are elements of good practice that now become obligatory.
For example, Sections 1.4.1, 1.4.2 and 1.4.5 include speciic requirements in relation to learning
outcomes that have no equivalent in the old standards. Well-written learning outcomes would
likely already meet the requirements of these standards; however, now it is obligatory that all
learning outcomes be of a quality suficient to do so.

A whole new section on diversity and equity (2.2) again makes good practice essential, as
do requirements for a critical incident policy (2.3.5), recording of research outputs (4.1.3),
expectations for research training (4.2) and information systems content and security (7.3.3).
Beyond basic good practice, the new standards also include signiicant new requirements around
public reporting. If there is one change in the new standards that is going to rufle feathers, it is
likely to be this.
From January 1 2017, providers will be required to publish online a range of information relating
to:
• formal establishment of the entity and regulatory status
• members of the governing body and senior executive
• inancial standing
• total student enrolments and annual enrolments per course

4 • org chart
• list of locations including overseas and an overview of facilities and services at each location
• any third party arrangements to deliver courses
• annual reports
• how to lodge a complaint
• contact details.

While most providers already provide access to some of this material, very few will currently be
publishing all of it.
CHANGED ELEMENTS
Admission, academic assistance and progression

These three components are no longer clearly separated, with admission assessments and RPL
now formally feeding into early assessments for the purpose of academic assistance. Admission
and academic assistance are now also notionally connected in the standards to student
performance measurement. While admission and academic assistance practices have always
been a lever for improvement of performance, in the new standards their connection has been
clariied, with admission through to performance measurement dealt with in standards clearly
following one from the other. The new standards formally specify monitoring of trends in student
performance data, which would have been expected though previously remained unstated.

Whereas in the past a provider must have had appropriate admission policies, now they must
also be documented and applied fairly and consistently (1.1.1). This is consistent with the new
standards’ overall shift towards effective implementation. Similarly, while the old standards
addressed policies in relation to assessment of prior learning, the new standards also require that
these assessments are undertaken, that their results are recorded and students advised (1.2.1).
While these actions would have been expected in the past, they are now formally required.

Admission processes now also must include assessment of individual students and cohorts
(1.3.2a) in order to establish needs and preparedness for study and also to link students to
appropriate academic support (1.3.2b), implemented across all courses of study (1.3.4). This
process is expected to continue once students are enrolled and studying, with early assessments 5
or reviews identifying needs for additional support. Formative assessment now must provide
students with timely feedback that assists in their achievement of learning outcomes (1.3.3)—that
is, when formative assessments are used, they must achieve their purpose. Again the theme
here is implementation of policy, but it also relates to the other major thematic change around
tailoring of higher education delivery to the needs of particular students and cohorts.

The pivot towards student outcomes is perhaps nowhere clearer than in section 1.3.6 of the
new standards, which speciies that students have equivalent opportunities ‘irrespective of their
educational background, entry pathway, mode or place of study’. The comparable section in
the old standards only speciied that course design was such that equivalent learning outcomes
were ensured, not referencing students at all.
 ASSESSMENT

Section 1.4.3 combines elements of PCAS 5.1, 5.3 and 5.5 in the old standards to explicitly
connect assessment methods with academic integrity and ensuring students assessments test
students for appropriate level of attainment. It is no longer suficient that assessments provide
opportunities for students to demonstrate achievement of learning outcomes—students now must
have demonstrated achievement of the learning outcomes on completion of the course (1.4.4).
The new standards also add a new speciication of expectations around integrity of assessment
for research higher degrees (1.4.6).

COURSE DESIGN AND REVIEW

The primary change relating to course design (putting aside the far more thorough speciication
6 of requirements relating to learning outcomes) is the new requirement that course content
includes new developments (3.1.2c)—speciically, “emerging concepts that are informed by
recent scholarship, current research indings and, where applicable, advances in practice.” This
formal linkage of scholarship to course design makes explicit the connection between stafing
and course design. This has the potential to catch out many providers that have been keeping
these elements separate—course content and course development could now potentially be
used by TEQSA as a way to address stafing. Providers buying in intellectual property they allow
to languish may ind this leads to more trouble than before, as TEQSA may be able to use this as
an indication of an issue with scholarship more generally.

The new standards now specify some of the elements that a course review must include (5.3.2)
and a minimum seven-year frequency for these reviews (5.3.1). It is now made clear that student
feedback must inform institutional monitoring (5.3.5); that monitoring, review, benchmarking
and student feedback are all part of risk mitigation in relation to academic quality (5.3.7); and
that regular monitoring must feed into course reviews (5.3.3).
STAFFING

In keeping with one of the general themes, a provider’s stafing complement must now be
tailored to the needs of its student cohorts (3.2.1) and must be tailored to the nature and level of
learning outcomes of their courses. Similarly, academic assistance provided by staff must now
be provided at a level “consistent with the learning needs of the student cohort.”

The other major change to stafing relates to which staff are covered by skill and knowledge
requirements. Qualiications, knowledge and skills requirements previously applying only to
teaching staff now extend to those with responsibilities for academic oversight and those with
supervisory roles in courses or units (3.2.3).

Scholarship requirements for academic staff are also now more substantial (continuing the
theme under ‘course design’). Each teacher, academic leader, course/unit supervisor must now
have "knowledge of contemporary developments in the discipline or ield, which is informed
by continuing scholarship or research or advances in practice" (3.2.3a). The greater emphasis
on ‘currency’ in course design extends to staff and applies to teachers, course supervisors and
academic leaders. This change has the potential to catch out providers that have worked to the
letter of the standard with stafing.

However, along with the tightening up of requirements for staff qualiications and scholarship
the new standards now include a caveat to allow for special cases—in particular staff teaching
specialist knowledge and teaching staff in training—where staff do not meet the full set of
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standards in relation to stafing. They can be employed in teaching roles provided they "have
their teaching guided and overseen by staff who meet the standard" (3.2.4).
 FACILITIES, SUPPORT SERVICES AND
LEARNING RESOURCES
The new standards go beyond the 2011 Threshold Standard speciication that there must be
some appropriate form of student meeting and recreation areas, to requiring speciically that
the learning environment must “support academic interactions among students outside of formal
teaching” (2.1.3).

Although it would be hoped already to be the case, it is now made clear in the standards that
library information and resources must be relevant and current (3.3.1). Following the tailoring
theme running through the new standards, the type and scope of support services available to
students must now be informed by the needs of the student cohorts (2.3.3), as must learning
support services (3.3.4).

Additionally, providers must now offer training to students and staff in operation of the LMS
(3.3.2), and must ensure avoidance of potential barriers to access to IT resources and specialised
teaching facilities (3.3.3). It is no longer enough simply to provide resources.

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CORPORATE GOVERNANCE AND
ACCOUNTABILITY
New corporate governance standards make clear that the corporate governing body (CGB)
is accountable for all higher education operations, including “for continuing to meet the
requirements of the Higher Education Standards Framework and for the provider’s representation
of itself” (6.1.1). An entity is now required to comply with its own constitution (6.2.1a)—previously
assumed, but now formally required. These requirements were taken by TEQSA as implicit in the
old standards—now that they have been made explicit, they will be more readily enforced.
On the other hand, requirements around external members have been relaxed—while the CGB
must still include at least two independent members, they now need not constitute a majority.
Nonetheless, inclusion of a majority of external members is still considered best practice, so
providers would be well advised to maintain this in practice for their own advantage—and while
TEQSA can no longer demand majority external membership, they may still question a board’s
independence if it is stacked with internal members or their associates.

Most changes to corporate governance requirements relate to action and implementation.

Previously delegations needed to be “appropriate, documented, observed and regularly
reviewed.” Now the corporate governing body is formally responsible for “monitoring the
implementation of those delegations” (6.1.3b). Again this is rifing on the general theme
of implementation. Similarly, whereas previously the governance arrangements needed to
demonstrate development, implementation and review of policies, now the CGB must conirm
that provision of higher education is in accordance with policies—i.e. that they are implemented 9
(6.1.3c). At a site visit, TEQSA could ask board members how they conirm implementation of
the provider’s policies and, if board members are unable to answer, this will demonstrate non-
compliance.

The focus on implementation and action makes more clear the responsibilities of a corporate
governance body. Independent reviews of the effectiveness of CGB and academic governance
processes must be undertaken at least every seven years and agreed actions must be implemented
(6.1.3d). Action must be taken to address underperformance against performance targets
(6.2.1b). Formal complaints, allegations of misconduct, breaches of academic or research
integrity and critical incidents are monitored and action is taken to address underlying causes
(6.2.1j). Non-compliance with the Higher Education Standards Framework must be identiied
and monitored, and prompt corrective action taken (6.2.1k)—it is now a form of non-compliance
to fail to appropriately mitigate against non-compliance.
What evidence could TEQSA possibly ask for in relation to these? Well, likely minutes of the
CGB or delegated committees. CGB activity compliance can no longer be assumed without
evidence as insuficient minutes can no longer be used as a cover—incomplete minutes are now
also a form of non-compliance, as the 2015 Standards require that a true record of the business
of the CGB must be maintained (6.1.3e).
 ACADEMIC GOVERNANCE

10 Academic governance receives a major change in that there is now no reference in the Standards
to an Academic Board or similar structure. In fact, there is no speciication of structure in relation
to academic governance. The overall focus is now on the outcomes of academic oversight—as an
abstraction rather than as a speciic structure.

While the agent of academic governance is no longer speciied, some of the agent’s actions are
more sharply deined. For example, there is now an explicit requirement to set and monitor quality
benchmarks (6.3.1b)—TEQSA can now ask, 'what benchmarks are set?' and 'how do you monitor
they are being met?' Being unable to provide an answer means non-compliance with a standard.

The agent/s of academic oversight are now clearly advisors and their advice is provided both to
the CGB and to management (6.3.1d)—this clariies ambiguity in the old standards around roles
and reporting. The agent/s of academic oversight are responsible for “critically evaluating the
quality and effectiveness of educational innovations or proposals for innovations” (6.3.2f) and for
“monitoring and reporting to the corporate governing body on the quality of teaching, learning,
research and research training” (6.3.2fh). Again following the theme of implementation, agent/s
of academic oversight are responsible for delegations of academic authority and also requires
action to conirm implementation (6.3.2b).
In summary, while academic governance is less precisely speciied in terms of structure, the
responsibilities that any agent/s of academic oversight take on are more speciic.
CONCLUSION

TEQSA has conirmed in a recent 2015 Threshold Standards overview that it intends to focus more
on evidence of implementation and effectiveness of policies rather than on the mere suitability
of documents. This is in keeping with the new Standards’ pivot towards action, outcomes and
implementation. However, it is not entirely clear how TEQSA will put this pivot into effect. After
all, outcomes are notoriously hard to measure, and action itself is invisible to a ‘desktop review’
regulator unless the action is crystallised into a form of documentary evidence. TEQSA has an
epistemological problem—it always has, although now the problem is exacerbated by a set of
standards that call for greater contextual awareness. In any case, providers would be advised to
take care that they can demonstrate measures to ensure implementation of policies, and to take
care they can demonstrate that their operations have been tailored, across all domains, to the
needs of their students.