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Repositioning Quality Assurance and Accreditation in Australian Higher Education Grant Harman V Lynn Meek Centre for Higher Education Management and Policy University of New England 00/2 May 2000 Evaluations and Investigations Programme Higher Education Division Department of Education, Training and Youth Affairs Instructions for pdf navigation Use the arrows on the Acrobat menu bar to navigate forwards or backwards page by page Alternatively, use the arrow icons on your keyboard to navigate through the document. To enlarge the viewing screen either: use the magnifying glass by clicking on the area you wish to enlarge or by forming a marquee over the area you wish to view (ie. hold the mouse button down and drag the magnifying glass over the area); or use the view options menu bar at the bottom of the Acrobat screen. To pan out from the page, hold down the option button on your keyboard to change the +ve symbol on the magnifying glass to a –ve symbol , then click the mouse. To search for a word or phrase use the binoculars icon on the menu bar. The Contents pages are live, ie. if you click on a topic you will go to that page. You can return to the Contents page by clicking your mouse on ‘Contents’ on the top of each page. CONTENTS

Transcript of Repositioning Quality Assurance and Accreditation in ...

Repositioning QualityAssurance and

Accreditation in AustralianHigher Education

Grant Harman

V Lynn Meek

Centre for Higher Education Management and Policy

University of New England

00/2

May 2000

Evaluations and Investigations Programme Higher Education Division

Department of Education, Training and Youth Affairs

Instructions for pdf navigation• Use the arrows on the Acrobat menu bar to navigate forwards or backwards page by page

• Alternatively, use the arrow icons on your keyboard to navigate through the document.

• To enlarge the viewing screen either:

– use the magnifying glass by clicking on the area you wish to enlarge or by forming a marquee over the area you wish to view (ie. hold the mouse button down and drag the magnifying glass over the area); or

– use the view options menu bar at the bottom of the Acrobat screen.

• To pan out from the page, hold down the option button on your keyboard to change the +ve symbol on the magnifying glass to a –ve symbol , then click the mouse.

• To search for a word or phrase use the binoculars icon on the menu bar.

• The Contents pages are live, ie. if you click on a topic you will go to that page.

• You can return to the Contents page by clicking your mouse on ‘Contents’ on the top of each page.

CONTENTS

CONTENTS

© Commonwealth of Australia 2000

ISBN 0 642 23992 4

ISBN 0 642 23993 2 (Online version)

DETYA No. 6474.HERC 00A

This work is copyright. Apart from any use as permitted under theCopyright Act 1968, no part may be reproduced by any process withoutpermission from AusInfo. Requests and inquiries concerning reproductionand rights should be addressed to the Manager, Legislative Services, AusInfo,GPO Box 84, Canberra ACT 2601.

This report is funded under the Evaluations and Investigations Programme ofthe Department of Employment, Education, Training and Youth Affairs.

The views expressed in this report do not necessarily reflect the views of the Department of Education, Training and Youth Affairs.

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Contents

Executive summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .v

1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

2 Quality assurance and accreditation . . . . . . . . . . . . . . . . . . . . . . . . .7Quality and higher education . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8The concept of quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9Quality assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11Related concepts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12Accreditation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14Main quality assurance approaches and methodologies . . . . . . . . . . . . . . . .16Concluding comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26

3 Australian higher education providers and current arrangements for accreditation and quality assurance . . . . . . . . . . . .29

International education enrolments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33Current accreditation arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .35Special protection for international students . . . . . . . . . . . . . . . . . . . . . . . . .50Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51

4 The changing quality environment and the Modern Australian Model . .53The changing quality environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53The Modern Australian Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .62Other options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63

5 Accreditation of courses and institutions . . . . . . . . . . . . . . . . . . . . . .73Responsibility for accreditation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74Greater uniformity of legislation, criteria and processes . . . . . . . . . . . . . . . . .76Reporting on accreditation of institutions and courses . . . . . . . . . . . . . . . . . .79Other compliance functions for accrediting agencies . . . . . . . . . . . . . . . . . . .79Staffing and resourcing of State and Territory accreditation agencies . . . . . . .80Links between accreditation and quality assurance . . . . . . . . . . . . . . . . . . . .80

6 Quality assurance and improvement plans . . . . . . . . . . . . . . . . . . . .81Comments on suggested model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .81Who should require and publish plans and links with institutional audits? . . . .83

7 Quality audits and a new quality agency . . . . . . . . . . . . . . . . . . . . .85Characteristics of and criteria for the new mechanism . . . . . . . . . . . . . . . . . .86Legal basis and structure of new agency . . . . . . . . . . . . . . . . . . . . . . . . . . .91Preferred model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .92Review teams will report to the Council. . . . . . . . . . . . . . . . . . . . . . . . . . . . .94

Appendix A Project brief . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .95Appendix B List of interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .99References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

TABLES AND ACRONYMS

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TablesTable 2.1 Main approaches and methodologies at the national level 17Table 3.1 Higher education accredited awards offered by private providers 31Table 3.2 Total ‘off-shore’ student enrolments of

major higher education providers, 1998 34Table 3.3 Largest off-shore enrolments in particular countries

by institutions, 1998 34Table 3.4 Legislation providing for accreditation of courses and institutions 35Table 3.5 Legislation relevant to the establishment and operation

of Australian universities 40Table 3.6 Summary of legislative protection offered nationally

to Australian universities 41

AcronymsAAU Academic Audit Unit

ANTA Australian National Training Authority

AQF Australian Qualifications Framework

AVCC Australian Vice-Chancellors’ Committee

CNAA Council for National Academic Awards

CNE Comite National d’Evaluation

CRUI Italian Standing Conference of Rectors

DETYA Department of Education, Training and Youth Affairs

HEFCE Higher Education Funding Council of England

NOOSR National Office of Overseas Skills Recognition

MCEETYA Ministerial Council on Employment, Education, Training and Youth Affairs

OECD Organisation for Economic Cooperation and Development

RAE Research Assessment Exercise

RTO Registered Training Organisation

TAFE Technical and Further Education

VET Vocational Education and Training

VSNU Association of Cooperating Universities of the Netherlands

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Executive summary

Introduction1. This report has been prepared for the Commonwealth Department

of Education, Training and Youth Affairs (DETYA) to assist indeveloping an improved national approach to both quality assuranceand accreditation. The current arrangements are inadequate andAustralia needs a more rigorous quality assurance and accreditationsystem: to protect the international reputation of our higher education;for public accountability purposes; to inform student choice; and topromote and improve quality processes and outcomes as well asdisseminate good practice.

2. Various models for a new approach to quality assurance andaccreditation have been reviewed, including refinement of the current Australian model, the recently modified New Zealand model,the new United Kingdom model, the model used by the VocationalEducation and Training (VET) system in Australia and a ‘ModernAustralian Model’.

3. The Modern Australian Model provides separate arrangements for both institutions which have been given power to accredit their owncourses and for non-self accrediting providers. For institutions withpower to accredit their own courses, the main requirements will be:(a) rigorous scrutiny of financial and quality aspects before foundinglegislation is passed or other authorisation is given; (b) annualpublication of Quality Assurance and Improvement Plans for theforthcoming triennium; (c) a quality audit of each institution every five years following a detailed self-assessment; and (d) compliancewith any additional measures which may be necessary to ensure themaintenance of acceptable high standards of degrees. For non self-accrediting providers, the main features may include: (a) rigorousscrutiny of provider capacity before accreditation; and (b) review ofprovider performance and accredited courses every five years.

4. The task for the project was to develop the Modern Australian Modelas an alternative to the other four models; advise under whoseauthority it should be run and whether a legislative base is needed;assess whether it would be sensible and appropriate to make use of the AQF; elaborate the possible nature of the five yearly

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self-assessments for self-accrediting institutions; comment on thedesirability of focussing on outcomes and standards as well asprocesses; consider how to achieve rigour and independence whileretaining the cooperation and confidence of universities; and advise on the role of professional associations within the model and thenature of the audit of the courses of non self-accrediting providers. We were requested to evaluate the Modern Australian Model againstthe following criteria: credibility; effectiveness; ability to provide legal clarity for students and providers; ability to promote and enhance improvement and good practice; how well the model couldbuild on the key features of the current system and possibly exploitthe role of professional associations in accrediting courses; minimumbureaucracy; and cost.

Quality assurance and accreditation5. Quality assurance in higher education is defined as systematic

management and assessment procedures adopted by a highereducation institution or system to monitor performance and to ensureachievement of quality outputs or improved quality. Quality assuranceaims to give stakeholders confidence about the management of qualityand the outcomes achieved.

6. Accreditation refers to a process of assessment and review whichenables a higher education course or institution to be recognised or certified as meeting appropriate standards. In Australia, the termaccreditation has developed three specialist meanings: a process ofreview or assessment conducted by a government agency to enable a Minister or approved authority to recognise and approve a highereducation institution or course; a process of review carried out by a government registration body to enable graduates of particularcourses to practise in the particular State or Territory; and a process of assessment and recognition carried out professional associations. In this report, we are primarily concerned with the first usage.

7. Quality in the context of higher education can be defined as ajudgement about the level of goal achievement and the value andworth of that achievement. It is also a judgement about the degree towhich activities or outputs have desirable characteristics, according tosome norm or against particular specified criteria or objectives.

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8. Over the past decade, extensive experimentation has taken placeinternationally with quality assurance and how it is managed. The literature reporting these developments points to tremendousvariety in approaches and methods. The main approaches can besummarised under the following headings: the agency or unit withresponsibility for the management of quality assurance; participationin reviews and other activities; the main methodologies employed; the focus of quality assurance activities; the purposes of suchactivities; and reporting and/or follow-up.

9. The most common pattern at national level is for responsibility to liewith a specialised government agency, or with the central departmentresponsible for higher education coordination. In a small number ofcountries, however, responsibility lies with an agency set up by highereducation institutions themselves.

10. An important variation between quality assurance systems is whetherparticipation is voluntary or compulsory. Many countries began withinstitutional audits on a voluntary basis. Generally, however, withnational reviews of disciplines, participation is compulsory and, evenwhen participation is voluntary, strong moral and professionalpressures usually produce in a high level of participation.

11. Most quality assurance mechanisms depend on one or a combination of a limited number of methodologies, the most important of which areself-studies or self-evaluation; peer review by panels of experts; use ofrelevant statistical information and perf o rmance indicators; and surveysof key groups, such as students, graduates and employers. At thenational level, the most common forms of assessment are ‘horizontal’reviews of disciplines and ‘vertical’ evaluations of institutions.

12. Quality assurance programs serve a variety of purposes but generallytheir primary purposes are a combination of public accountability,efforts to ensure credibility, improvement and renewal. In some cases, there is a gap between stated purposes and actual purposes,and frequently there is tension between accountability andimprovement purposes.

13. Reporting and follow-up activities are important, with a majorchallenge being to devise fair and effective methods likely to lead to improvements without damaging the institution being reviewed.Various approaches are used with regard to the distribution of reports. In some cases, reports are provided solely to the institutionconcerned but increasingly the practice is to make the results morewidely available.

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Higher education providers and current arrangements14. For the purposes of this study, Australian higher education providers

can be categorized into five distinct groups: public universities andother public higher education institutions established under State,Territory and Commonwealth legislation; non-government institutionswhich operate under their own legislation and have self-accreditingpowers; institutions not established by legislation but who have been given government approval to operate; private providers whose courses have been accredited by State or Territory accrediting agencies; and private providers whose courses have not yet been accredited.

15. Accreditation of higher education institutions and courses is under the control of State and Territory Governments who view thisresponsibility as flowing from their responsibilities for education underthe Commonwealth constitution. Generally, the relevant legislationmakes provision for private providers to secure accreditation andapproval to offer courses. In other cases, legislation provides foraccreditation of both institutions and courses.

16. The considerable differences between the provisions of State andTerritory legislation and the criteria and processes constitute a majorproblem needing attention. In a number of cases, legislation providescontrol over the use of the terms ‘university’ and ‘degree’, and overdegree titles. The most detailed legislative controls operate in Victoria,New South Wales, Queensland and Tasmania. Additional protection isafforded with regard to the establishment and recognition ofuniversities by other Commonwealth, State and Territory legislation.

17. Recently the States and Territories have agreed on procedures forconsidering applications and authorisation to offer higher educationcourses in two or more States and Territories, and operationalguidelines to achieve this were endorsed by MCEETYA in April 1999.

18. The current system of quality assurance operates at a number of levelsand includes the activities of professional associations and associationsand networks set up by groups of universities for benchmarking andother quality assurance purposes.

19. Internal quality assurance processes in universities include: assessmentof new courses and units of study; reviews of courses, units anddepartments; student evaluation of teaching; use of external examinersfor higher degree research theses and sometimes bachelors honourstheses; surveys of graduates and employers; use of performance

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indicators; benchmarking and participation in benchmarking networks;and special projects for the improvement of teaching and specialawards for teaching excellence.

20. The current national quality assurance mechanisms include: reports byuniversities on quality assurance and improvement plans;encouragement of innovation and good teaching; and publication ofCharacteristics and Performance of Higher Education Institutions.

21. Various professional bodies conduct accreditation of professionalcourses in fields such as medicine, law, engineering and architecture.Professional associations have formed a peak body, the AustralianCouncil of Professions.

22. Special Commonwealth mechanisms, consisting of legislation and aregister of courses, provide protection for international students. Forexample, The Education Services for Overseas Students (Registration ofProviders and Financial Regulation) Act 1991 helps ensure that onlyquality courses are offered to foreign students studying in Australia.

23. While there are various desirable characteristics of the current qualityassurance and accreditation arrangements, at the same time there areclear weaknesses that need attention. The major weaknesses inquality assurance is lack of a national agency that can publicly vouchfor the quality of Australian higher education while with regard toaccreditation there is need for uniform approaches and criteria acrossStates and Territories and a better system of reporting and providingpublic access to information concerning which courses and institutionshave been accredited.

Changing quality environment and the Modern Australian Model

24. Important recent changes have taken place in the quality assuranceenvironment. These can be categorised under the headings of:globalisation and changes in educational technology; internationalrecognition of qualifications; recent changes in quality assurance inother industrialised countries; new quality assurance arrangements in‘off-shore’ education countries; the needs of Australia’s educationexport industry; increased accountability pressures at home; incidentswith private providers and increases in the number of privateproviders; and complaints from applicants seeking accreditation.

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25. The Modern Australian Model of quality assurance and accreditationhas many strengths. It makes important distinctions between thefunctions of accreditation and quality assurance, and between thepossible treatment of self-accrediting institutions and non-selfaccrediting providers. DETYA documentation specifies that qualityassurance and accreditation mechanisms should satisfy a numberof criteria: the mechanisms relating to self-accrediting institutionsshould not be solely at their discretion; there needs to be someexternal review or audit of the claims made by institutions aboutquality and standards; the mechanisms should be credible withinternational and domestic interest groups and be able to protect theinternational reputation of Australian awards; the mechanisms shouldhelp satisfy Australian taxpayers of value for money; any auditmechanism should have rigour, but at the same time be cost effective,not unnecessarily intrusive and be able to retain the cooperation ofpublic universities; and the mechanisms should provide legal clarityfor students and providers and be able to promote good practice andfacilitate improvement.

26. Refinement of the current Australian model of accreditation and qualityassurance would provide valuable improvements but Australia’sarrangements would still fall far behind international good practiceand do little to provide additional safeguards for the education exportindustry, or to lend additional international credibility to Australianawards. The recently modified New Zealand Model provides for anational government agency but there is some uncertainty about howsuccessful will be the plan for the new agency to approve variousaccrediting bodies. The new United Kingdom model is still developingits procedures but to date its proposals have been somewhatcontroversial and have yet to secure support from the well-establisheduniversities. The current VET model of accreditation and qualityassurance is now well accepted in the VET sector and widelysupported by industry but this model does not appear suitable for the higher education sector.

27. Important models not canvassed in DETYA documentation are theDutch and French models of quality assurance. The Dutch model is based on a well-organised program of disciplinary reviews, whilethe French model uses both disciplinary reviews and institutionalaudits. The Dutch program is operated by the VSNU, the associationrepresenting the heads of Dutch universities, while the Frenchprogram is the responsibility of a special government agency.

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Accreditation of courses and institutions28. Any process of accreditation would need to be concerned primarily

with: approval for new universities to operate, to use the nameuniversity, and to offer degrees and other awards; approval andaccreditation of courses of study leading to degrees and other awardsby other higher education providers; and re-accreditation ofinstitutions and awards.

29. There is strong support for the proposition that accreditation is a matter for government and not the higher education sector, and that the States and Territories should continue to exercise theirresponsibilities in this area. Continuation and extension of the presentwork being undertaken by the MCEETYA Multilateral Joint PlanningCommittee seems likely to produce a professional national approachto accreditation.

30. To date the Multilateral Committee has put most of its efforts intodeveloping a common approach to the accreditation of universities.This has raised issues about the distinguishing characteristics ofuniversities today in Australia and what criteria should be used inaccrediting new and overseas universities. There differences in viewsover use of the titles of ‘university’ and ‘degree’. State and Territoryofficials see value in maintaining and strengthening current controlsover these titles.

31. Perhaps more important for the Multilateral Committee will be todevelop uniform protocols for the recognition of new and overseasuniversities and agreement on the criteria to be applied. Thereappears to be agreement that criteria should include topics such asfinancial viability, the legal basis of the institution, and the processesof governance, internal quality assurance and accountability but lessagreement about whether the criteria should include quantitativeindicators with regard to staff, buildings and facilities, and libraryholdings and specialised laboratories. Other issues that need attention include: protocols and procedures for the accreditation ofinstitutions other than universities; whether the recognition of newand overseas universities should automatically carry with it the rightsof self-accrediting powers; whether all institutions need some formof accreditation before their courses can be accredited; requirementswith regard to ‘out-state’ Australian institutions operating in otherStates and Territories; whether accredited institutions should berequired to seek special approval to offer courses to internationalstudents at special international student campuses; whether

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universities and other self accrediting institutions need specialapproval to enter into franchise arrangements to offer higher educationcourses with non accredited institutions such as VET providers; andwhether legislation in all States and Territories should provide for boththe accreditation of institutions and courses.

Quality assurance and improvement plans32. Continuation and strengthening of the current requirements of the

Commonwealth with regard to institutional quality assurance andimprovement plans appears to be a well-conceived and sensiblestrategy. Good management practice requires that all institutionsshould have in place appropriate quality assurance and improvementplans, and submission of these to some outside body provides usefuldiscipline for institutions to keep plans up to date. Such plans shouldcover all major aspects of operations, including ‘off-shore’ efforts anddistance education offered internationally.

33. While some universities have made major advances in benchmarking,this development has not been uniform across the sector and that itmay be helpful to provide additional assistance. Institutions should beencouraged to document in detail their monitoring and qualityassurance procedures for ‘off-shore’ efforts.

34. With regard to quality assurance plans currently required by DETYA, itwill be important that discussions take place with any new qualityassurance agency to ensure that DETYA requirements do not inconflict with any documentation requirements for institutional audits.

Quality audits and a new quality agency35. A non-intrusive and sensibly conceived quality assurance mechanism

involving both the higher education sector and the State andTerritories seems likely to attract considerable support. Certainly thereis wide appreciation of some of the strong influences that requireestablishment of a new national mechanism.

36. One important issue is the legal basis of any new agency, thegovernance structures to be employed and its accountabilityarrangements. In our discussions four main models were identified: a Ministerial Committee set up by the Commonwealth Minister;

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an agency established by Commonwealth legislation; an agencyestablished by joint Commonwealth and State legislation; and anagency set up as a company, possibly responsible to MCEETYA.

37. Our preferred model for the new quality assurance mechanism andagency is as follows:

• A new quality assurance mechanism should be established as ajoint Commonwealth, State/Territory, and higher education initiativewith the aim of strengthening public accountability, protectingacademic standards and the reputation of Australian higher edu-cation providers and awards, and promoting good practice inquality assurance. We suggest that the new mechanism shouldbe called the Higher Education Quality Assurance Council.

• The central function of the Council will be conduct of program of institutional reviews or audits. Review teams will carry out sitevisits, following completion of self-assessments carried out byinstitutions, which will include reviews of the processes ofmanaging quality including monitoring performance andbenchmarking. Institutions will provide review teams with areport of their self-assessments, together with documentationon institutional mission and objectives, quality assurance andimprovement plans, details on methods used to monitor andbenchmark achievements and the results of monitoring andbenchmarking. Participating institutions will be reviewed every five years.

• The Council will be established as an independent agency, at ‘armslength’ from both government (Commonwealth and State) and fromthe higher education sector. It will be governed by a board consist-ing of an independent Chair, two Commonwealth nominees, twomembers representing the States and Territories, two representativesof the higher education sector and one representative drawn fromthose professional associations involved in accreditation within thehigher education sector. The Executive Director will be an ex-officio member and the board will have the power to coopt up totwo additional members with special expertise in academic auditsand assessment. Commonwealth representatives will be appointedby the Minister for Education, Training and Youth Affairs, while thetwo State and Territory representatives will be appointed byMCEETYA. Members will serve four year terms.

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• Funding for the work of the Council will come from annual grantsfrom the Commonwealth and from the States and Territories, and annual membership fees paid by individual higher educationinstitutions who wish to participate in the program of reviews.

• The terms of reference of the Council will be as follows:

– to review within participating higher education institutions the mechanisms for quality assurance, monitoring performanceand academic standards, and enhancing quality;

– to publish the reports of reviews;

– to report publicly from time to time on the effectiveness ofquality assurance procedures in participating institutions, theextent to which procedures ensure academic standards andreflect good practice in maintaining and improving quality, and other relevant matters;

– to identify and disseminate good practice in quality assurance inhigher education; and

– to undertake and sponsor studies related to effective qualityassurance management practices and academic standards inhigher education.

• In carrying out reviews, review teams appointed by the Council willfocus particularly on:

– appropriateness of quality assurance and improvement plans inrelation to institutional contexts and missions;

– rigour of the mechanisms employed to review courses andacademic organisational units, and monitor performance againstinstitutional plans;

– effectiveness in monitoring outcomes and in benchmarking, bothnationally and internationally; and

– success in communicating the results of the monitoring outcomesand academic standards to stakeholders.

Review teams will report to the Council.

• Each year the Council will draw up a program of reviews for thefollowing year, after consultation with institutions likely to bereviewed.

• Review panels, generally of no more than five members, will beappointed by the Council. Members of review teams will be drawnfrom the higher education sector, the Commonwealth and theStates. Members may also be drawn from the professions andprofessional associations, and from business and industry.

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Review panels will normally visit institutions for two consecutivedays after the institution has completed a self-assessment andsupplied other documentation as required. Institutions offeringcourses ‘off-shore’ for international students should document indetail the procedures followed for safeguarding and monitoringquality, and the results of any assessments.

• Following the visit of the review team, the draft report will beforwarded to the institution for comment. Once the report iscompleted it will be considered by the Council and then published.Copies will be provided free to DETYA, State and Territory accred-iting agencies, all participating higher education institutions, andrelevant professional associations. For each review, a single reportwill be prepared and published.

• Should a review reveal serious weaknesses, the institutionconcerned will be given up to 12 months to correct weaknessesprior to a supplementary review. Failure to rectify weaknesseswould be a matter for DETYA to address (in the case of Common-wealth funded institutions) or for the relevant State or Territoryaccrediting agency. One possible action would be to remove thename of the institution from the AQF list of accredited institutionsuntil such time that as minimum standards are achieved.

• Every effort should be made to encourage private universities andnon self-accrediting institutions to participate in the review program.

• Prior to arrangements for the Council being finalised, the highereducation sector should be consulted about the proposed terms ofreference for the Council, the composition of the Council’s boardand the method of conducting reviews.

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Repositioning Quality Assurance and Accreditation in Australian Higher Education

1 Introduction

1.1 This report has been prepared for the Commonwealth Department ofEducation, Training and Youth Affairs (DETYA) to assist in developingan improved national approach to both quality assurance and accred-itation. The current arrangements are judged to be inadequate andDETYA considers that Australia needs a more rigorous quality assur-ance and accreditation system:

• to protect our international reputation in respect of both the quality of our educational processes and our standards;

• for public accountability purposes, particularly to satisfy thetaxpayer about value for money and that government subsidies are supporting education activities of an appropriate standard;

• to inform student choice, especially in the light of diversity ofofferings; and

• to promote and improve quality processes and outcomes atindividual institutions as well as disseminate good practice, leadingto overall system improvement (DETYA Project Brief 1999, p 3).

1.2 Various models for a new approach to quality assurance and accre d-itation have been reviewed, including refinement of the curre n tAustralian model, the recently modified New Zealand model, the newUnited Kingdom model, the model used by the Vocational Educationand Training (VET) system in Australia and a ‘Modern Australian Model’.

1.3 Refinement of the current model could include strengthening theinternal processes within universities through benchmarking andaccreditation by external agencies as well as some modification toexisting legislation relating to accreditation of new providers and newcourses, and modifications of guidelines relating to Corporations Law.

1.4 The newly proposed modified arrangements for quality assurance inNew Zealand will require providers to be quality assured through arecognised quality validation process in order to be eligible forgovernment funding. The Quality Assurance Authority of NewZealand, which will have responsibility for the quality of publiclyfunded tertiary education, will grant recognition to those bodies thatare able to provide credible and rigorous quality validation processesin the sector, rather than carrying out quality audits itself. Presumablythe New Zealand universities may seek to have quality validationcarried out by the Academic Audit Unit which was established in theearly 1990s (Malcom 1993).

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1.5 In the United Kingdom, quality assurance is the responsibility of theQuality Assurance Agency which was established in 1997, followingsubmission of the Dearing Report (Higher Education for the LearningSociety 1997) to the Blair Government. The Quality Assurance Agencyhas responsibility to assure

• the standards of awards;

• program outcomes against standards; and

• the quality of learning opportunities.

The new approach requires independent verification of programsdelivered to ensure that:

• they achieve their intended outcomes; and

• student achievement meets the standards required of the institutionfor its awards by reference to subject benchmarks and the views ofaccrediting bodies.

It is expected, for example, that Quality Assurance Agency reviewerswill interact with subject/departmental review processes withinuniversities, review overall academic management, and conductperiodic audits of overseas and other collaborative arrangements.While use will be made of members of panels from universities andthe professions, a considerable amount of audit effort will be carriedout by professional staff of the Agency.

1.6 The model of accreditation and quality assurance for the VET sectorhas been developed and further refined in recent years, followingestablishment of the Australian National Training Authority (ANTA).Under the Australian Recognition Framework that came into effecton 1 January 1998, initial registration of a training organisation isdependent on demonstrated capacity to meet National Core andrelevant Product/Service Standards, and any other requirement of therelevant State or Territory. Continuing registration is dependent uponcompliance measured through monitoring and audit. The Standardsrepresent the core requirement, which the organisation needs todemonstrate to the recognition authority to become registered.Training Packages, which are developed and validated by industry, areendorsed nationally by the National Training Framework Committee ofANTA and by Education and Training Ministers. The Standards alsospecify national competency standards and assessment guidelines, andAustralian Qualifications Framework (AQF) outcomes. Under theAustralian Recognition Framework, there is also provision for theaccreditation of courses where no relevant Training Packages exist.

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1.7 The Modern Australian Model for quality assurance and accreditationthat has been developed by DETYA seeks to build on current andrecent practice. It provides separate arrangements for both institutionswhich have been given power to accredit their own courses and fornon-self accrediting providers. For institutions with power to accredittheir own courses, the main requirements will be:

• rigorous scrutiny of financial and quality aspects before foundinglegislation is passed or other authorisation is given;

• annual publication of Quality Assurance and Improvement Plans for the forthcoming triennium;

• a quality audit of each institution every five years following adetailed self-assessment; and

• compliance with any additional measures which may be necessaryto ensure the maintenance of acceptable high standards of degrees.

1.8 For non self-accrediting providers, the main features of the approachmay include:

• rigorous scrutiny of provider capacity before course accreditation; and

• review of provider performance and accredited courses every five years.

1.9 The task for our project was to develop Model 5 (a Modern AustralianModel) as an alternative to the other four models; advise under whoseauthority it should be run; advise whether the framework would needa legislative base; assess whether it would be sensible and appropriateto make use of the AQF; elaborate the possible nature of the fiveyearly self-assessments for self-accrediting institutions; comment onthe desirability of focussing more than in the past on outcomes andstandards as well as processes; consider how to achieve rigour andindependence for the process while retaining the cooperation andconfidence of universities; and advise on the role of professionalassociations within the model and the nature of the audit of thecourses of non self-accrediting providers. More specifically, we wereasked to make a comprehensive assessment of the Modern AustralianModel against the following criteria:

• Credibility (how well the model would be credible with inter-national and domestic interest groups and potential customers,and the marketability of the arrangements);

• Effectiveness (ability to address learning outcome standards as wellas quality assurance processes);

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• Ability to provide legal clarity for students and providers;

• Ability to promote and enhance improvement and good practice;

• How well the model could build on the key features of theAustralian higher education system, where universities areestablished under State/Territory/Commonwealth legislation asautonomous institutions with the power to accredit their owncourses, and where higher education courses developed anddelivered by other providers are accredited by State/Territorybodies;

• How well the model could exploit the role of professionalassociations in accrediting courses;

• Minimum prescription and bureaucracy; and

• Cost (DETYA Project Brief 1999, pp 8–9).

1.10 The brief required consultation with key stakeholders (eg theAustralian Vice-Chancellors’ Committee (AVCC), State accreditingbodies, the National Office of Overseas Skills Recognition (NOOSR)and professional associations) as appropriate. A copy of the projectbrief is reproduced in Appendix 1.

1.11 In carrying out the project, we have interviewed a range of keystakeholders, reviewed relevant literature and analysed key documentsto which we gained access. A list of interviewees is provided inAppendix 2. Documents analysed included Commonwealth and State government reports and legislation; materials supplied by ANTAand the Australian Qualifications Framework Board Secretariat;materials from the Ministerial Council of Employment and Education,Training and Youth Affairs (MCEETYA); materials from the AVCC and professional associations; and material supplied by Universitiesand other higher education providers. As researchers, we acknowledgethe generous assistance we received from many individuals andorganisations.

1.12 For the purpose of this report, quality assurance in higher education is defined as systematic management and assessment proceduresadopted by an higher education institution or system to monitorperformance against objectives and to ensure achievement of qualityoutputs or improved quality. Quality assurance enables key stake-holders to have confidence about the management of quality and theoutcomes achieved. Stakeholders are individuals and groups who havea major interest in the higher education institution or system and itsachievements. This definition implies that missions, goals and objec-tives will be clearly specified and available to stakeholders; that

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appropriate procedures will be in place to monitor and reviewperformance; that the results of monitoring and review will beavailable to all stakeholders; and that mechanisms will be in place to ensure improvements in performance and the adoption of goodpractice. In any higher education system, it would be assumed thatquality assurance mechanisms would address particular issues ofconcern, such as the quality of awards during a period of rapidexpansion in student numbers, or the quality of courses offered tointernational students studying in Australia and for awards from anAustralian provider through some ‘off-shore’ arrangement.

1.13 In its generic form, accreditation refers to a process of assessment and review which enables a higher education course or institution to be recognised or certified as meeting appropriate standards. In Australia, the term accreditation has developed three specialistmeanings. The first is of process a review or assessment conducted by a government agency to enable a Minister or an approvedauthority, acting under the authority of appropriate legislation, toapprove or recognise a higher education course and/or award asbeing of an appropriate standard and being delivered in an approp-riate manner. In some cases, accreditation of a higher educationinstitution means that from then on it is able to accredit or certify thequality its own courses, while it other cases accredited institutionsmust also seek accreditation for each course. A second specialist useof the term accreditation in Australia is in relation to processes carriedout by a government registration body to enable graduates ofparticular courses to practise in the State or Territory. A third specialistuse is in relation to assessment and recognition carried out profes-sional associations in such areas as engineering, accounting, law andarchitecture. If a particular course is accredited, its graduates will beeligible for membership of the professional association. In this reportwe are primarily concerned with the first specialised Australian usageoutlined above.

1.14 One important practical and theoretical question is the relationshipbetween quality assurance and accreditation. Internationally,accreditation is often one of the main mechanisms of qualityassurance but, as already noted, this report is concerned primarilywith accreditation carried out by government agencies and relating inthe first instance to new providers and new courses. Qualityassurance, on the other hand, refers to processes of on-going review,assessment and monitoring that should apply to all recognisedproviders in order to ensure that courses and awards are of a highstandard and that institutional monitoring of performance is effective.

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While the standards and criteria used in the assessment of institutionsand courses should inform quality assurance mechanisms, there is noclear reason why the same agency should be responsible for bothaccreditation and quality assurance. At the same time it is obviouslydesirable that Australia should have an overall consistent and robustapproach to both quality assurance and accreditation.

1.15 In Chapter 2, a more detailed discussion is provided of the conceptsof quality assurance and accreditation.

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Chapter 2

Quality assurance and accreditation2.1 This chapter explores in greater detail the concepts of quality

assurance and accreditation. It also comments on the concept ofquality and other concepts related to quality assurance andaccreditation. A final section reviews in summary form the mainapproaches to the management of quality assurance at the nationallevel that have been adopted internationally over the past decade.

2.2 Quality and quality assurance have become key issues for highereducation internationally in the 1990s (Kells 1992; Kells and van Vught1988; and Craft 1992 and 1994). In many countries, managers ofhigher education systems and institutions are concerned about qualityand how to put in place appropriate quality assurance mechanisms.Governments are concerned about the costs of providing credibleacademic and professional awards and the need to ensure thatstandards are maintained at an appropriate level, while rapid increasesin enrolments and often falling financial support per student unit raisedoubts about whether quality is being maintained. Quality issuesdominate the higher education debate in many countries, as ministers,bureaucrats, employers and business interests become increasinglyconcerned about the outputs of higher education institutions and thesuitability of graduates to meet the needs of employers. Many peoplequestion whether their societies are getting real value for their massiveinvestment in higher education and urge the adoption by governmentsof mechanisms to achieve more control over the work that highereducation institutions do. Quality and accountability thus havebecome key elements in the efforts of many countries to become andremain internationally competitive in a world where interdependencein trade is rapidly growing. Apart from this, there is more emphasison quality associated with increased mobility of professional andskilled labour, and the greater need for recognition of qualificationsacross national boundaries. As Craft (1994, p viii) points out:

‘globalisation’ and international migration mean thatacademic and professional qualifications need to be ‘portable’a c ross national borders, and so both institutions and nationstates are keen to learn more about each other’s pro c e d u re sfor assuring the quality of tertiary education pro v i s i o n .

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2.3 The main issues in the quality debate about higher education in manycountries are the maintenance and improvement of levels of teaching,learning, research and scholarship; improvements in the quality andadaptability of graduates; how to define and measure quality;management approaches likely to improve outcomes from universitiesand colleges; the use of benchmarking and performance indicators;and how to convince stakeholders that institutions and systems aredoing a competent job in ensuring quality outputs.

Quality and higher education2.4 In one sense, the quality debate in higher education is not new,

although in the past universities and government agencies useddifferent terms such as academic standards, standards of degrees anddiplomas, student assessment, and accountability (Harman 1994).In the past too, the main issues in the quality debate were largelyabout maintaining academic standards according to some nationalor international norm, the maintenance and improvement of levels ofteaching and learning, and how to provide sufficient financial andother resources to achieve quality higher education. Many of theseissues are still important today, but the new quality debate is largelyabout the achievement of quality outcomes; the establishment ofappropriate management processes to monitor achievement and theextent to which specified goals and objectives are being met; assessingthe suitability of graduates for the workforce and professions; andproviding information to stakeholders in order to assure them of thequality and credibility of outputs. One of the big differences betweenthe old quality debate and the new quality debate is that, while theold was concerned largely about inputs and national and internationalacademic standards, the new is much more concerned about manage-ment processes and their effectiveness, the assessment of outputs andmonitoring performance, and how well outputs meet employer andother needs.

2.5 Various studies and papers produced over the past decade or so havedocumented key aspects of the quality debate in OECD countries, andin major geographic regions such as Western Europe and NorthAmerica (eg, Ball 1985; Sizer 1990; Frazer 1991; Neave 1991; Williams1991; Anwyl 1992; Craft 1992; Lindsay 1992; van Vught andWesterheijden 1992; Lindsay 1994; Craft 1994; and Harman 1996a).

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But quality is also becoming a major issue in the higher educationsystems of Asia and the Pacific, although within the region there arevery considerable variations about how quality issues are perceivedand in the priorities that different governments and higher educationsystems are giving to tackling quality problems.

The concept of quality2.6 The recent international literature on quality and quality assurance

in higher education reveals considerable difficulties and ambiguities in the definition of a number of key terms. This is not surprising asquality deals with a number of complex notions. For example, in theliterature only in the widest sense is there broad agreement aboutwhat quality is, and how to define a number of key concepts used in the current debate about quality. Within many universities too,there are often quite surprising variations of views about the essentialelements of quality, about what characteristics of institutional work areregarded as being of the greatest value and why, and what constitutesacademic performance at the highest level and how such performancecan be recognised. Sometimes too there is disagreement within manyhigher education institutions about what constitutes good teaching,and about which graduates have the most valued characteristics. Apart from this confusion and lack of agreement, scholars interestedin researching quality issues differ significantly in their views aboutkey terms. Many see quality as a relative concept, meaningful onlyfrom the perspective of particular judges at particular points of time,measured against some either explicit or implicit standard or purpose.But despite these differences in views, there is an increased degree ofconsensus emerging about key terms. For this report we draw on thisgrowing consensus and set out a number of working definitions.

2.7 Apart from differences of views in the academic debate, managers and experts in educational measurement for many years have beenwrestling with difficult technical questions about such matters asmeasuring academic performance of students, comparing academicstandards over time and between different institutions, and devisingmeans to ensure that teaching in academic departments or institutionsis of consistently high quality.

2.8 By quality in the context of higher education, we mean a judgementabout the level of goal achievement and the value and worth of thatachievement. It is a judgement about the degree to which activities oroutputs have desirable characteristics, according to some norm or

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against particular specified criteria or objectives. Ball (1985) refers to quality as ‘fitness for purpose.’ According to this definition, a courseof study in a higher education institution is of satisfactory qualitywhen it conforms to the particular standards or levels of achievementfor the purpose it was designed. In the absence of any overall agreedstandards in a higher education system, it is necessary for institutionsto specify their mission, goals and objectives and then be evaluatedagainst these.

2.9 While the variety of different definitions of quality can be confusingand frustrating, different perspectives on quality have their positiveaspects. The value of different perspectives can be well illustratedfrom the work of the American scholar, Robert Birnbaum, who in astudy of American college presidents reports on three different viewsof quality in higher education that he found in practice. (Birnbaum1994). He describes these as the meritocratic, social, and individualisticviews of quality. With the meritocratic view, Birnbaum found thatcollege presidents assess quality in relation to conformity to someinstitutional or universalistic professional or scholarly norm, andso generally use the academic profession as a reference group. Those presidents who take a social view of quality base theirjudgements on assessment about the extent to which the institutionsatisfies the needs of important constituencies and audiences -whatpeople have now come to refer to as the stakeholders. Thus thereference point are the views of a particular community. Presidentswho take an individualistic view emphasise the contributions that theinstitution makes to the personal growth of students, using theindividual learner as the reference point.

2.10 Lindsay (1992) has categorised key approaches differently, identifyingtwo distinct approaches to discussions of quality in higher education.One approach, which he terms the ‘production-measurement’ view,treats quality as a synonym for performance, and so discussions ofquality revolve around the definition and measurement of resourcesand outcomes. The other approach, which Lindsay terms the ‘stake-holder judgement’ view, is based on assessments by various key actorsinvolved in higher education. These assessments may incorporate‘imponderable elements of our conceptions of educational processesand outcomes, and their dependence on contested value positions’(Lindsay 1992, pp 154-156).

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2.11 Middlehurst (1992) usefully identifies four different ways that the termquality has been used in the recent higher education debate, primarilyin the United Kingdom. These are quality as a defining characteristicor attribute; quality as a grade of achievement; quality as a particularlyhigh level of performance or achievement which, by virtue of generalconsensus and reasonable stability over time, comes to be seen as astandard against which to judge others; and quality as fitness forpurpose achieved through performance that meets specifications.

Quality assurance2.12 The term quality assurance has come into the higher education

vocabulary only over the past decade or so. While there are manydefinitions of quality assurance in the literature (eg, see Ball 1985;Birnbaum 1994; Lindsay 1992; van Vught and Westerheijden 1992), inessence, as already noted, quality assurance refers to systematicmanagement and assessment procedures adopted to monitor perform-ance and achievements and to ensure achievement of specified qualityor improved quality. Some authors (eg Brennan 1997) prefer use ofthe term quality assessment instead of term quality assurance.However, while a great deal of effort in quality assurance relates toquality assessment, quality assurance in this report is thought of as abroader term which embraces not only assessment but also otheractivities including, for example, follow-up efforts aimed to achieveimprovement.

2.13 While the concept of quality assurance is new, many of the ideasbehind the concept are by no means new. What is new, however,apart from the new language, is a more systematic and far reachingapproach to monitoring performance and ensuring that institutionsand systems have in place appropriate and effective mechanisms forreview and assessment, and for renewal and improvement. Comparedwith past approaches, the new mechanisms also put much moreemphasis on external scrutiny, seeking the views of employers andgraduates and, in various ways, making the results of assessmentsmore widely available.

2.14 The quality assurance movement of the past decade has sprung froma variety of factors. As already noted, particularly important have beencommunity and government concerns about academic standards andthe levels of achievements of graduates in a time of major expansionin student numbers associated with decreasing government fundingsupport per student unit. But the quality assurance movement has also

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been driven by the impact of increased international competitiveness,the need for increased mobility of professional labour, demands forgreater accountability by public institutions which flows from theemergence of the ‘evaluative state’ (Neave 1997), concerns related tothe expansion of private higher education, and pressure fromemployers and the professions for university courses to become morerelevant to work place needs.

2.15 Quality assurance has become a particularly important element inthose higher education systems which have adopted a self-regulationapproach to relationships between government and higher education.With this approach, governments set the policy framework and steerfrom some distance but put a major emphasis on monitoringperformance (van Vught (1994b). Thus quality assurance becomes of vital importance. In addition, quality assurance becomes of greatimportance in countries where, as a result of increased governmentemphasis on competition, market forces and encouragement of privateproviders, there are community concerns about the possibility ofquality being sacrificed in the search for profits.

2.16 Rajavaara (1998) has developed a typology of four different types of quality assurance: political-administrative; citizen-based; business-oriented; and professional. Under the political-administrativetype, the main approaches used are legislation, service standards andquality indicators. Under the citizen-based type, the main approachesare action groups concerned about quality and the introduction ofalternative social models. The business-oriented type is distinctivelydifferent depending on Total Quality Management, ISO 9000, qualityawards and benchmarking, while the professional type dependsmainly on professional training and professional ethics, professionalaudits, peer review and self evaluation.

Related concepts2.17 There are a number of related concepts that are frequently used in

discussion about quality. The most important of these are qualitycontrol, quality audit, quality assessment, quality management andself-study.

2.18 Quality control refers to the processes or mechanisms within aninstitution or system used to ensure compliance with quality standardsor achieve improvements in performance. It is about evaluating andguaranteeing standards. The term appears to have been adapted from

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industry where quality inspectors or quality controllers, somewhatindependent of the main workforce, monitor the production processand particularly the quality of outputs. Experience in industry hasshown that it is not sufficient to have an efficient quality monitoringgroup, but rather the workforce as a whole needs to be convinced of the importance of quality in order to achieve the highest levels of production performance. In higher education, quality control canfocus on inputs, outputs, the mechanisms used to monitor quality, or some combination of these.

2.19 Quality audit refers to the processes of external scrutiny used toprovide guarantees about the quality control mechanisms in place.Quality audit is based on the ideas of self-study and peer review, andon the notion of a detailed report which becomes available to theinstitution to assist in improving procedures and achieving enhancedoutputs. The concept was developed and popularised following theestablishment of an Academic Audit Unit in 1990 by the Committee ofVice-Chancellors and Principals in the United Kingdom (Frazer 1991).

2.20 Quality assessment has come to mean a review or systematic exam-ination, usually conducted externally, to determine whether qualityactivities comply with planned arrangements and whether the‘product’ (the educational process) is implemented effectively and issuitable for achieving the stated objectives. However, there are somedifferences of opinion in the literature as to whether the focus is, orshould be, on the mechanisms to achieve quality, or the educationalprocess and outcomes, or all of these.

2.21 Quality management has come to refer to the management of qualitycontrol and quality improvement, and to those aspects of the overallmanagement functions that determines and implements the qualitypolicy. (van Vught and Westerheijden 1992). It is also about the designand maintenance of quality assurance mechanisms.

2.22 The term self-study has come from the work of American accreditationagencies and refers to the internal preparation of detailed evaluationdocument to be presented to an outside review panel who will visitthe institution and provide a written report. Many quality assuranceapproaches put a major emphasis on a self-study or self-evaluation.

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Accreditation2.23 The term accreditation in higher education originally came from

the United States, but over the years many of the key ideas have been adopted by professional associations and government agenciesinternationally. This section will briefly review the development of voluntary systems of accreditation in the United States and morerecently the development of accreditation by professional bodies and government backed accreditation systems in Britain andCommonwealth countries.

2.24 In the United States, for almost a century accreditation has beenassociated with quality assurance processes in higher educationassociated mainly with voluntary self-regulation carried out byprofessional accrediting organisations and regional accreditingassociations, independent of government. Today there is a widevariety of professional accrediting organisations covering traditionalprofessional areas such as medicine, engineering, law, dentistry andarchitecture and well as many newer occupational areas. Suchassociations accredit particular courses of study. Regional accreditingassociations, on the other hand, accredit institutions (Dill 1997).

2.25 In the 1980s, in addition to the traditional processes of voluntaryaccreditation, a new quality assurance mechanism emerged in theUnited States under the rubric of assessment. By 1990, over two thirdsof the states had passed legislation encouraging public institutions ofhigher education to implement various forms of student assessment,designed to place greater institutional attention on the improvement ofstudent learning. Ultimately, all five regional accrediting associationsalso adopted an assessment criterion as one of their criteria forreviewing institutions of higher education.

2.26 In the 1990s the United States moved to establish a much morecomprehensive national system of quality assurance beginning withpassage of amendments to the Higher Education Act of 1992 whichinvolved the Federal Government for the first time in quality assur-ance. This legislation required States to create State PostsecondaryReview Entities with responsibility for reviewing the quality of allpostsecondary institutions and their eligibility for federal studentfinancial aid. In addition, under pressure from the Federal Departmentof Education the various accreditation agencies formed a NationalPolicy Board on Academic Accreditation, which proposed morerigorous national standards for academic accreditation with particularemphasis on student learning. These changes were widely expected to lead to a more rigorous national system of quality assurance but,following the 1994 Congressional elections, Federal funding for the

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proposed State Review Agencies was eliminate. The following yearproposals from the National Policy Board on Academic Accreditationwere rejected by public and private higher education institutions (Dill 1997, pp 15–16).

2.27 Prompted by the new pressures for strengthening quality assurance,over the past decade important changes have been made to thetraditional American approach to accreditation in response to publiccriticism. This has led many of the regional accreditation associationsto revise key elements of their approach, resulting in more emphasison assessment of quality management mechanisms within institutions,reconsideration of the practice of making reports available only tothe institution concerned, and making the results of accreditationprocesses more generally available to the public (Crow 1994).Accreditation agencies now have more detailed guidelines with clearlyspecified evaluative criteria. While there is considerable variationbetween accrediting agencies, detailed written guidelines generallyfocus on four main areas:

• organisational and administrative matters;

• resources currently available to the unit (including financialresources; personnel; space and equipment);

• the curriculum; and

• statistics showing the performance or other outcomes for graduates(El-Khawas 1993).

2.28 Over the past three decades, accreditation systems on the Americanmodel have been established in many countries of Asia and LatinAmerica. In the Asian region, accreditation systems play a key role inthe higher education systems of Japan, Korea, Taiwan and thePhilippines. In the Philippines, a system of voluntary accreditation wasdeveloped among private colleges in the 1960s, but only in the lastdecade has this been extended to public universities and colleges(Arcelo 1992). Recent efforts have attempted to strengthen accreditingagencies and their procedures. The Federation of Accrediting Agenciesof the Philippines, for example, has developed common accreditingstandards, while a Congressional Commission recommended that thepolicies and practices of the accrediting agencies be reviewedperiodically (Cooney and Paqueo-Arrezo 1993). Similarly, in Taiwan,well-established accreditation systems have been strengthened withacademic associations being given an enhanced role (Su 1993). In Latin America, accreditation systems operate in Brazil, Colombiaand Chile (Ayaraza 1994), although generally there is not a strongtradition of quality assurance, despite the extensive expansion ofprivate higher education.

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2.29 In Britain and many Commonwealth countries, somewhat similarmechanisms were developed for accreditation of courses by profes-sional associations and government registration boards, and foraccreditation or validation of courses in non-university sectors. Accred-itation by professional associations goes back certainly to the preSecond World War period, although for many countries the historyof these mechanisms is not well documented. Accreditation conductedby government agencies was first developed for non-university highereducation and the particular approach of the Council for NationalAcademic Awards (CNAA) in Britain soon became the model adoptedby many Commonwealth countries. In 1990, for example, such asystem was established in Hong Kong for non-university institutionswith the tasks of advising on academic standards and validating degreecourses offered by the two polytechnics, Lingnan College, the Academyfor Performing Arts and the Open Learning Institute (Tsim 1993).In Australia, the current accrediting functions carried out by a numberof State and Territory agencies grew out of the accrediting bodies foradvanced education which operated in the 1970s and 1980s.

Main quality assurance approaches and methodologies

2.30 Over the past decade or so extensive experimentation has taken placewith quality assurance and how it is managed. The literature reportingthese developments points to tremendous variety in approaches andmethods, and also to a significant degree of borrowing by nationalsystems of higher education from one another. While such borrowing isto be commended, it is important that any procedures and approachesfit well within the culture of the particular system or institution. AsCraft (1994 p ix) has warned, ‘procedures need to be adopted andadapted with care and sensitivity if the quality assurance/accreditationmovement is not to be a new form of cultural imperialism’. Qualityassurance policies in most countries currently are in a process of rapidevolution and change, although at the same time there is an increasingconvergence internationally in terms of approaches.

2.31 The main approaches to quality assurance management are summ-arised in Table 2.1 which is drawn from a published paper by one ofthe authors (Harman 1998). This table sets out under separate categ-ories information on the agency or unit with responsibility for themanagement of quality assurance; participation in reviews and otheractivities; the main methodologies employed; the focus of qualityassurance activities; the purposes of such activities; and reportingand/or follow-up activities.

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Table 2.1 Main approaches and methodologies at national Level

A. Responsible agency/unit

• Unit or section within a Government agency

• Separate quality assurance agency established by Government

• Separate agency established collectively by higher education institutions

• Agency established jointly by Government and institutions

B. Participation in reviews and other activities

• Voluntary

• Compulsory

• Voluntary, with some measure of pressure/persuasion

C. Methodologies of review and assessment

• Self study or self evaluation

• Peer review by panels of experts, usually with use of external panelmembers and site visits

• Analysis of statistical information and/or use of performanceindicators

• Surveys of students, graduates, employers, professional bodies

• Testing the knowledge, skills and competencies of students

D. Focus

• National reviews of disciplines

– reviews of research only

– reviews of teaching only

– reviews of combination of research, teaching, and other activities

• Institutional evaluations

– reviews of teaching only

– reviews of research only

– reviews of quality assurance processes

– comprehensive reviews usually including teaching, research,management, and quality assurance processes

• Comprehensive national evaluations of higher education system

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E Purposes

• Accountability

• Improvement and renewal

• Combination of purposes

F. Reporting and follow-up activities

• Report provided solely to the institution or unit concerned

• Report provided to the institution or unit but also published or made more widely available

• Formal reports provided to the Minister, Ministry, or coordinating board

• Public reporting

• Use of ranking and wide publication of the results of such ranking

• Performance funding

• Accreditation or validation

• Improvement and renewal activities

Administrative responsibility2.32 The most common pattern at national level is for responsibility to lie

with a specialised unit or agency set up by Government, or with thecentral agency responsible for higher education coordination, whetherit be a Ministry or a University Grants Commission. Thus in Denmarkthere is the Evaluation Centre set up by the Government with amandate to initiate evaluation processes, develop appropriate methodsfor assessing academic programs, inspire and guide institutions inquality and evaluations, and compile information on national andinternational experiences (Thune 1994). Somewhat similar arrange-ments operate in France, Finland, Korea, and Thailand. On the otherhand, in Sweden control of quality assurance lies with the SwedishNational Higher Education Agency while in South Africa the HigherEducation Quality Committee is a sub-agency of the Commission forHigher Education (Strydom 1997).

2.33 The two major issues concerning government quality assuranceagencies are what degree of independence they should have bothfrom Ministers and from major ministries and departments, and whatlinks there are between quality assurance and funding. In summary,the main arguments for a high degree of independence are that suchindependence will lead to greater trust and confidence, and enhanceprofessional judgments, whereas others argue for government control

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in order to integrate quality assurance more closely with planningand coordination. An agency with considerable independence fromthe Minister and the agencies of executive government is the FrenchComite National d’Evaluation (CNE) which reports to the Presidentand is independent of the Prime Minister, the Minister of Educationand other executive agencies (van Vught 1994a). In other cases,attempts have been made to ensure that the management of qualityassurance is captured neither by the Ministry nor by the highereducation institutions; in Finland, for example, the Higher EducationEvaluation Council is made up of 12 members appointed by theMinistry, together with re p resentative of universities (4), polytechnics ( 4 ) ,student organisations (2) and business and industry (2) (Liuhanen 1997).

2.34 In a small number of countries, responsibility for aspects of qualityassurance at the national level is under the control of an agency setup by higher education institutions themselves. Such examples arefound in the Netherlands, Italy and in New Zealand (at least up to thepresent), where quality assurance programs are conducted by agenciesset up by the peak association of universities. In the Netherlands, thecurrent system of quality assurance for both the University and thenon-University sectors sprang from a restructuring in the mid-1980s of the relationship between the Ministry of Education and Science and higher education institutions. An understanding was developedthat, in exchange for a greater degree of financial and managerialautonomy, the institutions would demonstrate that they were offeringquality education. Originally it was planned that this assessment ofquality would be a responsibility of the Inspectorate for HigherEducation but, in the end, after negotiations, the two voluntary bodiesrepresenting higher education institutions in both university and non-university sectors respectively agreed to take responsibility.However, follow-up activities are the responsibility of the Inspectorateof Higher Education, an independent body set up by the Government(Zijderveld 1997). In Italy since 1992 an important role in qualityassurance has been performed by the Italian Standing Conference ofRectors (CRUI) which stimulates reflection and dialogue on issuesrelated to the establishment within universities of periodic evaluationpractices, and provides assistance to universities in setting up theirinternal evaluation systems. The CRUI has also created a commoninformation system based on evaluations (Boffo and Moscati 1997).The New Zealand scheme for University audits has been under thecontrol of universities rather than the Government (Malcom 1993).

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2.35 An example of joint government-university control is in Korea whereresponsibility lies with both the Ministry of Education and the KoreanCouncil for University Education. In 1992, the Ministry and the Councilagreed to establish an independent accreditation body within theCouncil, called the Council of University Accreditation. The latter bodyis composed of 16 representatives from universities, industry andgovernment. The Ministry of Education and the Korean Council forUniversity Education jointly decide annually which universitydepartments will be evaluated, while the Council for UniversityAccreditation consults with relevant professional associations andorganises accreditation committees made up of university staff. Aftereach evaluation, staff of the Korean Council for University Educationreviews reports and produce total scores for each department, leadingto grading of departments as good, moderate, or poor. The list ofgood departments is announced and reports and documentation areconsidered by the Ministry of Education’s Advisory Council for HigherEducation (Lee 1993).

Participation in the program2.36 An important variation between quality assurance systems is whether

participation is voluntary or compulsory. Many countries began withinstitutional audits on a voluntary basis. Thus, in Britain theinstitutional audits run by the AAU were voluntary (Williams 1991),while the Research Assessment Exercise run by the Higher EducationFunding Council of England (HEFCE) for the funding councilscontinues to be based on the principle of voluntary participation. In Finland, when the Ministry of Education launched the program of university reviews in 1991 on an experimential basis, twouniversities—Oulu and Jyvaskyala—volunteered to be involved. When the Evaluation Centre was set up in Denmark one of its three guiding principles was that participation would be voluntary(Thune 1994).

2.37 Generally, however, with national reviews of disciplines participation iscompulsory and even when participation is voluntary strong moral andprofessional pressures usually result in a high level of participation.

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Methodologies2.38 Most quality assurance mechanisms depend on one or a combination

of a limited number of key methodologies, the most important ofwhich are self studies or self evaluation; peer review by panels ofexperts; the use of relevant statistical information and performanceindicators; and surveys of key groups, such as students, graduates and employers.

2.39 Self studies have proved both effective and cost efficient, achieving a high degree of ownership since key staff are heavily involved andsuch involvement increases the chances of improvements beingachieved. Experience points to the value of combining self-studieswith external peer review to ensure that evaluation is taken seriouslyand outside perspectives are included.

2.40 Self-studies first developed in the United States with institutional andcourse accreditation, but over the last decade or so it have become animportant feature of many quality assurance systems. Self-studies havemany positive features: they are cost effective, since the main work isdone internally, often with little additional resources being necessary;they usually achieve a high degree of ownership since key staff areheavily involved and such involvement increases the chances ofsubstantial improvement being achieved; and the process of review or assessment is made less threatening. On the other hand, experiencepoints to the value of combining self study with some element ofexternal peer review, especially to ensure that the self-study is takenseriously and to bring in outside perspectives. Combination of self-study with external peer review provides a strong incentive forstaff to take the activity more seriously. One of the strongest pressures on any group of academics is the prospect of being judged by seniorpeers in the discipline.

2.41 Peer review is a well-established academic process and generallyworks well provided external members are included and panelmembers show respect for the values of those being evaluated andaccept that often their main contribution will be in assisting with self-learning. At the same time, it must be recognised that peer reviewcan easily introduce outside values and constructs. In its traditionalformat, peer review generally involves a visit by a group of well-regarded academics in the particular field but recent practice,especially for reviews of programs or disciplines, has been to addother experts to panels, such as persons from industry or business,practising professionals, or elected public officials.

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2.42 External reporting often is thought necessary in order not only toensure accountability requirements but that staff take a self-studyseriously. Related questions are to whom should external reports go,and how widely and publicly should such reports be distributed.

2.43 Most evaluations combine self-study with the use of statisticalinformation and/or performance indicators, and now frequently theresults of surveys of students, graduates and employers. In some cases,a national program of reviews is accompanied by the use of nationalstatistical collections and published performance indicators. In the caseof France, for example, the CNE quality assessment disciplinaryreviews begin with self-evaluation reports produced by the institutionsbeing reviewed and statistical reports produced by the CNE, govern-ment offices and the institution (van Vught 1994a). In Finland, anextensive nationwide university data base (KOTA) was established inthe late 1980s, containing key statistics about university performanceby institutions and disciplines (Liuhanen 1997). This data base coversthe following topics: applications for admission; home and foreignstudents; degrees including the duration of masters degrees; teachingand other staff; appropriations; premises; graduate placements;continuing education; open university instruction; researcher visitsabroad; scientific publications; and the target number of degreesagreed in Ministry-University consultations.

2.44 In a number of counties, particularly the United States, variousinitiatives have been taken to develop tests to assess student know-ledge, skills and competencies. The main efforts here have been atinstitutional level, although there are examples of statewide initiatives.By 1990, over two thirds of states had passed regulations encouragingpublic institutions of higher education to implement various forms of‘student assessment programs’ designed to place more emphasis onimprovement of student learning. Regional accrediting bodies alsohave adopted new assessment criteria for reviews of higher educationinstitutions (Dill 1997).

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Focus2.45 At the national level, the most common forms of assessment are

‘horizontal’ reviews of disciplines and ‘vertical’ evaluations ofinstitutions. Reviews of disciplines are usually carried out by panels of experts using site visits and analysis of documentary information,much of which is usually produced by the academic units beingreviewed. Some disciplinary reviews concentrate on teaching only,some on research only, while others look at both teaching andresearch. Generally disciplinary reviews result in published reports,with often detailed comments being made on the work within eachdepartment or faculty.

2.46 Institutional reviews include academic audits of quality assuranceprocesses and outcomes, and more extensive comprehensive reviews.The international practice of institutional academic audits has beenconsiderably influenced by the methodology developed a decade agoby the AAU in the United Kingdom. Under this approach, the focus isa meta-evaluation of the mechanisms and approaches to qualityassurance management, rather than an assessment of the qualityachieved. Institutions are visited by small teams of academics,following a ‘negotiated invitation’, and these teams make an on-siteaudit using a checklist of good practice. A general report is preparedfor the university as a whole, while confidential reports on sensitiveissues are produced for the Vice-Chancellor. Practice varies onwhether reports are published, and whether the results are reportedofficially to the government or funding agency.

2.47 In a number of countries, there is a long tradition of periodic national,comprehensive reviews of higher education, often conducted byspecial committees or panels. Thus in Britain, there was the RobbinsCommittee in the 1960s and more recently the Dearing Committee,while in Australia parallel reviews have been held under the leader-ship of Sir Leslie Martin and Mr Roderick West. In many cases,however, such comprehensive reviews are not considered as part of a national program of quality assurance, although in Sweden the briefof the new Swedish National Higher Education Agency includesinvestigating and evaluating the higher education system and itsresults in relation to the society’s overarching general goals for highereducation (Asking and Bauer 1997).

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Purposes2.48 Quality assurance programs can often serve a variety of purposes

but generally their primary purposes are a combination of publicaccountability, improvement and renewal. In some cases, thereis a gap between stated purposes and actual purposes and frequentlythere is tension between accountability and improvement purposes.

2.49 Frequently the stated purpose of a national quality assurance programis linked to a particular philosophical approach to evaluation and toparticular views about the role of government in the control of highereducation. As already noted, the current system of quality assurance inthe Netherlands was clearly linked to a new philosophy about therelationship between the state and higher education institutions andon a belief that the assessment process should be as non evasive aspossible (van Vught 1994a).

2.50 Similarly, in the case of Sweden, the approach adopted by theSwedish National Higher Education Agency stems from the transitionfrom ex-ante regulation to devolution of authority and ex-post control(Bauer and Franke-Wikberg 1993). While the Agency has a number of functions including both enhancing and controlling quality, to dateit has given clear priority to supporting and enhancing activities. In itsown guidelines, the Agency has underlined its supportive role andexpressed its strong commitment to a ‘soft’ approach to its evaluativetasks (Askling and Bauer 1997).

Reporting and follow-up2.51 Reporting and follow-up activities are vital components, but a major

challenge is to devise fair and effective methods likely to lead toimprovements without damaging the unit or units being reviewed. A variety of approaches are widely used with regard to the distributionof reports. In some cases, reports are provided solely to the institutionor the unit concerned, but increasingly the practice is to make theresults more widely available. At national level, reports for institutionalevaluations or disciplinary reviews now are frequently provided toMinisters, Ministries and funding agencies. Precisely what happens toa report can be one of the most contentious issues in qualityassurance programs. While participants in the institution or departmentbeing assessed often wish to limit circulation of a report, particularlyone which includes critical comments, the demands of accountabilityusually require wider circulation.

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2.52 Associated with this is a difficulty often experienced by review panelsin preparing reports which will be considered by different stake-holders. What is desirable is that the issues of reporting and follow-upshould be explicitly addressed in guidelines prior to commencementof any review. In this way both reviewers and the unit being reviewedwill know from the outset who will see the final report. However, it iswidely accepted that whatever the final distribution of a report, theinstitution or unit being assessed should have an opportunity tocomment on the draft report.

2.53 Some agencies have adopted systems of rankings based on perform-ance in relation to established criteria. In the United Kingdom, forexample, participating university departments are ranked in separatereviews of performance in both teaching and research, and theseresults are publicly announced.

2.54 In a minority of cases, some element of performance funding is usedas part of a quality assurance program. In the United Kingdom,performance in research as measured by the Research AssessmentExercise (McNay 1997) is used as the basis by the three fundingcouncils and the Department of Education of Northern Ireland forallocating substantial research funding to institutions. In the UnitedStates, performance funding has been used for many years by thestate of Tennessee to improve higher education by adopting a singleset of outcomes and rewarding institutions for their performance (El-Khawas 1997). Currently the maximum reward for performance is an amount equal to 5.5 per cent of an institution’s overall budget.In the fiscal year 1995, $27 million was allocated.

2.55 A number of arguments are advanced in favour of performancefunding: key ones are that such mechanisms provide strong incentivestowards excellence and sends out clear messages from governmentagencies to institutions and academic staff. On the other hand, oppon-ents argue that performance funding can distort the purposes ofevaluation, damage the links between evaluation and improvementand, by denying funding to lesser performing departments or insti-tutions, damage their reputations, their ability to recruit staff andstudents, and their capacity to improve.

2.56 In a limited number of cases, the final result is accreditation orvalidation of the program or institution. As already noted, accre d i t a t i o nhas had a long history in the United States. In late 19th centuryAmerica, growing diversity in institutional forms and lack of centrallydefined standards led to a degree of chaos. In the end, institutionstook the initiative and developed mechanisms of quality assurancewhich included accreditation of institutions and academic programs.

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2.57 Accreditation usually involves a process of self-review by theorganisation or unit seeking accreditation, resulting in the develop-ment of extensive documentation with detail on goals, resources,facilities and internal evaluation mechanisms, as well as an assessmentof achievements in relation to goals. Production of the self-study isusually followed by a visit of a team of external assessors and a finaldecision, using pre-defined standards on whether or not the institutionor the program meets the specified criteria.

Concluding comments2.58 In reviewing recent international practice with regard to the

management of quality assurance, especially for academic activities,this chapter has pointed to the tremendous variety in experimentationthat has taken place in recent years, providing a rich source of modelsof evaluation and review, and of reporting and follow-up activities. In many countries, the main emphasis at the national level has beenon academic audits and institutional evaluations, and reviews ofdisciplines and professional areas. The current experimentation seemslikely to continue, especially with the effects of increased of increasedtrends towards globalisation and increased economic competitionbetween nations. Many of the experiments appear to have producedpositive benefits, including improvements in academic programs,closer links with employers and professions, and increased confidenceamong key stakeholders. On the other hand, questions are beingasked about the financial and administrative costs of quality assurancemechanisms in relation to the benefits derived.

2.59 As a result of the experimentation of the past decade, there is now a growing body of experience and evidence available about how welldifferent approaches are working in particular settings. Such inform-ation can be of considerable assistance to national higher educationsystems or institutions interesting in developing new quality assurancesystems, or modifying existing systems. One lesson to be learnt is thatgreat care should be taken is selecting mechanisms likely to enhancecredibility both nationally and internationally and in estimatingresource implications. A number of the methodologies in frequent usecan prove expensive to implement in terms of both personnel timeand financial resources, although with most methodologies there areusually ways of keeping administrative costs in check, at least to someextent.

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2.60 International experience demonstrates well the value of placing amajor emphasis on quality improvement within a quality assuranceprogram. While most quality assurance programs quite understandablyhave accountability as a major driving requirement, it is highlydesirable that all quality assurance programs be deliberately designedto achieve improvement and renewal.

2.61 In order to succeed and produce major benefits at either institutionalor system levels, any quality assurance program needs the support of the higher education community. In particular, the benefits will bedisappointingly limited unless academic and administrative staff canbe persuaded to participate and provide support. Gaining this supportmay not be easy, since in a number of the recently introduced qualityassurance programs academics have seen the particular initiative asconstituting a threat to their professional independence and work.

2.62 In developing a new quality assurance program or evaluating anexisting program, the following criteria are suggested as constitutinghighly desirable features:

• The purposes of the program are explicitly stated, with the overalldirection fitting well with the culture and values of the particularsystem or institution;

• Approaches and methodologies are congruent with the statedpurposes of the program, and likely to be cost effective and attractthe support of staff;

• The methodology incorporates elements of self-study, peer review,and external reporting;

• Guidelines are clear and provide for a transparent process, wherejudgements will be based on analysis of evidence and the proced-ures will be fair to all parties involved;

• Guidelines provide for checklists to assist review panels, and forthe institution or unit being reviewed to have input into the choiceof external panel members;

• Administrative arrangements provide for an overseeing committeeor group to have responsibility for the organisation of any review,including the appointment of panels, and review of the reports of panels;

• Clear external reporting arrangements are specified in the guidelines,or the pro c e d u res provide for reporting arrangements to be agre e dby the parties concerned prior to commencement of any review; and

• The program places major emphasis on improvement, renewal andthe application of ‘good practice’.

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Chapter 3

Australian higher education providers and currentarrangements for accreditation and quality assurance

3.1 This chapter describes and categorizes Australian higher educationproviders in the context of accreditation and quality assurance, andthen outlines the current arrangements for accreditation and qualityassurance. This is intended to provide a basis for assessing thestrengths and weaknesses of the current system in relation toparticular providers and proposed changes.

Australian higher education providers3.2 For the purposes of this study, Australian higher education providers

can be categorized into five distinct groups. The first group comprisespublic universities and other public higher education institutionsestablished under State, Territory and Commonwealth legislation. This group includes the 37 public universities and also a smallnumber of non-university higher education institutions, such as theAustralian Maritime College in Launceston and Batchelor College inthe Northern Territory. All these institutions have the power toapprove or accredit their own courses and all receive operating grantfunding from the Commonwealth under Higher Education Fundinglegislation. Significantly, the Australian Maritime College wasestablished under Commonwealth rather than Tasmanian legislation.

3.3 A second group of institutions is made up of non-government instit-utions which operate under their own legislation and have self-accrediting powers. The oldest of these is the Melbourne College ofDivinity, established in 1910 by an act of the Victorian Parliament. The College was established because the University of Melbourne wasunable to offer degrees in Divinity springing from traditions ofseparation of church and State (Smith 1998, p 3). It is operated byparticipating Christian denominations as a private institution, withoutthe benefit of government funding. Costs are met through student fees and endowments. More recent institutions are Bond University on the Gold Coast and Notre Dame University at Fremantle, both of which enjoy their own acts of parliament, giving them similarpowers to public universities. These two universities depend on

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fee and endowment income, although the Commonwealth Govern-ment has agreed to fund Notre Dame courses for indigenous studentsat Broome.

3.4 The third group comprises institutions not established by legislationbut who have been given government approval to operate. The bestknown example is Melbourne University Private, which is a jointventure between the University of Melbourne and private partners. It gained approval in 1998 to operate for a period of five years underthe Victorian Tertiary Education Act 1993 (Smith 1998, p 11) but thiswas conditional on the University of Melbourne bering responsible forcertification of its courses (but not for accreditation, which lies outsidethe statutory powers of the University of Melbourne) This categoryalso includes the National Art School in Sydney, which was once aTAFE institution but now an independent higher education institutionfunded by the state. However, it is not self-accrediting and each of itscourses must be considered separately for accreditation. In 1998, theSchool gained approval for a Bachelors Degree in Fine Arts under theapproval process provided under the New South Wales HigherEducation Act 1988.

3.5 The fourth group comprises private providers whose courses havebeen accredited by State or Territory accrediting agencies. In 1998there were 68 authorised providers offering 225 accredited under-graduate degree and postgraduate award courses. Details of these areset out in Table 3.1

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Table 3.1 Higher education accredited awards offered by private providers

Bachelor Grad Cert Grad Dip Master Doctoral

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Vic 17 2 10 5 1

NSW 24 2 26 6 0

SA 26** 9 14 9 1

ACT 6** 25 15 – –

Qld 9 3 6 3 –

WA 1 – – – –

Tas – – – – –

NT – – – – –

Nat. Total 83 41 71 23 2

* appropriate numbers as advised by State and Territory Officials, August, 1998

** includes TAFE degrees

Source: Smith 1998, p 3.

3.6 Private providers have existed for a long period, generally operating inrelatively small but often well-established market niches. The mostdurable of these providers are the theological colleges and church-related colleges, whose courses generally closely resemble universitycourses. The largest are Avondale College operated by the SeventhDay Adventist Church and the Australian College of Theology, whichis a national federation of various denominational theological colleges.The Commonwealth funds teacher education courses at AvondaleCollege. Another sub-group in this category are long-term ‘industry’commercial providers who conduct courses at tertiary level to meetthe needs of their particular market areas. Notable features of this sub-group are high motivation of students, a focus on particular disciplineareas and user-pays principles.

3.7 Smith has further divided this sub-group of commercial providers intotwo separate sub-groups, with a third emerging (Smith 1998, p 3).First, there are the highly specific professional associations, such asthe Securities Institute, the Institution of Engineers and the RoyalAustralian College of General Practitioners. For many years, theseand similar bodies have conducted ‘in service’ professional educationprograms for their members, awarding credentials on completion.

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Courses have been conducted at a level which has led to consistentsuccess in obtaining accreditation for their courses.

3.8 The second set within the sub-group consists of establishedcommercial providers such as general business colleges offeringprograms across the full spectrum of commercial courses. While therehave been some spectacular individual failures in this area, thesecolleges have generally met an important market need and continue to do so.

3.9 A third set consists of loosely coordinated but rapidly growinginstitutions in the area of alternative health practice. TraditionalChinese Medicine and other alternative approaches to health caresuch as Naturopathy and Homoeopathy have become increasinglypopular throughout Australia in recent years. While training courses in these areas have been available from private providers for manyyears, the considerable public interest at the present time and theneed to ensure that such practices are safe to the public, is causingpublic health authorities to review the level and nature of trainingoffered in alternative health practice.

3.10 Alternative health practitioners themselves are recognising that thegrowth of their profession will be dependent on having agreedminimum acceptable academic standards. Last year over thirtyTraditional Chinese Medicine organisations across Australia have been meeting to reach agreement about minimum standards oftraining. These practitioners seek to determine standards appropriatefor achieving professional status. Several universities, notably Southern Cross, Victoria University of Technology and RMIT havealready responded to industry demands and are offering degreeprograms in acupuncture. Private provider programs in naturopathyhave been approved in Queensland and Victoria.

3.11 A fifth category comprises private providers whose courses have not yet been accredited. Relatively little is known about this group, but it includes providers who offer sub-degree work and providers whosecourses are approved for credit transfer for entry to degree programsat various public universities. Examples of the latter include providersestablished by universities (such as Insearch owned by the Universityof Technology, Sydney and the Sydney Institute of Business andTechnology which has been established by Macquarie University) and private providers who have established special relationships withparticular university faculties (such as the Faculty of Economics at theUniversity of Sydney with the Universal Education Centre).

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3.12 In 1998, public higher education institutions in category 1 enrolledabout 671 853 students of whom some 72 183 were internationalstudents. Comparatively little is known about enrolments in the otherfive categories. However, one State officer has estimated that there maybe 15 000 higher education students enrolled in courses accredited byState and Territory agencies while a Commonwealth official estimatesthat total enrolments in higher education courses outside Common-wealth funded institutions may total 40 000 to 50 000 students.

International education enrolments3.13 Since pressures for strengthened accreditation and quality assurance

arrangements are being driven substantially from concern to protectthe higher education export industry, it is important to consider moreclosely details of international student enrolments. Of the total of72 183 international students enrolled in 1998 in institutions funded byCommonwealth operating grants (plus the Australian Film and Tele-vision School, the National Institute of Dramatic Art and the AustralianDefence Forces Academy), 37 719 were males and 34 464 werefemales. Total load was 59 463 EFTSU. The three most importantsources of international higher education students by country, in rankorder, are Malaysia, Singapore, and Hong Kong. In 1997, according toUNESCO figures, Australia ranked third after the United States and theUnited Kingdom in terms of the total number of enrolled overseasstudents. With the exception of Singapore (where Australia is the topprovider) and Malaysia (where the United Kingdom is top provider),the United States is the most popular destination for internationalstudents from all of Australia’s top 10 source countries. Australia rankssecond behind the United States in Hong Kong, Indonesia, India,Thailand and China; and third behind the United States and the UnitedKingdom in Taiwan, South Korea and Japan. Australia outranksCanada and New Zealand in all of Australia’s top 10 source countries.

3.14 Of the total number of international students enrolled in 1998, a totalof 22 583 were enrolled in ‘off - s h o re’ programs. Of these, 65.9 per c e n twere enrolled in bachelors degrees while 21.6 per cent were enrolledin masters degrees by course work. Table 3.2 shows the total off-shoreenrolments of Australia’s major ‘off-shore’ providers. Together, theseseven providers account for almost 15 000 students. In terms of modeof attendance, 60 per cent of total Australian ‘off-shore’ highereducation students are internal, 38.8 per cent are external and theremainder are classed as multi-modal. In terms of total numbers of

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Australian off-shore students in different countries, the largest numberare in Hong Kong (7 204) followed in rank order by Singapore(6 898), Malaysia (2 994), New Zealand (584) and Japan (560). Thelargest concentrations per country for single institutions are shown inTable 3.3.

Table 3.2 Total ‘off-shore’ student enrolments of major higher education providers,1998

Institution Enrolments

RMIT 3008

University of Southern Queensland 2323

Curtin University of Technology 2211

Monash University 2181

University of Ballarat 1836

University of South Australia 1711

Charles Sturt University 1549

Source: DETYA, Selected Higher Education Statistics 1998

Table 3.3 Largest off-shore enrolments in particular countries by institutions, 1998

Institution Country Enrolments

RMIT Singapore 2202

VUT Hong Kong 1255

Uni of South Australia Hong Kong 1035

Curtin University Hong Kong 975

Curtin University Singapore 952

Uni of South Australia Malaysia 928

Source: DETYA, Selected Higher Education Statistics 1998

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Current accreditation arrangements3.15 Accreditation of higher education institutions and courses in other

than universities and other institutions established under their ownlegislation (State, Territory or Commonwealth) is under the controlof State and Territory Governments who view this responsibility asflowing from their responsibilities for education under the Common-wealth constitution. The relevant legislation in each of thesejurisdictions is shown in Table 3.4. Most acts listed make provisionfor private providers of higher education to secure accreditation andapproval to offer courses. In other cases, legislation provides foraccreditation of institutions and courses. The main aim of the variouslegislation is to protect the status and quality of awards, to ensure thatprivate providers have met minimum criteria with regard to facilitiesand staff capacity, to ensure that the provision of higher educationservices by private providers is consistent with that offered bypublicly-funded institutions and, in keeping with National Competitionprinciples, ensures that private providers to offer courses which meetappropriate standards. Some of the legislation also aims to protectstudents from providers who cease to be financially solvent.

Table 3.4 Legislation providing for accreditation of courses and institutions

Victoria Tertiary Education Act 1993

Queensland Higher Education (General Provisions) Act 1993

South Australia Vocational Education and Training Act 1994 and Business Names Act

Tasmania Universities Registration Act 1995

New South Wales Higher Education Act 1988

Australian Capital Territory ACT Vocational Education and Training Act 1995

Northern Territory Northern Territory Education Act 1995

Western Australia Business Names Act 1962

Source: Smith 1998, p 6.

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Accreditation of courses3.16 While the details of the arrangements differ between the various states

and territories, in each case providers make applications following aspecified format. Applications are subject to a rigorous review processcarried out by expert panels which include experienced personnelfrom public universities. Panels make recommendations to theMinister, or to a person or body with powers delegated from theMinister or provided for in legislation.

3.17 Each of the States and Territories has developed criteria and proced-ures that determine the way that applications for course accreditationare assessed. For example, the Victorian Tertiary Education Act 1993 ,obliges the Minister to have regard to whether the course of study isequivalent in standard to a course leading to an award of that type orlevel in a University. In deciding whether or not to accredit a course,the Minister may take into account all or any of the following matters:

(i) student selection procedures;

(ii) the number of students;

(iii) class sizes;

(iv) student contact hours;

(v) curriculum;

(vi) premises, equipment, materials and resources;

(vii) course nomenclature;

(viii) qualifications and experience of staff(Tertiary Education Act 1993, p 10).

3.18 The Victorian Minister is advised by University academics and industryspecialists through a Ministerial Standing Advisory Committee andvarious ad hoc expert panels (Smith 1998, p 8).

3.19 In New South Wales, under the Higher Education Act 1988, detailedguidelines have been developed dealing with the documentationrequirements of applications for course accreditation, the compositionand selection of new assessment committees, and the role of chair-person and secretary of assessment committees. For committeesassessing courses leading to the award of a bachelors degree or higherlevel, the New South Wales Vice-Chancellors’ Conference nominatestwo members, one who is knowledgeable in the major academic fieldbeing addressed in the course under assessment and the second whois experienced in course planning and assessment. The 1988 Act wasdrafted with accreditation of advanced education courses in mind and,

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possibly for that reason, no explicit specification is provided of theassessment criteria to be used.

3.20 In Queensland, accreditation of higher education courses is governed

by the Higher Education (General Provisions) Act 1993. Under this

legislation, the Minister is the accrediting authority for courses leading

to higher education awards. The Minister may accredit a course for a

higher education award or proposed award if he or she ‘is satisfied,

following an assessment made in accordance with accrediting proced-

ures and criteria approved by the Minister, that the course, and the

way of delivering it, are appropriate to the type of award’ (Section 10

(2)). Detailed documentation is available to applicants from the Office

of Higher Education in Education Queensland. This sets out proced-

ures and criteria for the accreditation of higher education courses

offered by non-university providers. These procedures and criteria are

probably the most detailed of any State and Territory and cover topics

including the nature and purpose of accreditation, the accreditation

process, accreditation fees, criteria for accreditation, and required

documentation. The extended section on criteria states that a course

assessment panel ‘must satisfy itself that the application before it

meets the criteria with respect to the standard and quality of the

course and the capacity of the provider to deliver it’ (Education

Queensland, Office of Higher Education 1997, p 19). The section on

criteria then goes on to specify information required on such matters

as statement of mission and purpose of the course, legal status of

body providing the course and governance arrangements, educational

oversight, composition of the course advisory committee, the financial

standing of institution, qualifications and expertise of staff, and

educational requirements. Under educational requirements, it is stated

that, before recommending accreditation, a course assessment panel

must be satisfied that:

• the field of study in which the course is proposed does indeed

constitute a coherent body of knowledge, supported by an

appropriately developed theoretical framework, and a substantial

body of scholarship and/or reflective professional practice;

• the course proposed is comparable in standard and educational

value to a course leading to a similar award in a university, in

terms of the overall goals for the course, course entry requirements,

the breadth and depth of course content, the structure of the

course in terms of the mix of general and specialised skills and

knowledge, the levels of skills and knowledge developed, the

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duration and workload of the course, and the methods of

delivery and assessment;

• the course satisfies the guidelines for the proposed qualification

laid down in the Australian Qualifications Framework (AQF); and

• the general educational practices and standards of the provider,and the processes adopted for monitoring the operation of theeducational program, are adequate to maintain the offering of the course (Education Queensland, Office of Higher Education1997, p 23).

3.21 In contrast, procedures and criteria in use in the Australian Capital

Territory are much briefer, reflecting the smaller staff capacity of the

relevant section of the Department of Education and Community

Services. Power to accredit higher education courses in the ACT

comes from the Vocational Education and Training Act 1995 which

gives the Accreditation and Registration Council power to ‘accredit

courses in the higher education sector, including but not limited to

vocational education and training courses, whether provided in the

Territory or elsewhere’ (Section 13 (c)). While assessment criteria are

not set out, these are specifically referred to and the Department must

provide on request copies of assessment criteria. The Act gives the

Minister power to examine, or cause to be examined, the operations

of a non-university provider, including the standard of the course,

the way of delivering it, and the ability (including financial ability)

of a non-university provider to deliver the course. Such examinations

may take place during the period for which a course is accredited.

3.22 Recently the States and Territories have agreed on procedures for

considering applications and authorisation to offer higher education

courses in two or more States and Territories, and operational

guidelines to achieve this were endorsed by MCEETYA in April 1999.

These guidelines cover the procedures for considering applications,

format of applications, fee structure, determination of which state or

Territory authority should consider an application, concurrent assess-

ment panels, and accreditation outcomes. Joint or concurrent accred-

itation procedures are now in place and the states and territories are

currently working to achieve greater consistency in criteria and

procedures. Significantly, the document endorsed by MCEETYA made

no mention of the criteria for assessment and accreditation.

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Accreditation of new or overseas universities3.23 The States and Territories have overall responsibility for the higher

education institutions that operate within their jurisdictions and in a

number of cases through legislation there is control over the use of

the terms ‘university’ and ‘degree’, and over degree titles. However,

there are significant differences in terms of legislation and the

processes by which new or overseas universities can be recognised.

3.24 Table 3.5 summarises the provisions in the various States and

Territories with regard to recognition of new universities, recognition

of universities established in other States and Territories, and

recognition of foreign universities, while Table 3.6 summarises

legislative protection offered nationally to Australian universities.

It will be noted that the most detailed legislative controls operate in

Victoria, New South Wales, Queensland and Tasmania. From Table 3.6

it will be noted that The Trade Practices Act and related State/

Territories legislation protects against misleading advertising. Business

names legislation restricts the use of the word ‘university’. The

Corporations Law places restrictions on the use of the name

‘university’. Under relevant guidelines consent will normally be

granted to use the word ‘university’ where a body has been given

accreditation to operate as a university. This includes a foreign body

accredited outside Australia. The difficulties arising from the breadth

of the guidelines in The Corporations Law is currently the subject of

discussion between the Treasury and DETYA. The guidelines estab-

lished as part of this process may be useful to the States in relation to

their business names legislation.

3.25 In Victoria, the Tertiary Education Act 1993 protects use of the terms

‘university’ and ‘degree’, regulates the titles of all higher education

awards, and regulates the establishment of new universities in the

State. There is no impediment to universities recognised elsewhere in

Australia operating in Victoria, although they must have Ministerial

approval if they wish to deliver courses to overseas students. Foreign

universities require Ministerial approval to operate. To date, major

reviews have been conducted under the 1993 Act to consider

applications from Ballarat University College and Melbourne University

Private. For the 1993 review of the application of Ballarat University

College, the Panel placed considerable emphasis on 1989 criteria for

the essential characteristics of Universities published by the AVCC. It

recommended that a new University be established under its own act

of Parliament, with a five year sponsorship by an existing major

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university (Report of Review Panel 1993, p 23). The 1998 review of

Melbourne University Private also used the 1989 AVCC criteria but

noted that the AVCC had in 1997 published further criteria. The report

of the panel commented as follows:

The proposal from Melbourne University Private asserts that the

AVCC criteria are not applicable. The panel does not agree with

this view. However, the Victorian Government’s policy commit -

ment to the AVCC criteria relates to the earlier statement rather

than the later one (Report of Panel 1998, p 16).

Table 3.5 Legislation relevant to the establishment and operation ofAustralian universities

State/Territory Legislation

Western Australia • No generic legislation protecting title ‘university’, or degree orregulating establishment or operation of a university

• There is no impediment to a university from another Stateoperating in WA and no explicit protection against ‘bogus’ oroverseas institutions.

Victoria • The Tertiary Education Act 1993 protects the title ‘university’and ‘degree’ and regulates the establishment of universities inVictoria

• There is no impediment to universities recognised in otherAustralian States/Territories operating in Victoria. However, ifthey want to deliver courses to overseas students in Victoria,they must have the Minister’s endorsement. Foreignuniversities require Ministerial approval.

Australian Capital • There is no explicit legislation protecting the title ‘university’ Territory or ‘degree’ or regulating the establishment and operation

of a university, including a foreign university.

New South Wales • The NSW Higher Education Act 1988 regulates accreditationof higher education courses & nomenclature and protects theuse of the title ‘university’

• Varying levels of regulation apply to overseas universitiesseeking to operate in NSW, but not to other Australianuniversities

• Universities are regulated by individual university enabling acts.

Northern Territory • The NT Education Act places certain restrictions on theconferring of higher education awards (this includes overseasinstitutions, but not other State/ Territory universities). Thereis no explicit provision covering the establishment of a newuniversity.

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Queensland • The Higher education (General provisions) Act 1993 explicitlyprotects the title ‘university’ and ‘degree’ and regulates theestablishment of universities in the State. It allows otherAustralian universities to operate in QLD, but requires anoverseas accredited university to seek Ministerial approval.

South Australia • The Vocational Education, Employment and Training Act1994 (VEET Act) provides for the accreditation of degreecourses (except for a South Australian university, butincluding universities from other Australian States andoverseas universities).

• There is no explicit education legislation protecting the title‘university’ or regulating the establishment or operation ofuniversities in South Australia.

Tasmania • Tasmania has explicit legislation (Universities Registration Act1995 and Universities Registration Amendment Act 1997)protecting the title ‘university’ and ‘degree’ and regulating theestablishment of universities in the State. It also controlsforeign universities.

• The University of Tasmania was established under its ownlegislation.

• There is no impediment to universities from other Statesoperating there.

Source: Papers for Meeting of Multilateral Joint Planning Committee, 30 June 1999

Table 3.6 Summary of legislative protection offered nationally toAustralian ‘universities’

The Trade Practices Act and Protects against misleading advertisingrelated State/Territory legislation

Corporations Law Protects term ‘university’, but requires tighterguidelines

State Business names Legislation Protects titles ‘university’ & ‘degree’—but may need tighter guidelines

State Higher Education Legislation • Protects the title ‘university’ in Victoria,NSW, QLD, Tasmania

• Prevents overseas institutions operatingexcept with permission in Victoria, NSW,NT, QLD, South Australia, Tasmania

Note: The legislation does not provide protection against an institution of questionable quality, which

has been accredited in a State or Territory, from operating except in South Australia.

Source: Papers for Meeting of Multilateral Joint Planning Committee, 30 June 1999

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3.26 In applying the original AVCC criteria, the review panel forMelbourne University Private saw the need for some flexibility inview of the special nature of the proposed institution. At the sametime, it placed considerable importance on the maintenance ofstandards. This led it to recommend that, as a condition ofapproval, awards be offered only if they were certified by theUniversity of Melbourne. It also recommended that MelbourneUniversity Private plan to develop its own independent researchprofile and have at least three per cent of its student load ingraduate research programs (Report of Panel 1998, p 23).

3.27 In these two assessments and in assessments in other States andTerritories, the original 1989 AVCC guidelines have played animportant role, even though these were developed at the time ofthe foundation of the Unified National System as a device forcontrolling entry to membership of the AVCC. The 1989 criteriawere detailed and highly restrictive. In order to achieve the statusof a university, the AVCC guidelines specified that an institutionmust meet twelve criteria including a commitment by its staff ‘tothe search for and preservation of knowledge by teaching andresearch’, ‘courses which meet national and international standardsat a high level’, ‘a fundamental commitment to the training ofresearchers’, academic staff with ‘high qualifications and profes-sional standing in the community and with their peers’, and ‘ahigh level of material and financial resources to support itseducational activities on a continuing basis’ (AVCC 1989). Inassessing whether an institution met the detailed criteria, thefollowing minimum quantitative indicators were to be used:

(i) the institution should have a significant student load (of theorder of 5 000 EFTSU) in each of at least three broad fields ofstudy, such as humanities, science, engineering or education;

(ii) the institution will require a minimum proportion of itsstudent load to be allocated to postgraduate research students(3 per cent of total student load);

(iii) staff of the institution will be expected to have obtained aminimum number of competitive research grants (one per full-time equivalent staff of lecturer and above per annum);

(iv) staff of the institution will be expected to have an average of 0.5 refereed publications per annum per full-time equivalentstaff member; and

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(v) at least 25 per cent of all academic staff (both full-time and part-time) of the institution will be expected to have both a relevantPhD and research experience.

3.28 For a well established university, a higher profile was expectedincluding more than 5 000 EFTSU across four or five broad fields ofstudy, a postgraduate load of more than 7 per cent, an average ofthree research grants to 20 full-time equivalent staff, and two to fiverefereed publications per annum per equivalent full-time staff. Varioussenior officers of the AVCC have commented that it would beinteresting to apply all these indicators to all established public andprivate universities today, particularly those relating to research andresearch training activities, and the publication and research grantsrecords of academic staff.

3.29 The revised 1997 AVCC criteria are expressed in much broader andless restrictive terms and do not include specific indicators of perform-ance (AVCC 1997). No longer is there mention of courses meetingnational and international standards and requirements having acommitment to research training, and there being an extensive library.Also there are no longer specific quantitative requirements about size,postgraduate load, staff qualifications and staff achievements inattracting research grants and in publications.

3.30 In New South Wales, the Higher Education Act 1988 protects theuse of the title ‘university’, and there are varying levels of regulationapplying to overseas universities wishing to operate in the state,but not to other Australian universities. In Queensland, the HigherEducation (General Provisions Act) 1993 explicitly protects the titles‘university’ and ‘degree’ and regulates the establishment of newuniversities in the State. It allows other Australian universities tooperate in the State, but requires overseas accredited universitiesto seek Ministerial approval. In Tasmania, the titles university anddegree are protected and there are powers under 1995 and 1997legislation to regulate the establishment of new universities and theoperation of foreign universities. In Western Australia, the AustralianCapital Territory, and South Australia, there is no legislation protectingthe titles university and degree, except in the case of the AustralianCapital Territory and South Australia where there are some controlsthrough accreditation powers.

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Protection through other legislation3.31 As Table 3.6 indicates, additional protection is afforded with

regard to the establishment and recognition of universities by other Commonwealth, State and Territory legislation. All Australianproviders offering education and training services to overseas studentsin Australia must be accredited to provide specific courses by therelevant State/Territory authority, be approved to provide thosecourses to overseas students by the relevant State/Territory authority,be registered on the Commonwealth Register of Institutions andCourses for Overseas Students (CRICOS). The Education Services forOverseas Students Act (ESOS) protects students’ fees and provides forcertain other protection. Commonwealth Corporations Law and Stateand Territory business names legislation prevents a company fromcarrying on a business as a university unless it registers its names. The Trade Practices Act 1974 and related State and Territory legislationprotect against misleading advertising while both Business Nameslegislation and Corporations law place restrictions on use of the worduniversity. Action can be taken by the Australian Competition andConsumer Commission against an institution engaging in such conductunder The Trade Practices Act, or by State consumer affairs officesunder relevant legislation.

3.32 In addition, entry to regulated professions is a matter for variousregistration authorities operating under State and Territory legislation.Regulated professions include most health-related professions, law and architecture. There are a number of other professions, notablyaccountancy and engineering, for which registration or licensing isconfined to specific areas of professional activity. However, evenwhen registration is not mandatory, membership of the appropriateprofessional body is often helpful for employment purposes and inthese cases generally only the graduates of courses accredited by theappropriate professional association are eligible for full graduatemembership. Later in the report the accreditation processes used byprofessional associations are discussed in more detail.

National recognition and guarantee3.33 Currently the only national policy instrument guaranteeing with regard

to accreditation and quality assurance is the AQF. Universities estab-lished by legislation and institutions otherwise accredited by Stateand Territory accrediting bodies are listed on the AQF as beingempowered to accredit courses of study and to issue qualifications. Itis believed that inclusion on the AQF register signals that governments

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represented in MCEETYA vouch for the quality of the awards given bythe institutions concerned.

Current system of quality assurance

3.34 The current system of quality assurance operates at a number oflevels and includes the activities of professional associations andassociations and networks set up by groups of universities forbenchmarking and other quality assurance purposes. Some mech-anisms such as peer review of research proposals and articles forrefereed journals are international in character, while others are local.In summary, the main quality assurance mechanisms for universitiescurrently are as follows:

Internal processes within universities3.35 The internal quality assurance processes in Australian universities

are similar to those in other OECD countries. However, theseprocesses have been considerably strengthened since the early 1990s.One major factor leading to improvements was the 1993–1995 nationalquality assurance program and the publication of detailed reportsincluding information on good practice. The main internal processesinclude the following:

• Processes of assessment for new courses and units of study;

• Regular review of courses and units;

• Reviews of departments, faculties and research centres;

• Student evaluation of teaching;

• Use of external examiners for higher degree research theses andsometimes bachelors honours theses;

• Surveys of graduates and employers to assess graduate satisfactionand information on course experience and suitability of graduatesfor employment;

• Use of performance indicators for management purposes and forthe allocation of funding;

• Benchmarking and participation in networks which offer specialopportunities for benchmarking and sharing of information; and

• Special projects for the improvement of teaching and specialawards for teaching excellence.

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National mechanisms3.36 The current mechanisms include the following:

• Universities currently report on their quality assurance andimprovement plans that set out their goals, the strategies adoptedto achieve these, the indicators they use to assess their success inachieving these goals. The first set of institutional plans in relationto quality is about to be published by the Commonwealth.

• Encouragement of innovation and good teaching throughCommittee on University Teaching and Staff Development andspecific initiatives funded by under the Higher Education InnovationProgram, including the development of an instrument to testgraduate generic skills;

• Publication of Characteristics and Performance of Higher EducationInstitutions, a report which provides indicators covering such topicsas source of funds, distribution of expenses, research funding,gender and age distribution of students, basis of admissions,overseas students, mode of study, course breadth and staffing aswell as graduate satisfaction with their courses and employmentexperience.

3.37 In addition, there are traditional peer review and assessment systemswhich are widely used in considering applications for competitiveresearch grants, and in handling articles and book manuscriptssubmitted for publications to refereed journals and scholarly publishersincluding University presses.

3.38 As already noted, from 1993 to 1995, a major national qualityassurance program operated. This was a three-year programintroduced by Peter Baldwin as Minister for Higher Education.Although participation was voluntary, all universities participated. Like a number of other national quality assurance programs that were established in the late 1980s and early 1990s, this program wasbased on academic audits of participating universities. This involvedself-assessment on a number of aspects following detailed guidelines,evaluation of institutional submissions and review teams, visits tocampuses and public reporting by the Committee for QualityAssurance in Higher Education. But what was markedly different wasthat in the audits in the Australian program assessed not only qualityassurance processes but also quality outcomes. Further, the schemealso included:

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• ranking of institutions into bands, based on annual assessments of particular specified aspects of quality assurance, and publicationof these rankings;

• publication of detailed individual annual reports on eachparticipating institution; and

• performance funding, with funding coming from a specialadditional government allocation (Harman 1996b).

3.39 In retrospect, both critics and supporters agree that the positive effectsof the program were substantial, leading particularly to a more seriousapproach to evaluation, increased attention to the assessment ofoutputs and increased integration of strategic planning with budgeting.Even now, it appears that many of these achievements remain, eventhough the 1993-1995 program was not followed by any substantialquality assurance mechanism. At the same time, there is doubt aboutwhether the gains were worth the effort and costs involved andcertainly there is a large measure of agreement that the program hadserious effects on the reputations of lower performing universities andtheir subsequent ability to attract both students and staff.

3.40 In contrast, the quality assurance programs introduced in a number ofEuropean countries in the late 1980s and early 1990s did not publishoverall rankings of institutions or detailed reports on individualinstitutional assessments, or used performance funding in an overtway. Most depended on either ‘horizontal’ national reviews ofdisciplines or ‘vertical’ reviews of quality assurance processes inindividual universities, or a combination of these approaches. In theNetherlands, for example, the system of quality assurance developedin the late 1980s was based on horizontal reviews of academicdisciplines. While published reports discussed study programs in eachinstitution visited, there was no system of rankings of institutions andno use of performance funding (Zijderveld 1997). In France, theprogram included both institutional evaluations and disciplinaryassessments, with reports going to both universities and the Ministerresponsible for the institutions visited. However, there was no systemof rankings and the results of the assessments were not used directlyin making annual allocations to institutions (van Vught 1994a).

Accreditation by professional bodies3.41 For many years, various professional bodies and association have

conducted accreditation of professional courses in fields such asmedicine, law, engineering and architecture. More recently,accreditation systems have been developed for newer areas such

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as computer science, software engineering and various health science areas. Professional associations have also formed a peak body, the Australian Council of Professions, whose secretariat islocated in Canberra.

3.42 One of the oldest and most highly organised accreditation systems isthat run by the Institution of Engineers, Australia. There is nocompulsion on engineering schools to have their courses accreditedexcept that only graduates for accredited courses are eligible formembership of the Institution. The accreditation process proceeds asfollows. Engineering schools make a detailed application following aprescribed format. A panel of three members is appointed to conductthe review and in addition consultant panel members are appointedfor each engineering speciality to be considered. After receiving advicefrom the consultant members, the three core members visit theinstitution for two days for discussions with staff and students, and toview facilities. However, consultant members may join the visit if theyhave particular concerns. Following the visit, a draft report is preparedby the Chair and the other core members of the panel and this iscirculated to the university and consultant members for comment.Panels may recommend accreditation or provisional accreditation, ormay recommend that accreditation is refused. Accreditation is for aperiod of five years after which each course must be re-accredited. Inits accreditation system, the Institution does not rank universities orpublish performance data. In its work in accreditation and qualityassurance the Institution of Engineers works closely with the Councilof Deans of Engineering Schools, especially in promoting best practiceand methods of benchmarking.

3.43 Currently the Institution of Engineers is implementing a new approachto accreditation, following a review of engineering education in 1996-1997 conducted jointly with the Australian Council of EngineeringDeans, and the Academy of Technologicial Sciences and Engineering(Changing the Culture 1996; and Beyond the Boundaries 1998). In itsexecutive summary, the review explained that an initial finding was‘the need for a culture change in engineering education, ultimately toextend throughout the profession’ (Changing the Culture 1996, p 7).The report went on:

The present emphasis placed on engineering science resultingin graduates with high technical capacity has often acted tolimit their appreciation of the broader role of engineeringprofessionals. Graduates must understand the social,economic and environmental consequences of their

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professional activities if the profession is fully to assume itsexpanding consequences (Changing the Culture 1996, p 7).

3.44 The review was conducted because of concern that engineeringeducation tended to be somewhat introverted and in the modernworld needed to produce graduates better able to interact with otherprofessionals. This in turn prompted the review committee to thinkmuch more in terms of the desired outcomes for graduates.

3.45 This new approach focusses mainly on graduate attributes rather thaninputs. The Institution is now well advanced in implementing the newapproach. The framework was piloted in 1998 and since then tworounds of reviews have been completed. By the end of 1999, the newapproach will have been employed in assessments in half the totalnumber of engineering schools.

3.46 Documentation explains that, under the new approach toaccreditation, engineering education at university level ‘provides thelearning base upon which competence for a professional engineeringcareer is built’ and that it is important ‘that the education provides thegraduate with … generic attributes’ (Policy of Accreditation of Courses1999, p 1). Generic attributes for a graduate are specified as follows:

• ability to apply knowledge of basic science and engineeringfundamentals;

• ability to communicate effectively, not only with engineers but also with the community at large;

• in depth technical competence in at least one engineeringdiscipline;

• ability to undertake problem identification, formulation and solution;

• ability to utilise a systems approach to design and operationalperformance;

• ability to function effectively as an individual and in multi-disciplinary and multi-cultural teams with the capacity to be a leader or manager as well as an effective team member;

• understanding of the social, cultural, global, environmental and business responsibilities (including an understanding ofentrepreneurship and the process of innovation) of the Professional Engineer, and the need for and principles ofsustainable development;

• understanding of an commitment to professional and ethicalresponsibilities; and

• a capacity to undertake lifelong learning.

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3.47 In implementing the new system of accreditation, the Institution hasfound that it is necessary to try to achieve a balance between anemphasis on outcomes and processes. Engineering schools also havefound some difficulties in assessing particular graduate attributes, butthe view of the Institution is that it is the responsibility of engineeringschools to explain what they are doing and how they make educat-ional judgments and on what basis. Overall, the Institution considersthat engineering schools have been receptive to the changes.

3.48 To date, the Institution of Engineers has not been requested toaccredit courses offered by private universities or other privateproviders. However, it is well aware of the likely problems with‘off-shore’ teaching of international students and has adopted thepolicy that in accrediting an engineering program the engineeringschool must provide documentary detail on all pathways to graduationincluding courses offered at branch campuses, overseas campuses, by distance education, or through twinning of franchise arrangements.In the case of off-shore campuses, and twining and franchisearrangements the Institution requires information especially onteaching and assessment methods, staff qualifications and staffdevelopment for all academic personnel involved, whether they areemployed by the University or a partner, and academic standards.Alternatively, accreditation of a twinning or other off-shore teachingoperation may be treated as a separate accreditation.

3.49 The Institution of Engineers has close relationships with parallelbodies in other countries. It has been deeply involved in thedevelopment of the Washington Accord, an agreement betweeneight industrial countries about equivalence of engineering degrees,and regularly exchanges information and documentation with fraternalassociations.

Special protection for international students3.50 Special Commonwealth mechanisms, consisting of legislation and a

register of courses, have been put in place to provide protection forinternational students. As already noted, The Education Services forOverseas Students (Registration of providers and Financial Regulation)Act 1991 helps ensure that only quality courses are offered to foreignstudents studying in Australia. All providers offering education andtraining services to overseas students must be accredited to providespecific course (and approved to provide these courses to overseasstudents) by relevant State and Territory authorities, and be registered

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on the Commonwealth register of International Courses for OverseasStudents. For Commonwealth registration, institutions must supplyadditional information including audited balance sheets, and have adesignated trust account, a tuition assurance scheme, and a specificstudent fee refund policy. However, these mechanisms generally donot apply to international students studying ‘off-shore’ in campusesestablished by Australian providers, or under twinning of franchisearrangements. This legislation was amended in 1998 to provide for athree year extension to the original sunset clause, following a reviewwhich demonstrated universal agreement amongst stakeholders thatcontinuation of the cooperative model as provided under the act wasappropriate for the future regulation of the industry.

3.51 Some additional protection is provided by State legislation. In Victoria,for example, the Tertiary Education Act 1993 gives the Minister powerto endorse or cancel the endorsement of any course offered by apost-secondary education provider as suitable for overseas students.In deciding whether or not to endorse a course, the Minister may takeinto account a number of matters including financial planning,marketing and promotional material, use of agents contracts withrespect to students, student grievance procedures, welfare of studentsand student housing and accommodation as well as more academicmatters including student selection procedures curriculum and coursenomenclature (Section 6).

Assessment3.52 While there are many strengths associated with the current quality

assurance and accreditation arrangements for higher education, at thesame time there are clear weaknesses that need attention. Perhaps themajor weakness with respect to quality assurance is that there is nonational agency, responsible for quality assurance that can publiclyvouch for the quality of Australian higher education. This stands incontrast to the situation in the Netherlands, France, the UnitedKingdom and New Zealand. Associated with this is the problem thatthe rigour with which individual universities pursue quality assuranceacross all aspects is almost entirely at their discretion, even thoughthere are some safeguards with the requirement to have qualityassurance and improvement plans and with the use of publication of various performance indicators. The lack of a national agency is widely acknowledged as a drawback in the international marketingof Australian higher education. Amongst both government officials and

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university management there is wide recognition of the need for astronger mechanism related to off-shore education.

3.53 With regard to accreditation, there is clearly a need for uniformapproaches and criteria across the States and Territories. Also neededare an increase degree of sharing of information and documentationon an ongoing basis between the various accrediting agencies and a better system of reporting and public access to informationconcerning which courses have been accredited and which providershave been given approval to operate as self-accrediting institutions.Some accrediting agencies have detailed criteria whereas in othercases the criteria are brief and possibly inadequate. Some accreditingagencies cover areas related to business plans and financial viability.Some provide for the accreditation of both institutions and courseswhile others deal with course accreditation only. Some have listsavailable of the courses that have been accredited whereas others do not. In most cases there is some difficulty with regard to whatextent accreditation should be dependent on minimum standards offacilities including library holdings, and this is becoming more difficultwith the use of distance and on-line teaching and use of on-linelibrary and reference sources. Some State agencies are well staffedwhile others have been reduced to a bare minimum of personnel and thus unable to offer effective services.

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4 The changing qualityenvironment and the Modern Australian Model

4.1 In a number of important respects, the quality assurance environmentfor Australian higher education has changed to a marked extent inrecent years. This chapter will first outline some of these changes andthe pressures that are driving them, and then comment on keyfeatures of the proposed Modern Australian Model of qualityassurance and accreditation.

The changing quality environment4.2 The changes over the past decade in the environment with regard to

quality assurance and accreditation have been substantial and some-what unexpected. In the late 1980s and early 1990s, these changes ledthe Commonwealth Minister for Higher Education at the time, PeterBaldwin, to request the Higher Education Council to review qualityassurance practices and outcomes in Commonwealth funded instit-utions and to recommend a process of external review. About thesame time, a number of States introduced new legislation givingadditional powers of accreditation and control over providers offeringhigher education courses to international students.

4.3 In the past four years, however, since the end of the 1993–1995quality assurance program, there have been various further importantdevelopments, which make review and strengthening Australia’saccreditation and quality assurance arrangements urgent. These variouschanges can be summarised under the headings of globalisation andchanges in educational technology, international recognition ofqualifications, recent changes in quality assurance in other indust-rialised countries, new quality assurance arrangements in Australia’s‘off-shore’ education destinations, the needs of Australia’s educationexport industry, increasing accountability pressures at home, incidentswith private providers and the increased number of private providers,and complaints from applicants seeking accreditation.

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Globalisation and changes in educational technology4.4 Globalisation and rapid changes in educational delivery technologies

are creating substantial changes internationally. Globalisation hasmeant that employers, government agencies, professionals andstudents are better acquainted than ever with developments in othercountries. Bad news affecting international education now circulatesmore rapidly. Developments in electronic communications enablehigher education providers to offer courses in new forms by distanceeducation, both in Australia and overseas. Electronic communicationsare also providing students with access to new forms of educationalresources. Now in many disciplines students may use resourcesavailable on the web as much as traditional library resources. Inaddition, the new electronic communications are enabling overseashigher education competitors to provide education services withinAustralia as well as targeting Australian overseas education markets,especially in Asia. All this in turn is creating pressures for concertedaction by institutions and government agencies within and acrosscountries to improve quality assurance and controls over newproviders.

4.5 Another side of globalisation is the increased ability by bothgovernments, students and potential students to compare the coursesand awards of courses offered by providers in different countries.In many cases detail of courses is available on the web.

International recognition of qualifications4.6 Globalisation, increased mobility of skilled personnel, international

mobility of students and offering of higher education courses acrossnational boundaries has led to increased mobility of labour and toincreased pressures for reciprocal relations in the recognition ofacademic and professional qualifications. This in turn raises importantquestions about the standards of qualifications offered by Australianproviders and the mechanisms used to guarantee quality and theacademic and professional standards of awards.

4.7 Staff in NOOSR experience considerable frustration about the lack of anational quality assurance mechanism in Australia. They speak openlyof the ‘charade of Australian quality assurance’. They explain that, intheir experience, enquirers from government agencies and professionalbodies in other countries are often puzzled by the lack of a govern-ment backed national quality assurance agency in Australia, while atother times spokespersons in other countries are openly critical of lack

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of equivalent agencies to that found in the United Kingdom, France,the Netherlands and New Zealand.

4.8 In many overseas countries with which NOOSR has close cooperation,there is considerable concern about the activities of private highereducation institutions, ‘fly-by-nighters’ and degree mills. NOOSR staffalso see the need for a strong quality assurance framework to facilitatethe international marketing of education and to assist in the recog-nition of Australian qualifications in other countries.

4.9 A particular need for a strong national quality assurance agency relatesto international conventions and agreements signed by Australia withregard to the recognition of post-secondary education qualifications.The three key conventions where Australia is a signatory are theUNESCO convention on the recognition of qualifications for theEuropean region, the UNESCO convention for the recognition ofqualifications in Asia, and the recent Lisbon Convention on the recog-nition of qualifications concerning higher education in the Europeanregion. While the requirements of these conventions may not beregarded as particularly onerous, they do require signatory countriesto provide pathways for the recognition of overseas qualifications anddetailed information on local higher education qualifications and theirstanding. According to the Lisbon Convention, each signatory countryis required to provide adequate information on any institution belong-ing to its higher education system and on any program operated bythese institutions with a view ‘to enabling competent authorities ofother Parties to ascertain the quality of the qualifications issued bythese institutions’. According to the Convention, such information shalltake the following form:

(i) in the case of Parties having established a system of formalassessment of higher education institutions and programmes:information on the methods and results of this assessment, and ofthe standards of quality specific to each type of higher educationinstitution granting, and or programmes leading to, highereducation qualifications.

(ii) in the case of Parties which have not established a system offormal assessment of higher education institutions andprogrammes: information on the recognition of the variousqualifications obtained at any higher education institution, orwithin any higher education programme, belonging to their highereducation systems (Council of Europe 1997, Article VIII.1).

With many European countries establishing more rigorous nationalsystems of quality assurance, it seems reasonable to predict that in the

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future international conventions may well expect all signatories tohave national systems of quality assurance in place.

4.10 In addition to conventions, Australia has signed various agreements ormemoranda of understanding with other countries concerning therecognition of qualifications. Two recent agreements were theagreement with Italy of 1996 and the memorandum of understandingwith Germany of 1998. While neither agreement explicitly mentionsquality assurance, it is likely that in future negotiations national qualityassurance mechanisms may become of increasingly importance.Further, it is clear that in the various bilateral negotiations to datethere have been various points of dispute and in the future on suchpoints it is possible that much more weight could be given to theviews of national quality assurance agencies.

4.11 For the future an issue of particular importance is whether theAustralian graduates from off-shore operations will be included inbilateral agreements and multilateral conventions. Associated with thisis a generally growing concern about the proliferation of awardsespecially at the postgraduate level, and the considerable variations inthe length of courses.

Recent changes in quality assurance made by other industrialised countries4.12 Among both many senior officials in government and senior manage-

ment in universities, there is a wide appreciation that a number ofother countries have made recent changes to strengthen their accred-itation and quality assurance arrangements. In particular, there hasbeen considerable interest in the establishment and development of thenew Quality Assurance Agency in Britain and the proposed Qual-ifications Authority in New Zealand. These developments reinforce theview that Australia’s quality assurance mechanisms do not stand upwell internationally. At a recent international quality assuranceconference, speakers from Britain drew attention to Australia’s lack of anational quality assurance agency. In addition, since countries in theAsia Pacific region often look to Australia not only as a source ofuniversity education but to benchmark for their own universitystandards, Australia needs an exemplary record in quality assuranceand efforts to monitor academic standards.

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New quality assurance arrangements in off-shoreeducation countries4.13 Another factor prompting review and strengthening of quality

assurance mechanisms is that a number of counties in the Asia Pacificregion have recently strengthened their own quality assurancemechanisms and are showing increasing concern about allowingforeign universities to operate within their borders. Malaysia recentlyhas established an Accreditation Board that will cover the activitiesof foreign providers as well as local institutions, while in Hong Kongnew regulations govern the activities of foreign universities operatingin the Territory. The establishment of the Accreditation Board inMalaysia has been prompted by the Malaysian Government’s wishto encourage high quality foreign universities to establish campusesin Malaysia.

4.14 In India, a case went to the High Court of Madras in 1997 concerningthe operations of an overseas university within India and to date thiscase has not been concluded. At issue here is whether institutionsother than those specified under the 1956 University GrantsCommission legislation can grant degrees in India. Essentially, thislegislation specifies that only universities incorporated under Indianfederal or state legislation can grant degrees. In March 1997, theMonopoly and Restrictive Trade Practices Commission restrained16 institutions from offering courses on the grounds they were notapproved institutions, while in July 1997 the High Court of Madrasissued an order restraining foreign universities from granting degrees,directly or indirectly, in India. The catalyst for this was a series ofadvertisements inserted by a number of agents regarding admission tovarious international courses without making it clear that thesecourses were being offered in countries outside of India. One suchadvertisement was by two Australian agents for admission to an MBAcourse. The case came up for hearing on 27 August 1997 with theGovernment of India being named as one of the respondents. In viewof various allegations made in Asian and Pacific countries about theoperations of foreign universities, it seems likely that more effort willbe made by countries within the region to regulate the activities offoreign institutions. One common allegation made in India is thatsome foreign universities are dumping low quality courses in Asiancountries that these institutions would not be allowed to offer in theirhome countries.

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Needs of Australia’s education export industry4.15 One of the strongest arguments put by many of those interviewed for

strengthening quality assurance and accreditation mechanisms relatesto providing additional safeguards to protect Australia’s highereducation and VET export business. Australia’s export educationbusiness continues to expand and is a major source of income bothfor providers and the country. To safeguard this industry, it is widelyargued that there needs to be a national quality assurance agency aswell as better mechanisms to accredit private higher educationproviders and courses. Many make the point that the VET system ismuch better placed than higher education to guarantee quality throughgovernment sponsored agencies.

4.16 In our discussions, a number of informants made the point that whilethe number of unfortunate incidents related to quality and accred-itation with Australian providers were few to date, it is possible thateven fairly minor but widely-publicized incidents could haveparticularly damaging effects. Such cases are often difficult to repairand their effects can continue for substantial periods. Disaffected staffcan do considerable damage in making allegations about lowacademic standards and failure to follow specified procedures,whether or not these allegations might be true.

4.17 Various unfortunate events in the late 1980s and early 1990s,particularly the closure of private institutions, prompted the passage ofboth Commonwealth legislation and separate legislation in someStates, and that in a number of cases the Commonwealth had toprovide substantial funds to assist affected students. Closures ofcolleges in the late 1980s, resulting from the inability of a number ofprivate providers to refund prepaid course fees to students who wererefused student visas under tightened entry measures applied by theDepartment of Immigration and Multicultural Affairs in response toevidence of non-compliance with student visa conditions, predom-inantly from the People’s Republic of China, led to students in manycases being without a higher education place and the funds to payfees. This in turn led to the 1991 Commonwealth Education Servicesfor Overseas Students Act. As a result of these incidents, theCommonwealth expended over $66 million in refunds to students,with only $4.5 million being eventually recovered. In 1993, twoliquidated colleges closed in Western Australia with no funds beingheld in special trust accounts and the Commonwealth had to provide$1.3 million in assistance to students.

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4.18 Expansion of off-shore operations through the establishment ofuniversity campuses in foreign countries, twinning and franchisingarrangements, and the delivery of courses to students in othercountries by distance education, or a combination of distanceeducation and face-to-face teaching, is creating new needs for morerigorous quality assurance mechanisms. As already noted, almost23 000 of Australia’s international higher education student areenrolled through various ‘off-shore’ arrangements. ‘Off-shore’ deliverycreates special management problems for providers and makes theneed of well-developed, detailed administrative procedures andreview mechanisms even more necessary.

4.19 Various well publicised incidents pointing to administrative and otherfailures of British higher education providers in ‘off-shore’ endeavourspoint to the kind of difficulties that similar incidents could have forAustralian education exports. The most recent case was about theUniversity of Derby and its off-shore operations in Israel (TimesHigher Education Supplement, 23 July 1999). It is alleged that, forfinancial reasons, the University has been admitting unqualifiedstudents to degree courses and that it has been ‘dumbing down’courses. These allegations have prompted an enquiry by the Israeliquality assurance agency.

4.20 A number of the major Australian higher education providers wellrecognise the dangers in off-shore delivery and in response havedeveloped additional management and monitoring processes and haveput in place their own quality assurance audits. Monash University,for example, has in place regular internal reviews of each of its ‘off-shore’ operations, with each of these being chaired by an externalmember with special expertise in quality assurance and accreditation.In addition, Monash has contracted with an international qualityassurance agency to conduct regular external audits of each off-shoreoperation. RMIT has similar internal reviews in place and in additionhas used auditors from the Quality Assurance Services to gainISO certification.

4.21 As already noted, another concern about ‘off-shore’ operations iswhether all ‘off-shore’ courses in particular professional areas such as accounting are covered by accreditation conducted by Australianprofessional associations. Comparatively little information is availableon this matter, but it could be a particular problem in cases where allteaching and examining is conducted by academic staff employed bypartner institutions operating under franchise arrangements.

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Increasing accountability pressures at home4.22 Generally in the Australian community pressures continue to grow for

increased accountability of public institutions and of governmentfunding or subsidies. In the case of higher education, this is likely toincrease further as public universities become more commercial inorientation. Further, community concern seems likely to demandstronger quality assurance mechanisms as the higher education systemmoves increasingly to further competition between institutions andpossibly towards a system of student based funding.

Incidents with private providers and increased numbers of private providers4.23 A small number of well-publicised cases concerning private providers

has raised the level of concern generally about quality assurance andaccreditation mechanisms. This concern has been felt particularly byMinisters, government officials and those universities with largecommitments in the areas of international education and with linkswith private institutions.

4.24 In our discussions, various informants mentioned the University ofGreenwich case, the case of the two institutions from South Australiawhich had secured approval for the use of the word university incompany titles and various cases of private VET providers andlanguage training schools closing because of insolvency. Apparentlythe University of Greenwich made enquiries from at least twogovernment accrediting agencies in States and Territories beforeapproaching the Norfolk Island administration.

4.25 The number of private providers offering accredited higher educationcourses clearly has increased substantially over the past five years andthere are rumours of considerable interest by overseas universitiesabout establishing campuses in Australia or delivering courses toAustralian students by distance education. These overseas providersinclude major American universities as well as ‘no-frills’ providers.

Complaints from applicants seeking accreditation4.26 Another reason why State and Territory officials are concerned about

current accreditation and quality assurance arrangements is that overthe past five years there have been an increasing number ofcomplaints from private providers seeking accreditation.

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4.27 Smith (1998) reports that there have been various complaints fromprivate providers who sometimes complain that the accreditationprocess is biased against them. In particular, it is sometimes alleged by applicants that the ‘playing field’ is not level and that Universityacademics on accreditation committees are not flexible enough toappreciate different paradigms and emerging disciplines. Privateproviders also suspect that the time taken in considering some courseaccreditation proposals is evidence that members of panels frompublic universities are trying to protect vested interests.

4.28 On the other hand, it should be noted that most of the relevantlegislation is sufficiently general in wording and intent to cateradequately for diversity in course applications. Smith (1998, p 8)points out that in New South Wales accrediting panels:

… are required to assess whether a proposed course displaysacademic objectivity and rigour and enables intellectualinquiry and discourse which are essential features in anyhigher education course. Panels do not concern themselveswith the desirability of or need for a course, other than to besatisfied that there is sufficient demand to make a programacademically viable.

4.29 Another common problem is that the role of review panels inaccreditation is often not well understood. In each case, panels areappointed to evaluate submissions and offer advice to the Minister orthe approving authority, and are not responsible for offering adviceand assistance to applicants. At the same time in making assessments,panels often provide comment which applicants sometimes takeaboard to modify and improve their proposals, but this function is notpart of the formal responsibilities of panels.

4.30 Still another problem is that often the appeal process is not wellunderstood. In Victoria, for example, unsuccessful applicants have the right of appeal to the Administrative Appeals Tribunal which hasbeen in place since 1993. However, to date there have been fewappeals and no appeal has proceeded to a formal hearing orjudgment (Smith 1998, p 10).

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The Modern Australian Model4.31 The Modern Australian Model of quality assurance and accreditation

proposed by DETYA has many strengths. In the first place, it makesimportant distinctions between the functions of accreditation andquality assurance and between the possible treatment of self-accreditinginstitutions and non-self accrediting providers. In Chapter 2, we definedboth accreditation and quality assurance. Both terms are usedinternationally in a variety of ways, but in the Australian context theyhave developed particular meanings. In summary, quality assurancein Australian higher education has come to refer to a range of manage-ment and assessment procedures to monitor performance, to ensurethe quality of outputs and to give stakeholders confidence, whereas inrelation to government agencies accreditation refers to a process ofassessment and review leading to recognition of a higher educationprovider or higher education course. As already noted, while closelyrelated the two processes are somewhat different. For one thingaccreditation is primarily concerned with new institutions and newcourses, whereas quality assurance generally relates to the activities ofestablished institutions. At the same time, it is seems highly desirablethat there should be linkages between accreditation and qualityassurance procedures and that information should be shared in thecase that the two functions are carried out by separate agencies.This need for linkages is even more important if the functions are tobe carried out by separate levels of government.

4.32 With regard to the distinction between self-accrediting institutions andothers, it is important that adequate consideration should be given tothe special characteristics of both sets of institutions, since they oftendiffer significantly in size and administrative depth. However, ideallyany new quality assurance mechanism should have the capacity tocover all higher education providers. In our interviews, a number ofrespondents made that point that, as far as possible, all highereducation providers should be treated in a similar manner. It shouldbe noted that for the 1993–1995 quality assurance program only publicuniversities participated.

4.33 DETYA documentation specifies that quality assurance andaccreditation mechanisms should satisfy a number of criteria. Themechanisms relating to self-accrediting institutions should not be solelyat the discretion of the institutions themselves; there needs to be someexternal review or audit of the claims made by institutions aboutquality and standards; the mechanisms should be credible with inter-national and domestic interest groups, and should and be able to

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protect the international reputation of Australian awards; themechanisms should help satisfy Australian taxpayers of value formoney; any audit mechanism should have rigour, but at the same timebe cost effective, not unnecessarily intrusive and be able to retain thecooperation of the public universities; and the mechanisms shouldprovide legal clarity for students and providers and be able topromote good practice and facilitate improvement. We support theseas desirable principles.

Other options4.34 In its documentation, DETYA refers to four alternative options to the

Modern Australian Model. These are refinements to the currentAustralian model, the New Zealand model, the British QualityAssurance Agency Model and the VET sector model.

4.35 Refinement of the current Australian model provides for enhancedaccreditation processes which remain in the hands of the States andTerritories, with institutions continuing to take major responsibility fortheir own quality assurance but with encouragement to strengthenthese processes through benchmarking, and use of external auditssuch as having processes assessed according to ISO standards, andminor modifications to legislation. While the suggested improvementswould provide for worthwhile improvements, the major difficulty isthat Australia’s arrangements would fall far behind practice in anumber of competitor countries and would do little to provideadditional safeguards for the higher education export industry, or tolend additional international credibility to Australian awards. Thebiggest gap is the absence of some national agency that can certifythe quality of Australian higher education.

4.36 The recently modified New Zealand model has a number of strengths.In particular, it provides for a strong national government agency withan appropriate legislative base, it includes an institutional auditprocess and it provides for a coordinated approach for the wholetertiary education sector. On the other hand, it is by no means certainhow successful will be the approach of the Quality AssuranceAuthority in granting recognition to accreditation providers, especiallyin terms of achieving a reasonably uniform coverage in audits acrossdifferent sectors and in gaining international recognition and localcredibility. The appointment of only one accreditation agency thatfailed to deliver according to specifications could be sufficient to domajor damage to the system. Presumably one reason for adopting this

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approach is that since the early 1990s the university sector has had itsown Academic Audit Unit and this system appears to be working well.Under the new arrangements, we assume that the New Zealanduniversities may choose to retain the services of the AcademicAudit Unit. It should be noted, however, the Academic Audit Unithas not covered the work of the 25 polytechnics and four collegesof education.

4.37 The New Zealand Academic Unit was set up with the following termsof reference:

• to consider and review the universities’s mechanisms for monitoringand enhancing the academic quality and standards which arenecessary for achieving their stated aims and objectives;

• to comment on the extent to which procedures in place inindividual universities are applied effectively;

• to comment on the extent to which procedures in place inindividual universities reflect good practice in maintaining quality; and

• to identify and commend to universities good practice with regard to maintenance of academic standards at national level(Woodhouse 1997, p 72).

In fulfilling these terms of reference, the Academic Audit Unit focuseson mechanisms for quality assurance in the design, monitoring andevaluation of courses in teaching, learning and assessment, in relationto the appointment and performance of academic staff, and inresearch. The Unit is instructed to take account with respect toacademic matters of the views of students, external examiners,professional bodies and employers. The Unit is funded jointly by theuniversities but is independent otherwise of the universities indiv-idually and the Vice-Chancellors’ Committee. Audit reports are publicdocuments and there is considerable pressure on universities to take seriously any criticisms made. As in other institutional auditprograms, universities carry out self audits before the visit of panels.Panels are made up of academics from New Zealand and overseasuniversities and members of the business community.

4.38 The new United Kingdom model based on the Quality AssuranceAgency which was established in 1997 is still developing itsprocedures. However, to date its proposals have been somewhatcontroversial and it has still to secure strong support from the well-established group of older research universities. Further, in thejudgement of many experts, the stated goals of the Agency appear tobe somewhat unrealistic and to date many of the Agency’s proposals

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have raised considerable controversy. Observers question the extent towhich the Agency appears likely to intrude substantially into the workof universities and the extent of funding that a fully operationalAgency will need.

4.39 It is important to recognise, however, that in the past decade therehave been three other important British experiments in qualityassurance, one of which is on-going. First, the Committee of Vice-Chancellors and Principals established the Academic Audit Unit, whichin turn became the Higher Education Quality Council followingabolition of the binary system. This development was based on theidea of institutional audits of quality assurance processes in thecontext of an institution’s stated aims and objectives. The aim wasto ensure public accountability for the maintenance and improvementof academic quality by finding out how institutions discharge theirobligations to provide high quality education and satisfy themselvesabout the academic standards they seek to uphold (Williams 1997,pp110–111). A report in 1996 at the end of the second round of auditsnoted that quality assurance procedures had become the norm in thehigher education sector.

4.40 Second, in the early 1990s, the higher education funding councilsestablished a system of quality assurance for teaching based on theassessment of disciplines. The purpose of these assessments was to‘ensure that quality was satisfactory or better, to encourage improve-ment, to inform funding and to reward excellence’ (Williams 1997).Student learning experiences and achievements were assessed againstthe provider’s aims and objectives. The process involved a self-assessment by the department, a visit to the department by externalassessors (mainly academics from other institutions trained by thefunding council), and judgements made on the quality of educationthrough observation of teaching and learning, scrutiny of students’work and discussions with staff and students. Initially, the method-ology developed by the Higher Education Funding Council of England(HEFCE) involved selective visits to subject providers on the basis ofself assessments submitted, and this resulted in the award of thegrades of excellent, satisfactory or unsatisfactory. Where no visits tookplace, subject providers were awarded a satisfactory grade. Criticismsof this methodology forced the HEFCE to revise its approach to onebased around a graded profile of subject areas constructed against sixaspects of provision (curriculum; teaching; learning and assessment;student progress and achievement; support and guidance provided;and quality assurance arrangements).

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4.41 Third, since 1986 the higher education funding councils haveconducted periodical assessments of research known as the ResearchAssessment Exercise (RAE). The purpose is to provide quality rankingsfor research carried out in each of the major subject areas in allgovernment-funded higher education institutions. The last 1996 inRAE, which followed earlier exercises in 1986, 1989 and 1992, wasconducted jointly by HEFCE, the Scottish Higher Education FundingCouncil, the Higher Education Funding Council for Wales, and theDepartment of Education for Northern Ireland. Each of these bodiesdistributes funds selectively to institutions on the basis of the qualityjudgements made by expert RAE panels and funds are intended tosustain a strong research infrastructure and a range of curiosity-drivenbasic and strategic research activities (Harman 1999).

4.42 RAE ratings are awarded by subject panels (60 panels in 1996 for69 assessment areas) of about 10 members each, made up ofdistinguished researchers in the particular subject, appointed afterconsultation with interested bodies such as learned societies andprofessional associations (Research Assessment Exercise: Criteria forAssessment 1995). Higher education institutions in 1996 could submitfor assessment any research carried out within the previous four yearsby those of their current staff they wished to present from thenominated subject areas. Universities were able to decide whichdepartments to put forward for assessment and which staff in eachdepartment. Some universities presented only a small number of theirtotal departments and staff for assessment, while high performinguniversities generally presented all departments and practically allacademic staff.

4.43 Assessments are based entirely upon the written materials submitted. A standard electronic template is used across all institutions andsubjects, and this includes:

• details of those staff whose work is offered for assessment in eachsubject area and selected recent research outputs for each of them(up to four per staff member);

• other information about research activity and the units ofassessment (eg numbers of research students, and research grantand contract income from various sources); and

• information about the institution’s support for research in eachsubject area (departmental structure, facilities and research plans)and other key information.

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4.44 In 1996 panels awarded a rating for each individual subjectsubmission on a seven point standard scale, ranging from 1 (researchquality that equates to attainable levels of national excellence in none,or virtually none, of the sub-areas of the activity) to 5* (researchquality that equates to attainable levels of international excellence in a majority of sub-areas of activity and attainable levels of nationalexcellence in all others) (Research Assessment Exercise: Guidance for Submissions 1995, Annex B).

4.45 The RAE is a peer review exercise with ‘assessments being made by the panels in the light of their collective knowledge and exper-ience of their field of academic research’ (Research AssessmentExercise: Criteria for Assessment 1995, p 1). In each case, panels areconcerned with making judgements about quality based primarily onselective reading of listed works and other evidence of reputation andstanding as set out in supplementary documentation. In making itsassessment, each panel takes into account only the work of those stafflisted as being ‘research active’.

4.46 Each of the funding bodies uses RAE results in somewhat differentways for allocating block grant funding to universities. For example,the HEFCE in 1998–1999 allocated 804 million pounds sterling onthe basis of 1996 rankings. The total funds were allocated between69 subject areas or ‘Units of Assessment’. Allocations to eachdepartment were based on the ranking given in the RAE, the costweight of the subject area, and the number of research activeacademic staff. Only departments that are awarded a 3b or betterreceive funding.

4.47 The sum of 804 million pounds sterling allocated to all English highereducation institutions by the HEFCE in the funding year 1998–1999amounted to 20.7 per cent of total funds allocated for teaching andresearch. The largest total research allocations went in order to theUniversity of Oxford, the University of Cambridge, University CollegeLondon, and Imperial College. Many of the strongest researchintensive universities received 50 per cent or more of their totalHEFCE allocation on the basis for research, while in a number ofex-polytechnic universities the total research component amountedto less than half a million pounds and far less than 1 per cent of theirtotal grant.

4.48 The RAE is a costly and labour-intensive form of assessment, both interms of administrative costs centrally (2.25 million pounds in 1996)and in the time demands it makes on academics and academic andadministrative departments. Academic departments play a major role

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in planning strategies and in collecting data but university centraladministrations also play key roles in collecting data and providingoverall coordination. The end result in each university is what onesenior academic described as ‘a mountain of documentation’.A particularly heavy burden is borne by the assessment panels, whichin 1996 considered the work of some 3 000 departments and 56 000academics in 192 participating higher education institutions.

4.49 According to various reports, the RAE has had various unintendedconsequences, such as generating suspicion about the integrity of datasubmitted by other universities, helping to break down traditions ofcollegiality, encouraging academics to put additional efforts intoseeking external research funding and adopting strategies to maximisethe number of publications (such as dividing papers into two or moreshorter papers and publishing books as journal articles prior to pub-lication of the full work). Others have criticised the lack of a clearlyarticulated philosophy for the RAE, possible defects in a peer reviewapproach and the fact that while RAE funding is on such a basis it isvery difficult for less strong institutions to attract additional funding into order to build on their strengths. Some newer universities have putconsiderable effort into building up research capacity of particulardepartments, but generally these efforts have attracted little additionalfunding and within such universities there is often considerable ill-feeling about the fairness of the RAE and about the indirect adverseeffects it has on teaching.

4.50 The current VET model of accreditation and quality assurance is nowwell accepted in the VET sector and widely supported by industry.It zalso has won admiration from various senior government officials,some who have suggested that it provides a suitable model for astrengthened quality assurance and accreditation mechanism forhigher education.

4.51 The VET model has separate but related national mechanisms ofaccreditation and quality assurance. Accreditation of training providerscertifies that the training meets industry needs and this is theresponsibility of the States and Territories. It is based on the AustralianRecognition Framework (ARF) which is a quality assured approach tothe registration of training organisations seeking to deliver training,assess competency outcomes, and issue qualifications. In the past onlyprivate providers had to be registered but now all trainers need to beregistered. National standards for registration comprise four sets ofStandards and Evidence Requirements, which give effect to theNational Principles. The registration cycle comprises four elements:

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initial registration, self assessment and evaluation, compliance audit,and re-registration. Training organisations can by registered either for(a) the provisions of training delivery, assessment and issuingnationally recognised qualifications and statements of attainment, or(b) the provision of skill recognition services and issuing of nationallyrecognised qualifications and statements of attainment. RegisteredTraining Organisations (RTOs) may be delegated power to selfmanage the scope of their registration and/or self manage accred-itation functions. RTOs may include TAFE colleges and institutes,private commercial providers, community providers, schools, highereducation institutions, enterprises and firms, industry bodies and anyorganisation that meets the requirements for registration. The Standards and Evidence Requirements contain a core which allorganisations seeking registration must meet; product/service standardsfor organisations seeking to deliver training, assess qualifications andissue certificates and qualifications; product/service standards fororganisations seeking to provide skill recognition only and to issuecertificates and qualifications; and separate standards for QualityEndorsement which provide for organisations to self-accredit coursesand/or self manage the scope of their registration, and which willoperate in conjunction with the quality assurance systems of each Stateand Territory (Australian National Training Authority 1998 and 1999).

4.52 One of the main VET sector mechanisms of quality assurance is thenational approval of Training Packages that define competencies forparticular areas and the qualifications to be issued. These Packagesare comprehensive, integrated products that provide national bench-marks and resources for the delivery, assessment and qualifications.They comprise endorsed components of national competencystandards, assessment guidelines and qualifications, combined withnon-endorsed components which may include learning strategies,assessment resources and professional development materials. TrainingPackages their main emphasis on outcomes and are meant to providea more flexible approach than accredited courses. Approval ofTraining Packages is the responsibility of the National TrainingFramework Committee, which reports to the ANTA Board. To date35 Packages have been approved.

4.53 In our discussions, we were surprised to find little support for theidea of integration of VET and higher education quality assurancesystems. Rather, most respondents, whether in universities, govern-ment agencies or ANTA, stressed the major differences between theVET and higher education sectors. On the other hand, it must beadmitted that there are some parallels between VET and higher

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education institutional accreditation for private providers performedby the States and Territories.

4.54 Other important models not canvassed in the DETYA documentationare the Dutch and French models of quality assurance. The Dutchmodel is based on a well-organised program of disciplinary reviews,while the French model uses both disciplinary reviews and instit-utional audits. The Dutch program is operated by the VSNU, theassociation representing the heads of Dutch Universities, while theFrench program is the responsibility of a special government qualityassurance agency. The Dutch scheme of reviews does not have anylink to government funding of higher education institutions, while inFrance the results of both disciplinary reviews and institutional auditsare used in developing funding allocations, although the precise linksare not made clear. The Dutch model would seem to be the moreuseful to consider carefully, especially as irs system of disciplinaryassessments is well developed with extensive documentation beingavailable in English. On the other hand, it seems unlikely that anymodification of Australian quality assurance mechanisms would beable to introduce both disciplinary assessments and institutional auditsand, as will emerge in the following discussion, it is not clear howeasily a Dutch style model designed for about 15 universities couldbe adapted to fit the needs of a public university system of37 universities, plus private universities and other providers.

4.55 The current Dutch system of reviews of disciplines for both researchand teaching had its origins in restructured relationships betweenhigher education and the Ministry of Education and Science whichwere achieved in the 1980s. Following publication in 1985 of thepolicy paper, Higher Education: Autonomy and Quality, discussionswere held between the higher education sector and the Ministry.In return for achieving increased financial and managerial autonomy,higher education institutions agreed to establish of an assessmentmechanism that might demonstrate to society the delivery of qualityeducation. Originally the Government intended that the assessmentfunction would be carried out by the Inspectorate for HigherEducation but, after negotiations, it was agreed that responsibilitywould lie with the Association of Cooperating Universities of theNetherlands (VSNU) for the universities, and the Council for non-university institutions for the HBOs. The University assessment beganwith a pilot program in 1988 and commenced on a more formal basisthe following year. Under this system, visiting committees review studyprogrammes in all universities on a six year cycle. In preparation forthe visiting committees, each participating study programme prepares

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a self-evaluation. Visiting committees consist of about seven membersand are appointed following consultations with the faculties to bereviewed. During visits committees hold discussions with Deans,senior management, academic staff and students (van Vught 1994a).

4.56 The reviews of research have been particularly successful and thedetailed methodology used continues to attract considerable interest inother countries. Over the period 1993–1997, 28 disciplines oracademic areas were reviewed, following a protocol that was agreedto in 1994. In the case of medical research, the VSNU and the RoyalNetherlands Academy for Arts and Science shared responsibility forthe assessment. A number of smaller institutes, some outside theuniversity sector, were also assessed by special request. In 1997, theVSNU Committee on the Future of Quality Assurance evaluated thereviews of research and, as a result, it was agreed to have a furtherround under a slightly modified protocol which was agreed to in1998. Under this new Protocol (VSNU 1998), there will be a muchgreater emphasis on the context specific aspects of research programsand faculties, and the review committees will be explicitly asked toanswer questions relating to the missions and the state of the art inthe academic area. The evaluation criteria continue to compromise theelements of academic quality, productivity, relevance and viability butthe emphasis on context-specific aspects requires application of thecriteria in the light of the faculty or institute’s mission. The Protocolstates that, as ‘in the first round, the most important functions will bequality assurance (improvement of university research quality as aresult of self-regulation within universities, faculties and researchinstitutes); accountability; and collection of information that can berelevant to third parties (NSNU 1999, p ii).

4.57 No reports are yet available for reviews conducted under the newprotocol, but the 1996 review of earth sciences illustrates well theapproach used in the 1993–1997 round. The review of earth sciencesconsidered the work of five faculties and their 25 research prog-rammes. In addition, at the request of the Board of the LeidenInstitute of Chemistry, the Committee also assessed Geo-biochemistryin that Institute although it was originally assigned to the ChemistryReview Committee. The assessment of earth sciences was conductedby a review committee of seven members, all of whom with theexception of the chair (who held the position of Professor of Astron-omy at Utrecht University) were foreign experts from Australia,Belgium, France, the United Kingdom and the United States.Following the assessment, the review committee produced a detailedreport of just under 100 pages, outlining its methodology, the key

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characteristics of the faculties and research programmes beingreviewed, and providing detailed comment on the state of earthsciences and on the work of each faculty and research programme.The committee assessed scientific quality, scientific productivity,scientific and societal relevance, and viability on a five-point scale ofexcellent, good, satisfactory, unsatisfactory and poor. While overall itreported favourably on the state of earth sciences, it identified anumber of issues of concern, particularly issues about lack of criticalmass in some institutions, workloads of senior staff, and the desir-ability of increased international mobility amongst students and post-doctoral fellows. Each research programme was given a descriptivegrade under the four criteria (VSNU 1996). One of the strengths ofthe program of research assessments is that apart from constitutingan important quality assurance and accountability device, reviewreports provide an overall detailed assessment of the various academicdisciplines and the work in each of these in the various universityfaculties. They are also forward-looking reports that can be usedto guide both universities and government agencies in theirforward planning.

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5 Accreditation of courses and institutions

5.1 This chapter considers the mechanisms for the accreditation of coursesand institutions in a Modern Australian Model of quality assurance andaccreditation. It will be recalled that the Model provides for differentarrangements for institutions that have the power to accredit their owncourses and for non self-accrediting institutions. For the first, the mainmechanism would be rigorous scrutiny of financial and quality aspectsbefore founding legislation is passed or other authorisation is given.For non self-accrediting institutions, the model is less well developedbut it is suggested that the main elements could be as follows:

• Rigorous scrutiny of provider capacity before course accreditation; and

• Review of provider performance and accredited courses every five years.

5.2 The term accreditation with respect to this chapter is used to refer toa process of assessment and review, carried out by a governmentagency and with legislative backing, which enables a higher educationcourse or institution to be recognised or certified as meetingappropriate standards. It is also a process leading to approval forhigher education institutions to operate within a State or Territoryor for particular courses leading to specified awards to be offered.As already noted, this process currently is carried out by the Statesand Territories.

5.3 With respect to the different categories of higher education institutionsoutlined in chapter 3, there is little problem with respect toinstitutions that currently have powers of self-accreditation, exceptthat in highly unusual circumstances it is possible that a State orTerritory Minister could institute an inquiry into a self-accreditinginstitution, or even dismiss the governing body. Further, as will beargued in a later chapter, it is highly desirable that, whatever nationalquality assurance mechanism is developed, it should cover private aswell as public universities, and self-accrediting as well as non self-accrediting institutions.

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5.4 Acceptance of the points made in the previous paragraph means themain concern of any accreditation process would need to be with:

• Approval for new universities to operate, to use the nameuniversity, and to offer degrees and other awards;

• Approval and accreditation of courses of study leading to degreesand other awards by other higher education providers; and

• Re-accreditation of institutions and awards.

5.5 There are also some related issues about whether there should be anyrestrictions on Australian universities operating in other states thanthe one in which they were established, about their ability todevelop relationships with private providers in other states and todevelop special courses or campuses for international students inother states, and about whether higher education providers who offercourses leading to particular awards of universities should be coveredby accreditation.

5.6 Still another topic that needs consideration is what links there shouldbe between accreditation and quality assurance in the proposedmodel. This will be taken up in later discussion.

Responsibility for accreditation5.7 In our various discussions, we found strong support for the prop-

osition that accreditation in the way defined in this chapter is clearly amatter for government and not the higher education sector, and thatthe States and the Territories should continue to exercise theirresponsibilities in this area. This means that States and Territorieswould continue to approve the establishment and operation of newand overseas universities and the approval of courses in non-selfaccrediting institutions. Many respondents considered it important thataccreditation should have a legal basis, especially as in the future it ispossible that there will be more challenges considering who shouldbe able to offer courses leading to degrees and other higher educationawards and what institutions should be able to use the titles ofuniversity and degree. State and Territory accrediting agencies clearlysee accreditation as a function for their level of government andconsider that, over the past decade, despite a number of weaknessesin criteria and processes, the various States and Territories have donea worthwhile job at a highly professional level. They point to existinglegislation in place and emphasise the constitutional responsibilitiesof the States and Territories for particular aspects of education. Further,a number of those interviewed made the point that in recent years the

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role of the States and Territories has been enhanced as the Common-wealth has moved from funding to subsidising universities.

5.8 We support the above arguments and note that a number of the Stateshave well developed offices which have had considerable experiencein accreditation, in some cases going back to the period of advancededucation. Further, in a number of cases the expertise in accreditationis of a high order and some of the documentation that has beendeveloped is particularly impressive.

5.9 We found no support at all for any other agency or body to performthe accreditation role. The AVCC considers that accreditation is aproper role for government rather than the sector and is concernedthat accreditation should have a proper legislative basis. Professionalbodies show no interest in the area and it should be noted that alarge number of disciplinary and professional areas are not covered bythe accreditation functions performed by bodies such as the Institutionof Engineers.

5.10 Another possibility would be for a new national agency for qualityassurance to take over the current work of the States and Territories in course and institutional accreditation. We found no support for thisplan and we advise against it. It would raise difficult constitutionaland intergovernmental issues and the accreditation functions couldoverburden any new agency charged with the difficult task ofdeveloping a new national quality assurance agency. Further, throughcontinuation and extension of the present work being undertaken bythe MCEETYA Multilateral Joint Planning Committee we consider thatit should be possible to develop a professional national approach toaccreditation, being operated by State and Territories working in closecooperation with one another. On the other hand, if the current workof the Multilateral Joint Planning Committee is unsuccessful, otheroptions than may have to be considered.

5.11 In these circumstances we consider that accreditation in terms of theapproval for the operation of new or overseas universities and theapproval of higher education courses offered by non self-accreditinginstitutions should remain, at least for the present, a State andTerritory responsibility. At the same time, it we see the need for eachState and Territory to report annually to MCEETYA on any changes inaccreditation legislation, guidelines and procedures, and providedetails on those institutions and courses which have receivedaccreditation over the past 12 months. We recommend adoption ofsuch a policy. Appropriate linkages also will need to be developedbetween accreditation and any system of national institutional qualityassurance audits.

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Greater uniformity of legislation, criteriaand processes

5.12 State and Territory accrediting bodies readily admit that there areproblems in the current arrangements with respect to uniformity inlegislation and other regulatory requirements, and in criteria andprocesses employed in accreditation. However quite rightly, they pointto the substantial progress made in the past five years, particularly in strengthening legislation, in sharing documentation and informationbetween offices, and in achieving reciprocal agreements that mean an institution operating nationally or in more than one State/Territoryneed only apply once for accreditation. They also point to recentprogress made by the MCEETYA Multilateral Joint Planning Committee.

5.13 The MCEETYA meeting of 22–23 April 1999 dealt with a number ofitems related to the recognition of universities. That meeting agreed to refer the issue of a common approach to criteria and proceduresemployed in the accreditation of higher education institutions to theMultilateral Joint Planning Committee. It asked the Committee to report on the current criteria and procedures for the accreditation of higher education institutions in each State and Territory and make recommendations on the most appropriate instrument for a common approach.

5.14 The former Higher Education Task Force had commissioned a projectin 1998 to be undertaken in Queensland to explore options to developcommon principles and a cooperative approach to quality assurance ofaccreditation processes among relevant State and Territory jurisdictionswith respect to the following areas:

(i) accreditation of higher education courses offered by private (non-university) providers, and registration of providers to offercourses; and

(ii) accreditation recognition of overseas and/or private universities,including arrangements, if any, with respect to:

• overseas universities that teach individual Australian distanceeducation students in Australia, although these may have nopresence in Australia, either through an agent or Australianbranch office;

• overseas universities that seek to operate in a State or Territory through an agent of by establishing a branch office or campus; and

• local institutions seeking to use the title and operate as a university in a State or Territory.

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5.15 A draft report on arrangements and procedures for the establishmentand recognition of universities throughout Australia has been preparedunder the Taskforce Consultancy. This is part of a larger report onaccreditation of higher education institutions.

5.16 The 10th meeting of MCEETYA on 22–23 1999 April also formallyendorsed the operational guidelines for use by State and Territoryaccreditation officers for concurrent accreditation and authorisation ofprivate higher education providers to offer higher education courses intwo or more States or Territories of Australia.

5.17 To date the Multilateral Committee has put most of its efforts intodeveloping a common protocol for the accreditation of universities.In turn this is raising the issue of what are the distinguishingcharacteristics of a university in Australia at close to the turn of themillennium and that criteria should be used in accrediting new andoverseas universities. Also it is planned to identify the gaps in legis-lative protection afforded to the Australian university system againstdomestic and overseas institutions operating in Australia withoutapproval of the relevant State or Territory authority.

5.18 With regard to controls over use of the titles of ‘university’ and‘degree’, there are some differences of opinion. State and Territoryofficials see value in maintaining and strengthening controls overthese titles, especially as this is an important element of regulatorycontrols over new providers and overseas institutions, and in main-taining the status and international credibility of current universities.On the other hand, some key figures within public universitiesconsider that Australia appears to be moving to an American typehigher education system where the title of university carries lessweight and where some prestigious institutions use the title institute orcollege and relatively low level institutions call themselves universities.

5.19 From a pragmatic point of view, it will be unfortunate if theMultilateral Committee is drawn into lengthy and time-consumingdebates about the characteristics of modern Australian universities.Perhaps more important is the need to develop uniform protocols forthe recognition of new and overseas universities and agreement onthe criteria to be applied. There seems a high degree of agreementthat criteria should include topics such as financial viability, the legalbasis of the institution, and the processes of governance, internalquality assurance and accountability. But there appears to be lessagreement about whether the criteria should include quantitativeindicators with regard to staff, buildings and facilities, and libraryholdings and specialised laboratories. Other issues are whether all

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universities should have an active involvement in research andresearch training and what might be minimum commitment to theseactivities for both new institutions and established overseasinstitutions.

5.20 Other issues that need attention include:

• protocols and procedures for the accreditation of institutions otherthan universities;

• whether the recognition of new and overseas universities shouldautomatically carry with it the rights of self-accrediting powers, orwhether some accredited universities might be treated in a similarfashion to the Melbourne Private University whose courses mustbe certified by the University of Melbourne and the accreditationlimited to a period of five years;

• whether or not all institutions need some form of accreditationbefore their courses can be accredited;

• requirements with regard to ‘out-state’ Australian institutionsoperating in other States and Territories;

• whether or not all accredited institutions need special approvalto offer courses to international students at special internationalstudent campuses;

• whether or not universities and other self accrediting institutionsneed special approval to enter into franchise arrangements to offerhigher education courses with non accredited institutions such asVET providers, especially when all teaching and assessment iscarried out by the staff of the franchisee;

• whether or not legislation in all States and Territories shouldprovide for both the accreditation of institutions and courses;

• the linkages between accreditation of institutions and courses;

• detailed protocols, criteria and procedures for the approval and accreditation of courses in institutions which do not have self-accrediting powers.

Many of these issues are quite complex and raise difficult politicalissues. On the other hand, already there is available extensivedocumentation in the offices of accrediting agencies.

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Reporting on accreditation of institutions and courses5.21 One current weakness is a lack of national information available to

members of the public, employers and higher education providersand potential providers about accreditation processes and whichinstitutions and courses have been accredited and over what periods.Some accrediting agencies have information and consolidated listingsof accredited institutions and courses readily available but in othercases this is not so. At a minimum, this information should be widelyavailable nationally and information should provide legal clarity tostudents, providers, employers and professional associations. Furtherthis information should be available in both print and on-line forms.It will be noted that we have already recommended that each Stateand Territory should report annually to MCEETYA on any changesin accreditation legislation, guidelines and procedures and whatinstitutions and courses have been accredited over the past twelvemonths.

5.22 We had discussions with various bodies about how a national listingmight be achieved. Some suggested a small office attached toMCEETYA or to the AQF Board Secretariat or that the developing andmaintaining a listing might be the responsibility of a new nationalquality assurance agency. However, the AQF Board Secretariatsuggested that possibly the most cost-efficient means might be foreach accrediting agency to have available both print and on-linelistings and for the AQF Web page to refer enquiries to the variousState and Territory Web pages. In addition the proposed nationalquality assurance might do the same. While this solution would be amarked improvement over the current situation and would be cost-effective, the main limitation would be that there would be no singlenational listing of all accredited institutions and courses. Further, thissystem would depend on the efficiency of each accrediting agency inkeeping its listing up to date.

Other compliance functions for accrediting agencies5.23 An important quality assurance function performed by State and

Territory accrediting agencies is monitoring that all higher educationinstitutions in their jurisdiction fulfil all statutory obligations withregard to accountability and providing annual reports to governmentagencies. The Victorian Office of Higher Education has a particularlywell developed system, whereby all universities are reminded annuallyof their various accountability and reporting responsibilities. Each is

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provided with a listing of all responsibilities and is required to sign offon each item as it has been met. This system could well provide amodel for those agencies that do not have such a formal system.

Staffing and resourcing of State and Territoryaccreditation agencies

5.24 While we recommend that accreditation should remain a State andTerritory function, it will be important that each State and TerritoryGovernment resource their higher education offices at an appropriatelevel. As already noted, currently the size and expertise of theseoffices vary to a considerable extent and in many cases administrativeweaknesses are a direct result of lack of staffing and other resources.If State and Territory accrediting agencies are to have an enhancedrole, there should be a clear understanding that adequate resourceswill be provided.

Links between accreditation and quality assurance5.25 An important part of the current accreditation process is the

reaccreditation of institutions at regular intervals. Generally the periodof acccreditation is five years. Clearly with any accreditation system itis necessary to review and re-accredit institutions and courses on aregular basis. However, with a new national accreditation agency, itwill be necessary to have clear policies about the relation betweenreaccreditation and quality assurance reviews. In particular, will a nonself-accrediting institution that subjects itself to quality assurancereviews be subjected to the same re-accreditation requirements as onethat does not? One solution could be that institutions which have hada quality assurance review within the past three years may be able toachieve re-accreditation via a less demanding process.

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6 Quality assurance andimprovement plans

6.1 This chapter considers the proposed strengthening possible under theModern Australian Model of internal quality assurance mechanisms forself-accrediting institutions. As already noted the Modern AustralianModel proposes putting considerable weight on the development andannual publication of Quality Assurance and Improvement Plans forthe forthcoming triennium. These plans would outline the institution’sgoals, strategies for achieving those goals and the indicators used tomonitor progress in achieving the goals. The plans would also providean analysis of the institution’s performance, commenting on such dataas the outcomes of the graduate satisfaction survey (CEQ) andgraduate employment outcomes (the GDS) over time and comparedwith appropriate benchmarks. The plans would also need to clearlyoutline the processes in place to assure quality of provision within itstotal ‘catchment area’.

6.2 This chapter comments on this proposal. It also discusses who shouldrequire institutions to submit the plans and who should publish theseand the need for some integration with the proposed quality assur-ance audits. It also comments on whether or not the proposal forquality assurance and improvement plans might cover other than self-accrediting institutions, and Commonwealth funded institutions as wellas those institutions not funded by the Commonwealth.

Comments on suggested model6.3 Continuation and strengthening of the current requirements of the

Commonwealth with regard to institutional quality assurance andimprovement plans appears to be a well-conceived and sensiblestrategy. Good management practice requires that all institutionsshould have in place appropriate quality assurance and improvementplans and submission of these to some outside body provides usefuldiscipline for institutions to keep such plans up to date. With dataavailable from the CEQ and GDS, it appears sensible that institutionsshould provide comments on these data for their own institutions,especially in relation to trends over time and make comparisons withappropriate benchmark data. The suggested requirement thatinstitutional quality plans should cover all major aspects of operations

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including ‘off-shore’ and distance education internationally, wouldconstitute an important addition to current guidelines. However,‘catchment area’ may not be the best term to use with regard to thismatter as it already carries with it specific meanings with regard to thehome address of students and those areas from which institutionsgenerally draw their students.

6.4 While some universities have made major advances in benchmarking,particularly in relation to other members of established networks orindividual institutions with similar characteristics, our impression is thatthis development has not been uniform across the sector and that itmay be helpful to provide additional assistance. Such assistance couldtake the form of special projects funded by the Commonwealth thatwould lead to experience and good practice being shared. In additionthere are various technical issues about aspects of benchmarking thatrequire additional consideration.

6.5 With regard to ‘off-shore’ international education, whether it is in theform of separate campuses established by an Australian university,twinning or franchising arrangements, or offering distance educationinternationally, it is particularly important that institutions shoulddocument in some detail their monitoring and quality assuranceprocedures. In an early chapter it was noted that in 1998 almost23 000 students were enrolled under ‘off-shore’ arrangements and thatthis form of enrolment seems highly likely to increase substantially.Further, ‘off-shore’ international education poses particularly difficultproblems of management and monitoring, while unfortunate incidentsrelated to such operations could have a particularly serious impact onAustralia’s international education effort, especially across the countriesof the Asia and Pacific region.

6.6 A number of major Australian international education providersalready have in place special review and external monitoringarrangements for ‘off-shore’ arrangements. Such developments arehighly desirable and it would be useful for the Commonwealth tofund a project which might address some of the special problems inquality assurance for ‘off-shore’ operations and help to circulate ideasof good practice.

6.7 Publication of Quality Assurance and Improvement Plans providesincentive for institutions to take the development of plans andmonitoring of performance seriously. It also provides a usefulmechanism for dissemination of good practice and innovation.Since the first publication of plans has not yet occurred it is difficultto know how publication will actually work in practice and what its

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effects will be. However, it should be noted that publication of instit-utional reports from the second and third rounds of the 1993–1995quality assurance program was found to be useful in many institutions.One important consideration will be the length and format of plans.While publication of plans may mean imposition of a tight word limit,this could work to reduce some of the value of institutions havingdetailed and comprehensive plans. Further, if the review of qualityassurance and improvement plans was built into a new audit processthis could well lessen the need for annual publication of plans.

Who should require and publish plans and links with institutional audits?

6.8 Currently DETYA requires institutions that it funds to prepare qualityassurance and improvement plans as part of the annual profileexercise. Senior officials at State and Territory level and seniormanagers in the higher education sector expressed no problem withthis arrangement, pointing out that any government agency thatprovides funding has every right to impose conditions on funding,particularly ones related to accountability. Further, it is widelyacknowledged that such plans help promote good practice.

6.9 There are however two fairly minor problems with this arrangementthat deserve some consideration. The first is that with the estab-lishment of a new national quality assurance agency it wouldbe desirable for there to be on-going discussions between DETYAand the quality assurance agency about what DETYA requires of theinstitutions it funds and what the quality assurance agency will requirein terms of documentation and self-studies prior to the visit of areview or audit committee or team. Ideally what DETYA requiresof institutions in terms of plans should be identical, or at least notin conflict with, required documentation for quality audits.

6.10 Second, since the requirements concerning preparation andsubmissions of plans applies only to those institutions funded byDETYA, there is the question of whether it would be desirable forsome requirement of this kind to be placed on non-DETYA fundedinstitutions, including the two private universities, other self-accrediting institutions and private providers. This raises difficult issuesabout constitutional and legal responsibilities, but possibly the Statesand Territories might consider placing some requirements aboutannual quality assurance plans on other than Commonwealth fundedinstitutions, or the new quality assurance agency could require all

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institutions to submit plans as part of the documentation submitted asthe first stage of institutional audits.

6.11 Associated with the need for on-going discussions between DETYAand the new quality assurance agency, it would also be desirable to have on-going discussions by DETYA and the new quality assurance agency concerning what requirements concerning thesubmissions of quality assurance and improvement plans and otherdocumentation that professional associations put on institutions andfaculties as part of accreditation and re-accreditation visits. While itmay be difficult to achieve a fully integrated approach, at least itwould be helpful if the key parties were able to exchangedocumentation on an on-going basis.

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7 Quality audits and a new quality agency

7.1 The final chapter considers the proposal for a new national system of quality audits and the establishment of a new agency of some kindto take responsibility of these audits. It will be recalled the proposalfor the Modern Australian Model is to have separate arrangements forself-accrediting and non self-accrediting institutions. For self-accreditinginstitutions, there will be a quality audit every five years and the actual audit will be proceeded by a self-study. However, non self-accrediting providers will not be subject to such audits but will be subject to reviews of performance every five years as part of a re-accreditation process.

7.2 The task for our project was to: develop the Modern Australian Modelas an alternative to the other four models; advise under whoseauthority it should be run; advise whether the framework would needa legislative base; assess whether it would be sensible and appropriateto make use of the AQF; elaborate the possible nature of the fiveyearly self-assessments for self-accrediting institutions; comment onthe desirability of focussing more than in the past on outcomes andstandards as well as processes; consider how to achieve rigour andindependence for the process while retaining the cooperation andconfidence of universities; and advise on the role of professionalassociations within the model and the nature of the audit of thecourses of non self-accrediting providers.

7.3 More specifically, we were asked to make a comprehensive assessmentof the Modern Australian Model against the following criteria:

• Credibility (how well the model would be credible withinternational and domestic interest groups and potential customers,and the marketability of the arrangements);

• Effectiveness (ability to address learning outcome standards as wellas quality assurance processes);

• Ability to provide legal clarity for students and providers;

• Ability to promote and enhance improvement and good practice;

• How well the model could build on the key features of theAustralian higher education system, where universities areestablished under State/Territory/Commonwealth legislation

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as autonomous institutions with the power to accredit their own courses, and where higher education courses developed anddelivered by other providers are accredited by State/Territory bodies;

• How well the model could exploit the role of professionalassociations in accrediting courses;

• Minimum prescription and bureaucracy; and

• Cost.

Characteristics of and criteria for the new mechanism7.4 DETYA documentation specifies the following criteria for a new

national quality assurance mechanism for self-accrediting institutions:

• The mechanism should not be solely at the discretion of theinstitutions themselves;

• There needs to be some external review or audit of the claimsmade by institutions about quality and standards;

• The mechanism should be credible with international and domesticinterest groups, and should and be able to protect the internationalreputation of Australian awards;

• The mechanism should help satisfy Australian taxpayers of value for money;

• Any audit mechanism should have rigour, but at the same time be cost effective, not unnecessarily intrusive and be able to retainthe cooperation of the public universities; and

• The mechanism should provide legal clarity for students and providers and able to promote good practice and facilitate improvement.

7.5 As already indicated, we support these principles. To have bothdomestic and international credibility, the mechanism should not beunder the direct control of higher education institutions. At the sametime, we consider that to ensure success and acceptance the mech-anism should be regarded as a cooperative enterprise betweengovernment and the higher education sector. We strongly support theidea of an external audit whose function will be to test the claimsmade by institutions about quality and standards. This should becombined with an institutional self-study which would take place priorto the visit of a review panel. An alternative would be to opt for theDutch model of disciplinary reviews, but for a number of reasons theinstitutional audit would appear to be more suitable. The institutionalaudit is likely to be cheaper and more cost efficient. It is more

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commonly used internationally than the disciplinary review mech-anism and it is better able to cater for a diverse sector with selfaccrediting and non-self accrediting institutions and both public andprivate providers. Further, the Dutch model is particularly effective ifthe main focus is on research and the state of the disciplines and theirfuture directions. Since the idea of institutional quality assurance auditsor reviews is well understood both in Australia and internationally, weconsider that, with appropriate structures and resources, and with thesupport of both government (including the States and Territories) andthe sector, an audit mechanism should soon gain strong credibility withinternational and domestic interest groups, and should be able toprotect the international reputation of Australian awards. The mech-anism should also help satisfy Australian taxpayers of value for money.Generally institutional audit mechanisms prove to be cost effective andnot necessarily intrusive and have been able to retain the cooperationof universities. In both Britain and New Zealand universities have beensupportive of the mechanism. An audit mechanism should help toprovide legal clarity for students and providers, although as wecomment elsewhere we see important legal clarity and protectioncoming from the new accreditation arrangements.

7.6 Further still, while our interview schedule was limited because of timeconstraints, we formed the view that a non-intrusive and sensiblyconceived quality assurance mechanism which involved both thehigher education sector and the State and Territories would be likelyto attract considerable support. Certainly both with the sector and withState and Territory accrediting agencies there is wide appreciation ofsome of the strong influences that require establishment of a newnational mechanism.

7.7 Apart from the criteria mentioned above, we suggest that other broadprinciples should guide the establishment and operation of a newquality assurance mechanism. These include the following:

Cooperative Commonwealth/State/Territory and higher education effort7.8 We consider it important that the proposed new quality assurance

arrangements should be a cooperative Commonwealth/State/Territoryand higher education sector effort, rather than a Commonwealthinitiative. Not surprisingly, officials in State and Territory accreditingagencies spoke strongly that the new mechanism should not besimply a Commonwealth creation, arguing on the basis of the

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constitutional responsibilities of the States in education, that overallaccountability lay with the States and Territories, Commonwealthofficials did not understand fully many of the key issues and that any new arrangements should accommodate the current legal and legislative responsibilities of State and Territory agencies. For somewhat different reasons, we feel confident that the idea of a cooperative effort would attract much greater support from the AVCC as opposed to the idea of the initiative led and controlled by the Commonwealth.

Small and cost efficient agency, with minimum bureaucracy7.9 We found strong support for the idea that, should a new national

quality assurance agency be established, it should be relatively smalland cost efficient, it should be independent of DETYA, State andTerritory Accrediting Agencies, and it should have a minimum ofbureaucracy. The size and activities of a new agency should resemblethat of the New Zealand Academic Audit Unit of the former BritishAcademic Audit Unit and Higher Education Quality Council. We foundno support for the idea that a new agency should be part of or havesome link with the AQF.

Focus on processes rather than outputs7.10 One of the most difficult questions facing the establishment of a new

quality assurance mechanism is whether the main focus should be onprocesses rather than on outputs and standards. We recognise thatthere is wide community and international interest in the issue ofacademic standards generally and particularly in standard betweendegrees offered by different Australian universities. There is alsoconsiderable interest in how Australian degrees compare with thoseoffered by universities in other industrialised countries, particularlythose that compete with Australian providers in internationaleducation. There are also domestic accountability pressures working to direct more attention to standards and outputs. On the other hand,to put an emphasis on standards is fraught with danger and difficulty.Many universities will be far less comfortable with an emphasis onoutputs and standards and will recall the controversy that attracted the ranking or ‘banding’ of institutions with the 1993–1995 qualityassurance program. Many newer and smaller universities consider that the rankings and performance funding seriously damaged theirreputations and are likely to be cynical about any audit programwhich would most likely give the oldest and research intensive

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universities the strongest rankings. Any serious attempt at focussing on outputs and academic standards is likely to raise difficult method-ological issues and be controversial. The recent experiences of theBritish Quality Assurance Agency point to how proposals to assessstandards are likely to be highly controversial and to be regardedespecially by major universities as being highly intrusive. We assumealso that special technical staff would be required or the proposedagency would need to make use of the services of consultants withspecial expertise in educational measurement and judging theequivalence of academic standards.

7.11 Three further arguments need to be mentioned against an emphasison outputs and standards. First, by placing the primary focus of auditson planning, management and monitoring processes within instit-utions, it is still possible for panels to collect considerable informationon outputs and standards. Further, the issue of outputs and standardsis probably best addressed in the context of reviewing institutionalquality assurance and improvement plans in the light of institutionalmissions, how institutions monitor and make judgements about theirperformance, and what evidence they have to substantiate the judge-ments they make. Hence the focus is not on making judgementsabout institutional performance but how effectively and professionallyinstitutions monitor their own performance and use the informationgained for institutional planning and improvement.

7.12 Second, we suspect that assessments of outputs and standards areunnecessary in terms of credibility, both in Australia and overseas.Quite simply, most enquirers wish to know whether or not there is a national agency for quality assurance and what programs of reviewsit has undertaken

7.13 Third, issues about outputs and standards can be addressed in simplerand more cost-effective ways. One possibility would for a new agencyto have a small budget for investigations and evaluations and tocommission studies that could address particular issues aboutstandards. Possibly one or more of the professional associationsinvolved in course accreditation might be interested in comparativestudies of course requirements, desirable graduate attributes andassessment methods for particular disciplines.

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Voluntary participation by higher education providers7.14 We favour the principle of voluntary participation in any new quality

assurance program. Such an approach is likely to be much moreacceptable to the sector and likely to achieve a much higher degree of support. It will be recalled that participation in the 1993–1995quality assurance program was voluntary yet, despite some threats of withdrawal, all universities participated in each of the three rounds.We favour an arrangement whereby all higher education institutionswould be eligible for membership and with all members paying anannual subscription fee that could be based on student load. At thesame time, review procedures would need to be sufficiently flexible to cater for institutions of differing size.

Name for new agency likely to attract support and credibility7.15 The actual name of the new agency could be important in gaining

support from the higher education sector and credibility both inAustralia and internationally. We favour use of the words ‘qualityassurance’ in the title, since this term has become well understood andhas been used recently in both the United Kingdom and New Zealand.The words ‘authority’ or ‘agency’ seem suitable for a relatively smallagency, but their use could lead to confusion with the British andNew Zealand bodies. For this reason the words council or board mightbe more appropriate. Ideally the title of the organisation should be, asshort as possible, but to assist with international education it could bethought useful to include the word ‘Australian’.

Mechanisms to commission studies about standards and good practice7.16 If an new agency is to play an important role in dissemination of good

practice and addressing questions about standards, this should bemade clear in the brief and there should be some understanding at the outset about the means by which such aims could be achieved.As already mentioned, one cost efficient means would be the use oflimited funds to commission studies, publish reports, and sponsorconferences and seminars.

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Legal basis and structure of new agency7.17 One important issue to address that will affect the success of any

new quality assurance mechanism is the legal basis of the responsibleagency, the governance structures employed and accountabilityarrangements. In our discussions a number of different models weresuggested and these can be summarised as follows:

• Ministerial Committee set up by the Commonwealth Minister;

• Statutory body established by Commonwealth legislation;

• Statutory body established by joint Commonwealth and State legislation;

• Agency set up as a company.

Each of these models has some attractions. A Commonwealthministerial committee is relative simple to establish and was used for the 1993–1995 quality assurance, but it could carry the impressionthat it is a DETYA controlled agency. A similar problem would beassociated with Commonwealth legislation. On the other hand, whilehaving many attractions, complementary Commonwealth andState/Territory legislation could take time to achieve. The companymodel has many attractions. Possibly a company could be establishedwith similar arrangements and links to MCEETYA as those for theCurriculum Development Centre.

7.18 Officers in one of the State accrediting agencies suggested a two levelstructure whereby most of the work in quality assurance would bedone by the States and Territories, while at the national level arelatively small body would set basic principles and oversee theprocess. While this model would be likely to facilitate integration ofaccreditation and quality assurance functions, we favour a singlenational agency and consider that it is of utmost importance that theCommonwealth should be intimately involved.

7.19 We are not in a position to advise on the desirability of the proposedagency having a legislative base, but certainly one issue that needsconsideration is whether, by having an appropriate legal basis, theagency would be more likely to be protected in the case of litigation.

7.20 Perhaps more important than the legal basis is the system of gover-nance and accountability. We favour the new agency being managedby a board or council made up a Commonwealth, State/Territory, andhigher education representation and having an independent Chair. Inorder to establish close links with the accrediting activities of profes-sional associations, it could be useful to include a board or council

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member drawn from one of the major professional associations orfrom the Australian Council of the Professions. Such representationshould be of a person with special expertise and major involvement inaccreditation. In addition, the governing body should have the powerto add one or two additional members with special expertise in theareas of academic audits and assessment.

Preferred model7.21 Our preferred model for the new quality assurance mechanism

and agency is as follows:

• A new quality assurance mechanism should be established as a jointCommonwealth, State/Territory, and higher education initiative withthe aim of strengthening public accountability, protecting academicstandards and the reputation of Australian higher educationproviders and awards, and promoting good practice in qualityassurance. We suggest that the new mechanism should be calledthe Higher Education Quality Assurance Council.

• The central function of the Council will be conduct of program of institutional reviews or audits. Review teams will carry out sitevisits, following completion of self-assessments carried out byinstitutions, which will include reviews of the processes ofmanaging quality including monitoring performance andbenchmarking. Institutions will provide review teams with a reportof their self-assessments, together with documentation oninstitutional mission and objectives, quality assurance andimprovement plans, details on methods used to monitor andbenchmark achievements and the results of monitoring andbenchmarking. Participating institutions will be reviewed everyfive years.

• The Council will be established an independent agency, at ‘armslength’ from both government (Commonwealth and State) andfrom the higher education sector. It will be governed by a boardconsisting of an independent Chair, two Commonwealth nominees,two members representing the States and Territories, two represen-tatives of the higher education sector and one representative drawnfrom those professional associations involved in accreditation withinthe higher education sector. The Executive Director will be an ex-officio member and the board will have the power to coopt up totwo additional members with special expertise in academic auditsand assessment. Commonwealth representatives will be appointed

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by the Minister for Education, Training and Youth Affairs, while thetwo State and Territory representatives will be appointed byMCEETYA. Members will serve four year terms.

• Funding for the work of the Council will come from annual grantsfrom the Commonwealth and from the States and Territories, andannual membership fees paid by individual higher educationinstitutions who wish to participate in the program of reviews.

• The terms of reference of the Council will be as follows:

– to review within participating higher education institutions themechanisms for quality assurance, monitoring performance andacademic standards, and enhancing quality;

– to publish the reports of reviews;

– to report publicly from time to time on the effectiveness ofquality assurance procedures in participating institutions, theextent to which procedures ensure academic standards andreflect good practice in maintaining and improving quality, and other relevant matters;

– to identify and disseminate good practice in quality assurance in higher education;

– to undertake and sponsor studies related to effective qualityassurance management practices and academic standards inhigher education.

• In carrying out reviews, review teams appointed by the Council willfocus particularly on:

– appropriateness of quality assurance and improvement plans inrelation to institutional contexts and missions;

– rigour of the mechanisms employed to review courses andacademic organisational units, and monitor performance againstinstitutional plans;

– effectiveness in monitoring outcomes and in benchmarking, bothnationally and internationally; and

– success in communicating the results of the monitoring outcomesand academic standards to stakeholders.

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Review teams will report to the Council.• Each year the Council will draw up a program of reviews for

the following year, after consultation with institutions likely to be reviewed.

• Review panels, generally of no more than five members, will beappointed by the Council. Members of review teams will be drawnfrom the higher education sector, the Commonwealth and theStates. Members may also be drawn from the professions andprofessional associations, and from business and industry. Reviewpanels will normally visit institutions for two consecutive days afterthe institution has completed a self-assessment and supplied otherdocumentation as required. Institutions offering courses ‘off-shore’for international students should document in detail the proceduresfollowed for safeguarding and monitoring quality, and the results ofany assessments.

• Following the visit of the review team, the draft report will beforwarded to the institution for comment. Once the report iscompleted it will be considered by the Council and then published.Copies will be provided free to DETYA, State and Territoryaccrediting agencies, all participating higher education institutions,and relevant professional associations. For each review, a singlereport will be prepared and published.

• Should a review reveal serious weaknesses, the institutionconcerned will be given up to 12 months to correct weaknessesprior to a supplementary review. Failure to rectify weaknesseswould be a matter for DETYA to address (in the case ofCommonwealth funded institutions) or for the relevant State orTerritory accrediting agency. One possible action would be toremove the name of the institution from the AQF list of accreditedinstitutions until such time that as minimum standards are achieved.

• Every effort should be made to encourage private universities andnon self-accrediting institutions to participate in the review program.

• Prior to arrangements for the Council being finalised, the highereducation sector should be consulted about the proposed terms ofreference for the Council, the composition of the Council’s boardand the method of conducting reviews.

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Appendix A

Project brief

A Modern Australian ModelThis model, which builds on the current or recent practice, wouldembrace two related functions - accreditation and quality assurance. It would have two distinct branches:

(a) For institutions which are given power to accredit their own courses

The main requirements for these institutions would be:

– Rigorous scrutiny of financial and quality aspects beforefounding legislation is passed or other authorisation is given.

– The annual publication of Quality Assurance and ImprovementPlans for the forthcoming triennium. These plans wouldoutline the institution’s goals, strategies for achieving thosegoals and the indicators used to monitor progress in achievingthose goals. An analysis of performance, including a consid-eration of the outcomes of graduate satisfaction surveys (theCEQ) and graduate employment outcomes (the GDS) overtime (say, the previous five years) and compared with approp-riate benchmarks, would form an integral part of these plans.The plans would need to outline very clearly the processes inplace to assure quality of provision within its ‘catchment area’—thus, if an institution operates offshore, whether physicallyor virtually, it would need to outline what mechanisms it hasin place to assure quality in relation to that provision.

– A detailed self-assessment, which would include benchmarkingof standards, to be conducted every five years. This assessmentwould be audited on a whole-of-institution basis. The auditteam could be made up of Government officials and/ormembers of independent bodies, such as the Council of theLearned Academies. Should the audit reveal serious areas ofweakness, the institution would be given 12 months to addresssuch matters. Failure to rectify serious deficiencies would resultin the Government removal of the institution from the AQF listof accredited institutions.

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– Compliance with any additional measures which may benecessary to ensure the maintenance of acceptable highstandards of degrees, in the environment described in theBackground of this brief.

(b) For non self-accrediting providers

Work is currently underway to develop a common approach toregulating the entry of private providers of higher educationcourses. The main features of such an approach might be:

– Rigorous scrutiny of provider capability before courseaccreditation; and

– Review of provider performance and accredited courses everyfive years.

IssuesNumerous issues need to be addressed in a consideration of a possiblemodel for Australia. These include:

• Under whose authority the quality assurance and accreditationsystem would be run. There are two obvious options - theCommonwealth alone or the Ministerial Committee for Education,Employment, Training and Youth Affairs. The case for the Common-wealth alone assuring itself of provider quality rests on the avail-ability of Commonwealth-funded subsidies.

• Whether the framework would need a legislative base or whether it could be set up as an instrument of government policy (as is thecase with the Australian Qualifications Framework (AQF)).

• Whether it is sensible and appropriate to make use of the AQF.On the one hand, it has high public visibility; on the other, theremay be resistance to building on something which has had a majorvocational education and training focus. It may be prudent to usethe AQF simply as a vehicle for listing accredited higher educationinstitutions—giving such institutions an official imprimatur.

• The nature of the five-yearly self-assessment for self-accreditinginstitutions.

• The desirability of focussing (more than in the past) on outcomesand standards as well as processes.

• How to achieve rigour and independence for the process whileretaining the cooperation and confidence of the universities.

• The role of professional associations within the model, andimplications of accreditation by them.

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• The nature of the audit of the courses of non self-accreditingproviders. The extent to which audits would focus on coursesrather than providers. The role and status of the audit teams needto be addressed.

The TaskThe task is to develop Model 5 as an alternative to models 1–4,mindful of the issues listed above, and make a comprehensiveassessment of this model against the following criteria:

• credibility. This involves assessing how well the model wouldbe credible with international and domestic interest groups andpotential customers, and the ‘marketability’ of the arrangements;

• effectiveness, ability to address learning outcome standards as wellas quality assurance processes;

• ability to provide legal clarity for students and providers;

• ability to promote and enhance improvement and good practice;

• how well the model could build on the key features of the Australianhigher education system, where universities are established underS t a t e / Territory/Commonwealth legislation as autonomous institutionswith the power to accredit their own courses, and where highereducation courses developed and delivered by other providers area c c redited by State/Territory bodies;

• how well the model could exploit the role of professionalassociations in accrediting courses;

• minimum prescription and bureaucracy; and

• cost.

ConsultationsConsultation with key stakeholders (e.g. the AVCC, State accreditingbodies, NOOSR, professional associations) should be undertaken as appropriate.

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Appendix B

List of interviews

CanberraMr Michael Gallagher First Assistant Secretary, Higher Education DivisionDepartment of Education, Training and Youth Affairs

Dr Tom KarmelAssistant Secretary, Higher Education Operations Branch Department of Education, Training and Youth Affairs

Ms Rebecca CrossChief Executive Officer, Australian Education InternationalDepartment of Education, Training and Youth Affairs

Mr Tom CalmaCounsellor (Education & Training)Australian Education InternationalAustralian EmbassyHanoi, Vietnam

Mr Giancarlo SavarisAssistant Secretary, NOOSRDepartment of Education, Training and Youth Affairs

Ms Margaret BellNOOSRDepartment of Education, Training and Youth Affairs

Mr Stuart HamiltonExecutive DirectorAustralian Vice-Chancellors’ Committee

Mr P RodleyAdministrative OfficerAustralian Vice-Chancellors’ Committee

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Ms Ann RyleAssociate Director, Education and MembershipThe Institution of Engineers, Australia

Professor Peter ParrConsultantThe Institution of Engineers, Australia

Ms Minou LambOffice of Training and Adult EducationACT Department of Education and Training

SydneyMs Lyndsay ConnorsDirector, Higher Education OfficeNSW Department of Education and Training

Mr Graham WoodPrincipal Policy Officer, Higher Education Office of Higher EducationNSW Department of Education and Training

Mr John WilliamsOffice of Higher EducationNSW Department of Education and Training

MelbourneDr Ian AllenDeputy Secretary Victorian Department of Education

Mr Tim SmithAssistant SecretaryHigher Education BranchVictorian Department of Education

Ms Wendy KatzManager, National Recognition PolicyAustralian National Training Authority

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Dr Judy ForsythExecutive OfficerAustralian Qualifications Framework Advisory Board Secretariat

Dr Grant McBurnieDirector, Transnational Quality Assurance ProgramsMonash University

Mr John McPartlandAssistant General ManagerMonash International

Professor Allan Lindsay Deputy Vice-Chancellor AcademicMonash University

Ms Noreen CruseActing Director, Quality AssurancePlanning and Quality UnitRMIT

Associate Professor Craig McInnisDirector Centre of the Study of Higher EducationUniversity of Melbourne

BrisbaneMs Leigh TabrettDirector, Higher Education OfficeQueensland Department of Education

Ms Sian LewSenior Policy Officer, Higher EducationQueensland Department of Education

Mr Steve McDonaldDirector, Industry and Training Framework TeamAustralian National Training AuthorityArmidale

Professor Brian StoddartDeputy Vice-Chancellor (Research and External)University of New England

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