by: Ian Thomson
As you should all be aware, the ‘Job Ready Graduates’ Amendment Bill was passed in October 2020, with many new provisions commencing during 2021 and 2022. Some of these, particularly around funding models, have already had a high profile and are well known by all providers.
But also in the Bill are some small amendments that could easily be missed by Universities and HE providers accessing Commonwealth Supported Places (CSP).
Critical for all CSP providers is an amendment to the notion of student protection based on removing access to funding for students who have a “low completion rate”. Providers will be required to cancel CSP access for students who do not meet certain requirements.
A student would be assessed as having a low completion rate if they have failed more than 50 per cent of their course of study after they have attempted eight or more units of study in a bachelor or higher-level course. For higher education courses lower than a bachelor level, this rule applies after a student has attempted four or more units of study.
This will apply from 2022 to all new students.
A student with a low completion rate can:
- Continue their course by paying upfront. If the student increases their completion rate to 50 per cent or higher by paying upfront for one or more units, they will once again be eligible for Commonwealth assistance for that course.
- Transfer to a new course. If a student with a low completion rate transfers to a different course, their previous completion rate will not carry over, i.e., they will access Commonwealth assistance for their new course.
- Depending on the content of their new course and the policies of their provider, the student may also be able to credit some (or all) the units they passed in their previous course towards their new course.
- Apply to their provider for special consideration for a failed unit or unit to not be counted towards their completion rate. The student will need to demonstrate special circumstances have applied to them for their application to be successful.
The application of this poses a lot of questions for providers to not only ensure you stay on the right side of this legislation but also to ensure you remain compliant with TEQSA standards on how you communicate with students.
Universities and providers need to look at the following aspects of their operations:
- Identification and Reporting – can you currently identify and report on students who reach the 50% threshold in an accurate and timely way, with students needing to be advised before they start their next teaching session? Who will be responsible for identifying students, and who will be responsible for notifying students?
- Policy (Unsatisfactory Academic Progress) – does current policy ensure compliance with this new legislation, or are changes required? Most providers will have a policy on Unsatisfactory Academic Progression (UAP), but does it have the same threshold levels as the new legislation.
- Policy (Resulting) – the new legislation uses the term “did not complete” in relation to progression through units, although they use the word “fail” in their published FAQs. Is your resulting policy clear? While a “fail” is obvious, there may be other reasons a unit has not been completed, and they may not all deserve to lead to a loss of CSP funding for the student.
- Procedure – again, most providers have a procedure around managing UAP. Will this standard UAP process be changed to include the access to CSP funding, or will the funding discussion operate separately?
- Student Support – given the stress that such an event is likely to cause students, the auto-generated system letter will probably not be well received. How will this process be managed, and how will students be supported through the process and the decisions they need to make?
- Special Consideration – is the process for a student seeking special consideration for units not completed readily available, transparent, and easy to navigate. Is there an effective appeals process in place where a student is not happy with a decision?
- Offer letters – should offer letters for new students accessing CSPs highlight the implications of potentially not meeting satisfactory completion targets?
- Systems – are existing student management systems and finance systems able to easily manage student transition from CSP to fee-paying and potentially back to CSP again?
If you currently have resourcing challenges and need any advice or assistance in making policy, process, or system changes to meet these new requirements, feel free to reach out on 1800 870 677, we are very happy to support you.
A copy of the relevant section of the new legislation is below for your reference:
36-13 Advice on whether a person is a Commonwealth supported student—failure to complete previous units
(1) A higher education provider must not advise a person that the person is a *Commonwealth supported student in relation to a unit of study if:
(a) in a case where the unit of study is part of a *course of study leading to a *higher education award that is a bachelor degree or higher qualification:
(i) the student has already undertaken 8 or more other units of study with that provider as part of that course of study; and
(ii) the student did not successfully complete at least 50% of those other units; or
(b) in any other case:
(i) the student has already undertaken 4 or more other units of study with that provider as part of a course of study; and
(ii) the student did not successfully complete at least 50% of those other units.
(2) In determining, for the purposes of subparagraphs (1)(a)(ii) and (b)(ii), the number of units the student did not successfully complete, disregard any units:
(a) not completed by the student; and
(b) in respect of which the provider is satisfied that special circumstances apply in relation to the student (see subsection (3)).
(3) For the purposes of paragraph (2)(b), special circumstances apply in relation to the student in respect of a unit of study if, and only if, the higher education provider is satisfied that circumstances apply in relation to the student that:
(a) are beyond the student’s control; and
(b) do not make their full impact on the student until on or after the *census date for the unit of study; and
(c) make it impracticable for the student to complete the requirements for the unit during the period during which the student undertook, or was to undertake, the unit.