by: Nicola Best

The Renewal of Provider Registration (or re-registration) is a critical process for all Australian higher education providers. It occurs at least every seven years (some providers have shorter intervals) and is designed to ensure the provider is complying with the Higher Education Standards Framework (Threshold Standards) 2021 (HESF).

The Tertiary Education Quality and Standards Agency (TEQSA) has moved to a ‘self-assurance’ model, focusing its regulatory assessments on a set of core HESF Standards (the Core Plus model). For re-registration applications, this means those Standards relating principally to Internal Quality Assurance (Domain 5) and Governance and Accountability (Domain 6).

However, the approach is a Core Plus model (emphasis added). There can be different reasons for an extended scope (that is, beyond the core Standards): this may include findings from other compliance monitoring, the provider’s regulatory history, material risks identified by TEQSA or other factors that warrant the assessment of additional HESF Standards.

Either way, it is essential that providers start planning their submission long before receiving the “Confirmed Evidence Table” (CET) that TEQSA normally issues about 6 months prior to the due date for submission.

And the Renewal of Provider Registration process normally goes hand-in-hand with other related submissions that have their own set of compliance requirements. For example:

• Research (for universities)
• Course re-accreditation(s) for non-self-accrediting providers
• CRICOS renewal.

Common pitfalls

Starting too late
• Don’t wait until you get your CET to begin planning and preparing. Our advice is to start at least 12–18 months before the final submission is due. This is particularly the case when doing multiple submissions.
• There are many risks in starting too late – particularly if a provider is tempted to “re-create” evidence or rushes in to fill gaps that it sees at the last minute.
• This is stressful. It can be costly. And it can lead to problems during the assessment process – including the potential of conditions on the re-registration.
• Tip: Start early.

Communication and institutional siloes
• Provider re-registration should be seen as a whole-of-institution process, from the highest levels of your governance, academic and corporate structure.
• Keep your corporate governing body, your academic board, other governance committees and your senior leadership actively informed of and engaged in the process.
• Be clear about your timeframes and what might be expected of different committees and managers.
• Tip: Focus on communication.

Poor project management
• A submission can involve hundreds of documents and evidence being collated (e.g. meeting minutes (including pin-pointed items), agendas, papers, policies and procedures, frameworks, registers, strategies, and internal documents).
• A small number of documents will be provided directly with the submission; the majority will be listed in the Index, clearly referenced in your 10-page Narrative (the self-assurance report) and mapped to the required Standards.
• Add in the requirements for multiple submissions (e.g. Research or Course Renewal applications) – some of these will overlap with the Provider Re-registration process, some will be unique to that other process – and you have a substantial project that needs managing.
• Having a comprehensive implementation plan backed up by a strong project management approach is the foundation for a well-managed re-registration process.
• Tip: Apply exceptional project management techniques.

Ignoring gap analyses
• Remember: No provider is perfect.
• In starting early and doing the appropriate gap analyses of your processes and practices at the right time (such as a health check or a mock assessment of your draft submission), you may be able to rectify some of these gaps. Common problems seen by DVE include:
• Inadequate corporate body understanding of their HESF obligations
• Inadequate understanding of HESF obligations and how they are implemented across work-unit/committee levels
• Outdated policies and procedures
• Failure by staff/work-units to follow policies and procedures
• Poor governance committee minute-taking and committee processes (including lack of quantitative and qualitative reporting and monitoring by the respective committees)
• HESF 6.1.3.d requires independent reviews of the governing body and academic governance processes at least every 7 years.
• These reviews form part of the required evidence. Critically, you need to get the right independent expert/s as per TEQSA’s guidance (see Independent Experts engaged by providers).
• The more robust your action plan is (that is, the agreed actions are clear and endorsed/approved by the relevant body) AND the more you can demonstrate progress in implementing the action plan (monitored by the relevant governance body), the stronger your submission will be.
• Tip: Do your gap analyses.

Inadequate narrative development
• The Narrative (the 10-page Self-Assurance report) has to bring it all together in a concise, clear and coherent manner. The evidence must directly relate to the standard you are addressing.
• The Index must directly align with the evidence referred to in the Narrative itself (much of it overlapping).
• Writing the Narrative (plus Index) can be more time-consuming – and complicated – than you think as it is drawing evidence and requires input from across the institution.
• Tip: Start early.

Solution

DVE has been working with different public and private higher education providers on their re-registration applications for 10 years. We understand that the quality of the application and the supporting evidence remain paramount to a smooth and successful re-registration.

It’s not enough to just say that quality is important and that you meet the Threshold Standards. Your submission needs to clearly set out how, and how well, you demonstrate the quality and capacity of your self-assurance process. You need to give effective assurances and evidence of your assertions. For example:

• You need to set out how you know your processes are working across your teaching (and research) endeavours, and how well your academic assurance processes are working.
• You need to show how you monitor, identify and then respond to a range of higher education risks.
• You need to understand and articulate what impact improvements have had, particularly on student learning and the student experience.
• You need to show that you are rigorous, use your data and feedback to identify issues and that comprehensive review and interim monitoring is embedded across your practices.
• Where you have agreements with third parties, you need to ensure that effective practices are in place and that you can show how they are properly managed.
• You need to ensure your policies and procedures are up-to-date and effectively implemented.

DVE is highly experienced in helping providers through their re-registration journey. See the Roadmap to TEQSA Renewal of Registration as a starting point.

We can deliver services appropriate to your needs, including:

• Project management support for your application/s (underpinned by a well-developed methodology such as evidence registers, document and process management tools and Narrative support to keep you on track)
• Full mock assessments and/or health checks (gap analyses)
• Independent external governance and/or course reviews
• Policy and procedure reviews and/or updates
• Focussed training and professional development for staff (e.g. minute-taking) and members of peak institutional bodies (e.g. HESF obligations for corporate governing bodies)

DVE provides support that is accurate, comprehensive and effective for your needs and expectations. If you would like to chat to our team about this or any aspect of the regulatory process (including initial registration and course accreditations) please contact us via info@dvesolutions.com.au and we will be happy to arrange an advisory session.

DVE: Your partner in the re-registration process.