CHARLES DARWIN UNIVERSITY - Department of Education and Training ...
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CHARLES DARWIN UNIVERSITY
Submission to: Australian Government Department of Education and
Training
Re: Consultation paper on the reallocation of Commonwealth
support places for enabling, sub-bachelor and postgraduate
courses
Office of the Vice-Chancellor/ Charles Darwin University / Darwin NT 0909/ vc@cdu.edu.au
February 2019Summary of CDU’s key considerations and recommendations
• The proposed re-allocation process is a one-size fits all approach. It assumes there is will be a
single set of principles that will best be able to achieve re-distribution of places across the sector.
This could only occur if universities used these places for similar purposes, which, particularly for
enabling and sub-bachelor courses, is not the case. An Institutionally specific approach, taking
into considerations the unique institutional and geographic needs, historical utilisation context
and future demand requirements is needed to deliver a model that is fair, and student centred.
• It also assumes that the current allocation can be incrementally adjusted over time to achieve a
more needs-based allocation. Given the extend of current under and over utilisation, and the mis-
alignment between regional need, institutional need and allocation an initial re-basing of the
allocations would be required. This would need to be implemented over a 2-3-year period, to
allow Universities who face significant re-adjustments to adapt.
• CDU highlighted in our recent submission to the National Regional, Rural and Remote (RRR)
Education Strategy, that granting special dispensation to regional universities, by allowing them to
operate without capped undergraduate, enabling and sub-bachelor place allocations, would be a
key to ensuring that there is a comprehensive and well supported University offering to support
the educational needs of RRR students. CDU re-iterates this recommendation in the context the
overarching principles contained in this consultation paper.
• Failing adoption of an uncapped regional university mode; geographical need coupled with
institutional track record in providing access opportunities at all level (including VET) for equity
target groups, should be the primary consideration for a re-allocation of sub-bachelor and
enabling places.
• In addition to this, within a capped funding environment, the overall number of sub-bachelor and
enabling places needs to be increased each year, by at least the same rate as the rate of increase
in bachelor places. This is the only way to ensure that equitable pathway options remain instep to
the proportion of overall undergraduate places that are available.
• A minimum viable allocation is required to build supportive sub-bachelor environment. The
minimum viable allocation is both a course-specific concept but also an institutional level concept.
In 2018 and 2019 CDU only has 58 EFTSL in sub-bachelor places (reduced from 2017 as part of the
2018 funding agreement re-alignment). 58 EFTSL is too small to allow CDU to offer a
comprehensive and appropriately supported pathway program using sub-bachelor places.
• A longer-term approach to allocation of places, extending beyond the funding agreement and
election cycles, is required to provide certainty for providers to facilitate better courses and
student support service planning. However, this needs to be balanced with the need for short-
term flexibility so that institutions can be adaptive to emerging student and industry needs.
• Student outcomes-based performance measures for assessment of allocation application, and
ongoing performance evaluation have theoretical merit. However, current variability in the way
enabling and sub-bachelor are used would mean the courses, and student cohorts are not
comparable and therefore would make a standard set of comparative performance base
measures unviable. Any such measure, applied within the current sector context would
disadvantage those using the sub-bachelor and enabling courses as pathways to bachelor
enrolment, in favour of those using the places to support students during or after (in the case of
Diploma of Languages courses) undergraduate studies.
CDU Submission / February 2019 Page 2• The nomination of an arbitrary percentage of places from all institutions to create a base pool for
re-allocation will lead to excessive administrative burden for Institutions and Government. In the
context of capped undergraduate non-designated places is it unlikely that a University could forgo
places and therefore under this model all institutions would need re-apply for places just to stay
at current funding levels. A more strategic approach to identifying underutilised and ineffectively
utilised places is required.
• Postgraduate courses which are determined by a professional accreditation body as, or emerging
as, career entry to a profession should be funded in the same way as bachelor level courses. In a
demand driven undergraduate system this would require flexibility to move allocation between
designated capped and non-designated un-capped profiles, as determinations by changes to
professional accreditation requirements. In a capped undergraduate system, caps would need to
move between the two profiles as required. A more Institutionally specific transition process also
needs to be considered when this occurs to ensure the most effective uses of available places at
the sector level.
1. CDU’s Response to proposed broad allocation principles
The consultation paper outlines, for each of the key funding areas (enabling, sub-bachelor and
postgraduate), a broad single principle for allocation of places. For enabling places high standards of
academic preparation and strong student outcomes were identified as the primary basis for
allocation. For sub-bachelor courses industry need was singled out. CDU acknowledges the
importance of student outcomes, academic preparedness and industry need. However, considering
the critical role enabling and sub-bachelor course play in providing pathways to disadvantaged
students, particularly those from RRR areas, we recommend that student need be adopted as the
primary principle for allocation for sub-bachelor and enabling places. Student need in this context
should assessed based on a university’s geographic region, in terms of target equity group profile;
coupled with that its track record in successfully engaging students from equity groups (across all
levels of study including VET) both within their region and beyond.
There are a range of issues associated with the primary allocation principles proposed in the
consultation paper, these are outlined for each area of allocation below.
1.1. Enabling Courses - allocated based on achievement of high standards of academic
preparation and strong student outcomes.
In principle, allocating enabling places to universities which produce high standards of academic
preparation and strong student outcomes has merit. However, in practice, the loose program
definition for enabling courses means achieving a meaningful metric which fairly and accurately
compares program outcomes, whilst taking into consideration their differences would be
unachievable. The likely outcome would be an overly simplistic metric which would produce perverse
allocation outcomes, likely disadvantaging those who most need Government funded enabling
pathways. Metrics associated with academic preparedness and transition to undergraduate studies
would be problematic for the following reasons:
CDU Submission / February 2019 Page 3• Inconsistency in course design and application means outcomes not comparable: There is a huge
degree of variability in enabling program design and purpose, ranging from comprehensive
preparation programs, to more bridging style enabling, course which are offered concurrent to
an undergraduate enrolment, effectively offering academic support not preparedness. It would
therefore not be possible to develop a fair test which compared the standard of academic
preparedness and student outcomes across programs and Institutions. Adopting existing
measures like the completion of enabling course requirements, the transition to an
undergraduate course after enabling, would favour those enabling courses which support
students studying concurrently in their bachelor’s degree, or those courses which bridge
subject-specific knowledge gaps before a student enters undergraduate study. Programs which
provide a genuine preparation pathway to students who otherwise would not be able to access
university would be comparatively disadvantaged, even though these programs more closely
reflect the intended definition of an enabling course.
• Course completion data not collected: Enabling course completions are not reported to
Government as part of the Course Completions data collection. This means there is limited
longitudinal understanding of the actual relationship between enabling course completions
and transition to undergraduate studies. Instead only the relationship between enabling
enrolments and subsequent enrolment in undergraduate studies has been analysed and this
data is muddied by incomplete, and/or never started enabling enrolments which are included
in the reporting of enabling enrolment data. This gives an inaccurate and inconsistent picture
of transition between enabling and undergraduate courses.
• Enabling courses are intended to facilitate early and debt free failure prior to undergraduate
attempt: Enabling courses are designed to allow a student to prepare for undergraduate
studies in a safe and fee free environment, allowing the them to potentially fail before
incurring an undergraduate debt or academic record. Programs which have higher
comparative failure or non-transition to higher education rates may not be symptomatic of
poor quality programs. They may, in fact, be programs that are using their enabling places to
providing access opportunities to students whilst setting appropriate academic attainment and
preparedness thresholds to ensure students are successful once they do start their
undergraduate degree.
• Lack of an agreed standard of attainment: There is no consistent sector-wide level of
attainment a student must reach to be deemed as having successfully completed an enabling
course, or to be deemed academically prepared for undergraduate study. The admissions rank
assigned to an enabling graduate will vary from university to university. Therefore, an
allocation metric which focused on the transition between enabling and undergraduate
studies, may have an un-intended consequence of disadvantaging those Institutions whose
enabling courses require the highest standards of academic preparedness, but that in-turn
produce lower comparative rates of throughput from enabling to undergraduate studies.
Enabling courses are a vital tool in the provision of access pathways for students from disadvantaged
backgrounds, and allocation of places is not currently prioritising the allocation of those places to the
students with the highest levels of need for pathway programs like enabling. High academic standards
and student outcomes are important, but this won’t mean the same thing institution to institution,
program to program or student to student.
CDU Submission / February 2019 Page 4Enabling Place Allocation Recommendations:
1. Student need, as defined by equity profile, coupled with institutional track record in enrolling
equity target groups, should be the primary allocation method for enabling places.
2. Universities in regional areas and in geographical areas of high levels of student disadvantage
should be given special dispensation to operate outside the designated funding caps for
enabling courses and be allowed to enrol as student demand dictates.
3. To retain this special dispensation, these universities should be required to demonstrate:
• Student satisfaction within the enabling program; and
• Enabling student success, at the same or better rate to the rest of that institution’s
first year undergraduate cohort. Success should be defined by the unit success rate,
and first year retention rate in the first year or time take to have taken 0.5 EFTSL
whichever is longer.
4. Enabling students should be included in the national Student Experience Survey to facilitate
the collection of comparable student satisfaction data for enabling courses.
5. The definition of an enabling course should be more tightly defined in the legislation and
should include broad levels of academic attainment required upon completion or such a
course.
6. The application of Government designated funding for enabling should be specifically directed
to pathway enabling courses and should exclude programs offered concurrently to an
undergraduate enrolment, or after the student has already been admitted to an
undergraduate course. This would facilitate the identification of a base pool of enabling places
available for re-allocation.
7. Enabling places should be focused across a small number of Universities, with high equity
profiles and track records in supporting students in access undergraduate studies via enabling.
A tighter definition of enabling courses, coupled with defined attainment standards would
facilitate these universities offering access pathways across the sector.
1.2. Sub-bachelor courses - priority given to courses that focus on industry needs and fully
articulate into a bachelor’s degree
CDU is supportive of consideration being given to courses which focus on industry needs. However,
one of the key drivers for funding sub-bachelor places is to provide pathway opportunities into
bachelor level degrees. Sub-bachelor programs also provide lower perceived barriers to entry for
students from disadvantaged backgrounds, and those who are first in family, where initial
commitment to a full bachelor level degree would otherwise deter them from attempting university
study. Therefore, the primary principle for the allocation of sub-bachelor places should be based on
the equity profile of a University’s catchment coupled with the university’s track record in enrolling
students from equity groups (across all levels including VET). This will ensure allocations go to
Universities where the need is the greatest.
Industry need should be a secondary consideration to the student need and should aims is to increase
recognised employment outcomes for sub-bachelor students. This will likely:
CDU Submission / February 2019 Page 5• increase genuine work integrated learning opportunities in later years of a degree.
• Provide genuine employment outcomes for students who for whatever reason are unable to
immediately progress onto the next stage of the undergraduate qualification.
• Provide quicker pathways to re-skilling and re-employment for the changing workforce.
Prioritisation of places to sub-bachelor level degrees that fully (100%) articulate into bachelor level
degrees may, have adverse consequences as follows:
• It may limit student flexibility across courses in the early stages of degrees. This may lead to
funding inefficiencies with students opting to change course paths getting less credit.
• It would prevent the inclusion of academic foundation support and preparation units which
may be required to offer fully supported pathways for students from disadvantaged
backgrounds. Allowing for this would provide a more efferent funding pathway for students
with a higher level of academic preparedness than enabling students, but a lower level of
academic preparedness that those commencing at the bachelor level.
Sub-bachelor Place Allocation Recommendations:
8. Student need, as defined by equity profile, coupled with an institutional track record in
enrolling equity target groups, should be the primary allocation method for sub-bachelor
places.
9. Universities in regional areas and in geographical areas of high levels of student disadvantage
should be given special dispensation to operate outside the designated funding caps for sub-
bachelor courses and be allowed to enrol as student demand dictates.
10. Articulation of a sub-bachelor course into a bachelor course should be a consideration but a
minimum threshold of 75% should be set, rather than full articulation, to allow for flexibility in
course design, and a design that best meets the needs of and supports pathway students.
1.3. Postgraduate courses - allocation informed by professional requirements and community
benefit.
CDU is supportive of professional requirements and community benefit being applied as the criteria
for assessing the allocation of places to new postgraduate courses. However, the current allocation
process doesn’t cater well to ongoing changes in professional accreditation requirements and
hampers an institution’s ability to negotiate with and react to professional accreditation changes.
The underutilisation of postgraduate places in the 2016 allocations shown in Chart 5 of the
consultation paper is largely due to historical place allocations for graduate diplomas of teaching
degrees, which from about 2012 were no longer accredited by state and territory teaching
accreditation boards. When this accreditation change occurred many universities, like CDU, shifted to
a graduate entry bachelor’s level course, and ceased postgraduate level delivery in this area. This lead
to long-term under-utilisation of postgraduate places by universities like CDU as the was no
adjustment made to the allocated postgraduate places until many years later. This caused
administrative inefficiencies, both for Institutions and Government, through ongoing misreporting in
government estimates and over-complication funding agreement negotiations.
CDU Submission / February 2019 Page 6In 2018 the Government reduced the postgraduate allocation to remove many of these unutilised
postgraduate places. At the same time, the Western Australian (WA) teaching accreditation board
ceased accrediting bachelor level graduate entry courses. CDU teaching students come from all
around Australia, and with a mobile local population in the Northern Territory, it is critical that a CDU
teaching graduate can be recognised as an accredited teacher in all states and territories of Australia.
Therefore, the accreditation decision in WA forced a shift for CDU to a master’s level teaching degree.
This shift coincided with a reduction in our allocated postgraduate places and left CDU hamstrung in
meeting student demand in one of our flagship study areas.
A more strategic approach to considering professional accreditation requirements in the allocation of
postgraduate places must be adopted. Government, universities and professional bodies must work
closer together to foreshadow emerging changes to professional standards, manage the introduction
better and phasing out of Commonwealth funding for postgraduate courses. Decisions by professional
accrediting bodies are currently not aligned to Government funding agreement cycles, and so aligning
the re-allocation of postgraduate places to funding agreements will not facilitate better management
of place needs that are driven by professional bodies.
The capping of postgraduate places in courses where the qualification is the entry point to a
profession creates an inequitable funding system, particularly where the overall number of places
allocated is less than demand. CDU is likely to utilise all the allocated postgraduate places for our
master’s level initial teacher education course before demand for the program and need from the
industry is satisfied. This means once our places are utilised, only those students with the capacity to
pay can access a postgraduate teacher qualification, and those who don’t will be locked out of this
pathway to the profession.
Postgraduate Place Allocation Recommendations:
11. As a broad principle, if a postgraduate course is deemed by the professional accrediting body
as the entry level requirement for the profession then it should be treated the same as an
undergraduate course from a funding perspective. In a demand driven undergraduate system
this would require flexibility to move allocation between designated un-capped and non-
designated caped profiles as determinations by changes to professional accreditation
requirements. In a capped undergraduate system caps would need to move between the two
profiles as required.
12. A more Institutionally specific transition process when professional accreditation affects
postgraduate allocation should be adapted which includes institutional transitional modelling
which for Universities with high part-time enrolments will most likely need to extend beyond
the current 3-year funding agreement cycle.
13. Courses that meet the national and/or State/Territory skills shortage register at postgraduate
level should be allocated commonwealth supported places. As per current ministerial
determination process.
14. A course register should be maintained by the department of prior determinations, which
have national, state, territory and/or regional applicability to streamline the process for
application and approval of new courses.
15. A more responsive approval process is required with longer lead times to facilitate better
postgraduate course planning.
CDU Submission / February 2019 Page 72. Utilisation as an indicator of demand and/or need
CDU supports the broad principle that long-term underutilisation of places be considered in assessing the
demand and/or need for places for enabling, sub-bachelor and postgraduate places. However, given
places have been poorly allocated and re-distributed historically, this picture is muddied by a wide array of
institutional specific narratives, which would require individual contextualisation. Applying unilateral
rule/s about underutilisation would likely lead to a re-allocation of places which would prove just as poorly
aligned to need as the present situation. The example given in section 1.3 above, regarding the removal of
postgraduate teaching places from CDU in 2018, as the postgraduate course to utilise these places was
introduced, is just one example of why a utilisation assessment based on data alone would not produce
optimal outcomes.
An assessment of need based on historical utilisation of places would be problematic for the following
reasons:
• The limited availability of additional CSPs and a poorly defined process for applying for places has
led behaviour by Institutions in both requesting and relinquishing places which contribute to the
patterns of under and over utilisation outlined in the consultation paper. This doesn’t reflect
demand or need.
• Pipeline enrolment issues must be considered to help contextualise under and over utilisation. For
CDU sub-bachelor level courses, it takes on average 5 years for at least 85% of those that will
complete the qualification to have completed, compared to 3 years nationally. Within this, for
Associate Degrees the average time to realise 85% of completers is 8 years, compared with 4
years nationally. This demonstrates the need for a longer-term view of allocation and transitional
arrangements to introduce places allowing them to ramp up over a longer period, and likewise to
be relinquished over longer terms as programs teach-out.
• There is a history of arbitrary policy-based changes to place allocations which means 2016
historical data used in the consultation paper and even the more up to 2017 data which is now
available, is outdated. As a demonstration of this, in CDU’s 2018 funding agreement CDU received
58 EFTSL in sub-bachelor places, when in the prior year we had been allocated more than 100
EFTSL. Therefore, the analysis of sub-bachelor place allocation per head of population, based on
2016 allocations is now outdated and incorrect.
• There is a history of arbitrary policy-based changes to place allocations which means historical
data, even the 2018 and 2019 funding agreement allocations don’t reflect need. As an example, in
2018 when CDU’s sub-bachelor allocation was reduced to 58 EFTSL, the University decided to
utilise 100 EFTSL from our enabling allocation to cater for the students already part way through
their sub-bachelor level degree, and the new students that had already been admitted as part of
the semester 1 intake before the funding agreements where distributed. To do this CDU had to
cap enabling intakes, and effectively turn away student demand for enabling places. Therefore,
using data alone, it would appear that CDU under-utlised enabling allocation in 2018 infering that
our allocation exceed student demand, but this is not the case.
• Some Universities have the financial capability to over-enrol above the caps, but other institutions
don’t. Therefore, over-enrolments by one institution doesn’t mean that demand is higher than for
an institution that uses all but doesn’t exceed its place allocations.
CDU Submission / February 2019 Page 8Utilisation Consideration Recommendations:
16. Long-term utilisation should only be considered in the re-allocation of postgraduate places,
and this should be assessed using a combination of data and contextual narratives provided
by institutions.
3. Process and Implementation
3.1. Proportion of places re-distributed
The nomination of a set percentage of places from all institutions has logical merit in terms of
providing a base level of security and stability whilst attempting to achieve a fairer and needs-based
allocation of places across the sector. However, it is likely to lead to excessive administrative burden
for both Institutions and Government, with all institutions having to apply for places just to stay at
current funding levels. The proposed approach would also only achieve incremental re-distribution
over a very long period and will not achieve the step change re-distribution that is required to more
fairly distribute places according to student need.
Proportion of places for re-distribution recommendations:
17. A more strategic approach is required to identify places not currently prioritising highest
student need as the base pool for re-allocation. For example: Enabling course definitions
could be tightened to only fund enabling course providing pathway into University, and places
currently being used to support students who have already gained access and already
studying a bachelor level degree placed in the pool for reallocation.
18. This strategic identification of places for re-allocation could then form the basis for a step-
change re-basing of the place allocations implemented over 2-3-year period, after which time
more incremental adjustment process could be adopted.
19. This would need to balance the need for stability and security for Institutions, staff and
students. This could be achieved if the implementation timeframe for the reallocation were
pushed out to 2021 and if transitional arrangements were put in place to manage teach out at
Institutions where places were re-distributed.
3.2. Timing
The proposed three-year timeline for re-allocation would provide greater stability and certainty than
the originally proposed annual cycle. CDU’s submission is based on the belief that allocation should be
undertaken as part of a one-on-one negotiation between institutions and government as part of the
funding agreement process, rather than a separate process driven by standardised metrics and
proforma applications. This would enable institutional and geographical need to be contextualised by
a range of Institutional planning factors.
CDU Submission / February 2019 Page 9However, whilst a three-year timeline for assessment of a possible re-distribution of existing places
seems feasible, there would need to be another mechanism which allowed Universities to apply to
Government for additional places to enable them to be responsive to student and industry needs.
Universities can currently apply for ministerial approval to adjust the place allocation; however, this
process could be improved by clearly defining the process and timelines for such requests.
4. Geographical consideration in distribution of places
Geographic need measured by prevalence of equity target groups, coupled with an institution’s equity
profile should be the primary consideration factor in the allocation of enabling and sub-bachelor places. It
should also be a key factor in assessing the number of postgraduate places allocated in course areas that
meet the course definition requirements for Commonwealth supported places, as students from areas
with high prevalence of disadvantage have a lower capacity to pay full-fee than students from areas with
lower levels of disadvantage.
Creating a meaningful allocation framework for allocating places according to geographic need would be
challenging given the sector has a limited understanding of relative levels of disadvantage within equity
target groups, i.e. the relative disadvantage of inner regional versus remote versus very remote; coupled
with the limited understanding of the relative impact of compound disadvantage across equity target
groups. Until more is understood about these factors, a metric-based allocation system would be a blunt
and ineffective instrument.
A simpler approach, which would deliver a more meaningful outcome for students from disadvantaged
backgrounds, would be to uncapped sub-bachelor and enabling places, as well postgraduate places in
courses which met the course definition criteria (professional entry, or community benefit), at Universities
in regional areas or with high equity profiles.
5. Minimum viable allocation
A minimum viable allocation is critical, particularly at the sub-bachelor level, where universities are unable
to offer full-fee paying places to supplement allocated places to achieve a viable cohort size.
CDU currently has a sub-bachelor place allocation which is well below the minimum viable allocation and
this constrains our sub-bachelor offerings. With only 58 EFTSL in sub-bachelor places spread across 23
different courses CDU is unable to offer units in sub-bachelor courses separate to those in the nested
bachelor level degrees. Therefore, sub-bachelor students enrol in the same units as bachelor students and
receive the same unit learning experience, with the same levels of auxiliary academic support as their
bachelor level counterparts. For this reason, entry standards for CDU’s to sub-bachelor courses are the
same as the bachelor level courses and therefore the sub-bachelor offering is not serving the pathway
needs of our geographical catchment.
Some things to consider when deterring
• The concept of a minimum viable allocation will be specific to each institution. It will depend
heavily on the cost of delivery, level of overheads, breadth of programs, mode of delivery, just to
name a few factors.
CDU Submission / February 2019 Page 10• Minimal viable allocation could apply to the number of places for a specific course and will vary
depending on the field of education and associated cost of delivery, as well as possibly the size of
the bachelor level course that the sub-bachelor course articulates into. However, if minimum
viability was only considered in the course context, then universities with small current place
allocations across broad programs would struggle to meet a minimum viable level for any course.
For example, for CDU to reach a minimum viable level for each of our 23 sub-bachelor courses in
their own right, we need all of the 834 enabling and sub-bachelor places currently proposed as
available for re-allocation in the consultation paper.
• Minimum viable could also be achieved at an institution level and would negate the need to
achieve individual course level thresholds. For CDU there is a minimum viable number of sub-
bachelor places that would enable us to deliver academic foundation and support for sub-
bachelor pathway students, which would supplement enrolment in nested bachelor level units.
This would require a minimum viable level across the collective allocation for sub-bachelor places
and would allow individual course allocations to be below minimal viability. This would require far
fewer places to reach minimum viability, than the aggregate requirement of each individual
course to reach minimum viability.
Minimum viability recommendations:
20. Minimum viability will depend on the institutional specific model for utilisation of the places
and should be determined in individual consultation with each institution.
21. Regional universities need to grow to achieve broader viability across the course profile and
this could be achieved by giving them special dispensation to enrol according to demand
across the commonwealth grant scheme. This would assist these institutions to achieve
minimum viability in an efficient and demand driven manner.
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