Attachment: CAPA Submission
The Council of Australian Postgraduate Associations (CAPA) welcomes the opportunity to contribute to Minister Nelson’s debate on our future higher education accreditation and approval arrangements. We value this opportunity for public consultation, and believe that this is integral to the process of reviewing the National Protocols. We submit the following response to the issues paper Building University Diversity: Future approval and accreditation processes for Australian higher education on behalf of all students enrolled in Australian postgraduate degrees.
CAPA is the national peak body representing Australia’s 247,000 postgraduate students. It has affiliated postgraduate associations in 34 of Australia’s public universities and in all States and Territories.
CAPA believes that the Australian higher education system should foster quality, equity and diversity in teaching, research and scholarship. For this reason, we feel considerable concern over some of the areas raised in Building University Diversity. We are extremely concerned by the prospect of significant changes to the National Protocols. In particular, we are concerned about possible changes to Protocol 1 that may result in teaching-only universities. CAPA’s position is that universities must have a research focus. Anything less would risk lowering the standard of university education in Australia.
CAPA is also concerned by the suggestion raised several times in Building University Diversity that the National Protocols accommodate specialised institutions. There is already considerable depth and breadth of course offerings in the current higher education system. CAPA’s concern is that the government may wish to concentrate research in a select number of universities, resulting in less funding for other universities to conduct research. Indeed, this has been referred to in Crossroads.
Funding of specialist institutions would pose a threat to the research funding base for many universities and particularly regional universities. The proposition that rural students in regional universities should only have access to a narrow breadth of study options of direct relevance to the regional economy has been proferred in Crossroads. CAPA views such suggestions as serving only to exacerbate the divide between rich and poor, and between the city and the bush.
CAPA acknowledges that the duplication of research infrastructure at every university is not necessarily a desirable outcome of every university maintaining a research base. A solution to this problem would be to encourage collaboration between universities, including arrangements for the sharing of resources between institutions. Such collaboration would need to be encouraged through financial reward incentives for the universities participating in collaborative activity. CAPA believes that institutional collaboration to teach disciplines with smaller student numbers is vastly preferable to the loss of those disciplines.
CAPA also believes that rules governing the operation of private universities must be the same as those required of public universities. CAPA is concerned that private providers are currently not subject to the same accountability mechanisms and quality audits as public universities. The governing bodies of public universities are guided by the requirement to act in the public interest. In contrast to private providers, public universities must conform with government reporting and accountability requirements and are subject to audit by the Australian Universities Quality Agency (AUQA). CAPA believes that public funding should not be extended to private providers because of the lack of provision to ensure the effective use of this funding.
CAPA is also concerned about the equity implications of providing public funding to private religious institutions that may not operate under the same EEO principles as public universities. In particular, CAPA strongly opposes the re-allocation of funding away from public universities to private providers. Ultimately, if private providers meet the criteria under Protocol 1, only then should they be able to access public funding.
CAPA believes that a non-self accrediting non-university that has successfully operated over a period of five years, should be able to seek authorisation to accredit its own courses. However, this self accreditation should only be for those courses the institution has successfully operated over the five year period. The institution would not be able to use the nomenclature ‘university’ unless they met the criteria for Protocol 1. These institutions should be able to call themselves ‘self accrediting institutions’ or ‘higher education institutions’.
In our submission, we address those consultative questions asked in Building University Diversity of most relevance to our postgraduate constituents, as well as providing additional information on areas of particular importance to postgraduate students.
CAPA’s key concern in this submission is the welfare and rights of international students. CAPA is very concerned about the number of unscrupulous agents (both education agents and migration agents) acting against the welfare of students.
The Migration Act and ESOS Act are designed to both:
There is an essential tension between these two roles which can result in legitimate migrants or visa holders being incorrectly or inappropriately targeted and punished after making honest mistakes, through the same legislative instruments they rely on for protection. CAPA belives that the protective elements of legislation and regulation should be the focus of the current review. Strong regulation of the migration advice industry will weed out both those agents who misinform potential legitimate migrants, as well as those who facilitate illegitimate immigration – indeed it is likely that the same agents undertake both roles.
We also comment here on some issues outside of the scope of the current review relating particularly to the off-shore education advice industry. Believing that the illegitimate migration advice activities of off-shore education agents are likely to go hand in hand with illegitimate education advice activities by the same agents, CAPA recommends a broader review of the offshore education advice industry with input from both DEST and DIMIA.