Attachment: CAPA Submission
The Council of Australian Postgraduate Associations (CAPA) welcomes the opportunity to comment on the JCHE’s draft National Protocols for consideration by the Ministerial Council on Education, Employment, Training and Youth Affairs
(MCEETYA). We value this opportunity for public consultation, and believe that this is integral to ensuring that the finalised National Protocols are the product of a thorough and exhaustive process. We submit the following response with particular regard to whether the drafting of the National Protocols is a holistic representation of the intent of the framework adopted by MCEETYA. At the same time, we also respond on any issues that need to be considered.
CAPA is the national peak body representing Australia’s 257,000 postgraduate students. It has affiliated postgraduate associations in 33 of Australia’s public universities and in all states and territories.
It is worthwhile drawing the JCHE’s attention to the fact that postgraduate students typically enrolled as doctoral candidates contribute to more than 60 per cent of research conducted at universities across Australia. Accordingly, CAPA is most vocal in emphasising the importance of maintaining research quality across Australia’s university system.
CAPA believes that the Australian higher education system should foster quality, equity and diversity in teaching, research and scholarship. CAPA’s position is that universities must have a research focus and welcomes the JCHE’s draft National Protocol E that stipulates a research focus. Anything less would risk lowering the standard of university education in Australia.
CAPA is concerned by the National Protocols allowing for 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. Funding of specialist institutions would pose a threat to the research funding base for many universities, particularly regional universities.
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. In this regard CAPA also welcomes the criteria set out in JCHE’s draft National Protocol B. These institutions should be able to call themselves ‘self-accrediting institutions’ or ‘higher education institutions’.
CAPA also believes that rules governing the operation of private universities and institutions operating in Australia must be the same as those required of Australian public universities. CAPA is concerned that private providers are currently not subject to the same accountability mechanisms and quality audits as public universities and welcomes JCHE’s draft National Protocol A that requires all higher education institutions to pass stringent quality control. Ensuring the relevant quality control of all higher education institutions is particularly important to maintain high education standards in Australia.
CAPA is concerned that foreign institutions may be able to operate in Australia as long as they meet the accreditation criteria in the country of origin. We believe this is not in Australia’s interest in terms of continuing to provide quality higher education. CAPA believes that foreign universities must meet similar standards to those of Australian universities. We also believe that any public funding should only be provided to Australian higher education institutions that meet the appropriate National Protocol criteria.
CAPA believes that to ensure national consistency of the Protocols the Australian Universities Quality Agency’s (AUQA) role should be expanded to provide an audit and quality review of the state and territory accreditation authorities in an appropriate timeframe. In view of AUQA’s role, we believe a review of the protocols should be no later than 2013.