2006 – Response to the RQF Development Advisory Group Guiding Principles

Attachment: CAPA Submission:

CAPA has provided two previous submissions to the RQF development process. As the development of the RQF moves forward and becomes focused, we feel that the process is increasingly secretive and nonconsultative. Our comments to the Guiding Principles are hampered by the lack of availability of supporting information and the refusal of the Chair of the RQFDAG to include CAPA in anything but a cursory consultation process.

This has also affected others in the sector and resulted in much discussion being held through the media rather than through forums and working parties. The RQFDAG has provided only selective opportunities for input and has failed to provide an ongoing opportunity for the sharing of ideas.

Much RQF modelling and testing has been undertaken at institutions across Australia. The results of these trials should be available to those providing responses. Similarly, a summary of issues still to be considered by the RQFDAG working parties would be helpful.

It is unclear how the Guiding Principles will correspond with the more specific issues not covered. Such issues include Indigenous research, multidisciplinary research and the research conducted by Higher Degree by Research (HDR) students. Because this consultation over the Guiding Principles is limited, it will be imperative that the RQFDAG refers back to issues raised in earlier consultations and submissions to ensure that all concerns have been addressed.

The Guiding Principles contradict recent statements by the Minister regarding the direction of the RQF. In particular her contention that “the work of research students is both regarded and considered towards RQF outcomes.” The Guiding Principles continue to exclude HDR research. This confusion can only serve to increase apprehension about the RQF.

We remain concerned that the RQF is not forward-looking. It does nothing to set up for future research excellence. This is particularly evident in the failure to consider the research environment in any evaluation.

General comments:

Many of our initial concerns arising from the Issues Paper have been taken into account. In particular we are very pleased to note that the CTS is now available for part-time students, and for those not in receipt of an APA. The
breadth of the training has also improved. We remain concerned about how distance education students may be catered for.

Comments on specific items in the draft guidelines:

8.90.1 and 8.95
Some smaller and newer universities are developing their research capacity by prioritising commercialisation and industry links. These institutions (and their students) should not be prevented by their size, research income, and
relative newness from accessing the scheme.

We would not want to see a situation where the wealthier universities are able to offer 6 months training on full scholarship while students at other universities received a minimal amount of training and no income support. We support flexibility in delivery but this should not extend to denying some participants a living allowance. Equitable treatment is incongruent with the provision of living allowances to only some of the participants. Living allowance should be available to all students participating in the CTS. This allowance should be of the same value as the scholarship the student is on or the equivalent of an APA (whichever is greater). This must also be available to students who are studying part-time or by distance.

This item appears to mean that students are being ‘encouraged’ to participate in the CTS early in their course. This may not be the most appropriate time for many students. Further clarification of this item with regard to eligibility criteria is needed. For example if a student applied for the CTS 12 months into their course, under the entitlement provisions of this section it would appear that they are ineligible for CTS funding.

Attachment: CAPA Submission


The Council of Australian Postgraduate Associations (CAPA) welcomes the opportunity to contribute its views on the DEST discussion paper. CAPA is the national peak body of postgraduate student organisations representing Australia’s 257,700 postgraduate students, including 47,300 research students and 261,500 students undertaking coursework qualifications.

General Comments

First and foremost, CAPA rejects the DEST discussion paper statement that “the transition fund will ensure that the sector can adjust to the changed funding environment by facilitating a shift from reliance on compulsory fees to other mechanisms.” CAPA believes that the transition fund is
(i) grossly undervalued and
(ii) will discriminate against all service and advocacy providers except for sporting and recreation bodies.
To this extent, CAPA agrees with the AVCC statement that the transition fund must be broadened to include other service, advocacy and representative bodies on campus.

It is CAPA’s contention that the transitional fund will provide little to no relief for the vast majority of student associations or service providers outside sport and recreation. CAPA further contends that the only benefit the transition fund will ensure is that sporting fields and pitches will be immaculate through the generous allocation of resources to purchase high quality turf, fertilizers, bindi weed killer and insecticides – and that no substantial sporting programs will be achieved.

Attachment: CAPA submission


The Council of Australian Postgraduate Associations (CAPA) is the national peak body of postgraduate student organisations representing Australia’s 257,800 postgraduate students, including 47,300 research students and 210,500 students undertaking coursework qualifications.

General comments

The European Higher Education Area (Bologna Process) aims to provide a top-level framework for higher education across Europe. Bologna contains many elements that are entirely interdependent and supportive of each other, such that individual elements cannot exist in isolation. The Bologna Process is unlikely to be effective in Australia if only particular elements are selected and promoted. Specifically, the Process must include stakeholder involvement and
a social dimension.

Attachment: CAPA Submission

Recent federal government proposals involving sedition laws and antiterrorism
legislation and guidelines have worrying consequences for
Australian research and academic freedom. The Code must be broad
enough to withstand changes to the political and funding environment.
Recommendation 1: That the Code contains an authoritative
statement about research independence and freedom of speech.

The Code will be ineffective without provision by institutions for
adequate funding to implement the resource requirements. Compliance
with the Code will be harder to ensure without this funding.
Recommendation 2: That the Code specifies institutional
responsibility for the funding of resource requirements.

While individual responsibility is important, this draft comprises too
much emphasis on the individual.
Recommendation 3: That the onus to ensure the responsible
conduct of research is firmly placed with institutions.

CAPA is apprehensive regarding the position of research students in
relation to requirements to ensure the responsible conduct of research.
Too often, when things go wrong it is the research students who lose
out the most. While recognising that research students come from a
variety of research and employment backgrounds, the Code requires a
general principle that they are subject to procedures that take into
consideration their status as students.
Recommendation 4: That the Code stipulates that student
status is recognised appropriately in institutional policies and
guidelines for the responsible conduct of research.

The Code asserts that ‘the community forms its views on research not
only by its outcomes but also by the standards by which it is carried
out’. The community also forms its views by the statements and policy
priorities of government and relevant ministers. The recent legislative
proposals to reduce the independence of the ARC, combined with the
public statements of the former Minister for Education regarding some
Humanities and Social Science research, can only have a detrimental
impact on community opinion of Australian research.

The Code claims to have ‘broad relevance across all research
disciplines’. CAPA advises that the developing bodies must ensure this
broad relevance by consulting widely and in particular with
representatives of the creative and performing arts, and Indigenous

The developing bodies state that ‘all institutions that receive funding
from the ARC and NHMRC to support their research are required to
adhere to this code.’ The Code should clarify that the institutions must
adhere to the Code consistently, not only in regard to research funded
through the ARC and NHMRC.

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.

Attachment: CAPA Submission


The Council of Australian Postgraduate Associations (CAPA) is the national peak body of postgraduate student organisations representing Australia’s 257,700 postgraduate students, including 47,300 research students. These research
students contribute approximately 70% of the research conducted in Australian universities.

The Issues Paper addresses the administrative arrangements for implementation of the Commercialisation Training Scheme, and specifically seeks feedback from Higher Education Providers. However, as the organisation representing the
potential recipients of these awards, CAPA would briefly like to draw attention to some areas of concern.

General comments on the scheme

While CAPA is supportive of the opportunity for students to gain additional skills, attention should not be diverted from the purpose of undertaking a research degree. In addition, students who are well supervised in universities that provide the necessary resources and extension and networking opportunities, will naturally acquire many of the skills that this scheme is promoting. CAPA rejects any suggestion that research graduates are not career ready. While this scheme is small in focus and funding, we are concerned that it may constitute the beginning of an attempt to change the purpose and direction of Australian research degrees.

The scheme is intended to assist business and industry by training potential employees in the skills and experience that might normally be developed through paid employment. Industry, as a major beneficiary, should contribute towards the funding of the scheme. This would free up government support to be directed towards related skills development for those involved in research that is not applied or immediately commercialisable.

The CRCs conduct training programs for their students that appear to be similar to the intentions of this scheme. An analysis and audit of these programs may well inform the decisions regarding the commercialisation-specific skills training that is most beneficial.

The Chief Scientist Dr Jim Peacock has counselled against interpreting the “drive to commercialisation…too literally.” We agree with this advice, and suggest that the concept of ‘commercial benefit’ and the links to ‘economic, social and environmental wellbeing’ must be explored further. We are concerned that otherwise the training may focus disproportionately on immediate benefit. Research outcomes are intrinsically unpredictable and efforts to identify short-term beneficiaries could fail to support potential capability.

Attachment: CAPA Paper

On the 15th of November 2006, the Minister for Education, Science and Training announced that the RQF would go ahead. The Minister also endorsed the RQF model recommended by the Development Advisory Group (DAG). Below is a summary of key recommendations from the approved model. Included also are some conclusions on what this might mean for postgraduate students.

For further detailed discussion and background on issues pertaining to the RQF, please refer to the CAPA submissions and briefings.

Attachment: CAPA Submission

Australia’s Universities: Building our future in the world. A White Paper on Higher Education, Research and Innovation

Response by the Council of Australian Postgraduate Associations September 2006

The Council of Australian Postgraduate Associations (CAPA) is the national peak body of postgraduate student organisations representing Australia’s 263,500 postgraduate students, including 48,200 research students and 215,300 students undertaking coursework qualifications.

CAPA is pleased to participate in the ALP higher education policy development process. We hope that the consultative approach, in marked contrast to that of the current government, will lead to significant improvements in postgraduate education.

Attachment: CAPA Submission

The Council of Australian Postgraduate Associations (CAPA) is the national peak body representing Australia’s 257,700 postgraduate students. These students are engaged in both coursework and research programs and include over 84,600 international students.

CAPA welcomes the invitation to respond to the recommendations in the Evaluation of the General Skilled Migration Categories report by Dr Bob Birrell, Professor Lesleyanne Hawthorne and Professor Sue Richardson.

Whilst CAPA recognises the importance of protecting local graduates who are competing in the employment market, we are concerned that some of the recommendations made will adversely affect international postgraduate students, both in the time taken and the financial commitment needed to acquire permanent residency. For example, CAPA imagines that there will be a time and cost imposition to international students for the implementation of requisite English language courses. As it is, many overseas students find it difficult to meet the points criteria for permanent residency now and these recommendations will make this goal that much harder.

CAPA welcomes the proposed change to English language ability criteria that raises the IELTS score from 5 to 6 with extra points for a score of 7. However, CAPA believes that if universities continue to allow students to enrol without meeting the requisite English language ability criteria, they must provide the appropriate training to enable these students to have the necessary communication skills to work in a professional Australian workplace. CAPA
considers this to be the university’s inherent duty of care obligations under the ESOS Act.

CAPA is concerned about the protection available to international postgraduate students who must undertake work experience. Under the recommendations being considered, a pathway to permanent residency requires international students to work 12 months full-time in an area of their nominated occupation. We are concerned that proper safeguards may not exist in current workplaces and that some employers may take advantage of international students and not provide them with the appropriate training, pay rates and work conditions. We believe that if international postgraduate students have a grievance against their employer they may not report this for fear of having their visa cancelled.

In regard to a ‘professional year’ as another pathway to permanent residency, how will it be ensured that the international postgraduate student receives the necessary skills to enable them to successfully compete for jobs in the Australian workplace? There have been concerns in the past with accredited bodies such as the Australian Computer Society providing accreditation to masters degree graduates without providing the necessary training.

CAPA’s other concerns are that international students are subject to high costs for their postgraduate studies in Australia and many have dependents and are supporting family in their home country. Further cost imposts may reduce the attractiveness of Australia for postgraduate study. We believe that if these report recommendations are implemented without further extensive consultation with key stakeholders as to how these measures will be effectively implemented, the outcome will adversely effect on international postgraduate students. CAPA believes it is paramount that the government enforces systems of monitoring and compliance measures of international student service providers such as higher education institutions, industry accreditation bodies and Australian workplaces for the protection of one of Australia’s main customer groups – international students.