Our submission to the TEQSA ‘Fees and Charges Proposal Consultation Paper’ is based on aggregated responses from our Member Organisations regarding the impacts of cost recovery on their ability to continue delivering quality higher education. While we support the current regulatory environment that evaluates and recognises best practices in the higher education sector, concerns were raised that require further consultation.
The concept of cost recovery policies as pursued by the current Government and reflected in the TEQSA ‘Fees and Charges Proposal’ was not an issue taken up. Instead, ACoP advocates for proportionate cost recovery and, after a careful analysis of the Consultation Paper, found that the proposed fees and charges would present issues regarding both the quantum of charges and their timing.
Our submission argued against the proposed implementation in 2022, as it does not take into account the impacts of COVID-19. This timing might also have the unintended consequence of forcing providers to cease offering accredited courses, which provide high quality, niche education that currently ensures curriculum currency for graduates to be work- and professional-practice ready.
ACoP also argued strongly for a reconsideration of the January 2022 commencement date given that financially prudent organisations would have already set and formally approved their budgets.
ACoP’s submission also noted that many of our Member Organisations are not-for-profits and accreditors already subject to regulation by multiple agencies and jurisdictions, resulting in duplication (at least) of compliance activity. We therefore asked for consideration of a model of cost recovery that reflects their unique, special and valued activities.
ACoP, on behalf of its Member Organisations, asked for further consultation to consider the best commencement date of the proposed changes and a fees introduction on an incremental scale over a 5-year period.
Our submission received broad and strong endorsement from our Member Organisations and the ACoP Education and Accreditation Committee.