Submission to consultation on the Higher Education Support Amendment (Job-Ready Graduates and Supporting Regional and Remote Students) Bill 2020

The Melbourne Centre for the Study of Higher Education (Melbourne CSHE) has provided comments on the exposure draft of the Higher Education Support Amendment (Job-Ready Graduates and Supporting Regional and Remote Students) Bill 2020.

These comments are those of the authors and do not necessarily represent those of the University of Melbourne. The authors are (in alphabetical order): Gwilym Croucher, Frank Larkins, William Locke, Ian Marshman, Vin Massaro, James Waghorne and Mark Warburton.

In brief, the Melbourne CSHE suggests consideration needs to be given to the following areas of the Bill:

  • Schedule 1, in which there appear several anomalies in the proposed grandfathering arrangements contradicting the stated intention of the policy measures and that may have the unintended consequence of reducing funding to support education below the level intended.
  • Schedule 2, which, by introducing the new ‘funding envelope’, may create unintended consequences for university operations and planning, in particular by removing in practice the current operation of the ‘floor’ in the Maximum Basic Grant Amount (MGBA).
  • Schedule 3, in establishing the new Indigenous, Rural and Low SES Attainment Fund (IRLSAF) it appears that the proposed future funding total will rest on a Ministerial determination and that the creation of the IRLSAF will come through an amendment of the ‘other Grants Guidelines’, creating uncertainty about whether these arrangements will be implemented.
  • Schedule 5 includes a proposed extension of a range of additional protections for higher education students which risks potentially adverse and unintended consequences for the operation of universities. Requiring universities to assess a student as academically suited to undertake a unit of study before enrolling could generate significant issues in implementation and operation. The proposed extension of Ministerial powers implies constraints on university autonomy that may have unintended consequences. This schedule in effect proposes to establish a parallel system of oversight to that of some TEQSA functions, which risks inconsistency and inconsonance.

Subjecting universities to a wider range of civil penalties could lead to the fundamental relationship between universities and government being altered. This would be an outcome that has not been extensively articulated in the explanatory material accompanying the exposure draft.

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