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Sector submissions to the Senate Inquiry

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Updated 12 October 2014 .

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 25 September 2014

Generally  supportive but with significant amendments

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The government’s higher education reform package – the Higher Education and Research Reform Amendment Bill 2014 – was referred on 3 September to the Senate Education and Employment Legislation Committee for consideration and report by 28 October. Submissions to the inquiry closed on 22 September. The committee has published 79 submissions on its website. Following are extracts from 27 submissions lodged by higher education organisations (peak bodies) and individual institutions. There is almost unanimous support for passage of the package, particularly fee deregulation, on the basis that the long run decline in public funding is damaging the sector. Several submissions express opposition or concern about the extension of public subsidies to private providers (ACU stridently so). There is a united view that the package needs to be amended, particularly to at least ameliorate the burden of debt on future generations of students, that would follow from the combination of substantial fee increases and the imposition of a real interest rate on student loans (although no unanimity on how that might be achieved). Deakin University says the proposed changes to the HECS repayment scheme are unfair and rejects any compromise on this issue. The Regional Universities Network and the Group of Eight have formed a unity ticket on additional support for regional universities and their students. Stephen Parker (vice-chancellor, University of Canberra) and the National Tertiary Education Union make strange bedfellows in urging rejection of the package in its entirety. The submissions can be viewed in full at the Senate website.   For background on the debate around fee deregulation, check The Scan archive – it’s extensive.

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ATN’s  “cautious support”

ATN logoThe ATN cautiously supports the removal of the maximum student contribution amounts that providers can charge for Commonwealth supported places. However, such fee deregulation must only be introduced if accompanied by appropriate safeguards which ensure students are not unfairly burdened by crippling debt levels.

The ATN believes that the Commonwealth Scholarships Scheme is an important safeguard to protect equitable participation and should be legislated as a package with fee deregulation.

In order for the Scheme to be both efficient and effective, it must be administered by universities and not centralized within Government. The maintenance of Higher Education Participation (HEPP) Funding for access by all universities will remain essential to progress access and participation goals.

The ATN rejects as regressive the application of the 10-year Australian Government Bond rate to the repayment of outstanding student debt. This measure should be scrapped in favor of less regressive alternatives.

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Notre Dame’s “strong support”Notre Dame

The University of Notre Dame Australia expressed its strong support for fee deregulation. While there is speculation that such deregulation will result in student fees rising to extreme levels, the university is of the opinion that the increased competition, coupled with socially responsible and accountable decision making by providers themselves, should act as a fetter on excessive fee increases across all universities. The fact that fee deregulation may result in significant diversity in fees being charged between universities does not mean that the quality of the system as a whole will suffer.  Indeed, it may well improve quality as providers seek to focus and invest more in areas of speciality.  Notre Dame expressed concern about funding cuts and, in particular, the proposed changes to the indexation rate on HELP loans.

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ACU generally supports reform proposals

ACU particularly endorses proposals to:acu-logo

  • Maintain the demand driven funding system for undergraduate university places.
  • Extend the demand driven funding system to sub-bachelor places.
  • Deregulate university fees.
  • Repeal the requirement for a mission based compact for universities.

ACU supports these elements as they provide a secure basis for maintaining the Australian higher education system with greater access for students who are first in family to attend university. They allow universities to plan and have a degree of fiscal independence and autonomy with reductions in reporting requirements. Greater financial autonomy will allow institutions to invest in research and ensure that the Australian higher education system is not left behind due to inadequate investment.

ACU opposes funding cuts and changes to student loan interest rates could cause students’ debt burrden to grow significantly faster and higher than incomes.

ACU strongly  opposes extending funding to non-university higher education providers.

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Holmesglen demands better treatment  of  NUHEPS

holmesglen-002Holmesglen welcomes the extension of the demand-driven system to non-university Higher Education Providers.  It says there remains no logical reason to deny Australians equitable access to undertake higher education at the provider of their choice with the support of the Commonwealth.  Holmesglen expresses concern that the proposal to fund non-university providers at a different rate creates an unequal playing field and will reinforce or create a perception in the community that non-university degrees are inferior to the equivalent university programs.

Holmesglen views the expansion of the demand-driven funding system to sub-bachelor places with some trepidation. The Review of the Demand-Driven Funding System (Kemp & Norton, 2014) highlighted sub-bachelor programs as the fastest growing level of higher education award. If universities are able to access unlimited Commonwealth funding at the same rate as bachelor degrees, it may have significant and detrimental effects on existing pathway programs from VET higher qualifications (diplomas and advanced diplomas).

It has substantial concerns that the proposal to increase the indexation rate and reduce the minimum repayment threshold, coupled with fee deregulation, has the potential to significantly increase the cost of tertiary education for students and saddle them with crippling debt levels.

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Avondale concerned over differential funding proposal

Avondale is supportive of the overall thrust of the proposed higher education legislation.  It says  the legislation is a logical next step in the demand-driven system that was introduced byAvondale the previous Australian Government and  provides a framework for the sustainability and expansion of the higher education sector that shares the costs between the taxpayer and the student.

The proposal that students in the non-university sector will only receive 70% of Commonwealth Supported Place funding compared with their peers in the university sector is inequitable and does not take adequate account of the fact that many non-university providers are performing at a high level in terms of learning and teaching outcomes, research output, and higher than average employment results for their graduates.

The proposed legislation does not take account of the fact that some students in non-university higher education providers are already receiving Commonwealth Supported Places. Avondale’s nursing and teaching students have had access to CSPs for more than a decade at the 100% level. It suggests “grandfathering” existing courses or including institutions with research higher degrees (especially PhDs) at the 100% level.  Avondale obviously offers HDRs.

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UWA fulsomely embraces fee deregulation

The key aspects which UWA supports are:

  • the deregulation of fees to allow each university to set their own prices;
  • the creation of a new commonwealth scholarships scheme (CSS) which will require each university to allocate 20% of additional fee income to measures which support access forUWA students from disadvantaged backgrounds
  • greater competition by providing commonwealth funding for students undertaking courses at non-university higher education providers (NUHEPs); and,
  • the retention of the HECS system meaning students won’t need to pay for their education upfront.

 UWA notes that the introduction of real interest rate charges on student debts which will disadvantage graduates who are out of work or earning less than the threshold, or who take career breaks.  It also expresses concern  that  cluster funding changes will have a disproportionate financial impact on science and technology courses.

UWA supports fee deregulation for undergraduate courses as a response to a longstanding underfunding of universities by successive governments.  As noted elsewhere, UWA has proposed a flat student undergraduate fee of $48,000 – an increase from current rates of up to 60%.

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Go8: no future in going backwards

Australia requires a diverse higher education system of high quality that responds to varying student needs and interests, produces graduates who can add value as workers and citizens,Go8 logo and advances knowledge that benefits human understanding and economic development. This necessitates an adequate level of sustained investment and the encouragement of provider diversity. To this end the Go8 supports the following measures:

  • continuing the demand-driven system of uncapped undergraduate places for domestic students
  • expanding sub-Bachelor Degree pathway programs within the demand-driven system
  • extending Commonwealth Supported Places (CSP) funding to all TEQSA-approved non-university
  • higher education providers @ 70% of the university funding rate
  • removing price caps for domestic undergraduate students
  • aligning HECS-HELP and FEE-HELP student loan provisions
  • requiring universities to allocate 20% of increased tuition revenue to support students from disadvantaged backgrounds
  • o improving the availability of information to guide student choice.

The Go8 believes that the proposed reform measures could be improved by amending the Bill in two main ways:

  1. indexing HELP debts annually by the long-term bond rate when graduate earnings exceed $50,637, and indexing by the CPI for periods when graduate earnings do not exceed that threshold
  2. providing a package, including a scholarship component, to assist universities in regional and outer metropolitan areas.

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UQ: failure to deregulate may lead to focus on the international market

UQlogoThe University of Queensland (UQ) generally supports the Go8 submission but makes the additional point that it is constrained in its ability to run a world class university on the funding available through tuition fee income set at the current levels.  Currently, UQ says it support sdomestic students and our research effort through the fees paid by international students (eg $30K + for international students vs S12K for domestic students in Business, Economics etc).    ln the absence of deregulation, it is likely it would have to prioritise access of international students over that of domestic students in order to stay world-class.  This is partly because available physical capacity now is used fully and additional growth without capital for infrastructure is not possible.  lt is not unthinkable that research intensive universities will consider moving from international students being additional to domestic students to a situation where they would be higher yield alternatives to domestic students.  Without fee deregulation we could therefore see a situation where we deprive Australians the right to access services they are prepared to pay for.

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COPHE:  reforms will drive an efficient and globally competitive HE sector

The Council of Private Higher Education (COPHE) supports the Bill in its entirety, except for : COPHE logo

  • Schedule 3 relating to the interest rate on loans where it proposes retention of the Consumer Price Index.
  • Application of the full Government Section 33-10 contribution amount should apply to students enrolled in self-accrediting and other higher education providers (HEPs) that are accredited by TEQSA to offer higher degrees by research.

The extension under Schedule 1 of Commonwealth Supported Places (CSPs) to students at private universities and non-university higher education providers (NUHEPs) would be particularly welcome COPHE also supports  the extension to sub-degree programs (diplomas etc) which will encourage those students progressing through these pathways, including many from disadvantaged and low SES backgrounds.

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OUA:  reforms will provide quality provision at overall lower cost

OUAThe proposed extension of funding to sub-bachelor courses and non-university providers will give Open Universities Australia and other non-university providers the opportunity to provide better quality education for tertiary education students at a lower cost. This is partly because of the lower focus on research, but also because of more nimble cost structures and in our case, a lack of expensive on-campus infrastructure.

OUA notes that the current Bill doesn’t have provision for purely online institutions, but allowing purely online private providers to access to government subsidies would likely further drive down prices and increase competition due to the scale, and lower infrastructure costs involved.

OUA acknowledges that some course fees will likely rise in a deregulated and competitive market. However, we are confident that for numerous courses, deregulation of fees will also lead to a significant decrease in the cost of tuition.  The potential for fee reductions will be magnified if competition from non-university  providers is allowed.

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CQU:  competition will foster innovative delivery

The deregulation of student fees are absolutely essential to offset the Commonwealth’s 20% reduction in cluster funding. To have the funding cuts not followed by fee deregulation CQU logowould be a terminal blow to many University institutions, including perhaps CQU.

The deregulation of student fees also removes the last remaining impediment to a completely free and competitive higher education market.  CQU is particularly enthusiastic about the opportunities that could flow to the more agile and responsive universities like CQU under an uncapped, deregulated fee environment.  The introduction of true price competition in the sector will drive a level of entrepreneurialism and innovation which hasn’t yet been truly cultivated in Australia, and whose absence has perhaps held many universities back from reaching their full potential. In CQU’s experience, being able to compete on affordable price with “its suite of products of comparable or superior quality to competitors will not only benefit CQU’s own student load, but it will force the rest of the market to enhance its offerings and affordability to match CQU. The institutions willing to embrace these reforms, such as CQU, will gain the most through this new environment, but ultimately it will be students who stand to win the most.

CQU supports the Regional Universities Network in strongly  opposing the linking of Student HELP loan interest to the full Treasury bond rate and in establishing a  “competitive regions fund”,  to ensure that all students throughout Australia have continued access to consistently high quality university education experience.

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Navitas:  reforms will benefit disadvantaged students

NavitasThe reforms introduce market mechanisms of competition, choice, and deregulated fees, which support innovation, differentiation and specialisation. The reforms will encourage competition, coupled with socially responsible and accountable decision making by higher education institutions. Ultimately fees will be judged by the market with respect to value for money, which will ensure a market responsible approach to course fee setting.

Fee deregulation is likely to result in significant diversity in fees being charged between institutions. It is also likely to lead to improvements in quality as providers seek to focus and invest more in areas of speciality, teaching and learning and student support services. To ensure that learners can make informed choices it is imperative that students have access to easily accessible and detailed information on the costs, courses, providers and comparative graduate outcomes.

Students in the non-university higher education sector stand to gain a great deal by these reforms by simply applying a level playing field, which will give them access to a Commonwealth Supported Place and no longer will see them incur a 25% loan surcharge on their debt.

Navitas does not support the proposed changes to the indexation rate on HELP loans,  which would disproportionally impact low income earners or those who take time out of the labour force, particularly women. Navitas supports maintaining Consumer Price Indexation and says placing a limit on the amount of debt a student can accumulate over a lifetime is a potential mechanism to control the budget exposure.

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RUN: funding must ensure that regional universities are sustainable

The Regional Universities Network (RUN) has called for a Competitive Regions Fund, regional scholarships, and an interest rate on HECS/HELP loans to be set at 50% of the Long RUN LogoTerm Bond Rate, with the students’ interest rate on the loan capped at 6 per cent.  RUN also proposes imposing a threshold on the Higher Education Participation Program (HEPP) to allocate funding to those universities with relatively high proportions and significant catchments of low SES students.

Given that regional universities play a fundamental role in the development of their  communities, operate in thin markets with low population density and demand, and  that the higher education sector is faced with a continuing decline in Government  funding per student, the Regional Universities Network (RUN) supports fee  deregulation, subject to changes to the Higher Education and Research Reform (HERRA) Bill and the Higher Education Participation Program (HEPP) to recognise the particular circumstances of regional universities and regional students.

RUN welcomes the removal of caps on the number of places that can be offered at sub-bachelor degree level, and the continuation of funding for the National Collaborative Research Infrastructure Strategy and Future Fellowships.

RUN strongly opposes a reduction in Commonwealth Grant Scheme funding as proposed because, if these cuts proceed without modification, there will be a substantial negative impact on regional universities’ teaching, research and community engagement activities.

RUN opposes the proposed real interest rate on Higher Education Loan Program (HELP) loans, particularly in an environment of potentially higher student fees. This policy is anti-family and may have other economic impacts in the mid to longer term.

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DASSH: funding cuts will disproportionately impact humanities

DASSHThe Council of Deans of Arts, Social Sciences and Humanities (DASSH)    is perplexed by the proposal to reduce the level of commonwealth funding to support university education, irrespective of any decision to deregulate higher education.  The proposed cut to Commonwealth Grant Scheme support for university education suggests a lack of government commitment to securing  Australia’s future.

The proposed cut will hit humanities, arts and social science (HASS) disciplines particularly hard, despite the proposed increase in Humanities CGS funding and the maintenance of Languages CGS funding. The suggestion that the CGS cuts will amount to a 20% cut in CGS income does not attend to the patterns of enrolment and internal cross subsidies that already exist in universities. Currently in the majority of universities, HASS disciplines cross-­‐subsidise STEM areas to ensure that there are sufficient resources to maintain high-­‐cost STEM education and research programs. Similarly, Social Science enrolments are often used within HASS faculties to cross-­‐subsidise low revenue Humanities, low enrolment Languages and high cost Creative Arts disciplines. Based on a normalised pattern of enrolment across Arts Faculties, the cuts are more likely to be in the region of 30%-­‐40%, not 20%.

DASSH is also concerned that the proposed changes to the HECS-­‐HELP system will result in disproportionately higher student HELP debt for HASS students.

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SCU: smaller campuses  “resource intensive”

As a regional university,  Southern Cross University  (SCU)  is not only operating in a ‘thin market’ (as developed further in the RUN submission), it is also drawing students from SCU-Logo-Whiteregional communities that are often more disadvantaged than many metropolitan areas.

Even within SCU, some of its markets are ‘thinner’ than others.  SCU has a unique partnership at Coffs Harbour (in the mid-north coast of New South Wales), through the Coffs Harbour Education Campus, where it shares facilities and operations with a senior college (high school) and North Coast Institute of TAFE .  In considering whether additional support is needed for regional universities, SCU urges the Committee to reflect on the resource-intensiveness needed to support these smaller campuses. A smaller campus such as Coffs Harbour not only remains critical to its immediate footprint,it is integral to the University as a whole,and part of our legislative mission to serve the north coast region of NSW (which also encompasses campuses in Lismore in the Northern Rivers up to the Tweed/Gold Coast regions).

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UA: reforms  necessary – with changes

ua-logo-ua-smallThe Higher Education and Research Reform Amendment Bill 2014 represents the most substantial change to Australia’s higher education system in more than thirty years.

The Senate is uniquely placed to craft and shape Australia’s higher education policy and, in doing so, create a legacy to be proud of. This cannot be achieved by opposing the Bill outright.

Underpinning every successful developed nation is a high quality, adequately resourced higher education system. Through teaching, scholarship and research, our universities are a critical part of the nation’s infrastructure for supporting and driving the knowledge economy to come.

Continuing with present arrangements will see universities struggle to meet the quality and performance expectations of students and employers, constraining Australia’s productivity growth. It will lead to an inevitable erosion in our national research and innovation capability and on-going threats of further funding reductions as government funding priorities change. In addition, as Australian universities already derive over 16 per cent of their revenue from international students, it risks over-exposing the sector to the highly competitive and volatile international education market.

While Australia has an acknowledged world class university system, it is at a crossroads. Public investment is inadequate and, despite strong public support for universities, per student funding has been declining over time. Up until now there has been very little ability for universities to recoup losses from government funding reductions through other means.

With public budgets under constant pressure it is difficult to foresee a time when Australian governments will fund universities at the level needed to maintain quality and as recommended by successive government inquiries.

The Higher Education and Research Reform Amendment (HERRA) Bill presents an opportunity for universities to build more predictable and sustainable business models that are less  vulnerable to government funding instability and frequently changing policy and budget priorities.

However, changes to the package are required to assure affordability for both students and taxpayers. Most critically, Universities Australia is calling for improvements in three key areas:

  • Moderating the proposed 20% reduction in the Government contribution to tuition fees, so as to reduce the upward price pressure on fees;
  • Maintaining the CPI interest rate on HELP loans for graduates; and
  • An adjustment package to assist students, universities and communities with the transition to a fee deregulated market-based sys

In the absence of any suggestion of increased public investment, discarding the proposals in their entirety would condemn the higher education sector to inevitable decline – in quality, performance, competitiveness and reputation.

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CSU: supportive but wary of  “unintended consequences”

While broadly supporting the position of Universities Australia, Charles Sturt University (CSU) says it is important the regional context of the debate be considered. CSU believes that inCSU logo addressing such challenges and providing meaningful reform for the sector as a whole, government must commit to a sustainable and growing regional higher education system. It is critical that we support increased participation for rural and Indigenous students and address regional labour market needs in areas of critical importance to the Australian economy. It is also vital that any reform supports the delivery of excellence in relevant research, enhances rural industry productivity and continues to make a substantial and growing economic contribution to regional development, population attraction and jobs, and economic growth in rural and regional communities.

Of the proposed measures contained in the Higher Education and Research Reform Amendment Bill 2014, CSU is cautiously supportive of deregulation of student contribution levels, though is wary of the potential effect on regional and disadvantaged students. However, CSU is opposed to the proposed scholarship scheme, as well as the decrease in Commonwealth contribution levels and the reorganisation of funding clusters. CSU also holds a number of reservations regarding changes to HELP debts, and the speed of implementation for providing Commonwealth funding to private providers. In relation to proposed changes to research funding and costs for higher degrees by research, CSU is concerned that these too are likely to negatively affect the number of students interested in pursuing research and innovation careers.

Finally, CSU is concerned that a deregulated market may have unintended consequences and that there needs to be a structured package which addresses market imperfections as advocated by Universities Australia. CSU argues any such package must focus on strategic investments in the long term development of s skills and infrastructure linked to identifiable rural and regional development outcomes.

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Murdoch: higher levels of debt will “dampen participation”

Murdoch-logo-squared-200x173In the context of further Commonwealth budget cuts to universities, deregulation will allow universities to raise the additional revenue through increased student contributions to ensure the continued delivery of quality higher education.

Murdoch says it is critical to strike a balance between meeting the revenue shortfall and the financial burdens imposed on students. Murdoch is exploring the percentage increase of fees to meet the revenue needed while remaining steadfast about the importance of retaining the HECS-HELP scheme and students’ ability to defer payment.

Murdoch considers that the proposed reduction of funding of a20% per student should be ameliorated so that Government funding can be retained at more reasonable levels.

Murdoch argues that proposed changes to the indexing of graduates HELP debt to the ten-year bond rate, resulting in much higher debt, will have a dampening effect on patterns of participation, particularly for mature age students already carrying levels of debt associated with such things as housing and child rearing.

The incurring of greater debt at the undergraduate level combined with income foregone during years of higher degree study and subsequent modest academic income levels, presents a strong disincentive for potential candidates for higher degrees.

Murdoch strongly advocate that funds under the Commonwealth Scholarships Scheme (CSS) to support students from disadvantaged backgrounds be pooled for distribution to universities based on enrolments of the target group of students along with an established record of improving access and equity. Among other things, Murdoch argues that pooling would make the scheme less susceptible to forms of gaming, for instance, where it is used as a recruitment ploy by an institution to lure potential students who have not prioritised that university.

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UNSW: deregulation a game changer

UNSW believes that given the substantial reduction in government funding proposed in this Bill, as well as the effects of the long term erosion of per student funding to our universities, UNSW Logo2there is no alternative to fee deregulation if Australia is to continue to be regarded as having one of the world’s best higher education systems.

UNSW also argues that deregulation will be a game changer for the sector, fostering flexibility, diversity and innovation. It will open up new educational pathways and increase student choice. There is evidence that a well-funded, differentiated and autonomous (de-regulated) system will perform better for both the nation and for students.

The following table summarises UNSW’s assessment of the individual elements proposed in the bill and suggests amendments that should be considered relating to funding cuts and student loan interest .

 

Proposed Reform UNSW Assessment Suggested amendments
Deregulation of fees Strongly supported and essential for the future of the Australian university system
20% reduction in Commonwealth Supported Place funding Given the already low levels of public per student funding we do not support reducing the CSP payment. If reductions in the CSP are required then we advocate a staged introduction by removing indexation for 5-6 years. This would achieve the same effect over time and make the transition far more manageable for the sector.
Creation of the scholarship fund from 20% of net revenue increase We strongly support this initiative but counsel against any proposal to centralise the funds available.
Cluster realignment (8 -> 5 clusters) We do not support the rationale behind  the cluster realignment- in particular we are concerned about the relative impact on STEM subjects (especially engineering). That this element be removed from the reform package and any cuts to CSP funding uniformly applied to the existing clusters.
A real interest rate on student debt We do not support the proposed changes to charging students a real rate of interest. Either leave the current arrangements in place or consider alternatives such as a loan establishment fee or staggering interest rates depending on income.
Changes to the Research Training Scheme We do not support the proposal to reduce the RTS and charge fees to higher degree by research students Given the importance of HDR students to the future of Australia’s research and innovation capabilities and the lack of significant private benefit, we believe this proposal should be dropped.
The extension of the demand driven system to sub-bachelor degrees and non-university higher education providers We support this proposal

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Deakin: proposals in their current form “unfair” and “disruptive”

Deakin's new logo...

Deakin acknowledges  that investment in higher education returns both private benefit and public good. Deakin does not, therefore,  oppose an increase in the student contribution to their education, but argues that the current balance between government and student contributions is broadly equitable.  The Commonwealth ought to maintain the value of its contribution.  A  student fee increase can be achieved either by a modest increase in tuition fees or by indexing these fees on an annual basis, or both. Either way, we need to address both the reality and the perception that growth in university funding has stalled, and failure to do so will inevitably compromise the quality of higher education services in the future.

The most significant concern to Deakin is the impact of the proposed changes to the way student HECS debts are repaid. The impact of compounding interest tagged to the ten year bond rate on student choice and future health and well-being is problematic.

It is Deakin’s view that the proposed revision of the original intent and purpose of the HECS repayment scheme is unfair and will result in it no longer providing a fair chance for all to aspire to higher education. Deakin rejects any compromise on this issue and urges the Senate to ensure that fairness and equity are upheld so Australians can access education and repay their debts within a reasonable period.

Deakin estimates that the accumulated cuts from the Gillard Government and the impact of the measures contained within the Abbott Government’s proposed Bill on Deakin’s annual revenue are approximately $73 million per annum.  Deakin’s preferred position is that the cuts are delayed and any shortfall of funding is offset by some delay to the introduction of funding to the non-university higher education providers. This would enable universities, communities and prospective students to consider how best to prepare for a reduced funding model.

Deakin argues that the impact of the reforms would be to undermine provision at its regional campuses  as the magnitude of the proposed cuts to university funding may mean that it “will have to consider financial stability and the dictates of the market at the expense of locating courses such as those described above at our regional campuses.”

The proposed higher education changes will lead to a direct loss of income of about $750,000 per annum for the Indigenous Tutorial Assistance Scheme (ITAS) at Deakin. This will impact on the University’s ability to drive opportunities for indigenous employment; increase participation and acceptance of Indigenous Australians in the economic and social life of the nation; and, address disproportionate disadvantage in remote Australia.  Deakin says that the minimal savings to the government accruing from this measure are out of all proportion to the consequential impact on higher educational opportunities for indigenous students.

University contributions to the research fabric of the country are seriously under threat with the abrupt financial disruption that the higher education changes are likely to impose. Even if the impacts only affect university bottom lines for two-three years, a great deal of progress can be rapidly lost in a short period of time if the significant human resources are eroded rapidly.

In terms of the argument that Australia needs at least one Princeton, Harvard or MIT, Deakin argues that this pursuit of excellence is a narrow perspective that will lead to further distortion to investment in higher education and a skewing of opportunity for Australian students.  Instead, Australia could advance a broader vision of 15 to 20 Australian universities in the world’s Top 300 – a broadly based, diverse national network of excellence in teaching and research designed to address national economic need and focussing on delivering the necessary number of graduates with the skills required to sustain Australia’s economic growth and regional economies. This would result in a program for growth in higher education focussed on national requirements, rather than one or two outstanding places on what are ultimately subjective international ranking tables.

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Bond: reforms long overdue

Bond University supports key elements of the Higher Education Reform Bill as  a policy that will support quality, encourage innovation, and drive expansion, and will result in more Bond logohigher education opportunities for more Australians. It saysthe current funding model and regulatory regime have held back the sector by not encouraging diversity and innovation and, as a result, made the sector less responsive to the diverse and changing requirements of our students.

In particular, Bond support sthe proposal to harmonise the HELP loan scheme so that all undergraduate students have equitable access to the Government loan scheme and proposs that the strat date be brought forward to January 2015 (rather than January 2016).

It says zero real interest loans with income-contingent repayments are a proven and effective measure for removing financial barriers to entry and extending opportunity.  The proposal to lift the student loan  interest rate ought to be reconsidered as higher indexation will be a perceived barrier for some students and introduce inequities for students whose career or life choices cause them to take longer to repay their debt.

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Federation: deregulation and regional support essential

FED UNI LOGO INSET (2)Federation University Australia opposes the proposed 20% reduction in Commonwealth Grant assistance to universities.  The impact on the learning, teaching, research, engagement and economic conduct of the university will be profound and will further exacerbate the unpredictability of funding arrangements recently experienced by Australian tertiary education providers.   Given, however, the high probability that the reduction will proceed, the university supports the corollary deregulation of student fees.

As student recruitment opportunities for metropolitan and regional universities are unevenly distributed, Federation proposes the creation of a regional adjustment fund by which systemic competitive inequalities between metropolitan and non-metropolitan tertiary education providers can be rectified, including provision for supplementation for regional students in the proposed Commonwealth Scholarship Scheme.

The deregulation of student fees and the creation of a regional adjustment fund are considered essential for the viability of the university in particular and regional universities in general.

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Melbourne: no practical alternative to deregulation

The University of Melbourne proposes that the Senate:Uni Melb pic

 Support fee deregulation for Commonwealth Supported Places (CSPs), in the absence of a firm commitment to increase public funding for higher education.

 In the absence of growth in public investment, deregulation is necessary to support a sustainable future for a demand-driven system of higher education in Australia. It is the only policy option currently on offer to ensure the viability of many courses of study and the sustainability of a quality system overall.

Support the current proposal for universities to set aside 20% of any extra fee rise for the new Commonwealth Scholarship Scheme.

 Robust equity measures are critical to ensuring that all qualified students can attend university. While HECS- HELP is central to this, additional  measures are needed so prospective students who have faced socio- economic disadvantage can attend university.  Modification of the proposal to ‘pool funds’ raised through the Scheme and then redistribute between different universities is regressive and should not be supported

Support limited structural adjustment funds to support equity and community engagement in universities exposed to risk of market failure.

 Where there is market failure under a deregulated system, such as in some regional areas, additional support is needed.

Oppose the cuts to public subsidies for student places by an average of 20%, noting the significant budget savings delivered by the higher education sector over the past decade, and recognise that budget savings should not be delivered by further cuts to research funding.

 The proposed average 20% cut to CGS funding risks serious consequences for the quality of teaching and affordability of courses under a deregulated system.  There is a strong case for maintaining public investment at current levels, including the depth of  funding cuts in recent years.

Oppose the imposition of the bond rate of interest on HECS, and support a single HECS-HELP scheme including future indexation for HECS-HELP loans at a rate that avoids regressive outcomes.  This might be achieved, for example by using CPI and a loan fee, or indexation at CPI when a borrower’s income falls below a certain level.

 An increase in the indexation rate from the CPI to a real interest rate is highly regressive for low income earners due to large debts that can easily accrue.

Oppose the 10% reduction in funding for the Research Training Scheme.

Maintaining current funds for a well-targeted Research Training Scheme is critical to ensuring world leading research training is viable in Australia’s universities.

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Parker: ignorance is looking more affordable by the day

Stephen ParkerProfessor Stephen Parker (vice-chancellor, University of Canberra) opposes the central measures in the Higher Education and Research Reform Amendment Bill 2014 and argues that there is simply no need for the rush with which the proposals have been formulated and pressed on the higher education sector.

The present funding system for Australian universities is arguably unsatisfactory, and the so-called efficiency dividend announced by the previous Government was very disappointing, but the package of measures now being considered by the Senate does not provide the answers.  Just restoring the previous funding levels and current indexation method (under the Higher Education Grants Index) would stabilise the situation.  Australia has one of the best university systems in the world, from the elite to the community provider level. The fact that some of our universities can continue to rise in world      rankings without these changes undermines any urgent case for the reforms based on arguments about global competitiveness.

If the urgency is attributable to an unexpectedly tight national budgetary situation, it was (and is) open to the Parliament to shift the balance between the taxpayer and the graduate by reducing Commonwealth Grant Scheme amounts and raising Student Contribution Amounts correspondingly. Professor Parker says he would have privately disagreed with that because he considers the balance is about right now, but no one can categorically say where around the middle the balance should be struck between the public good and the private gain of higher education. Shifting the balance in this way would have saved public money, at the expense of university graduates:

  • without the need for some of those savings to be diverted to private providers;
  • without the need for a real interest rate to be applied to graduate debt (which is unlikely to yield a great deal over the forward estimates);
  • without the need for a full uncapping of Student Contribution Amounts; and,
  • without the need for various other aspects of the reforms which create the impression of an ideological agenda that seems to have come from

As a package, these reforms have not been adequately discussed and considered. The National Commission of Audit recommended up to 12 months debate over arguably the most controversial proposal, fee deregulation, but this period of reflection has not been granted.

Professor Parker to emphasises  what he considers the damage that these measures will do to future graduates, and indirectly Australian society, the unfairness to existing debtors of having the basis of their repayments changed after graduating, the inequitable nature of the proposals as between  advantaged and disadvantaged people and the distorting impact that the reforms will have on some key professions such as teaching.

Under these circumstances, Professor Parker says the whole set of measures should be taken off the table and considered further.  Any fresh package should be put to the electorate at the next election if that is the Coalition’s wish.

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NTEU: reforms will shackle students with debt

The National Tertiary Education Union’s (NTEU) submission for the entire Bill to be rejected.

The union says that the Abbott Government’s proposed policies have nothing to do with reforming Australian higher education and setting our universities free to offer internationally nteu-logocompetitive teaching, research and community engagement, and everything to do with achieving large cuts to public investment in our universities and their students, no matter what the consequences.

The government wants to abrogate their financial responsibility to support a world class public higher system and in doing so will shackle future generations of Australians with student debt the size of a mortgage with some degrees costing more than $100,000.

Despite the fact that Australia, with the exception of Japan, has the lowest level of public investment in tertiary education in the OECD and that Australian students already pay amongst the highest fees to attend public universities anywhere in the world, the primary objective of the government’s policy is to shift the burden of who pays for higher education even further away from to government and onto students and their families.

Entry into an Australian university has been based on academic ability but this will be undermined if the government allows universities to charge whatever they like for a degree. Entry into university will be determined by a student’s willingness and capacity to pay.

While changing the way interest is charged on students loans may eliminate some of the highly unfair impacts on low income students and those who take career breaks (predominantly women with children), the likely alternatives will still impose very high costs on all students compared to current arrangements. The alternatives will only be more equitable in the sense that all students will be equally worse off.

A targeted regional assistance package would need to compensate universities for cuts to public funding and adverse effects of increased competition from private for-profit providers who will now have access to public funding.

Additionally, it would also have to take into account the perverse impacts of the new “Commonwealth” scholarship scheme on universities with relatively high numbers of students from economically and educationally disadvantaged backgrounds.

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Swinburne: cap HELP loans to protect students from crushing debt

Swinnie large_signSwinburne University of Technology has urged the Australian government to reconsider aspects of its current higher education package.

In its submission, Swinburne has further advanced earlier calls by Vice-Chancellor Professor Linda Kristjanson to moderate likely fee increases for students by placing a ‘soft cap’ on lending under the Higher Education Loan Program.

Swinburne says the government’s decision to remove all maximum HELP borrowing limits removes one of the few levers that the Commonwealth has to exert downward pressure on price, both for Commonwealth supported places and full fee places.

Swinburne’s proposal would limit the amount a student can borrow each year towards fees in Commonwealth-subsidised course. It would also mean that providers offering degrees priced above the maximum HELP loan limit would be required to justify any additional costs to their students.

The submission argues a ‘soft cap’ on HELP lending is consistent with the Government’s objective to allow universities to set fees in accordance with market demand whilst also ensuring that borrowing under the HELP scheme is sustainable.

The submission, based on Swinburne’s direct experience of market-based deregulation in Victoria, also argues that any changes to higher education policy should be rolled out in stages rather than rapidly introducing more than 13 major policy changes by 1 January 2016.

Swinburne has also called on the Commonwealth to:

  • provide additional funding to the Tertiary Education Quality and Standards Agency to ensure that it is equipped to effectively regulate the competitive higher education market which the bill establishes;
  • design the new Commonwealth Scholarship Scheme to allow national pooling of funds and a simple model of distribution to eligible providers based on the number of low-SES students enrolled at each institution
  • consider the introduction of a national tuition assurance scheme for domestic students modelled on the scheme already in place to protect international students.

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IRU: amended bill provides a viable basis for unis

The Innovative Research Universities (IRU) supports the passage of the Higher Education and Research Reform Amendment Bill 2014 (the Bill) with amendments to address IRU8495_logoweaknesses in the Government’s plan.

The Bill will put in place reforms to higher education that may provide a viable basis for universities over the next decade.  The Bill provides a way ahead. It retains open access to government supported higher education. It proposes mechanisms to give universities the resources they need. These combine Government funding with student fees agreed between university and student.

There are five areas in the Government’s plan that the Senate should address as it considers the Bill.

  1. The funding rates in the Bill will reduce funding per student overall by 20%. This cut should be scaled back to retain reasonable levels of Government The IRU supports the Government’s new five funding tiers, which better distribute the available funding than the current dated grouping of disciplines.
  2. The proposal to index graduates’ HELP debts by the ten-year bond rate rather than the CPI will extend considerably the period of repayment for graduates with lower incomes, particularly those who take time out of the workforce, for example for maternity and parental This needs to change, with the CPI index retained at least for the debts of graduates not earning sufficient income to make repayments.
  3. The Commonwealth Scholarships Scheme should pool the eligible funds from all providers as the basis for matching the funds for scholarships with the students for whom they are This will encourage students to choose their university based on their educational preferences.
  4. The IRU opposes the reduction in funding for research students pursing PhDs and Masters. This program creates our future research workforce in industry as well as It needs to grow, not shrink.
  5. Universities need support to make the transition to a market based system through a structural adjustment IRU universities serve outer metropolitan and significant non-capital city regions. We need to test how well the potential students in our catchment areas will respond.

The IRU urges the Senate to pass the Bill with the necessary amendments by the end of 2014. Students are now planning their 2015 studies without knowing the funding and fees that will apply to them from 2016.

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Grattan Institute:  package should be adopted, with some changes around HELPgrattan_logo10

  • Extension of the demand driven system to sub-bachelor qualifications would help students take the courses that best meet their academic

 Although the number of sub-bachelor places has expanded, their exclusion from the demand driven system has unfair consequences for students. For  example, lower-ATAR students who are not admitted to the limited number of CSP pathway programs can attend pathway college, but paying full fees.

  •  Extension of the demand driven system to private universities and non-university higher education providers would make Australia’s higher education system fairer:

 Fairness to students As with the sub-bachelor places, there are fairness issue in excluding private university and non-university higher education providers from Commonwealth supported places.

Supporting extension of pathway programs Pathway colleges were pioneered by the private higher education sector. Although some universities already have their own pathway colleges, it makes sense to use  organisations that already do it well.

Diversity in the higher education system The growth over time of private university and NUHEP enrolments shows demand for different types of higher education than is offered by the public universities.

Fee affordability and competition in the higher education The average annual fee for a bachelor degree in a NUHEP is just under $15,000, nearly 50 per higher than the maximum student contribution amount at a university. With a funding system less biased against NUHEPs and private universities, the industry structure may change in ways that lead to more direct competition with public universities. The TAFEs are in the best current position to do this. Their fees suggest low cost structures, they have existing campus networks, they have established brands and recruitment channels, and they have a mission commitment to affordable education.

  •  Extending the demand driven system to sub-bachelor qualifications but not non-university higher education providers would compromise the sub-bachelor reform undermine the business models of many NUHEPs, particularly TAFEs.
  •  Private benefits are already sufficiently high in most cases that reductions in Commonwealth contribution rates are unlikely to make a difference to the basic yes/no decision to undertake university .
  •  If the Senate approves admission of NUHEPs to the demand driven system, the number that actually enter will depend on what other parts of the package are If fee deregulation is enacted, many providers are likely to enter the market. If current Commonwealth and student contributions are maintained, fewer but still many NUHEPs are likely to enter. However, a package that cuts Commonwealth contributions without increasing student contributions would substantially reduce NUHEP entry.
  •  Rejecting savings measures in higher education risks alternative cost cutting that would have worse long-term outcomes.
  •  The financial costs of HELP to government are significant and need attention.
  •  HELP doubtful debt could be reduced by recovering HELP debt from deceased estates.
  •  A reformed loan fee on HELP borrowing and real interest only for repaying HELP debtors should be considered as an alternative to real interest on all HELP debt.
  •  The lower initial threshold for HELP repayment should be  introduced.

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USC:  smaller, newer unis need transitional support

USC logoWhile the University of the Sunshine Coast (USC) asserts that it has most of the attributes required to thrive in a more competitive environment, it says  the proposed changes will have a greater impact on USC than any other university . The threats to the University’s success in a more competitive environment are its short history and consequent relative lack of infrastructure, its small scale, and the almost complete absence of major industries and professional groups in the local economy. Accordingly , USC proposes:

  1. a substantial transition fund is established to support universities that are heavily reliant on the Commonwealth Grants Scheme and are embedded in under-developed or depleted local economies;
  2. the transition fund is designed so universities can develop applications for funds intended to address the underlying conditions that impair their ability to compete effectively in a deregulated sector;
  3. the transition fund is designed so it can support significant structural changes, such as the development of infrastructure for new study locations or the consolidation of existing sites; and,
  4. the interest rate on HECS/HELP loans be set at 50% of the Long Term Bond Rate, with the students’ interest rate on the loan capped at a maximum of 4%.

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Chapman & Higgins:  concern over haste and lack of consideration of HELP alternatives

This submission covers interest rate options to charge on HELP debt. The key points are:

  1.  The problem with bond rate indexation is that it leads to inequity between borrowers. This is because the interest accrued by graduates with lower incomes or who experiencePhoto: Andrew Taylorperiods out of the labour force (for example, to raise a family) will exceed the interest accrued by graduates with higher incomes and longer periods of continuous employment. This inequity can come about in particular when the interest applied to the loan in a particular period exceeds the compulsory repayments made.
  2. Loan surcharges or hybrid arrangements are both superior to the proposed bond rate indexation in terms of borrower equity, but there are advantages and disadvantages of the different arrangements. The preferred approach may depend on the level of future tuition fees, and the importance that the Government places on eliminating interest rate subsidies for new debt.

If fee deregulation proceeds and fees rise considerably for the majority of degrees, then a loan surcharge is likely to be superior to a hybrid indexation arrangement. If, on the other hand, fee deregulation does not occur, or if it occurs but the rise in fees is not excessive, then a hybrid arrangement and surcharge could produce similar equity improvements. The key risk of applying a surcharge is the uncertainty.

The authors say they are very concerned about the apparent haste and seeming lack of expert consideration of the many complex and potentially inequitable outcomes implicit in the suggested radical fee deregulation agenda that makes up the Commonwealth’s plans. It would have been, and remains clearly the case, that a more cautious and considered approach is a preferred public policy stance and one that is still feasible.  Increases in price caps to allow greater contributions from students, without compromising  some essential and highly desirable characteristics of the current arrangements, would be practicable and, moreover, would allow a considered assessment of impacts without compromising the prospects of further future reforms.

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Sydney:  need for a better balance

Uni sydneyThe University’s position on the Bill is that it should be passed with amendments to remove, reduce or phase in the proposed 20% cut to public funding per student, continue to index HECS-HELP loans to the Consumer Price Index, and set aside for detailed review the proposed introduction of tuition contributions for domestic higher degree by research students.
With these three key changes, the legislation would represent a better balance, within a constrained funding environment. They would ensure that the sector continues to deliver the productive capacity the nation needs, as well as provide accessible higher education for all qualified Australian students.

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CDU:  amendments needed to support regional unis needed to support 

  • CDU is concerned by the possibility that both the real and the perceived costs of Higher Education as a result of the Government’s proposed Reform Package will deter students CDU_logo_2010in the demographics of particular importance to CDU (mature and low SES) from tertiary study.
  • CDU supports changes to the Higher Education Participation Program (HEPP) to address equity and access challenges for low SES students by introducing a HEPP eligibility threshold that would restrict HEPP support to those universities with 15% or more of students from low SES
  • CDU argues for a lower than 20% reduction in CGS funding due to anticipated impacts on its student demographic and urges reconsideration of the per-place funding model
  • CDU does not support indexing HELP loans to the 10 year government bond rate as this would potentially differentially disadvantage CDU’s main student demographics (mature, low SES) by increasing their level of overall debt, and acting as a disincentive to tertiary and further
  • CDU strongly supports creation of a national scholarship pool from funds accruing from fee deregulation that would distribute funds to universities based on enrolment of, and performance with, student target equity groups.
  • CDU supports the creation of an Adjustment Fund to support small and regional universities like CDU to cope with adverse changes as a result of the Higher Education reforms and to ensure that opportunities for students in the Northern Territory are maintained and
  • CDU urges Government to delay or indefinitely postpone access to Commonwealth funding by currently non-funded providers in order for the impacts of other Reform Package changes to be assimilated and assessed by CDU would also expect that if private providers are to be eligible for Commonwealth funding that they will also be subject to the same quality control and reporting requirements that universities are required to meet.
  • CDU does not support the proposal to reduce Higher Degree by Research student funding by 10% on the basis that this funding is already insufficient to support research training CDU does not support charging fees for HDR domestic students who are critical contributors to the nation’s research enterprise.

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Alphacrusis:  level playing field needed for private providers

AlphacrusisAlphacrusis says the proposed  reforms are needed to put the current unsustainable higher education arrangements on a stronger footing, especially improving access to quality higher education for students from backgrounds with historically low participation.

The reforms flow from and are fully consistent with the demand driven system recommended by the Bradley Review, reinforced by the findings of the recent Kemp-Norton Review.   Most importantly the reforms put the interests of students before other vested interests in higher education.

Students at Alphacrucis would be greatly disappointed if the extension of funding to students beyond those at public universities does not proceed as announced by the Government.  Senators blocking the extension of funding would have to deal with large numbers of justly disappointed students, asking why their friends at public universities receive government funding and they do not.  Continued discrimination is indefensible as both their degree program and those of their friends at public universities are now equally accredited by TEQSA.  It is not defensible on quality grounds either as the quality of our business programs is, at the very least, comparable to those offered by universities.

We understand that the draft legislation suggests that degrees at existing universities be funded at higher rates than degrees offered by other institutions.  The division between providers should not be on the basis of universities vs other institutions, but on the basis of institutions offering accredited doctoral programs vs other institutions.  Providers receiving government funding at the lower rate should be able to recover the remainder of their costs from students.  If this is not allowed then the providers would be forced either to compromise quality (as the lower rate is below their existing fees) or be in the embarrassing situation of being unable to accept government funding, placing the full burden back on their students.

As an institution developing strongly in recent years and likely to seek university accreditation in the near future, Alphacrusis is concerned about the current lack of clarity about such accreditation.   The provider types (especially the ambiguous “University College” category) reflect their origins in a committee dominated by the interests of existing universities, and understandably seeking to maintain their monopoly over the title.

As suggested by the Kemp-Norton review of the demand driven system of funding undergraduate places, there needs to be a similar review of non-discriminatory access to research and research degree funding.  Removal of the distortions in the existing system would maximise the return on the government research dollar as funds would flow to the best projects regardless of whether they are at public Universities or private higher education institutions.

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JCU:  HE must be sustainable, accessible and affordable

James Cook University (JCU) notes that successive governments have reduced real per student funding and that the current government proposes, through the HERRA legislation, to jcu_logo_rgb_2amplify that reduction.  Accessible higher education is as fundamental to the national interest as it is transformative of individual students.  JCU endorses the submissions by Universities Australia and the IRU and recommends the passage of the Bill with key amendments to promote a higher education system that is financially sustainable, accessible and affordable for both students and taxpayers.

The required key amendments are:

  •  Moderating the proposed 20 per cent reduction to the Commonwealth Grant Scheme;
  • Maintaining the CPI indexation rate on HELP loans;
  • Adjusting the proposed Commonwealth Scholarship Scheme in order for it to meets the needs of students who are disadvantaged;
  • Abolishing the reduction in funding to the Research Training Scheme;
  • An adjustment package to support students, communities and universities to transition in response to the proposed.

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UTS:  deregulation needs to be more rigorously planned

University of Technology Sydney (UTS)  urges the Senate Education and Employment Committee to consider:

  • Affordable fees and access for any student who merits a place in higher education.  The Senate should ensure that a pricing regime is designed and implemented UTSthat does not exclude thousands of Australians who are financially constrained or have marginal means to support large long-term loans, from undertaking further study, both for their own.benefit and for the productivity and prosperity of our country, or in any way risk shrinking the potential pool of talented people.
  •  Supporting the UA position and calling for a reduction in the overall cuts to education in the package – which in total are approximately 30%, (including the announced 20% cut to CGS, cuts to EIF, RTS and indexation). The proposed cuts will dramatically impact the quality of our universities at a time when our international competitors, particularly in Asia are enjoying major boosts in Government.
  •  Moderated deregulation. Deregulation is a major structural change and any implementation should be rigorously planned.  In a particularly opaque and non-transparent market, the opportunities for pricing distortions are high.  The impact of the proposed cut of 30% (once all budget measures are included)   with unconstrained fee deregulation could lead to substantial increases in the cost  of a undertaking a degree. A moderated pricing mechanism is needed to avoid price shocks and protect affordability.
  •  A strong and generous scholarship scheme for ALL low SES and disadvantaged students regardless of location. Universities should control their own Scholarship funds and places, allowing students from low SES and disadvantaged backgrounds a wide choice of study Strong HEPP funding is essential for the infrastructure and services that are vital in supporting students from low SES backgrounds.
  •  Supporting the UA position and rejecting as regressive the application of the 10-­ year Australian Government Bond rate to the repayment of outstanding student This measure should be scrapped in favor of less regressive alternatives.
  •  An appropriate period of consultation to consider both potential changes and transition mechanisms. It would be unprecedented to massively restructure one of Australia’s leading industries in just six A 12 month period was recommended by the Federal Government’s Commission of Audit.

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ARC:  welcomes funding of Future Fellowship

UA Industry-Research-iconThe Australian Research Council advises that the amendments in the Bill result in altering three existing financial year funding figures and extend the forward estimates, resulting in additional spending of $760 million for the period 1 July 2014 to 30 June 2018.  The Bill allows additional investment in research through the Future Fellowships scheme. As part of the 2014-15 Budget, the Government announced that it would provide $139.5 million over four years to support research under the Future Fellowship scheme. The scheme would be funded on an ongoing basis.

The Bill also amends the ARC Act to apply a one-off efficiency dividend, applies indexation to existing appropriation amounts and adds an additional forward estimate amount of $736.972 million for 2017-18.

The ARC considers the Future Fellowship scheme to be an effective and beneficial component of the National Competitive Grants Program (NCGP) that enables the ARC to achieve its outcomes.  Mid-career researchers often face uncertain employment circumstances. Many face employment in short term, casual positions increasing the risk that they will either leave the research profession or pursue opportunities overseas. The Future Fellowships scheme was introduced to reduce these risks, build research capacity and support excellent research.

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DoE:  the official line

The Department of Education says the package of reforms announced by the Government in the 2014-15 Budget, most of which are enabled by the Reform Bill, aims to spread opportunity to more students, including disadvantaged and rural and regional students, equip Australian universities to face the challenges of the twenty first century and ensure Australia is not left behind by intensifying global competition and new technology.

The Reform Bill aims to create opportunities and choice for students through expansion of the demand driven funding system to sub-bachelor places at all institutions and bachelor level places at private universities and non-university higher education providers registered by the Tertiary Education Quality and Standards Agency (TEQSA). It will also create a new Commonwealth Scholarship Scheme to assist disadvantaged higher education students with the cost of their study. Higher education institutions will be required to allocate one in every five dollars of additional revenue raised from student contributions to this new scheme.

The proposed reforms aim to provide the opportunity for more students to access the right type of higher education for their personal circumstances, with a greater number and a wider diversity of study options for students, including at the sub-bachelor level.

The Reform Bill will give higher education providers more freedom to work to their strengths and respond to the changing economic and social environments in which they operate. Institutions will be able to make independent choices about the courses they offer, the fees they charge, the teaching methods they use, the scholarships they provide and the other support services they provide. This will enable institutions to access the resources they need to deliver world class education, ensuring Australia is not left behind at a time of rising performance by universities around the world.

The Higher Education Loan Programme (HELP) will be maintained, meaning that eligible students still need not pay a cent up front for the cost of their tuition, and the loan need not be repaid until the student earns over an estimated $50,638 in 2016-17. Students will benefit from the removal of the HELP student loan fee of 25 per cent for FEE-HELP and 20 per cent for VET FEE-HELP, and removal of the FEE-HELP lifetime limit. To maintain the sustainability of HELP, the indexation rate for HELP  debts will be changed to reflect the cost of Government borrowings (10 year bond rate), to a maximum annual rate of six per cent.

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BCA:  almost right but modifications needed

The Business Council of Australia (BCA)  says that, on balance, the reform package creates the right platform to build the higher education sector we need for the future by:BCA

  • Introducing market mechanisms of competition, choice and deregulated fees, which should lead to innovation, differentiation and
  • Extending uncapped funding to private providers, which will allow them to offer more customised education products, such as work-based learning or direct pathways into employment, in the government-subsidised This will benefit students, employers and the sector more broadly.
  • Extending uncapped funding to diplomas, advanced diplomas and associate This demonstrates the value of these qualifications in their own right. It brings them to an equal footing with undergraduate qualifications in terms of their importance to the labour market.
  •  Maintaining HECS for all.
  • Maintaining a strong focus on access, fairness and equity by expanding uncapped funding to diplomas, advanced diplomas and associate degrees, and introducing the new Commonwealth Scholarship.
  • Establishing transition arrangements for students and

Taken together, these changes will mean institutions focus on their strengths, which will lead to more responsive and flexible providers. It should also result in a sector that is more dynamic and offers greater differentiation and specialisation.

The extension of uncapped funding to private higher education providers, and to diplomas, advanced diplomas and associate degrees is a fundamental component of the package. The addition of new providers and courses to the uncapped funding market creates the environment for competition where fees can be deregulated. These two changes will work together and therefore need to be implemented at the same time.

While supporting the overall intent of the package, BCA says there are three areas that require additional work:

  • market design, including the transition arrangements for small and medium providers – BCA recommends the government establish an oversight role to monitor the market to minimise the potential for long-term costs to government, overpricing and poor value for money and recommends it intervene, if necessary, in thin
  • the need for more effective market information – BCA recommends the government identify and implement a way to significantly improve market information in the transition to the introduction of the new model in
  • the appropriateness of the indexation rate – BCA recommends the government adopt an indexation approach that removes the inequities associated with the bond rate while limiting the potential long-term costs to  government.

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TDA:  almost right but modifications needed

TAFE Directors Australia (TDA)  submits that  the reforms proposed in the Bill will not only address the current inequitable situation that blocks Commonwealth subsidies to TAFE students, they will stimulate broader choice, innovation and diversity across the tertiary sector. This will have significant flow on effects for Australia’s industries, enterprises and workforce productivity and importantly, will enhance the relevance of Australia’s tertiary education in our Asia-pacific region. The reforms will also bring greater alignment with many of our major international higher education competitors.

TDA makes three recommendations:

  1. The Committee support the expansion of the demand driven system to non-university higher education providers and sub-bachelor degree programs in order to address funding inequities in the current This reform will have significant flow on effects for Australia’s industries, workforce productivity and Australia’s standing in international tertiary education markets;
  2. The Committee support the establishment of a Commonwealth Scholarship Scheme based on clear principles that stipulate how scholarship monies will be distributed;
  3. The Committee review the implications to students should the 10 year government bond rate be applied to their Higher Education Loan Program (HELP) TDA prefers alternatives approaches such as the hybrid of indexation and a loan surcharge on HELP loans proposed by Professor Bruce Chapman and Timothy Higgins.

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Grattan Institute:  package should be adopted, with some changes around HELPgrattan_logo10

  • Extension of the demand driven system to sub-bachelor qualifications would help students take the courses that best meet their academic

 Although the number of sub-bachelor places has expanded, their exclusion from the demand driven system has unfair consequences for students. For  example, lower-ATAR students who are not admitted to the limited number of CSP pathway programs can attend pathway college, but paying full fees.

  •  Extension of the demand driven system to private universities and non-university higher education providers would make Australia’s higher education system fairer:

 Fairness to students As with the sub-bachelor places, there are fairness issue in excluding private university and non-university higher education providers from Commonwealth supported places.

Supporting extension of pathway programs Pathway colleges were pioneered by the private higher education sector. Although some universities already have their own pathway colleges, it makes sense to use  organisations that already do it well.

Diversity in the higher education system The growth over time of private university and NUHEP enrolments shows demand for different types of higher education than is offered by the public universities.

Fee affordability and competition in the higher education The average annual fee for a bachelor degree in a NUHEP is just under $15,000, nearly 50 per higher than the maximum student contribution amount at a university. With a funding system less biased against NUHEPs and private universities, the industry structure may change in ways that lead to more direct competition with public universities. The TAFEs are in the best current position to do this. Their fees suggest low cost structures, they have existing campus networks, they have established brands and recruitment channels, and they have a mission commitment to affordable education.

  •  Extending the demand driven system to sub-bachelor qualifications but not non-university higher education providers would compromise the sub-bachelor reform undermine the business models of many NUHEPs, particularly TAFEs.
  •  Private benefits are already sufficiently high in most cases that reductions in Commonwealth contribution rates are unlikely to make a difference to the basic yes/no decision to undertake university .
  •  If the Senate approves admission of NUHEPs to the demand driven system, the number that actually enter will depend on what other parts of the package are If fee deregulation is enacted, many providers are likely to enter the market. If current Commonwealth and student contributions are maintained, fewer but still many NUHEPs are likely to enter. However, a package that cuts Commonwealth contributions without increasing student contributions would substantially reduce NUHEP entry.
  •  Rejecting savings measures in higher education risks alternative cost cutting that would have worse long-term outcomes.
  •  The financial costs of HELP to government are significant and need attention.
  •  HELP doubtful debt could be reduced by recovering HELP debt from deceased estates.
  •  A reformed loan fee on HELP borrowing and real interest only for repaying HELP debtors should be considered as an alternative to real interest on all HELP debt.
  •  The lower initial threshold for HELP repayment should be  introduced.

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USC:  smaller, newer unis need transitional support

USC logoWhile the University of the Sunshine Coast (USC) asserts that it has most of the attributes required to thrive in a more competitive environment, it says  the proposed changes will have a greater impact on USC than any other university . The threats to the University’s success in a more competitive environment are its short history and consequent relative lack of infrastructure, its small scale, and the almost complete absence of major industries and professional groups in the local economy. Accordingly , USC proposes:

  1. a substantial transition fund is established to support universities that are heavily reliant on the Commonwealth Grants Scheme and are embedded in under-developed or depleted local economies;
  2. the transition fund is designed so universities can develop applications for funds intended to address the underlying conditions that impair their ability to compete effectively in a deregulated sector;
  3. the transition fund is designed so it can support significant structural changes, such as the development of infrastructure for new study locations or the consolidation of existing sites; and,
  4. the interest rate on HECS/HELP loans be set at 50% of the Long Term Bond Rate, with the students’ interest rate on the loan capped at a maximum of 4%.

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Chapman & Higgins:  concern over haste and lack of consideration of HELP alternatives

This submission covers interest rate options to charge on HELP debt. The key points are:

  1.  The problem with bond rate indexation is that it leads to inequity between borrowers. This is because the interest accrued by graduates with lower incomes or who experiencePhoto: Andrew Taylorperiods out of the labour force (for example, to raise a family) will exceed the interest accrued by graduates with higher incomes and longer periods of continuous employment. This inequity can come about in particular when the interest applied to the loan in a particular period exceeds the compulsory repayments made.
  2. Loan surcharges or hybrid arrangements are both superior to the proposed bond rate indexation in terms of borrower equity, but there are advantages and disadvantages of the different arrangements. The preferred approach may depend on the level of future tuition fees, and the importance that the Government places on eliminating interest rate subsidies for new debt.

If fee deregulation proceeds and fees rise considerably for the majority of degrees, then a loan surcharge is likely to be superior to a hybrid indexation arrangement. If, on the other hand, fee deregulation does not occur, or if it occurs but the rise in fees is not excessive, then a hybrid arrangement and surcharge could produce similar equity improvements. The key risk of applying a surcharge is the uncertainty.

The authors say they are very concerned about the apparent haste and seeming lack of expert consideration of the many complex and potentially inequitable outcomes implicit in the suggested radical fee deregulation agenda that makes up the Commonwealth’s plans. It would have been, and remains clearly the case, that a more cautious and considered approach is a preferred public policy stance and one that is still feasible.  Increases in price caps to allow greater contributions from students, without compromising  some essential and highly desirable characteristics of the current arrangements, would be practicable and, moreover, would allow a considered assessment of impacts without compromising the prospects of further future reforms.

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Sydney:  need for a better balance

Uni sydneyThe University’s position on the Bill is that it should be passed with amendments to remove, reduce or phase in the proposed 20% cut to public funding per student, continue to index HECS-HELP loans to the Consumer Price Index, and set aside for detailed review the proposed introduction of tuition contributions for domestic higher degree by research students.
With these three key changes, the legislation would represent a better balance, within a constrained funding environment. They would ensure that the sector continues to deliver the productive capacity the nation needs, as well as provide accessible higher education for all qualified Australian students.

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CDU:  amendments needed to support regional unis needed to support 

  • CDU is concerned by the possibility that both the real and the perceived costs of Higher Education as a result of the Government’s proposed Reform Package will deter students CDU_logo_2010in the demographics of particular importance to CDU (mature and low SES) from tertiary study.
  • CDU supports changes to the Higher Education Participation Program (HEPP) to address equity and access challenges for low SES students by introducing a HEPP eligibility threshold that would restrict HEPP support to those universities with 15% or more of students from low SES
  • CDU argues for a lower than 20% reduction in CGS funding due to anticipated impacts on its student demographic and urges reconsideration of the per-place funding model
  • CDU does not support indexing HELP loans to the 10 year government bond rate as this would potentially differentially disadvantage CDU’s main student demographics (mature, low SES) by increasing their level of overall debt, and acting as a disincentive to tertiary and further
  • CDU strongly supports creation of a national scholarship pool from funds accruing from fee deregulation that would distribute funds to universities based on enrolment of, and performance with, student target equity groups.
  • CDU supports the creation of an Adjustment Fund to support small and regional universities like CDU to cope with adverse changes as a result of the Higher Education reforms and to ensure that opportunities for students in the Northern Territory are maintained and
  • CDU urges Government to delay or indefinitely postpone access to Commonwealth funding by currently non-funded providers in order for the impacts of other Reform Package changes to be assimilated and assessed by CDU would also expect that if private providers are to be eligible for Commonwealth funding that they will also be subject to the same quality control and reporting requirements that universities are required to meet.
  • CDU does not support the proposal to reduce Higher Degree by Research student funding by 10% on the basis that this funding is already insufficient to support research training CDU does not support charging fees for HDR domestic students who are critical contributors to the nation’s research enterprise.

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Alphacrusis:  level playing field needed for private providers

AlphacrusisAlphacrusis says the proposed  reforms are needed to put the current unsustainable higher education arrangements on a stronger footing, especially improving access to quality higher education for students from backgrounds with historically low participation.

The reforms flow from and are fully consistent with the demand driven system recommended by the Bradley Review, reinforced by the findings of the recent Kemp-Norton Review.   Most importantly the reforms put the interests of students before other vested interests in higher education.

Students at Alphacrucis would be greatly disappointed if the extension of funding to students beyond those at public universities does not proceed as announced by the Government.  Senators blocking the extension of funding would have to deal with large numbers of justly disappointed students, asking why their friends at public universities receive government funding and they do not.  Continued discrimination is indefensible as both their degree program and those of their friends at public universities are now equally accredited by TEQSA.  It is not defensible on quality grounds either as the quality of our business programs is, at the very least, comparable to those offered by universities.

We understand that the draft legislation suggests that degrees at existing universities be funded at higher rates than degrees offered by other institutions.  The division between providers should not be on the basis of universities vs other institutions, but on the basis of institutions offering accredited doctoral programs vs other institutions.  Providers receiving government funding at the lower rate should be able to recover the remainder of their costs from students.  If this is not allowed then the providers would be forced either to compromise quality (as the lower rate is below their existing fees) or be in the embarrassing situation of being unable to accept government funding, placing the full burden back on their students.

As an institution developing strongly in recent years and likely to seek university accreditation in the near future, Alphacrusis is concerned about the current lack of clarity about such accreditation.   The provider types (especially the ambiguous “University College” category) reflect their origins in a committee dominated by the interests of existing universities, and understandably seeking to maintain their monopoly over the title.

As suggested by the Kemp-Norton review of the demand driven system of funding undergraduate places, there needs to be a similar review of non-discriminatory access to research and research degree funding.  Removal of the distortions in the existing system would maximise the return on the government research dollar as funds would flow to the best projects regardless of whether they are at public Universities or private higher education institutions.

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JCU:  HE must be sustainable, accessible and affordable

James Cook University (JCU) notes that successive governments have reduced real per student funding and that the current government proposes, through the HERRA legislation, to jcu_logo_rgb_2amplify that reduction.  Accessible higher education is as fundamental to the national interest as it is transformative of individual students.  JCU endorses the submissions by Universities Australia and the IRU and recommends the passage of the Bill with key amendments to promote a higher education system that is financially sustainable, accessible and affordable for both students and taxpayers.

The required key amendments are:

  •  Moderating the proposed 20 per cent reduction to the Commonwealth Grant Scheme;
  • Maintaining the CPI indexation rate on HELP loans;
  • Adjusting the proposed Commonwealth Scholarship Scheme in order for it to meets the needs of students who are disadvantaged;
  • Abolishing the reduction in funding to the Research Training Scheme;
  • An adjustment package to support students, communities and universities to transition in response to the proposed.

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UTS:  deregulation needs to be more rigorously planned

University of Technology Sydney (UTS)  urges the Senate Education and Employment Committee to consider:

  • Affordable fees and access for any student who merits a place in higher education.  The Senate should ensure that a pricing regime is designed and implemented UTSthat does not exclude thousands of Australians who are financially constrained or have marginal means to support large long-term loans, from undertaking further study, both for their own.benefit and for the productivity and prosperity of our country, or in any way risk shrinking the potential pool of talented people.
  •  Supporting the UA position and calling for a reduction in the overall cuts to education in the package – which in total are approximately 30%, (including the announced 20% cut to CGS, cuts to EIF, RTS and indexation). The proposed cuts will dramatically impact the quality of our universities at a time when our international competitors, particularly in Asia are enjoying major boosts in Government.
  •  Moderated deregulation. Deregulation is a major structural change and any implementation should be rigorously planned.  In a particularly opaque and non-transparent market, the opportunities for pricing distortions are high.  The impact of the proposed cut of 30% (once all budget measures are included)   with unconstrained fee deregulation could lead to substantial increases in the cost  of a undertaking a degree. A moderated pricing mechanism is needed to avoid price shocks and protect affordability.
  •  A strong and generous scholarship scheme for ALL low SES and disadvantaged students regardless of location. Universities should control their own Scholarship funds and places, allowing students from low SES and disadvantaged backgrounds a wide choice of study Strong HEPP funding is essential for the infrastructure and services that are vital in supporting students from low SES backgrounds.
  •  Supporting the UA position and rejecting as regressive the application of the 10-­ year Australian Government Bond rate to the repayment of outstanding student This measure should be scrapped in favor of less regressive alternatives.
  •  An appropriate period of consultation to consider both potential changes and transition mechanisms. It would be unprecedented to massively restructure one of Australia’s leading industries in just six A 12 month period was recommended by the Federal Government’s Commission of Audit.

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ARC:  welcomes funding of Future Fellowship

UA Industry-Research-iconThe Australian Research Council advises that the amendments in the Bill result in altering three existing financial year funding figures and extend the forward estimates, resulting in additional spending of $760 million for the period 1 July 2014 to 30 June 2018.  The Bill allows additional investment in research through the Future Fellowships scheme. As part of the 2014-15 Budget, the Government announced that it would provide $139.5 million over four years to support research under the Future Fellowship scheme. The scheme would be funded on an ongoing basis.

The Bill also amends the ARC Act to apply a one-off efficiency dividend, applies indexation to existing appropriation amounts and adds an additional forward estimate amount of $736.972 million for 2017-18.

The ARC considers the Future Fellowship scheme to be an effective and beneficial component of the National Competitive Grants Program (NCGP) that enables the ARC to achieve its outcomes.  Mid-career researchers often face uncertain employment circumstances. Many face employment in short term, casual positions increasing the risk that they will either leave the research profession or pursue opportunities overseas. The Future Fellowships scheme was introduced to reduce these risks, build research capacity and support excellent research.

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DoE:  the official line

The Department of Education says the package of reforms announced by the Government in the 2014-15 Budget, most of which are enabled by the Reform Bill, aims to spread opportunity to more students, including disadvantaged and rural and regional students, equip Australian universities to face the challenges of the twenty first century and ensure Australia is not left behind by intensifying global competition and new technology.

The Reform Bill aims to create opportunities and choice for students through expansion of the demand driven funding system to sub-bachelor places at all institutions and bachelor level places at private universities and non-university higher education providers registered by the Tertiary Education Quality and Standards Agency (TEQSA). It will also create a new Commonwealth Scholarship Scheme to assist disadvantaged higher education students with the cost of their study. Higher education institutions will be required to allocate one in every five dollars of additional revenue raised from student contributions to this new scheme.

The proposed reforms aim to provide the opportunity for more students to access the right type of higher education for their personal circumstances, with a greater number and a wider diversity of study options for students, including at the sub-bachelor level.

The Reform Bill will give higher education providers more freedom to work to their strengths and respond to the changing economic and social environments in which they operate. Institutions will be able to make independent choices about the courses they offer, the fees they charge, the teaching methods they use, the scholarships they provide and the other support services they provide. This will enable institutions to access the resources they need to deliver world class education, ensuring Australia is not left behind at a time of rising performance by universities around the world.

The Higher Education Loan Programme (HELP) will be maintained, meaning that eligible students still need not pay a cent up front for the cost of their tuition, and the loan need not be repaid until the student earns over an estimated $50,638 in 2016-17. Students will benefit from the removal of the HELP student loan fee of 25 per cent for FEE-HELP and 20 per cent for VET FEE-HELP, and removal of the FEE-HELP lifetime limit. To maintain the sustainability of HELP, the indexation rate for HELP  debts will be changed to reflect the cost of Government borrowings (10 year bond rate), to a maximum annual rate of six per cent.

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BCA:  almost right but modifications needed

The Business Council of Australia (BCA)  says that, on balance, the reform package creates the right platform to build the higher education sector we need for the future by:BCA

  • Introducing market mechanisms of competition, choice and deregulated fees, which should lead to innovation, differentiation and
  • Extending uncapped funding to private providers, which will allow them to offer more customised education products, such as work-based learning or direct pathways into employment, in the government-subsidised This will benefit students, employers and the sector more broadly.
  • Extending uncapped funding to diplomas, advanced diplomas and associate This demonstrates the value of these qualifications in their own right. It brings them to an equal footing with undergraduate qualifications in terms of their importance to the labour market.
  •  Maintaining HECS for all.
  • Maintaining a strong focus on access, fairness and equity by expanding uncapped funding to diplomas, advanced diplomas and associate degrees, and introducing the new Commonwealth Scholarship.
  • Establishing transition arrangements for students and

Taken together, these changes will mean institutions focus on their strengths, which will lead to more responsive and flexible providers. It should also result in a sector that is more dynamic and offers greater differentiation and specialisation.

The extension of uncapped funding to private higher education providers, and to diplomas, advanced diplomas and associate degrees is a fundamental component of the package. The addition of new providers and courses to the uncapped funding market creates the environment for competition where fees can be deregulated. These two changes will work together and therefore need to be implemented at the same time.

While supporting the overall intent of the package, BCA says there are three areas that require additional work:

  • market design, including the transition arrangements for small and medium providers – BCA recommends the government establish an oversight role to monitor the market to minimise the potential for long-term costs to government, overpricing and poor value for money and recommends it intervene, if necessary, in thin
  • the need for more effective market information – BCA recommends the government identify and implement a way to significantly improve market information in the transition to the introduction of the new model in
  • the appropriateness of the indexation rate – BCA recommends the government adopt an indexation approach that removes the inequities associated with the bond rate while limiting the potential long-term costs to  government.

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TDA:  almost right but modifications needed

TAFE Directors Australia (TDA)  submits that  the reforms proposed in the Bill will not only address the current inequitable situation that blocks Commonwealth subsidies to TAFE students, they will stimulate broader choice, innovation and diversity across the tertiary sector. This will have significant flow on effects for Australia’s industries, enterprises and workforce productivity and importantly, will enhance the relevance of Australia’s tertiary education in our Asia-pacific region. The reforms will also bring greater alignment with many of our major international higher education competitors.

TDA makes three recommendations:

  1. The Committee support the expansion of the demand driven system to non-university higher education providers and sub-bachelor degree programs in order to address funding inequities in the current This reform will have significant flow on effects for Australia’s industries, workforce productivity and Australia’s standing in international tertiary education markets;
  2. The Committee support the establishment of a Commonwealth Scholarship Scheme based on clear principles that stipulate how scholarship monies will be distributed;
  3. The Committee review the implications to students should the 10 year government bond rate be applied to their Higher Education Loan Program (HELP) TDA prefers alternatives approaches such as the hybrid of indexation and a loan surcharge on HELP loans proposed by Professor Bruce Chapman and Timothy Higgins.

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Griffith: outer urban unis face similar challenges to regionals

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Griffith University supports the submissions made by Universities Australia and Innovative Research Universities and offers the following additional comments.

The policy framework for the proposed new arrangements contained in the Regulation Impact Statement argues the case for correcting “market failure”. Economic considerations are central to a coherent public policy framework, but an effective and efficient higher education system is more than a function of market forces.

A balanced regulatory framework should promote business efficiencies in the internal management of institutions and in the relationship between regulators and providers. This should not be overlooked in the current debate about fee deregulation and related matters.

Special provision for designated regional institutions could overlook the situation of outer- metropolitan universities, often with multiple campuses, that face similar difficulties.

Griffith, for example, has among the highest numbers nationally of disadvantaged students in its five campuses spread over some 80 kilometres in southeast Queensland. This is a region containing areas of high growth, inadequate infrastructure provision and social disadvantage that are at least as severe as some designated regional areas.  The current narrow definition of “regional” is not the only synonym for relative disadvantage nor a simple function of distance from a State capital CBD.

If there are to be any special funding arrangements for regional institutions in a deregulated system, Griffith strongly urges appropriate consideration for outer-metropolitan universities.

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Field: extension of funding needs to be more equitable and market sensitive

The reforms proposed in the Bill are significant and will make a profound difference to the higher education sector. In their current form they will bring greater equity to Claire Field & Associatesnon-university higher education students. With minor modifications the reforms will provide greater student benefit, strengthen the higher education system by encouraging institutions to deliver a wider range of specialist, high quality programs, and ensure a maximum return on public investment in the sector.

The recommended funding rate in the Bill of 70% for students at NUHEPs is too low.  It is notable that the detailed analysis of teaching and learning costs undertaken in the year long Lomax Smith Base Funding Review3  recommended private providers should receive 90%.

until the new market arrangements are settled, there are likely to be insufficient mechanisms in the reforms to guard against excessive fee increases.

The design of the  scholarship scheme will require many private providers to increase their fees in the first year of the reforms merely to avoid making a loss.

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NUS: bill so flawed it should be rejected entirely

NUS logoThe National Union of Students (NUS) is not opposed to every measure in the Bill but is steadfastly  opposed to its core proposals of tuition fee deregulation, the application of bond market rates of interest to HELP debts and postgraduate research training fees.

Due to study debt aversion these measures will undermine access for many potential low SES, rural and mature age students.  Graduates will be facing repayments of over $100,000, which some will be repaying over a lifetime. There are also many broader social and economic consequences of these debts that have barely been raised in the public debate so far such as its impact on first home ownership, savings, entrepreneurialism and also the low rates of private return for Australian graduates compared to other OECD countries.

The Bradley Review of Higher Education recommended that the base funding for teaching should be increased by 10% and the Base Funding Review’s findings about widespread underfunding of many disciplines. Fee deregulation, while seen by many as providing a quick funding fix, will not serve the long-term interests of Australia.  Instead we need a funding system that is premised on affordable life-long earning that will be even more necessary for the high skill labour markets of Australia’s future.

NUS urges senators to vote down this bill in its entirety.

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CAPA: reforms would profound damage research capability

The Higher Education and Research Reform Amendment Bill if passed would hold damaging implications for the postgraduate and higher degree by research community, CAPAand in turn, Australia’s research workforce and future academic community. It would also have profound ramifications for students from low-SES, remote and regional, first- in-family, diverse equity, Aboriginal, and Torres Strait Islander backgrounds. We provide you with this feedback having been entrusted with it by the thousands of members of the postgraduate and research community who have engaged with our response to the Budget 2014-15 so far, and we hope that you will carry it forward and make a recommendation that reflects the grave concerns of the postgraduate and research student community.

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UoW: prospect of reforms already having equity impacts

Uni WollThe evolution of the demand driven system has created opportunity for most sections of the Australian population and it is  important  that  any  future  changes  do  not  negatively impact on the choice of opportunity our school leavers see before them.  Getting  these policy levers right is no easy task and UOW’s internal analysis is already indicating the impact of uncertainty on the decisions of potential students for 2015. As  of  mid-September, the NSW Tertiary Admission Centre (UAC) data is showing a fall in school Leaver participation for  2015  from  the  non-metropolitan areas,  demand  from  the  Hunter is down 8%, Wollongong 14%,  North Coast 14%, Central West 23%, Murray 16%, South Coast 12%, compared to the same time last year.  Potential students from more  affluent areas are currently appearing less impacted by the uncertainty as demand from Northern Sydney, Central Sydney and Western  Sydney out  to  Parramatta is stable.  As such, the University of Wollongong asks the Committee to seriously  consider  the following:

  •  The appropriateness of the mix of funding between Commonwealth Grants  and individuals. Allowing changes in this mix for the more price-sensitive would ensure Low socioeconomic background students are provided the opportunities to become the well-qualified graduates on whom our future economy depends.
  • With the deregulation of student fees there has been some suggestion of adding a new fee cap to ensure students are not burdened by ballooning This measure would be contrary to the objective of fee competition and indeed risks adding a price guide to the market. It is an unnecessary step, as institutions who charge excessive fees will simply be unable to compete in an open tertiary education environment.
  • The scale of  the  proposed  cut  to  the  Government’s contribution  is likely to  severely  impede  the  financial   circumstances   of  some universities,  which  would  in turn  flow  on to  the  quality  of  education  provided  to    It is highly unlikely that the scale of genuine efficiencies required to meet this  funding  cut  can be found  within  the  timeframe  required.
  • Under the proposed repayment methods students will undoubtedly be responsible for a greater portion of the costs of higher The impact of this will be very different between genders and locations and in fact may drive graduates away from employment in socially valuable occupations or regional areas, which is incongruent with other objectives of the Government. By considering a more modest interest rate or revisiting some of the debt forgiveness proposals, the impact of these changes will be more equitable across our society.

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Evocca: students need “skin in the game”Evocca

Evocca welcomes reforms that make education and training more accessible and by extension, further welcomes reforms that will contribute to the ongoing financial sustainability of the Government’s contribution to higher education.

Evocca supports the intention of the Bill  for higher education students to make an increased contribution to the cost of their studies. It has been Evocca’s experience that students with ‘skin in the game’ are more committed from the outset and are more likely to finish their studies and/or find employment. Lowering the current repayment threshold for Income Contingent Loans (ICL) from $53,345 to $50,638 will go some way towards the government seeing a return on its loan sooner (and will enable slightly more student ‘skin in the game’). However, Evocca supports this threshold being lowered even further, as was suggested in the Commission of Audit, so that ICLs can continue to be offered for future students over the long term.

Similarly, in an effort to make the system more sustainable over the longer term, Evocca supports the Government’s intention to raise the ICL repayment rate in line with the Treasury 10-year bond rate, to a maximum of 6%. Indeed, while we are not advocating for the New Zealand model, it is interesting to note, by way of comparison, that in New  Zealand, students pay back their ICL at a flat rate of 12% once their income exceeds $19,084 (2012/13), in a bid to make the New Zealand ICL model sustainable.

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VU: distinctive characteristics need to be recognised and supported

VU3Victoria University supports the submission of Universities Australia to the Senate Inquiry, but goes on to make points from the perspective of a “university that  has  some very important and distinctive characteristics”.  Victoria University is  a  university with a high incidence of students from low socio-economic backgrounds, and from culturally and linguistically diverse backgrounds, and is based in the fastest growing region of Australia, the West of Melbourne. It is also a relatively new university, established in 1991, and a dual-sector university providing vocational education and training as well as higher education. The combination of these factors present particular challenges for the University, in the context of an increasingly deregulated tertiary education environment.

Amendments that need serious consideration include the following:

  1.  putting a cap on income contingent loans (or CPI-indexed loans up to a certain level, and a real interest rate above that);
  2. having a more gradual transition process to the new system;
  3. having an independent body to oversight the market to monitor and review the effect of the market design;
  4. having a structural adjustment fund to support adjustment of institutions to the new environment;
  5. increasing funding for the Higher Education Participation and Partnerships Program;
  6. developing value-added measures of the contribution of universities to students and their communities.

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