Single Data Return – NOT

Those of us with elephantine memories will remember the advent of the Single Data Return which was glibly sold on the basis that it was going to be the one return that rules us all. The grand idea was that there would be one, and only one, reporting mechanism and that would satisfy all data collection and monitoring requirements on the part of all agencies with an interest in the Tertiary Sector.

Even now in 2018 the SDR Manual misleadingly states “The SDR provides one central point for the collection, processing and delivery of information from TEOs to education agencies.”

Over the years other reporting mechanism have been implemented. How do you report to NZQA, how do you report to StudyLink, did you use the Electronic Receipting System (ERS) developed and discarded by TEC? And now we all suffer from dealing with TEC’s Workspace 2 – the kind of reporting mechanism that was presumably designed by a spreadsheet enthusiast and is destined to be replaced.

In fairness to TEC in 2009 work was started on a replacement to the SDR. This was the Tertiary Learner Event Collection (“TLEC”) which, as the project faltered, then became the Tertiary Learner Event Project (“TLEP”), only to be abandoned in 2013 after $2.7 million had been expended and it had to be written off.

The ill-fated UIP (Unfunded International Provider) return was cobbled together from 2016 onwards by the Ministry of Education for a single purpose and without – by the Ministry’s admission – any input from TEC; although NZQA airily told us it would become a “Universal Record of Achievement”. That project must have cost well over $1 million to develop and has ongoing costs.

In addition to the millions of dollars being expended by the tertiary agencies there is of course also the compliance cost to the TEOs.

Not to be left out in the cold TEC at the end of 2016 started to hint at a replacement for the SDR to be developed from 2017 and ready for use in 2020. Several individuals from the sector were asked if they would be open to consultation in 2017. They weren’t asked and have heard nothing since.

But anyway, it did seem like it might be time to check with TEC what is occurring. So, I asked “Please can you provide me with information on any plans to replace the Single Data Return?” This very polite request – using the Official Information Act – has so far elicited the following response.

“Thank you for your email of 19 June 2018 requesting the following information:

please can you provide me with information on any plans to replace the Single Data Return?

Your request necessitates a search through a large quantity of information. In addition, the consultations necessary to make a decision on the request are such that a proper response cannot reasonably be made within the original time limit. Therefore, the TEC is extending the time limit for responding to your request  by 15 working days. The TEC will respond to your request as soon as possible but no later than 7 August 2018.”

I almost felt guilty that I could be the cause of such consternation, but I guess I’ll get over that. The scary bit about the response are these words: “the consultations necessary to make a decision on the request”.

The cynic in me, and past experience, suggests that they just mean that TEC needs another 15 days to construct a response along the lines that the information must be withheld because of commercial confidentiality; or to notify me of the vast cost to TEC of compiling a response. A cost I could not cover.

Somehow, I doubt though that they can use the cost argument since my original request elicited an invitation from TEC to meet for a briefing. The meeting would take an hour I was informed. You will understand that I had to turn down this offer because a meeting of this type with a verbal exchange of information has, in the past, proved to be far from satisfactory.

It is one thing to say something, and another to write it.

Fees Free – and so it continues

I don’t suppose that the Minster of Education reads my blog. He’s a busy person. One might say “a man with a mission”.

Unfortunately, sometimes it is better to hasten slowly, and this is particularly true of Fees Free. I suspect that the Minster is unaware of the problems affecting Fees Free and the rather messy train crash which awaits him. Regrettably you as a provider may get caught up in the crash.

TEC, which was given the task of implementing a highly complex and ill-planned scheme, was put in a wretched position, but we are nearly in June now and TEC is not helping itself or the Minister by pretending it is all under control.

How about this for example? A smallish provider reported the April SDR on 19 April. It contained enrolment data for 194 SAC3+ funded students, all of whom are consuming more than 0.5 EFTS. On 25 May a file containing 67,409 records was downloaded from Workspace2. This file purports to “contain a list of all NSNs that have been assessed as eligible for Fees Free tertiary study”. It doesn’t, because for those 67,409 records 9,519 show a status of “U – Unknown”. This type of misleading wording happens a lot with Fees Fee. It doesn’t help.

But here’s the real problem, 48 records for the 194 reported by the provider in the April SDR can be matched to records in the Workspace2 file: 47 of which show as a status of “Y- eligible” and one of which shows a status of “U – Unknown”.  Evidently then TEC is not successfully matching SDR data when determining Fees Free status. Five of the 48 students have withdrawn. They could happily wander off and enrol elsewhere thinking that they are Fees Free entitled.

48 out of 194 is certainly a high proportion but the same type of problem exists for other providers albeit to a lesser degree depending on the percentage of Fees Free students enrolling.

Another problem identified with TEC’s determination of Fees Free status is that what is shown in the Workspace2 file does not match what is on the FeesFree.govt.nz web site. Again a hapless student can be misled.

These problems and others have been drawn to TEC’s attention – some as far back as December 2017 – but have still not been addressed.

So, what does it mean?

  • A lot of extra compliance work for the providers.
  • A lot of frustration for individual students.
  • An inability by TEC to reimburse providers the correct value of fees covered by the Fees Free scheme.
  • Trouble for someone when the auditors get to work.
  • An unhappy Minister.

Now, TEC has never paid much heed to the compliance load on providers and students, as people, probably don’t figure much in TEC’s consideration. The misallocation of tax payers’ funds, on the other hand could lead to reviews and tears before bedtime.

Compliance costs, what compliance costs?

You may remember my post of 15 December.

Well it seems now that the universities are getting peeved about compliance costs, and if the universities are upset they sometimes get their way. You may recall the SDR postcode debacle. TEC said you must report two postcodes for each student. It was to be mandatory. The universities said don’t be silly, we use email. TEC buckled. It is not mandatory.

However this time the Minister has become involved; not perhaps the smartest move in these early months of his tenure. One wonders who is advising the Minister.

What is undeniable is that there is a very significant compliance cost and not only for TEC. Certainly TEC is bearing the brunt right now and even the most hard-hearted amongst feel sorry for the staff that have been given a massive tasks at very short notice. One doesn’t feel quite so much sympathy for those who are responsible for communicating TEC’s processes for handling fees free. The bold statement on 5 December that “TEC’s guidance and support systems for the sector are underway as we assist TEO’s navigate the ins and outs of fees-free” has not be born out, unless you count the sneaky emails with unreasonable demands on Friday afternoons.

The underlying problem is that TEC’s analysts and policy makers have little understanding of the reality of processing enrolments and fees. Their focus is – to some extent understandably – on meeting their own needs, even if that means shunting the compliance costs further down the line. That’s to you on an ongoing basis.

One interesting side-effect of TEC’s haste seems to be the possibility of legal challenges, so at least the lawyers will be happy.

Benchmark Fees and the TEC Course Register

If you have new courses in 2018, or you are increasing fees in 2018 in line with the AMFM, you will need to submit an SDR Course Register file with the new and changed course register records. Historically TEC advised against submitting course approval requests before and during the December SDR rounds to avoid unintended errors in their December SDRs.

Mysteriously TEC “recently discovered that TEOs can actually submit new course and qualification approvals for the New Year in December and January.” However there is some confusion about the method for doing so, and TEC has provided no specific communication about the topic.

This being the case my advice would be to make sure that your December 2017 has been successfully submitted before submitting the 2018 Course Register against the April 2018 return date.

If you have new qualifications and therefore new courses to add to the Course Register, and those courses have fees, then you may get caught up in the strange world of TEC’s benchmark fees. These seem to be a tool that TEC uses to determine whether the fees you are setting are within a set of ill- defined limits, as well as complying with AMFM policy as it relates to a fee increase.

I have been told that TEC’s decisions on fee levels use a process which is “partly automated and partly manual.” I’m thinking that the manual part has been a bit out of control. Consider that the fees approved by TEC for various TEOs for the same qualification in 2017 varied by up to 100%. Whether or not the actual fees charged were as approved is of course a different matter.

The other interesting point is that – search TEC’s web site as hard as you can – and I don’t think you will find mention of fee benchmarks. In the SAC3+ funding conditions you will find one oblique mention of “benchmark” in relation to fees, and in the new conditions released in relation to Fees Free there is no mention.

In short there is what some may call a “bugger’s muddle” around the matter of benchmark fees. So good luck if you are sending fee data via the SDR Course Register file for new qualifications for 2018. Let me know how you get on.

It could be getting a bit difficult

There do seem to be some problems with implementing Fees Free.

One thing that will certainly be going up is your compliance cost.

Fees Free – Not So Simple

It all seemed so simple but as the detail is revealed it isn’t simple at all. Indeed TEC’s communication of 11 December 2017 entitled “Fees-Free tertiary education payment for SAC level 3 and above on the New Zealand Qualifications Framework” completely gives the lie to the TEC’s earlier statement about Fees Free reporting to TEC that “Our objective is minimise additional reporting requirements.”

What a shame because it could have been simple but, instead, it is becoming a significant compliance burden. Read condition 15 in TEC’s 11 December communication and weep.

You have to feel sorry for the Minister because he is likely to catch the flak.

Clearly there are some things you need to do right now – like communicating with your students and modifying enrolment forms/student handbooks etc. Then there are some things that you can’t even start to do until TEC fills in the gaps. For example condition 15 requires you to report monthly but doesn’t tell you how.

I am compiling some material that will be useful when ensuring Fees Fee compliance. If you would like access to this material please contact me:

Richard@mercury.ac.nz

027 449-9187

2018 Funding Approval Conditions – Māori and Pasifika Trades Training reviewed

I have reviewed Māori and Pasifika Trades Training conditions and they are identical with the 2017 conditions.

Fishing Trip

Did you receive an email from TEC recently which stated “We have been working with StudyLink to monitor whether TEOs are reporting confirmed student enrolments correctly. Our analysis indicates that your organisation may have some enrolments that met the requirement for being reported under SoF 31 but were not reported in the SDR.

The email went on to say “Please review your enrolment data and if necessary, report any confirmed student enrolments that may not have been reported in August.”

Now, if TEC actually thinks you have confirmed enrolments which you have not reported, why don’t they give you the details instead of sending you off on a hunt without any guidance as to where to look?

Two of my clients have had TEC’s email and, on investigation, could not identify any unreported confirmed enrolments.

This would appear to be a case of TEC wantonly increasing your stress levels and compliance costs as part of an unnecessary fishing trip.

2018 Funding Approval Conditions – SAC1&2 Non-Competitive Reviewed

Please email me if you would like a copy of my review. If you are to use SAC1&2 Non-Competitive funding in 2018 I suggest that you read the review. There are some interesting differences between the 2017 and 2018 conditions, plus one rather obvious TEC whoopsie; such fun.

2018 Funding Approval Conditions – ILN Reviewed

  • I  have reviewed the 2018 Intensive Literacy and Numeracy (ILN) conditions and they are identical with the 2017 conditions. Yippee!