Māori and Pasifika Trades Training reviewed and found to be unchanged since 2017. 2017-12-05.
TEC has started to release 2018 funding approvals and is to be congratulated for doing so much earlier than in previous years. Each funding approval letter comes with a set of funding conditions. You will recall that the fund-specific funding conditions for 2017 were a bit of a mess with inconsistent wording, botched cutting and pasting between funds, typos and other problems.
One hopes that the 2018 conditions are more reliable but one may be disappointed. To date I have seen just one set of conditions for one specific fund (SAC 3+) and that contains an error which will require TEC to send out a new set to all the affected TEOs, plus there are a couple of other oddities which may cause someone grief.
If you would like to receive details of the problems, please send me an email.
I am keen to review the conditions for other funds, so if you care to send me just the fund-specific conditions (usually Appendix 2) for other funds (Youth Guarantee, SAC1&2 Competitive, etc.) I will compare it with the 2017 equivalent and make my comparison available to you. Don’t send me the other sections of the funding approval document: Funding Confirmation, Appendix 1, the Base Funding Confirmation, or Organisation-Specific Conditions.
I will update this post with each fund that I have reviewed, so stay tuned in.
Funds Reviewed to Date
- SAC3+ (Student Achievement Component – Provision at Level 3)
- YG (Youth Guarantee)
- SAC1&2 Competitive
- Intensive Literary and Numeracy (ILN) reviewed and found to be unchanged since 2017.
- SAC1&2 Non-Competitive
- Māori and Pasifika Trades Training reviewed and found to be unchanged since 2017.
There are a couple of things you may like to think about in relation to how TEC will measure your 2017 SCC rate for SAC3+ and SAC3&4 Competitive funding.
• TEC has yet to announce the parameters for performance linked funding for 2017.
• If ultimately such parameters are announced, and you are adversely affected by any decision that TEC made, you could have ample grounds to challenge that decision.
The first point is that TEC’s funding condition 7.3 which relates to performance linked funding still reads “There will be a performance-linked funding element that is applied to SAC provision for qualifications at Level 3 and above. We will inform you of how that will be applied separately.” To my knowledge this hasn’t happened. So, well into the 2017 year you have no knowledge of how TEC will make funding decisions for 2019 on the basis of your 2017 performance.
You will be aware that the 2016 funding condition stated “The minimum threshold for educational performance is an average course completion rate of 70% or higher” as had been the case for a number of years.
The question then is why has TEC not published any guidance and, when chased up about the matter, TEC simply passes the buck to the Ministry of Education? I quote from a TEC email: “The Ministry of Education is about to consult on PLF options.”
One answer to this question is that the inept and muddled introduction of the reporting of confirmed enrolments, and the related announcement that these would have an adverse effect on your 2017 Successful Course Completion and Student Retention rates, has left TEC unsure of its ground. Having already been hit by smart lawyers TEC may have lost its taste for confrontation.
As you will be aware providers receiving SAC3+ funding (funding codes “01” and “32”) are required to report confirmed enrolments from the August Single Data Return onwards.
TEC recently issued a document titled “Confirmed Student Enrolments – further information and guidance for implementation” which was presumably intended to assist you, and which also describes the interpretation of rules concerning fee refunds.
Though no doubt well-intended, the document seemed to confuse rather than enlighten me. Maybe that says more about me than the document!
However I took the opportunity to use the document and other material to put on paper how I think confirmed enrolments are to be reported and refunds handled.
If you would like a copy of the material I have prepared, please use the adjacent form to subscribe to my blog and I will email it to you.
If you receive TEC Now you will have received a notification on Tuesday 25 April that Conditions for 2017 for Youth Guarantee funding are available. As is often the case with TEC clicking on the link will have displayed the page that reads “Our new website – page not found”.
If however you search on the TEC website you might, if you’re lucky, come across YG funding conditions dated 24 April 2017.
Now, here’s the interesting thing. These conditions, like all YG conditions since 2012, are missing a specific condition that relates to claiming funding. This clause, which appears for other funding sources stipulates that for funding to be claimed for a student’s enrolment, that student must have “completed 10% or one month of the course for which they have enrolled, whichever is the earlier.”
Until last year the missing clause didn’t much matter because the SDR Manual included the rule (see page 30 of the 2016 SDR Manual version 1.1). However with the introduction of the concept of “confirmed enrolments” in the SDR Manual (2016 SDR Manual version 1.2) the clause that described the 10%/one month rule disappeared.
One wonders who this may affect providers receiving YG funding for the first time in 2017.
You may have read the notice sent out by TEC on 4 April titled “Confirmed Student Enrolments – further information and guidance for implementation”. It’s a classic communication: confusing, retrospective and ensuring still greater compliance effort on your part. I have a feeling that the document may need to be revised soon.
In the meantime, though, here are some initial thoughts about the notice as it affects PTEs. The notice has seven pages but only the front page is numbered, so the first thing for you to do is to complete the numbering yourself because the notes below refer to page numbers.
- Confirmed enrolments are to be reported only for enrolments funded by SAC3+ and SACL3+4 competitive provision. If you don’t have these types of funding you can stop reading.
- The test for a course enrolment to be reported as “Confirmed” is that the student has withdrawn from the course after the period during which they could have been refunded and before the enrolment could be claimed for funding. Effectively for a PTE this means the withdrawal is after 8 days for programmes longer than 3 months (or after 10% of the programme for shorter programmes) and before the student has completed 10% or 1 month of the duration of the course.
- Funding condition 4.2 describes the “after” state and funding condition 7.2 describes the “before” state.
- The term “withdrawal date” is now used by TEC to signify the end of the period during which a student may receive a refund. This is very confusing for most of us for two reasons. Firstly the Education Act carefully does not refer to a “withdrawal date”, and secondly most of us use the term “withdrawal date” to mean the date that a student withdrew which can be after the end of the period during which a student may receive a refund. Confusing?
- Note that TEC has added a section at the top of page 3 entitled “Determining when a student has withdrawn“. Read this carefully and ensure that your own withdrawal processes comply. The period which must elapse before you determine “disengagement” could be very important. If that is only 8 days or stretches out to the 10%/1 month period you will have no confirmed enrolments.
- The use of generic or sequential course enrolment dates has become more important because the balancing act between retaining fees, receiving funding, and protecting your course completion rate is now more of a challenge.
Give me a ring or send me a message if you would like to discuss these matters in more detail.
In a surprise press release the CEO of the Tertiary Education Commission today announced the replacement of the current SAC3+ funding mechanism. The Equivalent Full-Time Student (EFTS) metric will be cease to be in effect from 1 July, to be superseded by Weighted Learning Hours (WLH).
“In light of our focus on learning hours, and to ensure value for the taxpayer’s investment,” said the CEO, “we are returning to the funding mechanism used successfully by the Polytechnic sector until 1995. This was based on Weighted Student Hours.”
The press release also announced that the concept of investment plans, as a means of allocating funding, was to be replaced by a tool being developed by the Lotteries Commission. “As there is already a high degree of uncertainty for TEOs in anticipating funding, we thought this should be formalised” states the release.
TEC’s funding conditions are quite clear that you are not to use funding to deliver stuff to students which those students have already achieved. Fair enough. It’s just that the SAC1&2 Funding Conditions don’t actually spell this out. It is true that the table of contents lists section 5.9 as “Recognised prior learning” but, if you turn to that section you will see this. Something altogether different.
5.9 Students with prior qualifications
(a) Up to 10% of your enrolments for qualifications funded from the SAC1&2 (Competitive) Fund can have already achieved a qualification at Level 2 or higher on the NZQF (a prior qualification)………
Of course I have no doubt if you did claim funding for RPL, TEC would be upset and rightly so. My point is though, that notwithstanding the rather embarrassing letter of 1 March from TEC to providers notifying changes to wording, the Funding Conditions are still riddled with typos, ambiguities, redundant sections, and strange sections about “Confirmed Enrolments”.
TEC circulated a consolidated Funding Confirmation Guide in February 2017. This brought together the material that had originally been included in the funding approval letters sent out before Christmas.
This seemed like a good and useful idea but there is just one hitch. Either inadvertently or deliberately a number of changes had been made in the February version. Here’s an apparently trivial example relating to the definition of a valid domestic student.
Here’s the original:
(i) you are satisfied that the student is capable of completing the academic requirements of the programme of study or training in which the student is enrolled; or
(ii) you have ensured that the student has a school exemption certificate from the Ministry of Education; or
And here’s the changed version:
(i) you are satisfied that the student is capable of completing the academic requirements of the programme of study or training in which the student is enrolled; and
(ii) you have ensured that the student has a school exemption certificate from the Ministry of Education; and
Of course it may not be so trivial when you are audited. There are other anomalies in the consolidated document.