Fees-Free – An Unfortunate Series of Events

Sadly, the implementation of Fees-Free is not an engaging set of novels for the younger reader however, like the books it has “a dark, mysterious feeling”. One is never sure what will happen next.

And it was whilst pondering the latest debacle (being a fail by TEC with the preparation and distribution of the “Fees Free All Enrolments and Costs Data Validation – March 2019” file), that I decided that I would try to document the set of processes used by TEC to manage Fees-Free and to enumerate the causes of its failure.

A consequence of that failure is that you cannot know how much your Fees-Free payment from TEC will be, you are likely to be non-compliant with TEC’s funding conditions, and your compliance costs will have increased significantly.

If you would like to read this sorry story, please let me know. You may even find it useful when explaining to your boss why you can’t provide an accurate report of expected income, or when dealing with auditors.

Oh, and the most recent fail with the Validation Report? Well if the problem was restricted to the two new (and undocumented) fields in this report it will cause you confusion but no hurt. Still, if TEC gets something this simple wrong you have to wonder what other unannounced problems there are with TEC’s reporting processes.

SDR Validation Error 143

If you are being a good provider and following TEC’s advice to carry out a trial SDR well in advance of the April SDR you are likely to fall foul of Validation Error 143. This error is explained as “IWI is not valid”. The problem you will find is that even if you have reported a valid Iwi code – i.e. one listed in the 2019 SDR Manual Appendix – you still get error 143.

The TEC Sector Helpdesk explains that this is a known bug and will be rectified by 5 April. When I suggested to the Helpdesk that it could lighten its load by publicising the problem, and thus reducing the number of calls it receives. This idea was not warmly welcomed, and it was suggested that the Ministry of Education was responsible for the SDR: buck passed.

Again, one is prompted to suggest that the title “Helpdesk” is something of a misnomer. TEC really doesn’t care if providers waste time proving to themselves that they are not going crazy, and that the problem lies instead with the validation software. Meaning that the providers then have to call the Helpdesk and, in all likelihood their calls won’t go through because the Helpdesk is overloaded.

In short TEC’s basic principle of “less trust, higher compliance cost” is still in effect.

How’s this for a plan

You may recall that in my last post I pointed out that the latest Youth Guarantee funding conditions are not workable.

The 2019 funding conditions 4.1 and 5.4 contradict each other.

  • 4.1 defines 1 EFTS as 100 credits.
  • 5.4 defines 1 EFTS as 120 credits.

This bizarre situation is as a result of a well-meaning but flawed policy change designed to deliver 20% more funding to YG providers. However, in practice it will significantly reduce funding for certain YG providers – especially the more successful. I know of one case where it could result in a cut of nearly 60%.

TEC has been promising to resolve the anomaly since December 2018 but, despite acknowledging that a solution is urgent, there has been no action.

This is where my good idea comes in. YG has been around since 2012. TEC took until 2018 to recognize that funding was insufficient. So, pending finding a way of delivering 20% more funding without disadvantaging some providers, TEC should make a one-time payment equal to 20% of the funding delivered to providers from 2012 to 2018.

After all TEC is very quick to claim back overfunding. It would be only fair for TEC to make up underfunding.

Can TEC Survive Much Longer?

I am not noted for my warm feelings towards TEC, but the opinion piece by Tina Nixon in the Wairarapa Times Age was a doozy and in a league of its own. You can read it yourself, but here are just a couple of samples.

  • TEC is without a doubt one of the most bureaucratic organisations I have ever interacted with, and I have worked with a few.”
  • If the TEC and its current administration survive the next year, then this government will have failed the sector.”

I can’t compete with that, but I can supply a few thoughts on TEC’s current performance – or lack thereof. In all cases the problem seems to relate to a lack of consistency on the part of policy makers. One condition/policy/requirement contradicts another.

Fees Free

Admittedly TEC had very short notice to implement the Fees Free policy but over a year has gone by and they are still struggling. The wash-up return for 2018 was initially scheduled for 11 January 2019 but after receiving a lot of complaints the return date was extended to 16 January. This is where it gets tricky because the Fees Free return will not necessarily match data to be reported through the SDR which is not due until 31 January 2019. For example, a student who started in 2018 with a programme running into 2019 notifies the provider on 17 January that they will not be returning – i.e. they are withdrawing. The provider can record that for the SDR but it will have missed the Fees Free return on 16 January.

Youth Guarantee

The 2019 funding conditions 4.1 and 5.4 contradict each other.

  • 4.1 defines 1 EFTS as 100 credits.
  • 5.4 defines 1 EFTS as 120 credits.

 Go figure!

Until this issue is resolved YG providers would be ill-advised to start enrolling students because they may inadvertently contravene other YG funding conditions.

Funding Source 03 – Domestic Full Fee Paying Students

The Single Data Return Manual states that all students must be reported through the SDR, including non-funded students. However, from the 2018 version 2 edition of the SDR manual the use of Funding Source 03 – Domestic Full Fee Paying Students was changed to exclude students validly repeating courses already completed in a TEC funded programme. This is a practice that was applied to a student who withdrew from a programme several years ago but who returns to complete it and – at their own wish and the wish of the training provider – wants to repeat the few courses already successfully completed, paying a fee to do so. There is now no funding source code that can be applied to these enrolments and so how can they be reported?