Can we trust Workspace2?

I’m afraid that the answer to this question has to be “No”.

You may recall the problem I wrote about recently where the Fees-Free validation report had duplicate records for some providers and had to be re-released. That gave us a clue that all was not well in Workspace2.

The use of Workspace2 in relation to Fees-Free seems to be particularly badly affected as you will see from the following list.

  • A couple of weeks ago there were “intermittent login issues with Workspace 2”. You simply couldn’t login meaning that the template for the May Fees-Free return was not available.
  • Then when we did get the template and wanted to submit it we were told “We are experiencing intermittent login issues with Workspace 2. If you are unable to login, please contact the TEC Customer Contact Group on 0800 601 301 or email sectorhelpdesk@tec.govt.nz”.
  • The turnaround time for specific Fees-Free status requests is poor, apparently because they are processed manually and therefore only on working days.
  • The following message was sent out on 12 April. “Failure to load accurate Fees-Free data in Workspace 2. Please note: If you downloaded these files on April 10 or 11 please delete these as they contained errors. All learners that had their eligibility status changed as part of the statutory declaration process had their eligibility reset to ‘Unknown’ in error. The corrected versions are now published above.
  • Then there are the other discrepancies relating to students’ Fees-Free Eligibility status, for example: Can TEC explain how NSN nnnnnnnnnnn appears in 2018 Fees Free Consumption.csv and FeesFreeEligibility2019.CSV downloaded from Worksapce2 on 16-05-2019, but in the FeesFreeEligibility2019.CSV file the Fees Free Eligibility Flag is “Y” and not “8”? Apparently TEC cannot explain it because this question put to them on 17 May has yet to be answered.
  • The April Fees Free Multiple Providers and Cap Limit Report took a month to be released and now that it has, the report has invalid data in two columns.

Unfortunately, it is not just Workspace2 that is problematic. Have you tried to use the Search function on TEC’s web site? If you have, you were probably frustrated.

Often it doesn’t provide a response for even a straightforward search word or phrase. Other times it will provide several responses in a list but then not let you click through. I have been told that it is better just to use a Google search site specific search. For example, typing “Brendan Kelly site:tec.govt.nz” into a Google search will produce far more hits than entering “Brendan Kelly” into the search box on the TEC website. That tells you it has found 9 results but shows only 8.

Heaven protect us if any replacement for the SDR makes use of Workspace2 as a means of transferring files.

Overall it seems to me that there are a number of issues relating to TEC’s technology which come from poor business analysis, resulting in badly designed systems, further impacted by a lack of testing; but I stand to be corrected.

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.

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?

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.

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

Free Post School Education

The Labour Party Manifesto included the following item: “Labour will progressively introduce 3 years of free post-school education, allowing access to university, polytechnic or on-job training for young New Zealanders and those who have not studied before.

Now that Labour is forming a government one assumes that tucked away in a dark room on The Terrace TEC already has a team preparing material to implement the policy. This notwithstanding Labour’s view that “the Tertiary Education Commission is not operating as it was envisaged by Labour when it was established in 2003.” After all who else is going to get the policy implemented for 2018, and I assume that providers are already being asked by prospective students “Do I have to pay fees next year?

The first thing that TEC team will need to do is get guidance from the new Minister on the details of the policy. The various pre-election documents published by Labour have little detail and actually raise some pretty interesting questions. Here are just four.

  • Are PTEs covered? The Manifesto says “allowing access to university, polytechnic or on-job training for young New Zealanders and those who have not studied before” but another document published by Labour states “Accelerating the three years’ free policy, starting with one year fees free full-time equivalent for everyone starting tertiary education or training for the first time from 1 January 2018”.
  • What exactly does “fees free” mean? For example are compulsory course costs covered, or just tuition fees?
  • What is the precise definition of “formal post-school education” in the sentence “Labour will ensure that 3 years of free post-school education is available to adult learners who have not participated in formal post-school education in the past”?
  • What are 3 years? Are we talking about three years (as a period of time) or three EFTS of study being free to cover part-time study?

Anyhow, being a helpful soul, I would suggest that the TEC team consider what George Bernard Shaw said: “If history repeats itself, and the unexpected always happens, how incapable must Man be of learning from experience.” History is this case being National’s 1991 Study Right policy implemented in extreme haste and at great cost. Why, there was even a field in the SDR Course Enrolment file called “STUDYRT”. Maybe this field could be resuscitated?