How About No Goal Posts?

As an organisation TEC has plenty of fine words. Anybody remember the “High trust, low compliance cost” boast?

Or this bold statement? “Change in the tertiary education system cannot be delivered without improving the way that we operate. As an organisation, we also need to be more responsive, relevant and flexible to ensure that we are an enabler of system change.”

But when it comes down to doing the business TEC seems determined to fail, especially when it comes to letting the hapless TEOs know how their performance is actually monitored.

Previous practice has been for TEC to move the goal posts. Now we have gone one step further down the rabbit hole, there are no goal posts. Witness this recent question to TEC and TEC’s reply.

QPlease provide details of the performance-based funding methodology and minimum threshold being applied against the 2017 SAC and YG education performance indicators?

AThe Ministry of Education is currently consulting with the sector on performance-based funding methodology to be used with 2016 and 2017 education performance indicators. We will be able to provide further details once this consultation process is finished. If you want information about the consultation process please contact the Ministry of Education.

So, folks, you don’t know how your 2016 or 2017 performance is measured and TEC won’t tell you. Go and ask the Ministry. Maybe that’s being “more responsive, relevant and flexible”.

Confirmed Enrolments and Fee Refunds

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.

Confirmed Enrolments – The Diagram

Sometimes a diagram can be useful. Hopefully this one will help understand reporting confirmed enrolments.

Confirmed Enrolment

Same old same old

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.


Confirmed Enrolments

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.

  1. 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.
  2. 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.
  3. Funding condition 4.2 describes the “after” state and funding condition 7.2 describes the “before” state.
  4. 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?
  5. 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.
  6. 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.

April Single Data Return

 This post was edited on the afternoon of 7 April to reflect the fact that SDR dates had been changed at the last minute by the MoE.

It’s that time of year again. The April SDR has an extract date of 15 April and originally had to be submitted in the period from 16 April until 29 April inclusive. MoE and TEC seem to have remembered at the last minute that 29 April is a Saturday and that both Easter and ANZAC day fall in the submission period. Earlier today the period for submission was changed to be from 10 to 28 April.

Here are a couple of other things to think about in preparing for the SDR round.

1.      You must ensure that any qualification or course for which data is being reported has been approved by TEC.

2.      If you have not yet increased tuition and compulsory course cost fees for 2017, now is the time to do so up to the permissible maximum of 2%.

3.      If for any reason you need to re-submit a December 2016 SDR you must do so (with TEC’s permission) prior to 16 April.

4.      The April SDR is you last chance to submit 2016 course and qualification completions for inclusion in the published 2016 Education Performance Indicators.

On a lighter (sadder?) note this is a record year for TEC and MoE’s (mis)management of the SDR. It is the first time you will be going into the exercise without knowing from the STEO web site that your student management system has been certified. Also the SDR Manual applicable to the return was only updated on 7 April, replacing the December 2016 manual which contained misleading information.


Surprise Announcement

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.

SAC1&2 and RPL

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”.


New Models of Tertiary Education

There can’t be many people who can honestly claim to have read the Productivity Commission’s new magnum opus “New Models of Tertiary Education”. I’m certainly not one, but I did search the document for any evidence that the Commission has recognised that inadequate and sometimes inaccurate data is being collected by the agencies responsible for managing the tertiary education sector.

I did find the following comment which quickened my pulse, especially the last sentence. “Good quality assurance and good information both become more important in a tertiary education system with fewer controls on inputs, more at stake for providers, and more empowered student consumers. It is important that agency roles and responsibilities in these regards are clear.”

And I did find some mention of using data analytics to trigger academic and pastoral interventions, and making smarter use of data especially in relation to collecting increasingly reliable and relevant performance data. All good stuff, but I searched in vain for mention of a proper replacement of our old friend the Single Data Return.

This elephant still sits stubbornly in the room meaning, ironically, that the Commission itself would not have had all the information it required to do its job.

TEC Funding Conditions/Confusions

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.