EPIC: non-Māori, non-Pasifika

TEC’s EPIC template for 2019 is quite different from previous years. It omits an age focused goal (under 25 and 25+) but puts a lot more emphasis on ethnicity by introducing the concept of non-Māori, non-Pasifika.

Government and TEC’s policy is now focused on improving participation and achievement by Māori and Pasifika and therefore a means of accurately determining ethic rates is needed. With Statistics New Zealand’s move from “prioritised” to “total response” counting it is no longer possible to reliably express ethnic rates that sum to 100%.

Consider the tables below. There are 10 students.

The old “prioritised” method always resulted in being able to calculate a percentage for each ethnic group, and those percentages added to 100%.

The new “total response” method will always result in a percentage total of over 100% if any student identified with more than one ethnic group.

However when the count is binary. i.e. a student is either Maori or Pasifika if any one of their ethnicities is Maori or Pasifika, or they are non-Māori, non-Pasifika is none of their declared ethnicities is Maori or Pasifika, we once again have a total of 100%. Hence the table below for the same 10 students.


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.

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:


027 449-9187

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.

Dazed and Confused

I think I’m beginning to feel my age because I simply don’t understand the information being supplied by TEC about performance measurement.

Here is what I have found and don’t understand. Perhaps one of you can explain it to me?

  1. 2017 SAC3+ Funding Condition 8.1 (c) Criteria to be a “qualifying TEO” refers to an average 2016 course completion rate of 70%.
  2. The same 2018 SAC3+ Funding Condition refers to an average course 2017 completion rate of 70%.
  3. Historically 70% has been the basic threshold for ongoing funding. If you didn’t hit 70% in a return year (e.g. 2015) you wouldn’t receive any ongoing funding – i.e. a “zero initial allocation” would apply two years hence (that being in 2017 when 2015 was the return year). This method has been in place since 2012, albeit initially with a lower threshold.
  4. This threshold was different from the Performance Linked Funding (PLF) thresholds which could see you losing up to 5% of your funding.
  5. A TEC document circulated in October 2017 entitled “Changes to Educational Performance Indicators (EPIs) and performance-linked funding (PLF) for 2018 onwards” tells us several things:

5.1.    “There will be no PLF funding adjustments in 2018 based on 2017 (educational delivery performance data). This is because no thresholds were set for educational delivery in 2017 as the new EPI methodologies were under development and consultation. However 2017 EPI data will still be published.”

5.2.    “We are also making a small change to the definition of course completion rates following this year’s consultation process. The data used to calculate the course completion rate will now include the same students as used for the cohort-based qualification completion rate. This change will apply to 2017 performance onwards.”

  1. I have several questions. I’ll ask you first because maybe you have answers. Otherwise I guess that I will have to ask TEC and then wait, and wait, and wait ….. for answers.

6.1.    While the 2017 performance is not going to be taken into account for PLF purposes, is the modified 2017 SCC rate going to be taken into account for future initial allocations?

6.2.    If so commencing with which year?

6.3.    What are the details of the small change to the definition of the successful course completion rate from 2017?

6.4.    How many angels can dance on the head of a pin?

2018 Funding Approval Conditions – YG Reviewed

Following up on my previous post I have now reviewed TEC’s 2018 funding conditions for Youth Guarantee.

Please email me if you would like a copy of my review. If you are to use Youth Guarantee funding in 2018 I strongly suggest that you read the review. There are some very significant differences between the 2017 and 2018 conditions.

2018 Funding Approvals

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.

To Fee or Not to Fee?

This question doesn’t have quite the same ontological weight as Hamlet’s but it is a question that many providers face when rolling out new qualifications – and there is a fair bit of that happening nowadays.

When getting TEC approval for a new qualification for which fees are charged the provider must submit tuition and compulsory course cost fee amounts for approval. The fees are matched by TEC against some as yet unpublished benchmarks.

What we do know is that “Courses are assessed individually and course fee benchmarks are in turn determined individually using NZSCED code, Funding Category Code and Proposed EFTS provided.  We consider if fees proposed are consistent with fees charged for existing similar courses offered by other TEOs on a dollar per EFTS basis.  Generally, fees proposed should be in the middle of the range of fees charged by other TEOs.”

Yeah right! Have a look at the table below.

This is an actual qualification and the figures are the actual figures for two actual providers. I guess that that TEC’s process actually involves a wheel of fortune rather than any well thought out and equitable assessment.