This is the first of what will be regular Tertiary Education Commission (the TEC) monitoring updates. We gather a range of information about common issues or trends through our monitoring activities. At the TEC, we’re committed to partnering with providers. Sharing learnings from our monitoring work will help the sector build capability so we can all achieve better outcomes for learners.

We’ve made changes to how we monitor TEOs, to be more flexible and commit resources proportionately to the level of risk

To date we have been trialing and piloting new, more flexible monitoring approaches and are now pleased to confirm our new framework.

We now have three types of audits…

• Self-audits
• Desktop audits
• On-site audits.

The three levels of audit allow our monitoring activity to be better matched to the size of a TEO or the nature of any concerns we may have. Auditing provides assurance that the services we purchase from a TEO comply with our funding conditions. They may be randomly scheduled or undertaken in response to information or complaints received by the TEC.

...and have made our approach to investigations more flexible

Investigations now include both what we used to call reviews as well as investigations. What we used to call reviews will be blended into investigations. These are less tightly defined and able to respond to the levels of risk and issues identified. Investigations are no longer tied to a fixed scope of five years’ provision. We will investigate our specific concerns and if no further issues are identified, that will be the extent of the investigation. However, we do have the ability to expand the scope if needed. Our intention is to place as little burden on providers as possible, while still ensuring the interests of learners, government and the tertiary education system more broadly are protected.

We have prepared detailed guidelines to help TEOs understand our investigation process.  

Tertiary Education Commission investigation guidelines (PDF 334 KB) 

We are more focused on supporting TEOs to monitor themselves

This monitoring update is the first example of a renewed focus on sharing useful information with the sector, so that TEOs can monitor their own compliance and address issues before they require TEC intervention.

We regularly review broader issues and trends that affect the whole sector, or certain subsectors or disciplines. Findings from these will be included in future monitoring updates and help us to continue to improve our guidance to the sector.

A good example is the recent update to our guidance on Compulsory Student Services Fees (CSSF), which followed a review of the fees providers charge, the services offered, and information available to students.

Student services fees

Some suggestions for TEOs from our analysis of audits

We’ve analysed audit results from the last three years and will use our monitoring updates to share suggestions on how to prepare for an audit. Our analysis indicates that New Zealand has a robust tertiary education system, as the majority of the issues identified through TEC audits are easy to correct. Below we’ve outlined three of these issues - if you can make these small changes at your TEO, you can ensure a smoother audit.

1.  One of the most common, and easy to fix, issues our auditors run into is missing records

Having a robust student record and retention policy will make it easier for you to confirm eligibility for funding. The TEC requires that you keep records that show:

• student eligibility for funding (for instance: proof of domestic status, Ministry of Education exemptions for students under 15 years old, proof that funding is not being claimed for recognised prior learning etc)
• you have NZQA programme approvals for the courses being taught
• signed copies of student enrolment forms to verify the date of entry funding begins for these programmes.

2.  Check your subcontracting arrangements

While not a TEC funding condition, we recommend ensuring that the responsibilities of both parties are clearly set out in your subcontracting agreements. We have encountered issues where both a subcontractor and a TEO believe the other will submit completion of NZQA unit standards – without either having done so. Having clear agreements protects you, as you are ultimately accountable for the use of funding.

Reminder: all subcontracting agreements related to funded activities must be approved by the TEC, and the TEC will not fund subcontracted provision through certain funds, such as Youth Guarantee. Check with your Investment Manager if you have any questions.

3.  Ensure you can provide accurate data as it is imperative for TEC funding

While the accuracy of student information held on file and in TEOs’ Student Management Systems (SMS) is improving, you may need to implement better controls. Our suggestions include:

• implementing data checks at regular points to ensure data quality
• not having too many staff members having full access to data held in the SMS as this can lead to mistakes. Staff access should be restricted according to their needs. For example, teaching staff likely do not need full access to your SMS, but should have limited access to enter assessment results only
• ensuring you have an up to date policy to enable staff from different delivery sites and the main offices to apply enrolment procedures consistently.

The TEC is implementing the new Government’s Fees Free policy

You will already be aware that we have an information sheet for TEOs on what you need to know about the Fees Free policy. Monitoring of fees-free tertiary education will be a significant focus for the TEC in 2018. Implementation of Fees Free introduces a number of new practices for TEOs in 2018, including confirming student eligibility and reporting on fees-free enrolments. We will use the data submitted by TEOs and additional audits to ensure the policy is being implemented effectively.