Monitoring Update: January 2019

Monitoring Update: January 2019

Last updated 29 January 2019
Last updated 29 January 2019

This issue includes: our role in monitoring fees-free tertiary education, and improvements to be made based on audit analysis.

This is the third of the Tertiary Education Commission's (TEC’s) monitoring updates. We gather a range of information about common issues through our monitoring activities. At the TEC, we’re committed to partnering with tertiary education organisations, and sharing learnings from our monitoring work to help the sector build capability so we can all achieve better outcomes for learners.

Monitoring fees-free tertiary education

We – like all in the tertiary sector – have been focused on responding to some of the challenges presented by the implementation of the fees-free tertiary education policy in 2018. In 2019 we will continue our focus on ensuring both Tertiary Education Organisations (TEOs) and learners understand the system and assist them to meet their obligations under the fees-free policy.

1. False statutory declarations

Where a learner’s eligibility for fees-free tertiary education is shown as maybe, they may complete a statutory declaration to confirm they meet the criteria and be deemed eligible. In some instances, we have found learners are not eligible and the statutory declaration is false.

It is an offence under the Education Act 1989 and Crimes Act 1961 to give any altered, false, incomplete or misleading information or to make a false statement or declaration. The passing of the Education Amendment Bill 2018 introduced a new offence for learners who make false declarations and a fine of up to $5000.

To ensure the fees-free policy is effective and that government funds are used responsibly, our monitoring work includes routinely checking for potentially false declarations and taking appropriate action where they are identified.

2. Additional fees-free specific audits

We are also reviewing a number of instances where learners are accessing fees-free funding for graduate level study. While there are exceptions to qualification entry requirements and some graduate level programmes can be entered with sufficient evidence of professional experience, we are aware of some cases where learners have not declared prior study that should disqualify them from fees-free.

To ensure that learners are doing the right thing, we have written to a number of TEOs to request enrolment forms for these learners to confirm their eligibility, and will be repeating this exercise periodically.

We encourage you to check your own enrolments in a similar manner to ensure that your learners accessing fees-free are genuinely eligible. Our fees-free agreements with TEOs require you to "immediately notify us if you become aware of information that indicates that an eligible student should not have been determined by us to be eligible".

If you need to submit a list of learners whose eligibility you believe should change, you can email and ask to be sent the Fees Free TEO Change Eligibility Status template through Workspace 2. 

3. Compulsory student services fees

Compulsory student services fees (CSSFs) are included in fees-free for eligible learners. 

As part of monthly fees-free reporting, TEOs that charge a CSSF are required to attest they comply with the CSSF Ministerial Direction (PDF 34 KB) and the Education Act 1989. If our monitoring shows that a TEO is not compliant, CSSFs will not be included in Fees-Free payments for eligible learners or these may be recovered if we later find out that you have incorrectly declared their compliance. 

We monitor CSSF practices and provide regular feedback to TEOs. Please ensure you respond to this feedback, and direct any CSSF questions to

Audit activity

In our first monitoring update we made some suggestions for TEOs based on analysis of our regular audits. Here are a few suggestions for the new year to make the audit process run a lot easier.

1. Inducements / scholarships

Remember that an enrolment is not valid if it has been secured by way of an inducement.  An inducement may include a financial incentive or ongoing personal possession of physical items where they induce a student to enrol. 

This does not preclude you from offering scholarships, which can be used to reward academic achievement, aid those in need, or meet other clearly defined rationale. The full rules around scholarships are included in your funding conditions, but to ensure scholarships are not perceived as an inducement, we recommend TEOs clearly document:

  • the focus and rationale for the scholarships existence e.g. high academic achievement or a needs scholarship (to a student who would otherwise be significantly disadvantaged in accessing education)
  • the process that applicants must follow in applying for the scholarship, and
  • the review / assessment / approval process for granting a scholarship (note the final decision must be made by an independent staff member).

Please check with your Investment Manager if you need any assistance in determining whether a financial assistance offer meets the scholarship or inducement definitions. 

2.  Documenting fees-free processes

As fees-free payments are is relatively new, a number of providers haven’t yet documented or mapped the key processes. This is essential so that all roles and responsibilities are clear and appropriate delegations etc. are in place. 

3.  Expiring qualifications

A number of providers have qualifications that are closed off for new enrolments and about to expire. Remember to check the expiry dates of qualifications you are delivering to ensure that a replacement programme is in place for any nearing expiry. TEC does not fund expired qualifications.

Please contact your Investment Manager to make any changes required to your investment plans and Mix of Provision (MoP) for the replacement qualification.