12May2017 Secretariat Admissions Transparency IWG C50MA7 GPO Box 9880 CANBERRA ACT 2601 Dear Professor Krause Re: Consultation on admissions transparency implementation plan Thank you for the opportunity to provide feedback on the admissions transparency implementation plan. Swinburne commends the Implementation Working Group on the paper and its intent. Swinburne supports all the recommendations outlined in the Higher Education Standards Panel (HESP) report on improving transparency in admissions, particularly those recommendations which relate to supporting students and their advisors in navigating critical information regarding future study options. This student centred approach is consistent with Swinburne's ethos. We also note and support the principle of institutional autonomy and accountability, including the responsibility of ensuring that information published is accurate. However, Swinburne has identified a number of issues which we believe need to be addressed before full implementation is possible. We therefore offer the following feedback: Timing • The document proposes a timeline that requires providers to publish information about all courses by August 2017, including detailed statistics. The 'ATAR ranges' and 'Student Profile' data requirements for each course across the non-VTAC cohorts will be challenging to source and validate in the proposed timeframe. • The proposed 'best endeavours' approach through publishing a PDF still requires the provider to collect and validate statistical information about courses. The timelines may not allow providers to collect and validate all of the required statistical information. Publishing inaccurate or incomplete information would be misleading and unlawful. • Swinburne believes an acceptable 'best endeavours' would be providing the current course level ATAR information available through VTAC (for Victorian universities), i.e. clearly-in ATAR, %-below, Yr12 numbers and Total numbers, minimum raw ATAR, median ATAR etc., with full requirements to be met in 2019. Hawthorn Campus John Street Hawthorn Victoria 3122 Australia PO Box 218 Hawthorn Victoria 3122 Australia Telephone +61 3 9214 8000 Facsimile +61 3 9818 3649 www.swinburne.edu.au ABN 13 628 586 699 CR\COS Provider 00111D Effectiveness • The document indicates that the purpose of the standardisation is to support individuals in making better informed choices about providers and courses of study. We agree that standardisation of definitions and naming systems will assist, however the volume and level of detail of the information proposed in the templates may be too extensive reducing the ability of prospective students to comprehend the critical details. • The proposal to provide quartile-based statistics for ATAR ranges may be confusing to those who are not familiar with the interpretation of statistics. This may hide the most critical statistic (lowest adjusted ATAR) which answers the common question of likelihood of acceptance. • A further example is the requirement to include details of the application, enrolment and appeals processes on each course entry. The amount of information required to guide students through these process is extensive. Providing summary or partial information into the templates may be misleading. Providing links to relevant websites would be preferable. Mode of delivery • Many providers offer courses in different modes (on-campus and online) and physical locations. The student cohorts in these modes and locations vary significantly in their previous study backgrounds and admission profiles. • Swinburne would prefer if providers were given the option to present separate information (whole of institution and course level) for each mode and/or location. This would assist in meeting the 'cohorts' information requirements of the HE Standards and would also provide more accurate representations to prospective students. Non-university higher-education providers • Given that non-university higher-education providers will not be subject to the 7.5% 'at-risk' component of their Commonwealth funding, Swinburne believes that the Department must develop some guidance on what accountability there will be for these providers around meeting requirements, and that incentives should be created to encourage adherence. Equity category students • Swinburne is concerned that equity category students who are transitioning from vocational education to undergraduate study may be disadvantaged if ATAR remains the primary entry requirement, considered above Certificate level qualifications. • Swinburne would caution against any future requirement that would report success and completion against stratified categories of students due to potential disadvantage in the future. Recommendations Recommendation 1 - Best endeavours approach Swinburne recommends a best endeavours approach that involves providing current course level ATAR information available through VTAC (for Victorian universities), with full requirements to be met in 2019. Recommendation 2 - Student choice data Swinburne supports standardisation of definitions, yet recommends that quartile-based statistics may in fact confuse students. Therefore, we recommend a more basic suite of data, and referral to relevant websites wherever possible. Recommendation 3 - Mode of delivery Swinburne recommends that providers be given the option to present separate information (whole of institution and course level) for each mode and/or location. Recommendation 4- Non-university higher-education providers Swinburne recommends that the Department develop guidance on what accountability there will be for non-university providers around meeting requirements, and that incentives should be created to encourage adherence by these providers to the standards. Thank you for the opportunity to provide feedback on the implementation plan and for the high level of consultation on these reforms to date. Should you require further clarification on any of the matters raised in this submission, please contact Professor Chris Pilgrim, Pro Vice-Chancellor (Education and Quality) at [email protected] or 03 92145231. Yours sincerely Professor Duncan Bentley Deputy Vice-Chancellor (Academic) Swinburne University of Technology
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