To:
Secretariat
Admissions TransparencyIWG
Feedback on draft implementation plan for improving higher education admissions transparency
Equity Practitioners in Higher Education Australasia (EPHEA) welcomes the opportunity to provide feedback on the draft implementation plan for improving higher education admissions transparency.
As the national body of equity practitioners in the higher education sector we wish to ensure the continued essential work being undertaken by our members to support access and participation of disadvantaged groups into higher education. Our membership includes equity practitioners from all of Australia’s universities supporting Aboriginal and Torres Strait Islander peoples; people from low socioeconomic status backgrounds (LSES); people from regional and remote areas; people with disabilities; people from culturally and linguistically diverse backgrounds; and women in non-traditional areas.
We support the Higher Education Standards Panel’s recommendations and the Government’s commitment to these recommendations. Broadly we are in support of the implementation plan but wish to highlight some broader issues for consideration as well as address the specific consultation questions posed by the Implementation Working Group (IWG).
Broader issues discussed in the HESP recommendationsfor IWG to consider:
1)The six guiding principles for transparency of admissions policies (Recommendation 1) should take into consideration the particular needs of students from a diverse range of backgrounds and the unique challenges equity groups may have in being able to makeinformed decisions about their tertiary education options. This includes consideration of lack of cultural and social capital that both school-leavers and non school-leavers, and their parents/guardians/families may have in regard to determining appropriate pathways, and understanding and improving their eligibility for tertiary study to make informed decisions.
Removing the institutional barriers of access to higher education and compensating for the educational and financial disadvantage that students from equity groups may face is essential. Universities and Tertiary Admissions Centres (TACs) have been committed to this but improving the transparency, clarity, flexibility and ease with which students from equity groups can utilise these processes is important. Compensatory strategies such as alternative entry schemes and ‘bonuses’ are crucial in recognising disadvantage but need to be clearly articulated. Prospective students need support to be able to easily identify these opportunities, and negotiate these entry schemes without undue complexity and bureaucracy.
One of the most significant interventions supporting equity groups, particularly low socioeconomic students and students from Aboriginal and/or Torres Strait Islander backgrounds, has been the widening participation and outreach activities supported by the Higher Education Partnerships and Participation Program (HEPPP). HEPPP-funded outreach programs in every university across Australia provide key interventions aimed at improving students’ understanding of their post-school options including stimulating interest in post-school studies; assisting students to choose appropriate pathways to higher education; providing support to make tertiary study applications (school visits, explaining options, providing subsidies to pay for applications, alternative entry programs); and working with parents, teachers and communities to improve understanding of the processes. These initiatives are essential to improving the enrolments of equity target groups into higher education and need to be acknowledged and enabled as part of theimplementation plan.
2)EPHEA supports the recommendations (2, 3, 4 and 5) around a common terminology, plain language, comparable policies, and clarity around cut-offs and entry requirements. The introduction of alternative language for clarity and better alignment with the principles of equity, transparency, and fairness that should guide admissions means removing or altering the words ‘special’, ‘bonus’, ‘early’ as these imply ‘undeserved advantage inconsistent with their intent’. Introducing consistent terms such as ‘ATAR-related adjustments’ which are primarily for equity-related considerations destigmatises the circumstances for which these compensatory mechanisms were created.
When setting admissions policies and producing information/materials institutions and TACs must take into account the particular needs of prospective students and parents/guardians/families from low socioeconomic backgrounds for reasons mentioned above; people whose first language isn’t English;people who live in regional and remote areas where access to resources and technology is often limited; and providing the information in alternative formats for people with disabilities should also be a central consideration.
This clarity must also extend to the provision of clear alternative pathways to support people who may have completed non-traditional pathways to access higher education. School-leavers are taking on increasingly diverse pathways while still at school and need to have the flexibility to choose ATAR and non-ATAR entry to university. Diverse pathways are even more prominent amongst non school-leaver groups and so clear and easy to navigate pathways for both groups are important in removing unnecessary barriers to higher education.Clear recognition of prior learning and credit rules is also critical and all tertiary institutions have a responsibility to provide clear credit for prior learning, articulation and advanced standing. Recognition of prior learning is not a post-TACs choice – its part of the early decision-making prospective students make around pathways, admissions and enrolment and needs to be scoped into the implementation plan.
Apart from clear pathways school-leavers, non school-leavers, parents/guardians/families and school personnel need to be provided with tools and resources to make these choices in an informed way. The opportunity to be able to access free or low-cost quality career development in conjunction with admissions advice is instrumental. Widening participation activities where career development is embedded is part of this equation and TACS are also important in providing the appropriate resources, tools, and services to support appropriate study choices. Universities also need to provide clear about student supports such as access schemes, scholarships, and retention activities which support retention for equity groups. Clarity is required around opportunities to participate in co-curricular activities and work-integrated learning to improve employability outcomes[1].
3)TACS are an important source for students to get accurate and up-to-date information and have developed over a time a range of innovations to assist prospective students. They provide assessments for alternative and equity entry programs; access to STAT (alternative entry tests provided through all TACS); manage scholarship applications; link to career advisors; coordinate tertiary expos in major cities and regional areas; collaborating with university widening participation activities; and developing niche programs to assist cohorts. An implementation plan which supports TACs to continue this work, and provide it consistently across Australia, is an important element and some consideration needs to be given to improving supports to TACs to do this work in continued partnership with universities, widening participation programs, and schools. Issues such as access to career advisors, subsidies for STAT, and funds to support school visits and expos needs to continue to be part of the implementation plan.
TACs have a significant part to play in supporting the recommendations 6, 8, 9 and 13especially with regard to consistency of processes, standardised and comparable information and collaborating on best practice– not only with their member institutions but by sharing strategies between TACs.
Access to a centralised platform for students is useful to allow for comparisons and to explore a wide number of opportunities (recommendation 7 and 10) but state-based TACs still need to have the option to collaborate with member institutions and develop programs and initiatives which are appropriate to the needs of students at the local level.
National frameworks and indicators for recognising schools and areas of disadvantage based on socioeconomic background and regionality need to be consistent but also allow institutions to recognise the local needs of school partners and regions in their catchment where they see significant disadvantage as well as where they are working closely with local communities to lift participation e.g. partnerships and admissions processes for Aboriginal and Torres Strait Islander students; admissions programs targeting LSES students in local catchments; specialised programs that support Maori and Pasifika communities or refugees and students on humanitarian visas. Universities need to have the latitude to provide opportunities for students to access tertiary study through existing and new widening participation programs to improve participation of equity group students. A particular challenge to the implementation plan will be delay in Queensland in converting from Overall Position (OP) to ATAR which will not be fully in effect until 2019/2020. While the process is in train it will present challenges to the consistency at a national level.
4)Processes to monitor transparency and a process by which people can easily and impartially have disputes investigated (e.g. through an ombudsman or similar process) is essential to supporting prospective students having the opportunity to redress any disparities (recommendations 10, 11 and 12). These processes already exist within institutions and TACs but oversight of consistent and equitable processes through TEQSA is a positive inclusion in the implementation plan.
5)Finally EPHEA welcomes the Government’s investigation of the factors that contribute to student success, completion and attrition (recommendation 14). The more we know about how to support students to successfully complete university the better. Understanding the particular challenges for students from equity groups who, despite many personal challenges as well as significant public policy changes over time, have been increasingly enrolling and succeeding in higher education[2]. There is already significant research and practitioner experience which demonstrates best practice especially through research within universities, the National Centre for Student Equity in Higher Education (NCSEHE) and National Priorities Pool activities.
However, EPHEA cautions trying to draw conclusions about success and attrition from admissions entry standards. The ATAR is amethodology to rank students for entry to university and not a reliable indicator of success, ability or intelligence. Pervasive discussions correlating low ATARs with reduced ‘quality’ are problematic and inaccurate.Individual student success is based a wide range of academic, educational and personal factors – beyond ATARs. Admissions schemes which compensate students for financial and educational disadvantage are often targeted as problematic rather than recognising the inherent link between poverty and educational disadvantaged. Student success in not about ATARs, it’s about the right set of circumstances for individuals to be successful.
Aligning admissions policies to success and attrition is problematic. ‘Success’ is a relative term. For equity practitioners ‘success’ for students from disadvantaged backgrounds may be overcoming a range of issues to successfully complete school and gain entry; the opportunity to take an informed choice to a wider range of pathways; the chance to explore tertiary study and discover it is or isn’t their goal; to utilise pathways to move between programs and courses to find the best degree; or to successfully graduate while managing a range of difficult life circumstances. Any research into success and attrition needs to include:
-a better understanding why students leave their courses e.g. personal issues, student experience, academic preparedness
-whether students have moved on to other degree programs – and so should be removed from attrition statistics
-have some flexibility to turn partial completions into recognised sub-bachelor programs
Response toconsultation questions posed by the IWG:
6)Overall we support the implementation plan insofar as the goal is to provide clear, consistent information across institutions about application requirements, processes and outcomes, and make the process simpler for all, thereby addressing inequities experienced by equity group students.
The proposed implementation plan is ambitious and admirable given the aim is ‘best endeavours’. Having said that the implementation plan’stimelines are very tight and doesn’t give sufficient time to provide information to institutions and TACs to make some of these changes or to allow universities and TACs to forewarn prospective students of changes. Hastily making changes as a best endeavour may actually lead to further issues around promoting and introducing clear and transparent guidelines. Often changes to admissions policies need 1 to 2 years to be put on place if information that prospective students, families, career advisors and school personnel have used to make informed and accurate choices about future study options. Institutions and TACs will be able to ‘tidy up’ some anomalies and produce clearer information easily but in some areas there may need to be this 2 year lead time. Potentially there will be systems changes that institutions and TACs will need to make in this regard that require additional funds and resources beyond what is currently in place.
In an effort to improve transparency and public understanding the rush to make changes can easily cause more confusion. Greater transparency only works if there are mechanisms in place to assist prospective students and their families to navigate these changes. This may include:
-professional development for school personnel especially career advisors
-professional development for TACs and university personnel
-a strong centrally-managed promotional campaign to highlight changes
-continued close collaboration between universities and TACs
-time to re-develop marketing and widening participation activities and information to also promote these changes at the local level
-liaison with associated bodies such as the Career Industry Council of Australia, ATEND, Departments of Education, and EPHEA.
7)To this end the information sets proposed (Appendix C) may cause as much confusion as they do clarity. Again, without the appropriate resources – at school and community level, at TACs level and at institutional level it could be just as challenging for prospective students to unpack the information in the student profile information sets. All institutions already make disclaimers that the previous year’s ATAR cut-off is a guide only. Knowing what percentage of school leavers and non school-leavers were accepted to a particular course is not going to enhance an individual’s knowledge around their own circumstances. What is important that a prospective student knows there are multiple criteria for entry e.g. students can gain entry to the course on a variety of parameters such as year 12 with minimum ATAR; alternative entry scheme; work/life experience + STAT and ways to navigate a pathway to their chosen course/courses that suits their needs and goals. Students make a choice around study using a complex range of criteria beyond ATAR eligibility or QILT criteria. Issues such as location, transport, accommodation, access to scholarships, and ‘fit’ with their own work/life needs are often just as crucial to decision-making.
8)The broad grouping for basis of admission described in page 29 of the plan (recent secondary education, previous higher education study, previous vocational education, work and life experience) are overly simplistic. While providing a simple ‘at a glance’ method for seeing which courses they may be eligible for still requires students to delve into the detailed criteria. For universities reporting that students are in one of these four categories is also problematic. Students may be meeting the conditions for one course based parameters in multiple categories. As stated above (Point 2) even current Year 12s are following non-traditional pathways within school by combining traditional academic subjects with vocational education options. Year 12s are also admitted on the basis of alternative programs such as International Baccalaureates, music and dance studies, portfolios and auditions. The variation in qualifications that meet the ‘recent secondary education’ criteria is complex and the same can be said of all four categories.
Another example is where institutions may or may not use particular information about a prospective student’s academic history depending on their own admissions policy. A student who undertakes 6 months to under 1 year of tertiary study and fails may find some institutions will ignore this attempt because the degree was not a ‘like’ course or it was less than one year. This gives a student who has chosen the ‘wrong course’ to get a second chance at higher education. Alternatively, a student who has not fulfilled a pre-requisite subject via their Year 12 studies may have met this requirements via sub-bachelor or bachelor studies. To reduce the complex educational pathways students have to four broad categories is problematic and doesn’t recognise the existing tailored approach that institutions and TACs now have to provide greater flexibility to students to access higher education.
9)The common language proposed on page 32 of the plan goes some way to providing clarity around minimum entry ranks or cut-offs. But remembering that ATARs are a ‘queueing system’ institutions regularly raise or drop their ATAR to fill or limit under or over-subscribed programs. In a process where there is a minimum ATAR implemented institutions will have to think more flexibly about this and the impact on their numbers.It is a positive and transparent act to provide an ‘absolute minimum’ this means that students who apply at any time in the application process ATAR will meet minimum requirements regardless of the timing (whether early in the admissions process or in later rounds; or January or mid-year offerings).However, consideration also needs to be given for prospective students who have had adjustments on the basis of equity-related issues. Is the minimum ATAR cut-off 80 or is it 80 + adjustments? There are many universities with entry programs that are not reliant on ATAR and producing successful graduates as a result. The processes employed in many Aboriginal and Torres Strait Islander support units and a number of equity-based schemes where alternative criteria such as interviews and school recommendations are examples of where ATAR is not the primary criteria. As previously mentioned (Point 2) there is often negative connotations to the existence of equity-related bonus schemes or alternative entry programs and some reference to the fact that the minimum ATAR is inclusive of ATAR adjustments is important. Institutions need to be mindful of the inaccuracy that lowering ATARs to adjust for educational disadvantage somehow impacts quality (Point 5).Rather than reducing courses to arbitrary cut-offs is there scope to consider students who fall outside this system and assess tertiary readiness on other criteria.
To further complexify the aim of going to a national and standardised framework not all states are currently using ATAR. For example, in Queensland ATARs will not be in place until 2019/2020. As outlined in Point 3) converting the entry scores of students from both school-leaver and non school-leaver cohorts into one score is not currently possible due to state differences as well as differences in how the combination of an individual’s previous educational experiences is ranked and scored. While it is ideal to have one score by which students can determine their eligibility the calculation of that score regardless of where they are from and where they are applying too this requires considerable planning. ATARs or ATAR equivalents are based on both the individual’s educational experiences, common TACS schedules, and institutional policies that will need to be easily transferable into one national scheme and in the short timeframe proposed this will be a challenge.