Being TEQSA ready – harmonising the layers of regulation

There is still work to be done in aligning practice requirements of professional healthcare bodies and the higher education standards needed to receive a degree. Many qualifications require accreditation by professional bodies and the advent of TEQSA and in particular the AQF has brought into sharp focus the different quality assurance paradigms operating within professional accreditation and higher education. In our discussion we will use healthcare as an example to demonstrate some of the significant issues. Some are more relevant to healthcare than other disciplines, but in most cases the themes and issues are common. Healthcare is delivered by a complex multi-disciplinary constellation of professionals, and has a long history of quality and safety standards monitoring. Although many healthcare disciplines already have well articulated learning outcomes with comprehensive professional accreditation, there has been little, if any, formal articulation with academic quality assurance processes. In many instances the main purpose of quality assurance within healthcare disciplines is to meet the relevant legislative requirements for registration to practice within the discipline concerned. The Australian Health Practitioner Regulation Agency (AHPRA) is the new organisation responsible for the registration and accreditation of health professions across Australia. AHPRA’s operations are governed by the Health Practitioner Regulation National Law Act 2009, which came into effect on July 1, 2010. This law means that for the first time in Australia, health professions through their boards are regulated by nationally consistent legislation. The primary role of the board is to protect the public and set standards and policies that all registered health practitioners must meet. Nationally, educational institutions strive to ensure that their processes, structures and resources enable optimum teaching, learning and assessment of students and that the standards established by licensing and accrediting bodies are met. Graduates of regulated healthcare disciplines are then understood to have attained the learning outcomes consistent with industry standards and can register to practice as professionals in their field. It should be noted at this point that healthcare professional accreditation requirements now overseen by AHPRA, although stringent in themselves, are not always the same as academic standards for learning and teaching as required by TEQSA. Clearly the two are intimately related, however, there are at times subtle differences, most often in relation to the underlying purpose. In the case of academic quality assurance, there is a focus on student learning outcomes that culminate in the award of an academic qualification at a particular level. For professional accreditation, there is a focus on student learning outcomes in relation to the requirements for safe and competent professional practice. The ways in which these two processes can be out of step is illustrated by the lack of a neat fit for many healthcare qualifications with the recently formalised AQF. Level 7 bachelor and Level 9 coursework masters programs where there has been no preceding cognate Level 7 qualification, may both meet professional entry-level requirements for registration as a healthcare practitioner in a particular discipline. As noted above, healthcare is not alone in these challenges, and they affect all qualifications offered by higher education institutions that are also subject to professional accreditation processes. In these cases there is no distinction made on the academic standards of Level 7 as compared with Level 9 qualifications. There are, however, in some cases different expectations in relation to the inputs expected (for example in accounting there is less requirement on masters degrees to have generalist content). The new higher education landscape with the introduction of TESQA, established to ensure the maintenance of standards for courses of study, includes a requirement that there are internal processes that “take account of external standards and requirements, e.g. published discipline standards, professional accreditation, input from relevant external stakeholders, and comparable standards at other higher education providers” and that the qualification awarded meets the corresponding AQF requirements. Universities are currently managing quality assurance at multiple levels including internal quality reviews, professional accreditation processes for different disciplines, and the soon to be implemented institutional TEQSA risk assessments for continued registration as a higher education provider. At a practical level, this multi-layered regulatory requirement culminates in very elaborate spreadsheets, and/or matrices that collectively may or may not add value to the purposes of verifying quality teaching practices that assure graduate learning outcomes. Anecdotally, universities are increasingly drawing upon professional accreditation processes and outcomes to inform and, at times substitute for, institutional quality assurance at the program and at times course level. TESQA acknowledges that consideration of “reliance on third parties and professional accreditation” are an important component of their risk-based approach to regulation of higher education. Therefore there is much value to be gained if higher education institutions and professional accreditation bodies confirm and articulate the intersection of learning outcomes with the professional bodies’ standards and TESQA expectations. This process of identifying and matching the overlapping goals and expectations of educational, professional and government institutions will highlight any gaps or mismatches related to teaching, learning and assessment in such a complex context, and promote a continuous dialogue between institutions, accreditation agencies and TESQA. Only a comprehensive dialogue can ensure that the three stakeholders’ values and goals will be in harmony. The enhanced dialogue that must accompany the successful implementation of these indicators will promote the consistent standard of quality graduates across the sector. It will ensure that there is alignment around the expectations of industry and the course of study offered by institutions thereby promoting greater relevancy of content, learning and assessment in courses. It will also assist in minimising the amount of re-work that needs to be undertaken by institutions in demonstrating the quality of their courses and the level of student attainment to satisfy regulators. While this work appears relatively seamless in principle the challenge is in enacting this alignment so that there is congruency across higher education requirements and demonstration of professional standards. Apart from the very different operational nature of how these two systems work (for example, in the first instance the timing and frequency of these processes rarely coincide), there also exists stark differences in what information and how data is presented for each regulatory body. The challenge is consensus about the measures that are a valid indication that students have attained a requisite standard. The outcomes of the ALTC Learning and Teaching Academic standards project, in identifying broad learning outcomes in a number of disciplines, offers a useful framework to assist in this important work of alignment. The identification of threshold learning outcomes in health for example has supported active debate across 26 different healthcare professions around the potential to better align professional accreditation and academic quality assurance processes. Further work is currently underway to develop a framework of common assessment principles and processes for embedding these threshold learning outcomes and their assessment into existing healthcare course and program organisation and documentation. This is intended to satisfy professional accreditation and academic quality assurance requirements at institutional and program level, as well as for TESQA. Amongst matters yet to be fully resolved is the question of how “risk” will be assessed, firstly by case managers and subsequently by TEQSA commissioners in relation to the assessments made by professional accreditation bodies. n Professor Maree O’Keefe is associate dean learning and teaching, Faculty of Health Sciences, University of Adelaide. Professor Amanda Henderson is a clinical academic at Griffith University, and nursing director education, Princess Alexandra Hospital. Both are ALTC discipline scholars in health, medicine and veterinary science.