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TRANSCRIPT
Discussion Paper on the Review of VET Student Fees & Charges
December 2003
Contents
1. PURPOSE 3
2. CONTEXT 3
3. CURRENT FEES & CHARGES FRAMEWORK 5
3.1 Current Levels of VET resourcing 6
3.2 Strengths and Weaknesses of Current Policy 7
4. ISSUES GUIDING A FEES AND CHARGES FRAMEWORK 8
4.1 rin ss and participation 8 Ensu g student accity to P
9
ce ay 9 4.1.1 Capa
10 4.1.2 Concessions 4.1.3 Caps 4.1.4 Materials & Ancillary Fees 11
4.2 lici d consistency 12 Simp ty, practicality an4.2.1 Consistency Issues 12
4.3 Fee models 13
4.4 b 14 Parity etween providers 4.4.1 Alternative Delivery and Learning Methods 15
4.5 ic a VET 16 Publ nd private benefits o4.5.1 Private benefits of VET4.5.2 Public benefits of VET 17
f 16
5. NEXT STEPS 20
6. REFERENCES 21
APPENDIX ONE 23
Current Fees and Charges Policy 23
APPENDIX TWO 28
Question Template for Response 28
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1. Purpose The purpose of this discussion paper is to canvass issues that need to be considered hen developing the structure of a fees and charges framework for vocational education w
and training (VET) students in Victoria. The objectives of the fees and charges review are to:
• Conduct a fundamental review of the existing fees and charges policy and practices for government funded training delivery by TAFE Institutions, ACE providers and private providers, and
• Develop a new fees and charges policy to support Victoria’s skill development priorities and the directions outlined in the June 2002 VET Ministerial Statement Knowledge and Skills for the Innovation Economy.
2. Context The current fees and charges policy was established in 1995. It is largely based on a raditional classroom based delivery model and structured around a rate per student tcontact hour. ince this time there have been major changes at a national and state level in VET that Sforce us to question the continued usefulness of the 1995 framework. At a national level, major changes have included the introduction of New Apprenticeships, the expansion of the training market, training packages and the Australian Qualifications Training Framework. These changes have aimed to bring in a more ‘demand‐driven’ system that is more attuned to changing training needs of employers and individual students, and ensures improved national consistency. Training s increasingly delivered in a more customised manner, including being delivered to iworkplaces, online or by distance education. At the Victorian State level, the June 2002 VET Ministerial Statement Knowledge and kills for the Innovation Economy signalled key directions for vocational education and Straining. The Statement canvassed changes to VET priority setting and resource allocation processes, and assigned the Victorian Learning and Employment Skills Commission (VLESC) the responsibility for providing advice to Government on new strategies in these areas. The VLESC Report Vocational Education and Training Priorities in an Innovation Economy (July 2003) addresses these issues and highlights strategies that are eeded to implement identified government priorities, including an examination of fees nd charges. na
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The Statement highlighted the benefits that accrue to the public, individuals, businesses nd industry from VET, and the role of VET in strengthening pathways and access for astudents to make lifelong learning a reality. In addition to the major strategic changes in VET, there have also been difficulties identified with the interpretation and implementation of the current fees and charges policy. Previous reviews of the fees and charges policy have highlighted problems including ambiguous wording and issues around the linking of concessions with ommonwealth pensions. Issues raised in previous reviews have been incorporated in o this discussion paper. Ct Items t investigo be ated in the review of fees and charges include:
• The operation of the current concessions policy, including reimbursement to providers,
• Non‐tuition fees such as equipment costs and student services fees,
• Option ct hour, including examin
s for levying fees, not limited to a rate per student containg:
o differential fees by industry/occupation or qualification, o whether parity between fees in TAFE and ACE is still desirable, o the need for minimum and maximum fee levels, including caps,
• ation of the current policy, Issues regarding the interpretation and implement
• Future challenges regarding degrees in TAFE, and
• Consideration of issues of full fee paying students being educated alongside profile (government) funded students.
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3. Current Fees & Charges Framework The current fees and charges policy was established in 1995. It provides a framework or the setting of student tuition fees for government funded VET tuition in TAFE fInstitutions, ACE organisations and private training organisations. he Ministerial Directions prescribe a charging rate of $1.25 per student contact hour Twith exemptions, caps and concessions. ourses in adult education, including basic literacy and numeracy, are charged at the Cminimum rate. Concessions are granted to Commonwealth benefit recipients. Caps are placed on fees for apprentices and trainees and VCE students. Providers may grant a concession on, or xemption from, the minimum fee if they believe its collection may cause extreme ehardship. The policy provides the following restrictions on what providers may charge. A Provider must not charge fees in relation to an enrolment in a government‐funded course other
: than
(a) a tuition fee in accordance with these Conditions; or
(b) to recover no more than the actual cost of providing goods or materials to be retained by a student as his or her personal property. However, a student must be permitted to use equivalent goods or materials obtained from sources other than the institution; or
(c) to recover the actual cost of an excursion or field trip which is not a requirement of the accredited course; or
(d) in the case of a TAFE Institute or University TAFE Division a compulsory non academic fee, subscription or charge; or
(e) to recover no more than the actual cost of assessment of recognition of prior learning for the purposes of the course, but only if the assessment is conducted at
or with the cthe request, onsent, of the student. The fees and charges policy is not materially different across TAFE Institutions, government‐funded ACE providers and private providers, but is laid out in separate instruments:
• The fees and charges policy for TAFE is set out in the ‘Ministerial Directions to Councils of TAFE Institutes and Universities with TAFE Divisions’ (Schedule 1) made pursuant to the Vocational Education and Training Act 1990 (Vic).
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• The fees and charges policy for ACE is set out in the ‘Ministerial Directions to u t m a
hRegional Co ncils of Adul , Co munity nd Further Education’ (Schedule 1) made pursuant to the Adult, Community and Furt er Education Act 1991 (Vic).
• Compliance with the fees and charges policy for government‐funded private providers is required by the Performance Agreements for the Apprenticeship/Traineeship Training Program (ATTP) and the Priority Education and Training Program (PETP).
VET student tuition fees will increase in 2004 for the first time since 1995. The Minister, after consultation with the VLESC and ACFE Board, endorsed a fee rise of $0.25 per student contact hour for 2004, with a minimum and concession fee of $50 and a aximum fee of $625. This option is intended to balance the need to increase revenue to m
ensure viability of the VET sector with the need to ensure equitable access to VET. he current framework is detailed in Appendix 1. The table below summarises tuition ees in Victoria for 2004. Tf
for 200) Rate
Student Fees in Victoria ct Hour (SCH
fee
4 Student Conta $1.25Minimum/concession $50
rainees Maximum fee $625 Apprentices/t $290 VCE students $420
3.1 Current Levels of VET Resourcing
In 2002, revenue from student fees and charges generated 4 per cent of VET revenue ($49 million) in Victoria. Revenue from fees as charges is a comparatively small but important revenue source for the VET system. Revenue generation through student fees ay be particularly important for providers in rural and remote areas, who may have m
less capacity to engage in fee for service activities. The following graph outlines VET revenue in 2002.
VICTORIA 2002 Total Current Revenue $1,154.6 Million
2002 Current Funding Sourced from each State
and Territory's Appropriat ion
$570 M illion, 50%
2002 Revenue from Fee for Service, $247 M illion, 21%
2002 Current Funding Sourced from the Commonwealth/
ANTA $214 M illion, 19%
2002 Revenue from Student Fees and Charges
$49 M illion, 4%
2002 Revenue from Ancillary Trading & Other
$74 M illion, 6%
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3.2 Strengths and Weaknesses of Current Policy
The strengths and weaknesses of the current policy must be considered when deciding on any changes to the fees and charges framework. It is crucial that, in an effort to mprove the fees and charges system, we do not diminish the strengths of the current imodel. Advantages of the current system include:
• It provides consistency across TAFE, ACE and private providers,
• It is a simple model that involves the same fee per hour rate regardless of course,
• The system caters for equity and access through a set concession rate (currently $40), and
• The current system also shares some similarities with our neighbouring states, rate. as it charges on a student contact hour
Disadva t m include:ntages of he current syste
• Differing interpretations of the policy, particularly regarding concessions, calendar year charging practices, and withdrawals and refunds policies,
• The notion of paying per student contact hour can be questioned in an era of competency based training,
• The current framework provides for basically a flat student contact hour rate, regardless of:
o ortage area, whether the program is in a priority or skill sho is delivered, and where and how the trainingo private and public benefit.
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4. Issues Guiding a Fees and Charges Framework There are a variety of principles that should underpin a fees and charges policy. These principles are often competing and involve balancing individual, employer and community‐wide benefits, and providing access and equity whilst ensuring providers are able to generate sufficient revenue to remain viable. Alongside these principles are issues s interfacing with higher education and managi e issues examined in this section:
uch as targeting training to priority areas, th
• n, ng cross border issues. Listed below are
dent access and participatio• consistency,
ensuring stu
• simplicity, practicality and
• fee models,
• parity between providers,
• alternative learning and delivery methods, public and private benefits of VET, and
• the relationship between profile funded and fee‐for‐service activity. 4.1 Ensuring Student Access and Participation
VET is often fundamental to improving social and economic opportunities for individuals. As such, it is vital that fees do not present a barrier to participation, particularly for young people and disadvantaged groups in the community. In an era when the attainment of Year 12 or its VET equivalent is increasingly a prerequisite for abour market participation, it is vital to ensure that the current fee system maximises lparticipation in education and training (Watson 2003, p.8). An Australian Bureau of Statistics (ABS) survey on barriers to participation helps highlight issues that restrict student access to education. A variety of reasons were given by respondents for not being able to commence study in TAFE, including lack of time, family commitments and work reasons. However, 24 per cent of people who wished to tudy but were prevented from doing so give financial concerns as their prime reason sfor not studying (ABS 2001). TAFE caters for students from lower socio‐economic backgrounds, including early school leavers and lower paid workers seeking to re‐skill. Nationally, over a quarter of TAFE students are from low socio‐economic backgrounds, compared to 14.6 per cent of higher education students (DEST 2002, p.4). However, less TAFE students (51 per cent) earn below the median income than university students (57 per cent). This is perhaps ue to the fact that the majority of VET students (69 per cent) are employed (NCVER d2001). Several aspects must be examined when looking at access and equity issues. Broader ssues exist around capacity to pay include concessions policies and ancillary fees, ncluding materials and amenities fees. ii
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4.1.1 Capacity to Pay In Victoria, there are a higher proportion of students on lower income levels in universities than in TAFE Institutions. Although TAFE students appear to earn more than other tertiary students, the repayment of TAFE fees currently cannot be deferred and there is no access to a low interest loan scheme. However, VET student fees are round 5% of the course delivery cost compared to HECS fees which are around 30% aof the course delivery cost (Allen Consulting Group 2002, p.4). Although VET students may realise a benefit from their education in the future, they must access funds for it immediately. This may not be a concern for some students who re employed, and whose employer may be financing their studies. However, it may be a abarrier for students enrolling in entry‐level courses. A deferred payment system could prove more equitable for lengthy courses as students could pay fees via smaller instalments (as is occurring currently in some institutions), or ossibly defer paying fees until their income reaches a certain level. This may be padministratively complex to establish for short courses. Another capacity to pay issue that should be considered is the percentage of TAFE students employed at each Australian Qualifications Framework (AQF) level. Twenty‐four percent of TAFE students studying at AQF level 5 and 6 are employed full‐time and 30 per cent are employed part‐time. Forty‐four percent of students studying at AQF level 3 and 4 are employed full‐time, and 19 per cent are employed part‐time. Although students achieving higher AQF levels are likely to receive greater rewards from their tudies, it appears that their capacity to pay at the time of studying is less than students sattempting lower AQF levels. ubstantial ssues x st round students’ capacity to pay. S i e i a
How should a fee system be structured to reflect capacity to pay? • 4.1.2 Concessions round 30% of students in Victoria pay the concession rate. Providers in Victoria are
Aable to reduce or waive fees in the case of extreme hardship. There are several issues that need to be considered regarding a concessions policy. A key issue is how eligibility should be determined. Most states grant concession status to Commonwealth pensioners, Aboriginal or Torres Strait Islanders, Austudy recipients and apprentices and trainees. This creates a level of difficulty for service providers, as ommonwealth benefits are often changed. Applying the changes in benefits to Cconcessions policies can lead to inconsistencies between providers. The level of concessions varies markedly between jurisdictions. The following table summarises the concession fees levied across Australia in 2003.
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State/Territory Concession Tuition
Fee Comment
New South Wales Free to concession students
Northern Territory
Free to concession students
Queensland 75% fee concession Equates to $0.23 per in 2003, maximum fee of $715 per annum
SCH
South Australia Reduced rate bper SCH
y $0.50 Differential fees apply depending on course type. Fees are all inclusive
Western Australia
$0.64 per SCH Maximum oncession f of $441.70 per annum
c ee
Tasmania $0.50 per SCH Maaximum concession fee of $250 per nnum
AustraliaCapital T
n erritory
$0.60 per SCH
Victoria $40 (rising to $50 in Austudy rates are 50% of per SCH rate, up to half the maximum fee 2004)
Source: Watson 2003
Victoria is one of the least expensive states for concession students. Only New South Wales and Northern Territory are less expensive as they do not charge tuition fees for disadvantaged students. However, Austudy recipients in Victoria are treated differently to other concession students. Victorian Austudy recipients do not pay the concession rate, but are eligible to reduce their tuition costs by 50 per cent. Also, unlike New South Wales, students with a disability in Victoria are not automatically eligible for a concession. Students with a disability must receive a pension to gain concession status. For courses of 40 hours or less, Victoria is the most expensive state as it levies a flat fee, ather than a fee reduction as occurs in all other states. This flat fee provides an
ti students to commence longer courses. rincen ve for 4.1.3 Caps Other students, whilst not being classed as concession students, pay reduced VET fees because of a cap on the amount charged. Students undertaking courses in basic adult education, including literacy and numeracy and English as a Second Language, pay the inimum fee of $40 in 2003, rising to $50 in 2004. VCE students enrolled in VET ubjects pay $420 per year. Apprentices and Trainees pay $290 per year. ms This discussion raises several key questions around concession charges:
• Should concession rates be linked to Commonwealth benefits or should alternative eligibility criteria be used? If so, on what basis should concessions be determined?
• What form should concessions take – a reduction in the student contact hour rate, a fixed minimum or other?
• Should caps exist for basic adult education, VCE students and apprentices and trainees? If so, at what level/s should they be set?
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4.1.4 Materials & Ancillary Fees It is important to note extra fees that may be paid by students on top of tuition fees. Students may pay materials fees for consumables they purchase from a provider which are essential to their course. Students may purchase these goods from another supplier if they wish to. Either way, students keep the goods purchased. Materials fees vary reatly between courses, and can range from zero to several thousand dollars depending gon the course. An amenities and services fee (generally between $0.20 and $0.36 per student contact hour) may also be charged by TAFE Institutions. This fee relates to the provision of TAFE ervices and amenities, such as libraries and student counselling. Some institutions sapply a concession rate to the amenities fee. The extent to which additional fees are disclosed varies according to institution. Some nstitutions publish an itemised list of all likely non‐tuition fees alongside course iinformation, whilst other institutions provide no guidance on the likely additional costs. A recent study by NCVER included an examination of fees paid by students undertaking a Certificate 1 Course in Kitchen Operations (Watson 2003, pp21‐31). This course is ffered across Australia, although there are large differences in the number of electives, oand student contact hours, taken to complete the certificate. As shown in the table below, non‐tuition fees for the Certificate 1 Course in Kitchen Operations vary greatly between TAFE Institutions.
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Institution Fees in addition to tuition fees
Comment
Adelaide TAFE $113 tools of the trade (apron and knives)
Tuition fees, amenities and materials fees are capped at $1200 per annum and are included in the student contact hour rate. In effect, concession students receive a concession on all costs except tools.
Riverina TAFE NSW $165 in materials and tools
Concession students exempt from aying tuition fees. Amenities and ervices fees built in to tuition fees.ps
Tasmania TAFE $520 in uniform, knife kit, and student and
amenities fees
Gordon TAFE VIC $175 in materials fees, tools of the trade and
amenities fees
Includes $15 knife block hire
Victoria University of Technology TAFE VIC
$350 in materials fees, tools of the trade and amenities fees
Source: Watson 2003 As course charges vary, the course in kitchen operations is not reflective of the ‘average’ course cost. Whilst some courses have minimal materials, in other courses, particularly those in hospitality and visual and graphic arts, non‐tuition costs far outweigh tuition osts. Ancillary fees may be large in some courses, such as outdoor education, as they cmay include equipment hire and accommodation costs. This discussion raises several key points around materials charges and amenities fees:
• How should materials charges, ancillary fees and amenities fees be structured? For example:
o Should all fees and charges be built in to the SCH rate to give students a more accurate indication of course cost?
o Should all fees be included as part of course information to enable students to compare between courses and institutions?
o Should there be set materials and ancillary fees for identical courses across different institutions?
o Should a concession rate apply to materials, ancillary fees and services and amenities ees? f
o Should there be moderation between courses with high versus low materials costs?
o Should there be a cap on materials and ancillary charges? 4.2 Simplicity, Practicality and Consistency
Another key issue to consider when framing a fees and charges policy is simplicity and practicality. Students, both existing and potential, and service providers must be able to read and understand a fees and charges policy. It must be written in plain English, subject to minimal interpretation and auditable. Issues have been raised about the basis of charging per calendar period, in contrast to a twelve month enrolment period. Institutions may interpret and apply Ministerial Directions differently, with uncertainty existing around whether nominal or scheduled hours should be charged. Issues about he inflexibility of the charging model in only reflecting classroom based learning have lso arisen. ta
How do we ensure fees and charges are simple, practical and flexible? •
4.2.1 Consistency Issues The previous section raised the issue of the lack of consistency between providers. This occurs not only because of varying amenities fees and materials fees, but because the ame qualification can involve a varying number of modules and student contact hours s
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depending on where it is delivered. It is understandable that providers may choose to add electives to make qualifications more specialised and that amenities costs will vary between institutions. However, as
the NCVER study shows, the difference between providers is large, with hours required for core units for a Certificate 1 in Kitchen Operations varying from 116 to 139, and for course completions varying between 130 and 245 hours. This can affect how much a student is charged, as most states and territories levy tuition fees on a student contact our basis. New South Wales is an exception, as a set charge is levied based on the level f the course. ho Certificate 1 in Kitchen Operations Institution Core hours Total including electives
Murray TAFE (SA) 124 130 Gordon TAFE (VIC) 132 137 Central West (WA) 116 160 TAFE (NSW) 139 189 Spencer (SA) 124 210 Adelaide (SA) 124 245 Source: Watson 2003 his raises a key question: T• Should providers charge the same rate for identical qualifications?
4.3 Fee Models
Currently fees are set at a rate per student contact hour. There are a number of other possibl ed for a new fees and charges framework. These i
e structures that could be consider
• nclude: A differential structure by AQF level,
• A band structure based on number of hours – as was employed pre‐1995. This system was replaced, as it was deemed unfair that students who were at the low end of the band paid the same rate as students at the high end – in effect paying a higher rate per SCH,
• ernment priorities – for example offering A structure that takes account of Govreduced fees in priority areas, or
• A combination of the above elements.
Provided below is a matrix of fee models for Victoria’s two neighbouring states, South ustralia and New South Wales. These models have unique characteristics and provide ontrasting models to Victoria’s framework. Ac
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New South Wales (2004 fe hownes s )
South Australia
Method of charging
Flat tuition fee per AQF Level Includes most services & amenities fees
Fee charged er SCH based on level and field of study Fee includes all amenities and materials fee, although tools of the
p
New South Wales (2004 fees shown)
South Australia
trade may be charged Minimum fee $0 for concession, $300 for s
courses hort $0 for p ‐voc ional co ses re at ur
Maximum fee $1650 for a graduate diploma
$1200 per annum including materials fees
Concession $0 – includes ATSI and all Commonwealth benefit recipients
y and all disabled including Austudstudents
Reduction of SCH rate by $0.50
Apprentices and Trainees
$350 per annum Charged according to schedule as other students
same
$1200 maximum per annum Benefits Consistency – any student around
the State will pay $1650 tuition fee for a graduate diploma
Students are aware of their costs oon enrolling – there is n hidden
materials fee Concession students, by paying a
ratlower SCH e, receive a concession on materials Charging by field enables government to target training to priorities
Disadvantages Materials and tools costs vary greatly
The same course can have varying SCH, hence different costs, between institutions
• Should student fees be structured according to: o student contact hours o bands o AQF levels o priorities o a combination of the above, or other?
4.4 Parity between Providers
A key issue is whether all providers should be allowed or compelled to charge the same rate. TAFE, ACE and private providers are currently required to charge identical fees. Setting identical fees ensures competitive neutrality, and prevents cost distortions. Currently, providers must charge a minimum fee, unless they waive it in cases of
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hardship. Similarly, students must be charged the given rate per student contact hour. ome publicly funded providers may not wish to charge the set fee or any fee at all, and Smay choose to run training at a loss. An associated issue is around whether the student contact hour charging rate is appropriate for all courses, particularly non‐accredited courses in the ACE sector. These non‐accredited courses include preparatory courses which can lead to enrolment in accredited courses. Some of these courses are capped at the minimum charge as they fall within the definition of basic adult education, whilst others including computer courses are charged the per hour rate. However, these courses are delivered at the student’s own learning pace – rather than a set contact hour rate. Currently the charge for each student can be based on a notional number of delivery hours, or can vary according to how many ours of tuition the student requires. Should an alternative charging framework be esigned for these courses? hd
• Should fees continue to be consistent between TAFE, ACE and private providers? • Should providers be advised of ‘maximum’ rates they may levy – rather than be
compelled to levy a set rate? • In what circumstances should providers be allowed to set different fees?
Is a SCH rate applicable for self paced courses? •
4.4.1 Alternative Delivery and Learning Methods The current fees and charges policy refers to a student contact hour rate. As has been discussed in the parity between providers section, this rate may not be applicable to self‐paced learning. Equally, the same could be said of courses taught online or delivered hrough flexible learning and distance education. A fees framework must reflect modern tlearning styles. The current framework contains limited reference to the cost of recognition of prior learning (it states that students must not be charged at more than the actual cost of assessment) and does not refer to recognition of current competence. If a fees framework is aimed at supporting lifelong learning and skills development, it should nclude a cost‐effective mechanism for recognising students’ current level of chievement and competence. ia
• How do we cost new learning delivery arrangements in a fees and charges framework?
• How do we structure a framework to allow for recognition of prior learning and current competence?
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4.5 Public and Private Benefits of VET
Public and private benefits refer to the gains received from investing in a product or ervice for either individuals (private benefit) or the broader community (public sbenefit). Some products or services (including education and training) produce a mixture of public and private benefits. Individuals gain a private benefit from education and raining (eg career opportunities) and the public gains a benefit by having a more highly tskilled workforce and more cohesive society. Funding for education and training comes from a variety of private and public sources: governments, individuals, employers and taxpayers. Governments typically fund entry‐level training and transition from school to work. Education services are often not charged at market values and are often subsidised by government or other sources. t is important to consider the public and private benefits of VET in the context of a fees Iand charges policy. 4.5.1 Private benefits of VET he private benefits from investing in VET include increased employment opportunities, ncreasTi
ed wages and personal satisfaction. For example:
• Completion of a VET qualification improves the full‐time employment outcomes of graduates compared to individuals who do not undertake post‐school qualifications (Ryan, NCVER 2002, pp7‐8).
• A study by the National Centre for Vocational Education Research found that the increase in wages of employees with VET qualifications is around 10 per cent, although this varies according to qualification. This increase compounds according to AQF level completed – for example a person completing an AQF level 4 will earn around 10 per cent more than a person holding an AQF level 3 qualification. VET study that does not lead to qualifications may have little effect
on wages (Ryan, NCVER 2002, p.7).
• The return on VET qualifications is highest for those who work full‐time and study part‐time as their forgone income is relatively small, and they also obtain valuable full‐time labour market experience whilst undertaking their course
(Ryan, NCVER 2002, p.7). n the context of these private benefits, there are different clients of the VET system who nvest iIi
n different ways. For example:
• Individual students may invest in VET by enrolling in a VET program and financially supporting themselves in order to gain entry‐level training and secure employment. This investment is made through meeting direct costs such as
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tuition fees and materials charges and indirect costs such as foregone income and loss of leisure time (Haukka, Keating, Lambe 2003, p.9).
• Employers may invest in VET through sponsoring employees to participate in training, and pay for some (or all) of the costs involved with this training. In this case, the private benefits of VET may be shared between the student, who gains a
qualification, and the employer, who benefits from having a trained worker.
• Individuals may decide to enrol in VET programs to further their own interest in a particular subject area, rather than to develop vocationally oriented skills. NCVER surveys indicate approximately 12% of TAFE students are motivated to undertake training for this reason. In culture and recreation, which includes courses in music and dance, 38% of module completers and 28% of graduates
this reason.
undertake training for
VET4.5.2 Public benefits of VET is an example of a service that is subsidised as a ‘public’ good, as it brings ommunity‐wide benefits which result from assisting people to gain workforce entry,
hcand assisting those in t e workforce to further develop their skills base. There are significant public benefits to be gained from investing in VET, such as improved economic growth, reduced unemployment, improved social inclusion and re‐skilling people for the future, particularly in areas of potential skill shortages. overnment investment is needed to maintain and improve the existing skills pool, and o fund gaps in industry investment. Gt Priority setting he public benefits of VET strongly relate to the Government’s desire to direct public Tfunding towards priority industries for Victoria. The VLESC endorsed a Framework for Establishing Priorities for VET in December 2002. The Framework provides a structure for the processes of assessing the demand for training and establishing and implementing priorities for VET in Victoria based on a omprehensive range of quantitative and qualitative information sources validated
ugh a variety of sources including the Industry Training Advisory Boardscthro . The Vocational Education and Training Priorities in an Innovation Economy report was presented to the VLESC in July 2003. It is available at www.otte.vic.gov.au/employers/ResearchProgram.htm. The report discusses priorities or future resourcing of VET in Victoria, and individual industry reports highlight the fpriorities within each industry sector. The criteria u ded: sed to determine priorities inclu
• • Industry Skills Needs,
Individual Career Skills Needs, • Regional and Community Skill Needs,
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• itable participation, and Access and equ• Public Benefit.
A high priority for funding was given to training assessed as having a significant impact n the critical skills needs in the industry sector and as providing pathways into mployment. oe How could a fees and charges policy reflect public and private benefits of VET? here are several ways that a fees and charges policy could reflect the private and public Tbenefits of VET. Ideally, those areas of VET deemed to produce a greater public benefit would receive a greater public contribution through more government subsidy. Conversely, those areas here the private benefit is greater than the public benefit would receive less public w
funding, and be funded through greater private contributions. It may be appropriate for a fees policy to be focused on encouraging participation in high riority industries, and seeking greater individual or industry contributions for training n lower priority areas. pi Fee Elasticity When discussing priorities, it is also important to look issues of elasticity – whether a fee increase or reduction will actually affect a student’s willingness to enrol in a VET rogram. Research by Birsch, Koshy and Mclure from Curtin University (2002) ighlights ph
the likely affect of fee changes:
• The participation of students who do not receive concessions is likely to be more price‐sensitive than those who receive concessions,
• Demand for highly vocational courses, with discernable employment outcomes, is likely to be less price‐sensitive,
• ed Demand for specialised courses only offered in niche industries or deliver,
• and by a limited number of providers is also likely to be less price‐sensitiveDemand for adult and community education courses is price‐sensitive,
• Demand for training for leisure purposes will be more price‐sensitive. It is important to note that engaging in priority setting through altering fee levels may discourage students, especially non‐concession students, from studying lower priority courses. This will occur particularly if these courses do not have discernable mployment outcomes. Measures, such as offering merit based industry‐sponsored cholarships, may help provide equity and access in lower priority training areas. es This discussion raises several key questions around public and private benefit:
• Should the government differentiate course fees according to private and public benefit? If so, how do we assess public and private benefit?
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• Should the fee structure be changed to provide an incentive for greater participation in ‘high priority’ areas, such as, in areas of skill shortages?
o What level of funding should be provided to lower priorities? o Given the focus on attaining Year 12 or Equivalent, should courses at these
levels be less expensive? Relationship between profilefunded1 and feeforservice activity he current policy does not allow providers to run a course on a fee for service basis if Tthey are running the same course on profile funding. Allowing providers to run courses on profile funding, and run additional courses (or provide additional places) for Australian students as fee for service where there is excess demand, would enable more students to be trained and be responsive to demand, whilst maintaining existing government funded places. It would enable employers to have a greater say in the nature and timing of the delivery of training. It would also remove the currently anomalous situation, whereby if a government‐funded course is ull, an international student can access an additional place by paying full fees, but an fAustralian student is prohibited from doing so. A related issue concerns compliance training. For example, some providers run compliance training (such as forklift training) on a fee for service basis, while others ffer profile‐funded places but are limited in the number of students they can offer laces to. op This discussion raises a key question around the relationship between profile‐funded and fee‐for‐service activity:
• Should providers be able to run courses on profile funding, and run additional courses or provide additional places for Australian students on a fee for service basis?
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1 Profile funding refers to the government funding provided to TAFE institutions for the delivery of VET programs.
5. Next Steps In order to build a fees and charges framework that addresses these issues and best meets the needs of government, students and industry, we are seeking your input. Submissions from stakeholders are being sought. Submissions should address the issues aised in the discussion paper, as well as any broader concerns about the fees and rcharges framework. ou may wish to use the template provided at Appendix Two, which lists the questions Yraised in the discussion paper and provides space for response. n addition to receiving submissions, we will be holding consultations with peak Istakeholders throughout December 2003 and January 2004. ollowing consultations and analysis of submissions, a draft framework will be released Ffor comment in March 2004. t is intended that the framework will be finalised by mid 2004, and implemented on I1 January 2005.
submission to: Please send your Susan McDonald Assistant General Manager
ent Branch n and Training
Policy DevelopmDepartment of EducatioGPO Box 4367 MELBOURNE VIC 3001
edumail.vic.gov.au r email you submission to feesandchargesreview@O
Submissions are to be received by 9 February 2004. Please contact Aaron Johnstone (03 9637 2654) or Megan O’Connell (03 9637 3886) if you would like to discuss the review.
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6. References A dult, Community and Further Education Act 1991 (Vic).
Summary Statistics, National Centre for Voca Education Research, 2001 tional
n and Training Act 1990 (Vic). Vocational Educatio
rcing of Vocational Education and Training (Draft), August 2003 Access Economics, Resou llen Consulting Group, Roles and Responsibilities for Skill Development – Report to the
yment, Training and Tertiary Educa nuary 2002 AOffice of Emplo tion, Ja
n Australia (Draft),2003 ANTA MINCO, Resourcing VET i
rvey of Education and Training 2001 (Cat 8287) Australian Bureau of Statistics, Su irch, E.R, Koshy, P & McLure, M. A Policy Perspective on Vocational Education and
tern Australia, Curtin University, 2002 BTraining Fees and Participation in Wes epartment of Education & Training, Framework for Establishing Priorities for VET, D
December 2002 Department of Education & Training, Knowledge and Skills for the Innovation Economy: inisterial statement on the future directions for the Victorian vocational education and M
training system, June 2002 Department of Education & Training, Ministerial Directions to Councils of TAFE Institutes
mendment) 2003 and Universities with TAFE Divisions (A epartment of Education & Training, Ministerial Directions to Regional Councils of Adult
endment) 2003 DCommunity and Further Education (Am epartment of Education & Training, Securing Long Term Sustainable Financing for VET
t) May 2003 Din Victoria (internal working documen epartment of Education & Training, Vocational Education and Training Priorities in an D
Innovation Economy, July 2003 epartment of Innovation, Industry and Regional Development, Agenda for New D
Manufacturing, May 2003
net, Growing Victoria Together, November 2001 Department of Premier and Cabi aukka, S. Keating, J. & Lamb, S. Alternative Mechanisms to Encourage Individual ontributions to Vocational Education and Training, July 2003 HC
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Institute for Research into International Competitiveness (IRIC), Analysis of the Impact of inancial Barriers to Accessing Vocational Education and Training, Curtin University, F2002 ong, M. & Burke, G. HECS & VECS: Reflections on a Student Loans Scheme for VET, CEET
l conference, 26 August 2002 L6th Nationa elson, B. Varieties of Learning: The interface between higher education and vocational
n and training, Department of Education, Science & Training, 2002 Neducatio Ryan, C. Individual Returns to Vocational Education and Training Qualifications – their mplications for lifelong learning, National Centre for Vocational Education Research, i2002 ictorian Learning and Employment Skills Commission, Vocational Education and
iorities in an Innovation EconVTraining Pr omy, July 2003 Watson, L. What do TAFE Students Pay? National Centre for Vocational Education Research, 2003.
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APPENDIX ONE Current Fees and Charges Policy
Calculation of Tuition Fees
1.1 Subject to clauses 1.2 and 1.3, Providers must calculate each student's tuition fee on the basis of $1.25 for each enrolled subject hour of the courses or parts of courses in which the student is enrolled in any calendar year.
1.2 The minimum amount that must be charged as a tuition fee in respect of the total enrolments by a student in government-funded courses in any calendar year is $50.00.
1.3 The maximum amount that may be charged as a tuition fee in respect of the total enrolments by a student in government-funded courses in any calendar year is $625.00.
Collection of Tuition Fees
1.4 Tuition fees may be collected in respect of the relevant calendar year of enrolment only.
1.5 Providers must -
(a) not charge a tuition fee which exceeds the maximum charge; and
(b) not charge a tuition fee which is more than the minimum charge from a student entitled to exemption under these Conditions; and
(c) allow concessions on tuition fees in accordance with these Conditions.
Exemptions from Tuition Fees
1.6 A Provider must not charge a tuition fee which is more than the minimum charge in respect of a government-funded course which is in one of the following categories:
(a) Basic Adult Education courses; or
(b) Literacy or numeracy courses; or
(c) English as a Second Language courses; or
(d) Stream 2000 courses, where the principal purpose of the course is related to the matters referred to in (a) to (c) above; or
(e) Programs that specifically target one or more of the following groups:
(i) Women, where the program is designed to redress past disadvantage of women in relation to education, training or employment.
(ii) Persons who have been unemployed for the preceding twelve months.
(iii) Old-age pensioners.
(iv) Disabled persons.
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1.7 A Provider must not charge a tuition fee which is more than the minimum charge from a person who receives one of the following benefits, pensions or allowances or his/her dependent spouse or dependent child:
(a) Age Pension.
(b) Veterans' Affairs Service Pension (Age).
(c) Carer's Pension.
(d) Additional Family Payment.
(e) A Formal Training Allowance paid by the Commonwealth Department of Employment, Education and Training and Youth Affairs.
(f) Disability Support Pension.
(g) Veterans' Affairs Service Pension (Invalid).
(h) Job Search Allowance, provided that the person has not been a full-time secondary student in the preceding 16 weeks.
(i) Mature Age Allowance.
(j) Rural Adjustment Scheme.
(k) Sickness Allowance.
(l) Sole Parent's Pension.
(m) Special Benefit.
(n) Newstart Allowance.
(o) Widow's Pension.
(p) Youth Training Allowance.
(q) Partner Allowance.
1.8 A Provider must not charge -
(a) a tuition fee in relation to a student enrolled in a course at another government funded education institution who is undertaking part of that course at the Provider's institution under an arrangement between the Provider and the other education institution which provides for payment to the Provider for tuition and materials; or
(b) a tuition fee or any other fee or charge for a course, for which funding has been provided directly or indirectly by the Commonwealth or Australian National Training Authority, and where a condition of that funding prohibits the imposition of that fee or charge.
1.9 A Provider must not charge a tuition fee in relation to a student who is -
(a) a prisoner within the meaning of the Corrections Act 1986; or
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(b) an individual who is -
(i) detained (other than in weekend detention) under a sentence of detention in a youth training centre or a remand centre under the Children and Young Persons Act 1989 or the Sentencing Act 1991; or
(ii) detained (other than in weekend detention) in a youth residential centre established under the Children and Young Persons Act 1989; or
(iii) held on remand in a youth training centre established under the Children and Young Persons Act 1989; or
(iv) required to attend the course or courses concerned pursuant to a non-custodial order made under the Children and Young Persons Act 1989.
1.10 A Provider must not charge a tuition fee which is more than the minimum charge in relation to a student who is an aborigine or a Torres Strait Islander.
1.11 Where a student, who was previously eligible for an exemption or concession, becomes ineligible for the exemption or concession and then enrols in a further course or a part of a course during the year, the total tuition fee payable by the student in respect of all enrolments in that year must not exceed the maximum charge.
Tuition Fee Concessions
1.12 A Provider may grant a concession on a tuition fee where the Provider considers that its collection in full would impose extreme hardship. This may include a concession on, or exemption from, the minimum charge.
1.13 A Provider must grant a student who is in receipt of AUSTUDY a concession on the applicable tuition fee. The concession for a student on full AUSTUDY must be 50% of the applicable tuition fee. The maximum tuition fee payable by a student on full AUSTUDY in respect of all enrolments in government-funded courses in any calendar year is, therefore, $312.50. But if the student is also a dependent spouse or child of a person referred to in clause 1.7, the tuition fee payable by that student must not exceed the minimum charge.
Fees for Traineeship Programs and Apprenticeship Programs
1.14 A Provider must not charge a tuition fee which is greater than $290.00 in respect of the enrolment of a trainee in a traineeship program or an apprentice in an apprenticeship program.
1.15 If a student enrolled in a course referred to in clause 1.14 is also enrolled in another course or courses with the Provider's institution, then the total tuition fee payable by the student in respect of all enrolments in government-funded courses must not exceed the maximum charge.
Fees for VCE Students
1.16 A Provider must not charge a tuition fee in respect of enrolment in a Victorian Certificate of Education course conducted by its institution which is greater than $420.00.
1.17 If a student enrolled in a course referred to in clause 1.16 is also enrolled in another course or courses with the Provider's institution, then the total tuition fee payable by the student in respect of all enrolments in government-funded courses must not exceed the maximum charge.
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Student Services and Amenities Fees (applies in respect to TAFE Institutes and University TAFE Divisions only)
1.18 A Provider may impose a compulsory non-academic fee, subscription or charge for the purposes of providing student services and amenities. Any such fee, subscription or charge may be described as a "Compulsory Non-academic Fee, Subscription or Charge", a "Student Services and Amenities Fee" or a "General Services Fee".
1.19 If a Provider decides to impose a compulsory non-academic fee, subscription or charge, the fee, subscription or charge must be imposed, collected and expended in accordance with Division 3 of the Tertiary Education Act 1993.
1.20 If a Provider decides to impose a compulsory non-academic fee, subscription or charge, the Provider must -
(a) determine a scale of fees, subscriptions or charges to be applied; and
(b) make provision for appropriate concessions or exemptions in cases of hardship.
Statement about Compulsory Non-Academic Fees, Subscriptions or Charges (applies in respect to TAFE Institutes and University TAFE Divisions only)
1.21 A Provider must provide a copy of the statement about compulsory non-academic fees, subscriptions or charges prepared by it pursuant to section 12I of the Tertiary Education Act 1993 to the Minister within 14 days after the statement is published.
No Other Fees and Charges for Government-Funded Courses
1.22 A Provider must not charge fees in relation to an enrolment in a government-funded course other than -
(a) a tuition fee in accordance with these Conditions; or
(b) to recover no more than the actual cost of providing goods or materials to be retained by a student as his or her personal property. However, a student must be permitted to use equivalent goods or materials obtained from sources other than the institution; or
(c) to recover the actual cost of an excursion or field trip which is not a requirement of the accredited course; or
(d) in the case of a TAFE Institute or University TAFE Division a Compulsory Non- academic Fee, Subscription or Charge of the type referred to in clause 1.18 or
(e) to recover no more than the actual cost of assessment of recognition of prior learning for the purposes of the course, but only if the assessment is conducted at the request, or with the consent, of the student.
Refunds
1.23 If a student withdraws, by written notice, from a government-funded course at any time up until 4 weeks after the commencement of classes in that course, then the Provider must refund the tuition fee paid in respect of the course less the minimum charge and any other fees and charges paid by or on behalf of the student.
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1.24 If a student gives written notice to the Provider at any time up until 4 weeks after commencement of classes in a government-funded course that he or she proposes to withdraw from the course to take up a place at another educational institution and withdraws from the course within 4 weeks of the commencement of classes in that course to take up such a place, then the Provider must refund the full tuition fee and any other fees and charges paid by or on behalf of the student.
1.25 If a government-funded course is cancelled by the Provider at any time during the period of the student's enrolment, then the Provider must refund the full tuition fee, the pro-rata portion of any compulsory non-academic fee, subscription or charge and any fees for materials which have not been used in the course prior to the date of cancellation.
1.26 For the purposes of clauses 1.23, 1.24 and 1.25, if a student withdraws from only part of a course or if only part of a course is cancelled, the Provider need only refund the portion of the tuition fee and materials fee applicable to that part of the course.
1.27 If a student does not undertake tuition in part of a government-funded course because of recognised prior learning in respect of that part of the course, then the Provider must refund an amount equal to the difference between -
(a) the tuition fee which has been paid; and
(b) the tuition fee applicable in accordance with these Conditions in respect of the aggregate of the enrolled subject hours for that part of the course in which the student has undertaken or will undertake tuition in that calendar year.
1.28 Nothing in this clause prevents a Provider from granting refunds in other circumstances or of greater amounts as it sees fit.
Accounts and Records of Tuition Fees
1.29 The accounts and records kept by a Provider must clearly distinguish income and expenditure for fee-for-service courses or activities from government-funded courses or activities.
1.30 A Provider must establish and maintain a separate general ledger account to record receipt of income from tuition fees and the payment of refunds of tuition fees.
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APPENDIX TWO Question Template for Response Ensuring stude
Capacity to Pay nt access and participation
How should a fee system be structured to reflect capacity to pay? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________
________________________________________________________________________________________________ ________________ Concessions
Should concession rates be linked to Commonwealth benefits or should alternative eligibilitycriteria be used? If so, on what basis should concessions be determined? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
What form should concessions take – a reduction in the student contact hour rate, a fixedminimum or other? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
t Should caps exist for basic adult education, VCE students and apprentices and trainees? If so, awhat level/s should they be set? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
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_______________________________________________________________________________________________________________ Materials & Ancillary Fees How sh cillary fees and amenities fees ould materials charges, an be structured? For example:
• all fees and charges be built in to the SCH rate to give s u oShould t dents a m re accurate indication of course cost?
• be included as part of course courses and institutions?
Should all fees information to enable students to compare between
• re be set materials and ancillary fees for identical courses across different s?
Should theinstitution
• ssion rate apply to materi and Should a conce als, ancillary fees and services amenities fees?
• Should there be moderation between courses with high versus low materials costs? • Should there be a cap on materials and ancillary charges?
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ _ Simplicity, practicality and consistency
How do we ensure fees and charges are simple, practical and flexible? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
_________________________________________________________________________________________ ______________________ Consistency Issues Should providers charge the same rate for identical courses? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
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_______________________________________________________________________________________________________________
Fee Models
Should student fees be structured according to: o student contact hours
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
o bands
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
o AQF levels
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
o Priorities
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
o a combination of the above, or other?
_______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ __ Parity between Providers
Should fees continue to be consistent between TAFE, ACE and private providers? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
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_ ______________________________________________________________________________________________________________
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Should providers be advised of ‘maximum’ rates they may levy – rather than be compelled to levy a set rate? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
___________________________ ____________________________________________________________________________________ In what circumstances should providers be allowed to set different fees? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
_____________________________________ __________________________________________________________________________ Is a student contact hour rate applicable for self paced courses? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________
____________________________________________________________ ___________________________________________________ Alternative Delivery and Learning Methods How do we cost new learning delivery arrangements in a fees and charges framework? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ How do we structure a framework to allow for recognition of prior learning and current competence? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ _
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Public and Private Benefit
Should the government differentiate course fees according to private and public benefit? If so, how do we assess public and private benefit? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ Should reater participation in ‘high priority
the fee structure be changed to provide an incentive for g
• ’ areas, such as, in areas of skill shortages? What level of funding should be provided to lower priorities?
• Given the focus on attaining Year 12 or Equivalent, should courses at these levels be less expensive?
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ _ Relationship between profilefunded and feeforservice activity
Should providers be able to run courses on profile funding, and run additional courses or provideadditional places for Australian students on a fee for service basis? _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ __
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Additional comments
_______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ _______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ ______________________________________________________________________________________________________________ __ f you would like to be updated to with the outcomes of the review, please provide your contact Idetails: Name: ( Mr / Ms / Mrs / Dr ) _____________________________________________________________________________ Job Title: ____________________________________________________________________________________________________ Organisation: _______________________________________________________________________________________________ Address:_____________________________________________________________________________________________________
:Phone ________________________________________________ Fax: ________________________________________________ Email: _______________________________________________________________________________________________________
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