Consultation on proposed Rule changes

Closed 27 Apr 2018

From 12 March to 27 April 2018, the New Zealand Qualifications Authority (NZQA) consulted on proposed changes to NZQA Rules.

These changes sought to ensure that the Rules are clear, reflect operational changes, address emerging risks and enable NZQA to effectively perform its quality assurance functions.

Summary of consultation feedback

For a summary of the consultation feedback, and NZQA's response, see the:

Proposed changes

NZQA consulted on proposed changes to the following Rules:

  • NZQF Programme Approval and Accreditation Rules 2013
  • Consent to Assess against Standards on the Directory of Assessment Standards Rules 2011
  • Directory of Assessment Standards Listing and Operational Rules 2011
  • NZQF Qualification Listing and Operational Rules 2016
  • Private Training Establishment Registration Rules 2013
  • NZQF Industry Training Programme Approval Rules 2013
  • Industry Training Organisation Prescribed Quality Assurance Requirements Rules 2015
  • Quality Assurance (including External Evaluation and Review (EER)) Rules 2016
  • Student Fee Protection Rules 2013
  • NZQF Offshore Programme Delivery Rules 2012

The draft consultation document (PDF, 641KB) outlines each proposed change, reason for the change and anticipated impacts.

Consultation survey

The sector was invited to provide feedback on any of the proposed changes by completing a survey.

The survey closed on Friday 27 April 2018.

Consultation feedback on proposed changes to NZQA Rules

The following is highlights of the summary of consultation feedback NZQA received. For the full version, see the pdf (PDF, 131KB).

Number of submissions

NZQA received 88 submissions detailed in the table below:

Submission author typeNumber of responses
Peak body 1
Institutes of Technology and Polytechnics (ITPs) 11
Industry Training Organisations (ITOs) 4
Private Training Establishments (PTEs) 39
Individuals 25
Wānanga 1
Other stakeholders 7
 
Total: 88

Widely supported changes

Some proposed changes were supported by a majority of submissions with few comments.

These changes were to:

  • Directory of Assessment Standards Listing and Operational Rules 2011
  • NZQF Qualification Listing and Operational Rules 2016
  • Industry Training Organisation Prescribed Quality Assurance Requirements Rules 2015
  • Student Fee Protection Rules 2013
  • NZQA Offshore Programme Delivery Rules 2012
  • NZQF Programme Approval and Accreditation Rules 2013 - Rule 12.1, Rule 18.3, Rule 18.3(c), Table and Appendix
  • Private Training Establishment Registration Rules 2013
  • Quality Assurance (including External Evaluation and Review (EER)) Rules 2016 - Rule 18.5, Rule 13.4(a)

For full details on any of these proposed changes, see the summary of consultation feedback pdf (PDF, 131KB).

Removal of internal English language proficiency assessments (Rule 18.6)

NZQA proposed removing Rule 18.6 of the NZQF Programme Approval and Accreditation Rules 2013.

This Rule allows category 1 and 2 institutions to assess the English language proficiency of international students if the proficiency test is approved by NZQA and administered by the institution with approval.

There was a rough split in support for Rule 18.6, with a slightly higher proportion disagreeing with its proposed removal, or having reservations regarding its potential implementation.

Consultation feedback

Submissions noted concerns with the proposed change to Rule 18.6, i.e.:

  • disadvantaging providers
  • causing economic and reputational harm
  • lack of capacity at English language test centres.

Alternative suggestions included:

  • the management of internal English language proficiency assessment by a peak body or other such body, and
  • the development of a standardised New Zealand English language proficiency test to replace internal assessment.

NZQA response

After identifying significant issues with internal English language proficiency assessment, NZQA no longer has confidence that these assessments offer sufficient assurance that a student has met the requirements of Rule 18.

There is significant reputational risk to New Zealand if it fails to ensure that all international students have the appropriate level of English language proficiency.

NZQA is cognisant of the increased demand for international English language tests that will arise from the removal of Rule 18.6. While respondents primarily referred to IELTS, Appendix 2 of the Rules provides a range of tests, including TOEFL and Cambridge International English.

For full details see the summary of consultation feedback pdf (PDF, 131KB).

Requirement to keep up-to-date academic records

NZQA proposed a new rule as part of Quality Assurance (including External Evaluation and Review (EER)) Rules 2016. It requires all institutions and ITOs to keep up-to-date academic records, including assessment materials.

Submissions noted concerns about the proposed rule. It was viewed by some as excessively onerous and logistically challenging.

Submissions also asked for a transition period if the rule was implemented.

NZQA response

NZQA wants to ensure that the record keeping requirements for institutions and ITOs will be on par with those of PTEs, as set out in Rule 6.2 of the PTE Enrolment and Academic Records Rules.

NZQA will allow a transition period of three months from the time the Rule changes come into effect, 28 days after the changes are approved by the Minister. This will allow affected institutions and ITOs to review and adjust their storage facilities and practices.

For full details see the summary of consultation feedback pdf (PDF, 131KB).

Timeframe for reporting credits (Rules)

The majority of submissions supported the proposed changes.

However, there was concern that the reduced timeframe would be overly burdensome to some organisations and could cause issues with when credits are reported if assessment takes longer than 30 days.

Submissions suggested alternative reporting timeframes, from 30 working days to six months.

NZQA response

As a result of sector feedback NZQA will not make changes to Rules 10.1(b) and 12.1(b) until it has had more time to work with the sector to arrive at a suitable timeframe for reporting credits.

For full details see the summary of consultation feedback pdf (PDF, 131KB).

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