| Q1 |
Can a provider allow a student to study less than what was previously considered a ‘full-time’ load? |
| A |
Yes, a provider can allow a student to enrol in less than a ‘full-time’ load in any study period if:
- there are compassionate or compelling reasons for reducing the load;
- the reduced load is part of the provider’s intervention strategy;
- the student has studied, or plans to study, extra units in another study period;
- the student has only a few units left to complete and these do not constitute a full-time load;
- pre-requisite units are not available in that study period.
The National Code 2007 has moved away from the concept of full-time to focus on a student completing within the expected duration of the course. As a result, the National Code 2007 offers greater flexibility to manage a students’ work load. It allows students to spread their workload over more teaching periods, where a provider offers non-compulsory study periods, or to reduce their workload if they are having trouble adjusting.
This allows a student’s enrolment load to fluctuate during the course. However, the provider must ensure the student follows an enrolment pattern that will allow the student to finish within the expected duration in the normal course of events.
Note
By studying less than what used to be considered a ‘full-time’ load, a student is at risk of not completing the course within the expected duration as specified on the student’s CoE. This may require the student to catch up by studying subjects during a non-compulsory study period or by overloading in some compulsory study periods to compensate for those study periods in which the student was studying a reduced load. Alternatively, a provider may extend the duration of the student’s study as a result of the circumstances listed in Standard 9.2.
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| Q2 |
How often does the provider have to review each student’s enrolment against the CoE? |
| A |
It is up to the provider to determine how regularly it will review the student's enrolment against his or her COE. The provider needs to consider how long its study periods are, and how the frequency of monitoring may impact upon the student's ability to 'catch up' and attempt to complete the course with the expected duration.
For providers with semester long study periods, best practice would be to check each semester on the student’s progress towards completion within the expected duration.
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| Q3 |
Providers are required to have documented policies and procedures for monitoring students’ loads to ensure they will complete their course within the expected duration. What should these policies and procedures cover?
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| A |
DEEWR suggests providers’ policies and procedures should cover the following:
- how often and when the provider will check each student’s enrolment load;
- what the provider would consider to be compassionate or compelling reasons for extending the duration of the student’s study;
- what the provider will do if a student refuses to maintain an approved load;
- options students have for catching up on units missed;
- what the provider would do when it was obvious the student was not going to complete on time. (this may vary according to the reason – see next question)
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| Q4 |
If it becomes clear a student is not going to finish within the expected duration, what action should the provider take?
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| A |
Standard 9 requires that providers monitor each student’s enrolment load, take appropriate action if the student is not going to complete within the expected course duration, and retain evidence of the action taken. When a provider finds a student is not going to complete within the expected duration, the provider needs to decide how to respond.
Essentially, the provider has three options:
- encourage the student to ‘catch up’ by taking extra units; (see below)
- take steps which will enable the provider to issue a new CoE for the student; (see Question 5) or
- if the student has deliberately enrolled in a reduced load, despite the provider’s advice to the contrary, take appropriate action. (see Question 8)
As the intention of Standard 9 is that students genuinely try to complete their courses within the expected duration, the provider should encourage the student to pick up extra units during the course. These extra units could be picked up during compulsory periods, or during non-compulsory study periods where the provider offers these. However, for students who have failed some units, ‘overloading’ (taking more than a standard load in a compulsory study period) is not recommended.
If picking up extra units throughout the course is not appropriate, other actions should be considered. Different responses may be appropriate for different circumstances. The action taken does not necessarily have to involve in-depth counselling or extra study assistance.
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| Q5 |
Under what circumstances can providers extend the duration of a student’s study? |
| A |
Standard 9.2 allows providers to extend the duration of a student’s study if the extension is as the result of:
- compassionate or compelling circumstances; (see discussion below)
- the implementation of the provider’s intervention strategy for students at risk of not making satisfactory course progress; or
- deferment or suspension of study granted under Standard 13. (see Question 15)
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| Q6 |
What circumstances could be covered by ‘compassionate or compelling circumstances’? |
| A |
Compassionate or compelling circumstances are generally those beyond the control of the student and which have an impact upon the student’s course progress or wellbeing. These could include, but are not limited to:
- serious illness or injury, where a medical certificate states that the student was unable to attend classes;
- bereavement of close family members such as parents or grandparents;
- major political upheaval or natural disaster in the home country requiring emergency travel when this has impacted on the student’s studies; or
- a traumatic experience which could include:
- involvement in, or witnessing of a serious accident;
- witnessing or being the victim of a serious crime.
when this has impacted on the student. (these cases should be supported by police or psychologists’ reports)
- where the registered provider was unable to offer a pre-requisite unit; or
- inability to begin studying on the course commencement date due to delay in receiving a student visa.
These are only examples of what may be considered compassionate or compelling circumstances. Providers are asked to use their professional judgment and to assess each case on its individual merits. When determining whether compassionate or compelling circumstances exist, providers should consider documentary evidence provided to support the claim, and should keep copies of these documents in the student’s file.
Please note that, for the purposes of Standard 9, the following additional situations would be considered ‘compelling’ circumstances and could support the granting of an extension of the duration of a student’s study:
- if the student had failed occasional units throughout the course, but had not done so poorly as to be picked up by the provider’s intervention strategy for course progress. (In this case, the provider would need to document the findings of the monitoring process and the decision to extend the student’s duration of study in order to complete the course.); or
- if a student’s course progress or provider-approved study load prior to
1 July 2007 would lead to the student being unable to complete within the expected duration. (The provider will need to have evidence that the student was following the provider’s course advice.)
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| Q7 |
If a provider’s intervention strategy for a student at risk of not making satisfactory course progress leads to the student being unable to complete the course within the expected duration, what must the provider do? |
| A |
As long as the student is making satisfactory course progress, the provider must document the effect of the intervention strategy and issue the student with a CoE of a length which will enable the student to finish the course. However, if the student is not making satisfactory course progress in accordance with the provider’s course progress policies and procedures, the provider must report the student through PRISMS. For further information about course progress requirements, please see Standard 10.
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| Q8 |
If a student appears to be deliberately under-enrolling (taking less than a normal load without good reason) despite the provider’s advice, what can the provider do? |
| A |
A student who deliberately under-enrols without the provider’s approval may represent a risk for the provider’s compliance with Standard 9. The provider has two options to address this situation:
- cancel the student’s enrolment when the student refuses to enrol in an appropriate load; or
- document the student’s behaviour and, if the student requests an extension of duration of study, refuse to extend the CoE.
Any provider wishing to implement the first option must ensure ‘under-enrolment’ is listed as grounds for cancellation of enrolment – see Standard 2.1f and Standard 13. Please note that if a provider wishes to cancel a student’s enrolment under Standard 13, the provider must inform the student of its intention to cancel the student’s enrolment, and notify the student that he or she has 20 working days to access the provider’s internal complaints and appeals process.
If a provider chooses the second option, it must make the reasons for not granting a further CoE clear to the student.
Regardless of the option chosen, the provider must be able to demonstrate that it has monitored the student’s load and taken action to keep the student on track to finish within the duration.
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| Q9 |
If a provider uses an automated system to track students’ enrolment loads and issue warning letters to students regarding their loads, would this be sufficient to demonstrate monitoring for the purposes of Standard 9? |
| A |
Such a system would comply with the requirements of Standard 9 as long as the following conditions are met:
- the letter sent out to the student makes it clear to the student that he or she is not on track to finish within the expected duration and what the consequences of this could be;
- the letter also invites the student to discuss the situation with the provider; and
- the provider’s documented policies and procedures state that the provider is using an automated system and cover how the automatically generated letters will be followed up by interaction between staff and the students.
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| Q10 |
If a provider is aware that a student coming through a pathway programme has had previous study difficulties, can the provider implement an intervention strategy of a reduced study load for the first study period? |
| A |
Yes. If a provider has received notification from a pathway programme provider that a particular student has had study difficulties and may benefit from a reduced study load in the first study period, and the student agrees to such an intervention, this intervention would be allowed under the National Code 2007.
However, if a provider offered a reduced study load to all international students upon arrival, without assessment of each student’s capacity to handle a normal load, this would be contrary to the intention of Standard 9, for example that students’ loads are monitored so they finish within the expected duration in the normal course of events. If a provider believes all their international students need a reduced study load (leading to a longer than expected course duration) DEEWR would suggest that the provider reconsider its entry requirements: perhaps the requirements are too low and students who have little chance of succeeding in their studies are being accepted.
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| Q11 |
If a student studies online or by distance during non-compulsory periods and this leads to early completion of the course, what is the provider required to do? |
| A |
The provider notifies DEEWR of the student’s early completion via PRISMS. |