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To whom it may concern,

CDNM Response to ‘Driving Innovation, Fairness and Excellence in Australian Higher Education May 2016’

The Council of Deans of Nursing and Midwifery (Australia & New Zealand) (CDNM) (or the

‘Council’) is the peak organisation that represents the Deans and Heads of the Schools of Nursing and Midwifery in Higher Education providers that offer undergraduate and postgraduate programmes in nursing and midwifery throughout Australia and New Zealand.

Thank you for the opportunity to respond to this document. The CDNM addresses each of

the issues below.

The best options for students

• The CDNM recommends that subsidies for undergraduate and postgraduate courses be limited to public universities and TEQSA accredited higher education providers, to ensure cost management and quality assurance.

o Providing subsidies to all registered higher education providers will lead to significant growth in student numbers across the country as private providers, aim to expand their enrolments, increasing education costs. The

large number of private VET-‐sector institutions offering programs supported by VET FEE-‐HELP has seen a significant growth in taxpayer supported student debt over recent years.

Importantly, the private sector has maintained enrolment growth without

government subsidies to date.

o All education providers that receive Government subsidies must meet Australia’s higher education quality standards. With a growth in providers offering subsidized places, the higher education quality control agencies may not have the capacity to meet the need leading to a range of failures where students are seriously disadvantaged. This is a risk to the government.

o Australia has a strong international reputation in education. It is important therefore to safeguard that public investment is directed toward high quality higher education providers.

• The CDNM is concerned that a demand-‐driven system could lead to unfettered growth in nursing and midwifery student numbers increasing the burden on clinical placement providers. There is limited capacity and a natural ceiling, so to continually increase student numbers creates further stress in the system, compromising quality, which is significant problem. High student numbers may also lead to an over-‐supply of graduates into professions where there are

currently inadequate employment opportunities. We have witnessed significant numbers of new graduates being unable to find employment in their preferred specialty because of a variety of factors. More graduates will also add stress to the system. Retaining an uncapped demand-‐driven system poses potential unlimited expense to tax payers, which is not financially prudent.

• The CDNM supports the expansion of sub-‐bachelor courses as pathways to Bachelor of Nursing or Midwifery courses or leading to registration as an Enrolled Nurse as the right of individual universities to develop these types of courses to pursue their strategic directions. However, as per the CDNM’s comments above, a demand–driven system at this level will also pose a financial risk.

• The CDNM has concerns regarding subsidies for sub-‐bachelor courses as these

courses draw funds from other courses and thereby reduce the available pool for bachelor level courses and above.

• The CDNM strongly supports retention of subsidised postgraduate places, not only for programs leading to entry-‐level professional qualifications but also programs that address areas of workforce and/or societal need.

o In many nursing specialties, education is structured in a way that requires students to complete both a bachelor degree in order to be able to register with the Nursing and Midwifery Board of Australia, followed by a graduate qualification in the desired specialty, for example, intensive care or mental health in order to practice in the specialty area. These students undertaking postgraduate study do so to meet workforce needs and for professional development. These PG courses are in reality preparation for practice. Moreover, these courses have significant community benefit in that they address a professional discipline that has a lower salary scale and high demand for skills.

• The CDNM recommends that universities receive government funded PG places to

support nursing and midwifery programs that focus on areas of workforce/societal need.

• The CDNM supports a time limited learning entitlement up to ten years. This should not apply to RTS programs such as PhD and professional doctorates.

• The CDNM does not support a demand driven system. We have found that reducing subsidies significantly lowers the uptake of PG places by nursing and midwifery students.

• The CDNM supports additional places for skills deepening in the broad remit of STEMM for nursing and midwifery programs as science and evidence-‐based professions.

Improving support for disadvantaged students

• Nursing and midwifery courses draw a number of students from disadvantaged backgrounds. Scholarships (or potentially CGS places for sub-‐degree tertiary preparation programs for students who meet the criteria of “disadvantaged”) would be of great benefit. Universities have reported considerable success in enabling entry to higher education for students from disadvantaged backgrounds who would not otherwise have attempted further education, through

implementing HEPP-‐supported tertiary preparation/pathway programs. A funding scheme to allow this work to continue and/or grow would be welcomed.

• Nursing and Midwifery educational opportunities are often viewed as “second career or second chance” professions as the vast majority of student are women, many of whom did not have the opportunity to pursue these careers early in life. Through their experience of the health care system, they decide to enter these professions. Their commitment is high and they usually perform well.

• The CDNM expresses its concern that the Government removed $152m from the HEPP in the 2016 budget, without consultation and apparently prior to its evaluation.

Supporting the regional presence of universities

• The CDNM welcomes a fund to support the establishment of regional and outer metropolitan universities’ infrastructure. Though we suggest that it extend beyond university campuses/estates or virtual networks. Australia faces an unequal distribution of health professionals with many located in major cities, and paucity in regional and rural areas. To encourage nursing and midwifery students to explore the options of re-‐locating to regional and rural areas on graduation, clinical professional practice learning in these areas can be of great benefit. This means investment in infrastructure including student learning facilities, cost effective student accommodation, transport links in rural, remote and regional areas is essential.

• Given that many nursing and midwifery students also have financial commitments, living away from home for rural, remote and regional clinical placement places added burden, the CDNM seeks equitable financial support for these students. Any financial commitment must be ongoing/recurrent to enable multiple cohorts of students to access these placements.

• The CDNM supports investment in local learning hubs that are underpinned by strong connectivity.

Flexibility to innovate

• Universities already offer flagship programs and set fees for these. The CDNM is concerned that the proposal appears to be quite complex and as a consequence, probably expensive and administratively burdensome. We cannot see that it will add any benefit to what already exists. The CDNM argues that universities need the freedom to develop flagship programs according to their strategic directions, and to determine fees without onerous regulation. The market will then decide which courses and fees it will tolerate.

• Nursing and Midwifery courses comply with national accreditation standards and as such are already deemed as “flagship”.

More information for students

• The CDNM supports the collection of performance data. However, we are cautious about these data leading to league tables such as in the UK. Many university

ranking systems are in existence, both globally (Times HE, QS World Rankings, ARWU, CWTS Leiden) and nationally (Graduate Destinations, and Course Experience Questionnaire).

• The CDNM believes a longitudinal survey (up to 12 months) would be very useful to accurately capture graduate employment.

• The CDNM expects that performance data be presented fairly and accurately.

• Data collection and reporting is administratively burdensome. Any additional reporting activity undertaken by higher education providers will need to be appropriately funded.

A fair share from taxpayers and graduates

• The CDNM acknowledges that there needs to be some changes implemented to the current education funding arrangements for sustainability. However we prefer an incremental approach. Significant increases in student contributions and/or a major reduction in the repayment threshold disadvantages graduates who do not have a high earning capacity, of which nurses and midwives are two groups. Incremental change is more likely to be accepted by the community and does not compromise affordability in the short term. This will also ensure greater sustainability of the higher education system.

• The CDNM supports the re-‐introduction of quotas (capping). This will certainly contain government spending on higher education and enable nursing and midwifery programs to be sustained into the future.

• Expecting students to pay more will lead to graduates with higher debts and this will cause pressure for wage increases to offset the repayment costs. Nurses and midwives do not earn high wages.

• Health professional courses such as nursing and midwifery are costly courses to deliver due to the need for simulation laboratories and clinical practicum placements and the associated staffing and the infrastructure needed as well as the payments to access clinical sites and teachers/facilitators. The current cluster funding arrangements do not take these issues into account. Over the past decade, higher education providers have been expected to pay exorbitant prices for clinical placements and these prices have continued to escalate. The viability of some nursing and midwifery courses is in jeopardy leading to the potential of not educating the numbers of nurses and midwifes that will be necessary to meet the health care needs into the future.

• The CDNM has previously made submissions to funding cluster reviews. However, we have witnessed little change.

An affordable loan scheme

• The CDNM supports a modest loan fee in association with an incentive for upfront payment of fees. Such an incentive could contain spiralling public debt related to student loans.

• Any notion of fees and student loans automatically disadvantages some people.

Those who cannot afford an up-‐front payment will inevitably have a loan that they

will need to repay. Loan fees of 20% further disadvantage these groups, many of whom are already underrepresented in higher education. Many nursing and midwifery students come from disadvantaged backgrounds. High loan repayments will deter them from pursuing a nursing or midwifery qualification.

A renewable lifetime limit on HELP loans... other options

• The CDNM supports, in principle, the proposed measures. However, current lifetime limits on FEE-‐HELP are no longer adequate for many non-‐CGS supported degree programs, many of which already cost more than $100,000. Raising loan limits also ensures greater access to programs for everyone rather than access on ability to pay.

• Reasonable lowering the threshold for repayment of loans will recover student debt more quickly.

• Income tests are already used for a wide range of other Government payment schemes therefore student debt should be included.

• Deceased estates are already subject to debt recovery so this should not be different.

Other suggestions

• There is significant mobility of health professionals across the globe, especially in Nursing and Midwifery. This is an important matter as there have been numerous studies showcasing the potential serious shortage of nurses into the next decade. It is therefore essential to establish stronger mutual recognition of educational attainment between countries.

• Education is one of Australia’s export strengths. Attracting international students will be enhanced where those students are confident that their qualifications will be

deemed equivalent.

Professor Wendy Cross

Associate Dean, Nursing and Allied Health, Monash University

Chair of Council.