6. TEQSA's Regulation of Higher Education

Auditor-General Report No. 33 2019-20


The audited entity was the Tertiary Education Quality and Standards Agency (TEQSA). The objective of the audit was to assess the effectiveness of TEQSA’s regulation of Australia’s higher education sector.
This chapter:
provides an overview of the audit findings and TEQSA’s approach to regulating the higher education sector;
outlines its risk assessment process;
examines its compliance and enforcement frameworks; and
discusses matters related to regulatory approvals.

Chapter overview

The Committee’s inquiry into this report found that TEQSA’s regulation of the higher education sector was effective in some areas and was in need of improvement in others. Two problematic areas included the need to ensure timely re-registration and re-accreditation of low-risk providers, and the need to identify cyber security as a specific risk indicator and ensure measures are taken to develop cyber resilience. Recommendations are made to this effect at the end of this chapter.

Background and audit findings

TEQSA was established in 2012 under the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act). As a regulatory agency, TEQSA is responsible for the registration of higher education providers and the approval of courses offered by those providers.
The sector that TEQSA regulates consists of providers varying in size, received revenue and courses offered. In 2018, 1.56 million students were enrolled in courses that counted towards an Australian higher education award. Of this total, 90 per cent of students were enrolled at public universities.1
The audit concluded that the effectiveness of TEQSA’s regulation of higher education was ‘mixed’ and made the following five recommendations addressing compliance and enforcement that TEQSA:
Establish and implement a comprehensive compliance monitoring framework, supported by appropriate operational processes;
Ensure that it adequately documents its analysis and the outcomes of each stage of its compliance assessments in a timely manner;
Ensure material submitted by providers as part of formal conditions is assessed in a timely manner;
Establish and implement a transparent process for managing material change notifications, including documenting the assessment of all notifications; and
Ensure that its annual performance reporting includes information on the number of provider compliance activities undertaken and the outcomes of compliance activity.

TEQSA’s approach to regulation

The Australian Government established TEQSA as the national agency responsible for the regulation and quality assurance of higher education after the 2008 Review of Australian Higher Education (the Bradley Review).
Accompanying the TEQSA Bill 2011, the second reading speech outlined the purpose of the regulator, stating that:
TEQSA will focus its activities on encouraging and supporting both new entrants to the system and higher risk providers, while ensuring that existing, higher quality, lower risk providers will not be unnecessarily burdened.2
Citing this second reading speech, TEQSA explained that its governing legislation was designed with a focus on ‘meta-regulation’, which places an emphasis on reviewing the regulatory systems of institutions rather than directly assessing whether particular aspects of an entity’s operation are of appropriate academic standards.3
TEQSA outlined that its approach to regulation is to encourage as many regulated entities to be ‘leaders and move beyond compliance … to embark on a process of continuous improvement’. TEQSA indicated that if this approach is not taken, its role as a regulator may become ‘prescriptive and oppressive’. Such an approach would hinder TEQSA’s ability to achieve some of the objectives of the TEQSA Act, including supporting diversity and innovation in Australian higher education.4
According to TEQSA’s performance statement:
… fifty-nine per cent of responding providers rated it as good or excellent in assuring and regulating the sector without unnecessarily impeding the efficient operation of higher education providers. TEQSA’s good or excellent rating by for-profit providers was considerably lower at 43 per cent.5
TEQSA argued that its aim is to foster and support ‘a culture of effective self-assurance’ among providers to ensure that they meet the standards, thereby reducing the need for enforcement action. TEQSA’s aim is demonstrated through its design of the registration process, which requires higher education providers to achieve and maintain compliance with relevant standards, including through self-monitoring compliance and taking appropriate action if lapses occur.6

Risk assessments

Managing risk is an integral part of a regulator’s role. It can be used to inform the development of management systems and frameworks that support regulatory activity and ensure that available resources are efficiently allocated.
Like all non-corporate Commonwealth entities, TEQSA must comply with all nine elements of Commonwealth Risk Management Policy to establish appropriate systems of risk oversight and management.

TEQSA’s method for assessing risk

TEQSA’s annual risk assessment cycle involves assigning risk ratings to higher education providers by assessing each provider against a set of risk indicators. In its submission, TEQSA stated that it ‘considers regulatory history and standing as an indicator for arriving at its overall risk assessment for individual providers’. TEQSA also considers academic staff profile and financial viability and sustainability.7
Risk indicators used in TEQSA’s risk assessment process are informed by the Higher Education Standards Framework (Threshold Standards) 2015 (the Threshold Standards), which define the minimum standards of operation in the higher education sector. TEQSA’s role is to ‘assess, monitor and regulate the sector’ against these Threshold Standards.8
TEQSA explained that if potential risks are identified through risk assessments, ‘the provider is invited to submit further evidence regarding its risk profile and management’. The regulator further elaborated that if the provider is responding to their initial risk assessment, they are:
… asked to demonstrate actions or initiatives undertaken to mitigate any identified risks to students and the financial position of the provider, including ratings of likelihood and consequence, and accompanying treatments and controls. On the basis of the response, TEQSA then arrives at a residual risk rating, considering the provider’s inherent risk, risk mitigation and regulatory history.9

Source data

As discussed in Chapter 1, sound regulatory activity depends on the good collection and management of compliance data. This data is analysed during the risk assessment process and is then used to inform the design of a regulator’s compliance programs. Due to TEQSA’s use of source data that is usually two years old, the audit noted that the accuracy of TEQSA’s risk assessment is reduced.10
The ANAO explained that TEQSA relies on data that comes from a number of systems used by the Department of Education, Skills and Employment (DESE), such as the Quality Indicators for Learning and Teaching data and the Higher Education Information Management System. Once this data, often from the previous school year, is provided to TEQSA, it is two years old.11
TEQSA noted that through DESE’s Transforming the Collection of Student Information project, which aims to improve data availability, it will be able to access more recent student data for its risk assessment.12 The audit stated that this project may improve the timeliness of data by up to six months.13

Sector-wide risks

One of TEQSA’s four strategic objectives is to ‘support providers to deliver high quality education, protect student interests and enhance the reputation and competitiveness of Australia’s higher education sector’.14 The regulator indicated in its 2019-23 corporate plan that to achieve this objective it will ‘consult with stakeholders and identify issues and deliver strategies where guidance is required’.15
The audit concluded that ‘TEQSA provided appropriate support to the sector to address the majority of key sector-wide risks’.16
During the inquiry, the Committee received evidence related to TEQSA’s responses to sector-wide risks such as cyber security, sexual assault and harassment, and COVID-19.

Cyber security

The audit observed that ‘TEQSA has not yet taken any specific actions to respond to cyber security risk’17 and that its ‘process to assign risk ratings to providers also does not include specific consideration of cyber security issues’.18
TEQSA stated that in response to cyber security risks it:
… has directly engaged with universities who experienced significant cyber security failings and collected evidence that appropriate rectification was being conducted. TEQSA is working with the lead agency, the Australian Cyber Security Centre, in relation to this risk.19
TEQSA advised that its Higher Education Integrity Unit, established in June 2020, ‘is leveraging the expertise of both the Australian Cyber Security Centre and the Trusted Cyber Security Forum supported by the Department of Home Affairs to develop a cyber security resource that will support non-university providers enhance the protection of their cyber assets’.20
On the consideration of cyber security in risk ratings, TEQSA explained that it is working to further strengthen the risk assessment process ‘by including more evidence based on sector trends and provider data held by other agencies’. TEQSA also acknowledged that its annual risk assessments do not include a specific indicator for cyber security, but added that the risk is considered in compliance and registration renewal assessments, where there is an identified risk.21

Sexual assault and harassment

In 2017, the Australian Human Rights Commission released Change the Course: National Report on Sexual Assault and Sexual Harassment at Australian Universities. In response to this report, ‘the Minister requested that TEQSA assess providers and universities, in particular, on their policies, systems, controls for handling complaints or allegations of sexual assault and sexual harassment on campus’.22 The regulator then sought advice from an expert advisory group on the standards used to assess providers. This process, which commenced in 2019, remains ongoing as of the time of this inquiry.23
Although not a regulatory requirement, TEQSA issued the sector with guidance that providers may consider when handling complaints or allegations of sexual assault and sexual harassment.24 TEQSA stated that it also directly engaged with higher education providers on their policies and procedures around responding to sexual harassment incidents, during the re-registration process between February 2019 and June 2020.25 The regulator additionally noted that, since that time, it has sought to adopt a revised approach to addressing sexual assault and sexual harassment—proposing to ‘work with peak bodies, rather than individual providers’.26
TEQSA reported that its compliance assessments in relation to sexual assault and harassment have found no evidence of sector noncompliance, where the majority of the compliance assessments related to universities. Instead, when ‘TEQSA has identified areas of improvement, providers have engaged and responded appropriately and promptly’. From its assessments of providers in this area, TEQSA observed that ‘providers have a good understanding of their student safety and wellbeing obligations’.27 TEQSA explained further that ‘for the most part universities have well-established procedures, systems et cetera’ and that independent providers have sought advice or guidance from TEQSA on related policies and procedures that they may establish.28
The sector’s feedback on TEQSA’s work in this area ‘indicated a good level of satisfaction’. TEQSA’s 2020 stakeholder feedback report discussed this further, noting that guidance, other materials and resources ‘were largely appreciated by the sector, particularly when they addressed systemic issues (e.g. sexual harassment issues)’.29
To date, TEQSA has considered 23 matters related to alleged sexual assault and sexual harassment, which have been received as complaints or through other means, such as media reports.30


TEQSA outlined the process it used to evaluate the financial positions of providers, in light of the effect of COVID-19 on the sector. In 2020, the regulator asked all providers to supply information of their accounts from 30 June that year, which has been used ‘as a basis for assessing the ongoing financial viability’ of providers. TEQSA informed the Committee that it had completed its annual risk assessment cycle for providers and was in the process of sending these assessments to providers for comment. Once these responses have been received, TEQSA stated that the annual risk assessment will be finalised.31
TEQSA observed that the sector is ‘under pressure at present’. In particular, and of the smaller private providers, the regulator stated that English-language-teaching-only providers were experiencing a ‘significant collapse in the marketplace’. TEQSA advised that for other private providers risk categories around financial viability have been refreshed or revised.32
TEQSA expressed the view that ‘at present, the imminent collapse of providers’ is not apparent. TEQSA acknowledged that ‘providers have held up reasonably well in the face of the pressures of the last year’, however cautioned that ‘some lag impacts from COVID during the course of 2021 and 2022’ is expected.33

Online learning

As part of the response to COVID-19, many providers shifted to online learning modules, which became an area of focus for the regulator in 2020. TEQSA said that it held a series of webinars to support providers with their transition to online learning.34
TEQSA indicated that its annual survey had included questions targeting the implementation of online learning and more specifically, concerns from students.35 While some of those responders reported positively on how quickly providers were able to transition to online learning for modules previously taught in-person, TEQSA observed that there were some IT concerns. In addition to capacity and technical issues with the delivery of online services, these concerns also included the quality and depth of materials offered online.36
TEQSA recognised that isolation felt by students as a result of the transition to online learning was an issue and informed the Committee that this will be the subject of further surveys this year. The regulator also noted that the Quality Indicators for Learning and Teaching survey results indicate how student experience has shifted in the context of online learning over the previous year.37

Compliance and enforcement

Compliance and enforcement activities form an important part of a regulator’s role, as they have the responsibility of assuring Parliament and the public that regulated entities are compliant with their statutory obligations and that appropriate enforcement actions are taken when regulated entities do not meet such obligations.
This section details the actions that TEQSA has taken to address the audit’s five recommendations around compliance and enforcement processes.

Compliance planning and monitoring

The audit observed that TEQSA had ‘not undertaken any periodic compliance planning’ and was in the ‘early stages of developing priorities to guide future compliance activity’. Instead, compliance activity had ‘mainly been informed by media and self-reporting’.38 Accordingly, the audit recommended that TEQSA establish and implement a comprehensive compliance monitoring framework, supported by appropriate operational processes.39
Addressing this recommendation, TEQSA confirmed it has now established a Compliance Monitoring Framework that ensures ‘compliance monitoring is coordinated and prioritised, through transparent and established processes’.40 To guide TEQSA’s investigative work an Investigation Manual is being prepared41 and procedures for handling complaints and concerns have been revised, with staff receiving relevant training.42
TEQSA elaborated on the steps taken to ensure the Compliance Monitoring Framework is effective, including:
A Compliance and Enforcement Policy, documenting principles and standards for compliance and enforcement activities under Part 7 of the Tertiary Education Quality and Standards Agency Act 2011 and Part 6 and Part 7 of the Education Services for Overseas Students Act 2000, is currently being finalised.
A prioritisation model has been implemented. The model incorporates a triage process for prioritising complaints and concerns, based on risk and meaningful categorisation of concerns.
An annual compliance program has been established. The program ensures TEQSA targets current, systemic and emerging risks, using a range of compliance monitoring tools, such as out-of-cycle compliance audits and provider site visits.
TEQSA now has documented processes, procedures and other resources for its compliance monitoring activities, in support of operational planning and business processes.43
TEQSA noted that the framework will be reviewed annually or when there are substantial changes affecting students, the reputation or financial viability of the sector.44
TEQSA assured the Committee that during the process of implementing audit recommendations part of its focus has been to link its compliance activities to risks and ‘not just be reactive … to media concerns or specific complaints made to the agency’.45

Documentation of compliance assessments

Given that provider compliance history is one of the elements that TEQSA considers when assessing risk, the quality of recordkeeping around its compliance activities has an impact on the quality of its risk assessments.
The ANAO explained in its submission that adequate documentation of regulatory actions as well as the rationale for regulatory decisions facilitates ‘transparency and accountability’. This is particularly important, as a regulator’s approval decisions may be subject to external scrutiny, wherein it may be required to demonstrate how its actions and decisions were warranted.46
Based on its analysis of TEQSA’s completed compliance assessments, the ANAO recommended that the regulator adequately document its compliance assessments, inclusive of recording its analysis and the outcomes at each stage of the process in a timely manner.47
TEQSA advised that it has implemented a new reporting framework to demonstrate the status of its compliance assessments and that the naming standards of records have been revised. To further improve the compliance assessments process, the mapping of business requirements commenced in 2020-21.48

Management of conditions

To address concerns or areas of risk related to a provider’s higher education activities, TEQSA may impose statutory conditions on the registration and course accreditation of providers. As part of the process to evaluate compliance with conditions, TEQSA is required to assess materials submitted by providers and advise them of the assessment outcomes through periodic reports. Non-compliance with imposed conditions is considered a breach of the TEQSA Act.49
Based on audit findings, the ANAO recommended that TEQSA ensure materials submitted by providers, as part of formal conditions, is assessed in a timely manner. 50
TEQSA noted that ‘newly-developed resources and tools’ have been made available to support the management of conditions.51 TEQSA is also undertaking a Conditions Project, from which recommendations were expected to be implemented between May and December 2021. The project is focused on:
evaluating the effectiveness of conditions to date;
developing more specific, better targeted conditions to reduce the administrative burden on providers while still addressing risks; and
improving the management and timeliness of condition assessments.52
To support the timely assessment of submitted materials, TEQSA has made business improvements, including:
enhanced monitoring and reporting, so that assessments are allocated and tracked more efficiently; and
improved assessment capabilities, through resources and tools to support staff assessing provider compliance with conditions.53

Administrative Appeals Tribunal

If TEQSA does not approve an application or imposes conditions, providers may appeal the decision through the Administrative Appeals Tribunal (AAT). Through this process, appellants are able to provide new or updated evidence that was not available to TEQSA at the time the decision was made.
During the inquiry, TEQSA was asked whether it should consider changing its approach to give providers the opportunity to supply additional information prior to entering into an AAT appeals process. In response, the regulator noted that applicants are provided with opportunities to supply information before its decisions are formalised, adding that the volume of its involvement in external review matters is low, with approximately five per year since 2012. TEQSA further explained that it is not possible to provide an applicant with an extension to submit additional evidence beyond its legislative deadlines, as the regulator is required to meet these timeframes.54
When asked about potential issues with its regulatory functions, the regulator maintained that it continually reviews its approach to regulation, including in the context of external review proceedings. TEQSA stated that it will continue to consider the outcomes of such matters when reviewing its approach to regulation.55

Material change notifications

The TEQSA Act also requires registered providers to notify the regulator within 14 days of becoming aware of events that will either affect the provider’s ability to meet threshold standards or require an update to the National Register of Higher Education Providers. Such events that may require providers to alert TEQSA through a ‘material change notification’ include changes that may impact the financial viability and the good standing of any given provider.56
In relation to TEQSA’s management of material change notifications, the audit observed that the regulator ‘did not adequately document its assessment of notifications and whether further action was required’. Accordingly the ANAO recommended that TEQSA implement a transparent process for managing material change notifications, including the documentation of all associated assessments.57
On this matter, TEQSA advised that it has centralised the reporting and recording of material change notifications. All reported material changes and related assessments are recorded in the regulator’s case management system, with a monthly report of assessment outcomes issued to TEQSA’s Commissioners.58 TEQSA additionally noted that a communication plan, detailing the reporting requirements for providers, has been implemented.59

Performance reporting

Under the PGPA Act, Commonwealth entities are required to report on their activities against the performance measures published in their corporate plans through an annual performance statement.
The ANAO highlighted that:
To promote transparency and accountability, regulators should publicly report on the number and outcomes of core compliance activities such as compliance assessments. Regulators should also report on the extent to which regulated entities and individuals comply, and fail to comply, with obligations under the legislation. This provides the parliament with transparency about whether regulatory objectives are being met.60
From its examination of TEQSA’s 2018-19 performance statement, the ANAO identified that the regulator ‘did not report on the number of compliance activities commenced or completed or the outcomes of completed assessments’.61 The audit recommended that TEQSA include this information in its annual performance reporting.
In March 2021, the TEQSA Compliance Report 2020 was published. This report provided a snapshot of the regulator’s compliance activities between January and December 2020, including the number of compliance assessments initiated and finalised and the resulting outcomes of finalised assessments.62

Regulatory approvals

Sub-standard providers or courses have the potential to threaten Australia’s reputation of providing quality higher education. Protecting this reputation forms a key part of TEQSA’s role as a regulator.
As such, TEQSA’s registration approvals and course accreditation processes are an important part of its regulatory functions. The registration approvals process allows the regulator to ensure that only providers meeting the relevant higher education standards are operating in the sector. In the same way, the course accreditation process allows TEQSA to regulate the courses offered by registered providers.

Required documentation

All registration and course accreditation applications require providers to submit evidence demonstrating the ability to meet relevant higher education standards. The evidence needed is to be ‘based on the provider’s regulatory and compliance history, TEQSA’s annual risk assessment [of the provider] and any other intelligence held by TEQSA about … the provider’s risk context’.63
When asked about concerns around the volume of evidence that providers are required to submit, TEQSA claimed that its assessment is limited to a core set of standards (Core Plus Model) focused on the ‘provider’s internal and external reviews and reporting’, thereby reducing the volume of evidence needed. The regulator added that the scope of assessments, and therefore the breadth of evidence required, may change where concerns around potential non-compliance arise.64
TEQSA stated that while providers are encouraged to submit evidence relevant to the assessed standards, ‘it is ultimately up to a provider to determine the volume of facts and evidence’ needed to support their applications.65
The regulator advised that to reduce the administrative burden associated with low-risk assessments, it has ‘recently reviewed and refined its approach to Core Plus assessments’.66

Timeliness of regulatory decisions

The audit found that the timeliness of regulatory approvals was ‘mixed’.67 While it was observed that TEQSA met its statutory timeframes for initial registration and accreditation approvals in all but one instance, it ‘did not meet its targets for re-registration and re-accreditation approvals for low risk providers’.68
To improve the timeliness of its regulatory decisions, particularly for low-risk providers, TEQSA advised that it is undertaking ‘a number of projects’, including a review of the specialisation business process model and the development of risk priorities.69 The regulator explained that the business improvement projects have focused on ensuring:
Processes are streamlined and opportunities for continual improvement are identified, including by working with a LEAN consultant and end-to-end process reviews.
Processes support targeted risk-based assessments and decision making. The scoping of assessments has been improved to ensure they are informed by intelligence and data, focused on key risk areas, and proportionate to the risk-rating of the provider.
Enhanced provider-self-assurance. Where TEQSA has confidence in a provider’s own quality review and improvement processes, TEQSA no longer engages its own subject matter experts to review courses, significantly reducing processing times.
A refined “core plus” approach to assessments that reduces the administrative burden of regulation for providers. TEQSA’s re-accreditation and re-registration assessments focus on the provider’s compliance with a limited set of core Standards, relating principally to governance, internal quality assurance, student performance and student experience.70
As part of its efforts to further improve the timeliness of regulatory approvals, TEQSA is streamlining work practices through ‘a major IT transformation’, which would enable certain repetitive tasks to be automated and improve data capture.71

Assessments under the ESOS Act

Under the National Code of Practice for Providers of Education and Training to Overseas Students under the Education Services for Overseas Students Act 2000 (the ESOS Act), providers teaching international students are required to comply with another 11 standards (international student standards), in addition to the Threshold Standards. Initial registration and periodic reregistration of providers on the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) are the key types of approvals under the ESOS Act.
The audit found that ESOS assessments ‘did not involve input from experts’ and that ‘site visits were generally not undertaken’.72
TEQSA advised that, in the three years before this inquiry, it commissioned 39 reports from external experts to inform the ESOS assessments for over 20 different providers, ranging from small private higher education providers to large public universities. The 39 reports represented less than five per cent of assessments under the ESOS Act within the same three year period.73
TEQSA stated that it had undertaken seven physical site visits in the last three years as part of its assessment of providers seeking to renew their CRICOS registration, representing less than 10 per cent of total renewal applications for CRICOS registration.74

Committee comment

Although the audit found the effectiveness of TEQSA’s regulation of the higher education sector to be ‘mixed’, the regulator has made progress on implementing the five recommendations directed to improve its compliance and enforcement processes. The Committee notes that TEQSA has now directed resources and new tools towards establishing new processes and frameworks to improve its compliance and enforcement activity.
The Committee also notes the disparity in the stakeholder survey results between for-profit and not-for-profit providers. While this was not a major theme of the inquiry, the Committee highlights the importance of TEQSA building positive relationships with all types of providers. The Committee is interested in seeing TEQSA’s steps to improve relationships with private providers.
In relation to risk assessments, there were concerns around the use of two-year-old source data and the subsequent reduction in the accuracy of TEQSA’s risk assessments. However, the Committee is aware that this may be improved through TEQSA’s access to more recent student data through the DESE’s Transforming the Collection of Student Information.
TEQSA has generally demonstrated the ability to take appropriate action to support the higher education sector in relation to sector-wide risks, such as COVID-19 and sexual assault and harassment. In relation to cyber security risks, the Committee notes the adverse audit finding that the regulator did not specifically consider cyber security in its process to assign risk ratings. The Committee believes that TEQSA should consider cyber security as a specific risk indicator and take steps to develop cyber resilience.
While the Committee understands that TEQSA’s approach to regulation involves not burdening low-risk providers unnecessarily, it was noted that TEQSA ‘did not meet its targets for re-registration and re-accreditation approvals for low-risk providers’.75 The Committee heard that TEQSA is undertaking a number of projects to address this finding. Given that regulatory approvals form an important part of TEQSA’s responsibilities, as regulator of the higher education sector, the Committee is interested in the progress and outcomes of these projects.

Recommendation 5

The Committee recommends that TEQSA update the Committee within six months on the progress of its projects to ensure timely re-registration and re-accreditation of low-risk providers. TEQSA should also update the Committee on the outcome of the next stakeholder satisfaction survey, including a detailed analysis and comparison of the responses from private, university and other public providers.

Recommendation 6

The Committee recommends that TEQSA identify cyber security as a specific risk indicator and ensure measures are taken to develop cyber resilience across the sector.
In terms of a provider’s ability to appeal decisions to the AAT, the Committee acknowledges TEQSA’s advice that it is required to meet legislative timeframes and is therefore unable to provide additional time for providers to submit further evidence. The Committee considers there would be merit in TEQSA having the power to provide an extension of time where mutually agreed with a provider, which may reduce the necessity of AAT appeals. A recommendation is made to this effect due to the high percentage of matters that are either resolved after an appeal is lodged or successfully appealed to the AAT.

Recommendation 7

The Committee recommends that the Australian Government provide TEQSA with the ability to extend a deadline by mutual consent with a provider to allow providers additional time to submit further evidence in the interests of reducing the necessity of appeals to the Administrative Appeals Tribunal.

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    TEQSA, Submission 4.1, p. 15.
  • 71
    TEQSA, Submission 4.1, p. 15.
  • 72
    Auditor-General Report No. 33 2019-20, p. 37.
  • 73
    TEQSA, Submission 4.2, p. 2.
  • 74
    TEQSA, Submission 4.2, p. 2.
  • 75
    Auditor-General Report No. 33 2019-20, p. 31.

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