Professor Stephen Garton FAHA, FASSA, FRAHS
Provost and Deputy Vice-Chancellor
29 June 2012
Mr David de Carvalho
C/- Policy Section
Higher Education Division
Department of Industry, Innovation, Science, Research and Tertiary Education
By email: HIGHERED@deewr.gov.au
Dear Mr de Carvalho
Thank you for your letter of 25 May 2012 providing the University of Sydney with an opportunity to
comment on the DIISRTE’s Higher Education Staff Data Collection Review: Issues Paper May
2012 (‘Issues Paper’). The Vice-Chancellor has asked me to respond on behalf of the University.
While we have provided input to the Universities Australia (‘UA’) and Group of Eight (‘Go8’)
submissions, we thought it important that the University place some additional comments on the
record in its own right. We recognise that the outcomes of the Review have the potential to be
significant both for the University and the Australian higher education sector as a whole, and are
keen to provide further information and advice as the process continues.
As the Issues Paper notes, the Higher Education Staff Data Collection (‘Collection’) has not been
reviewed formally since its establishment more than 20 years ago. Over that time, the nature of the
Australian higher education system (and higher education globally) has changed dramatically. We
therefore strongly support the Review and its goals of determining what changes to the Collection
are required to ensure that it meets the needs of diverse users of the data.
We strongly endorse the principles-based approach to the review recommended by the Go8. As a
starting point we agree that the Review should be underpinned by a consideration of the limitations
of the existing Collection for key users. As submitting data for the Collection is a requirement
imposed on higher education providers under the Higher Education Support Act we feel it is
important that the Review clearly articulate the shortcoming of the current data relative to the long
term policy objectives and uses the Government has in mind for the Collection. Similarly, as it is
clear that the Review has been influenced by the desire to satisfy the data requirements of the
Tertiary Education Quality and Standards Agency (‘TEQSA’), it is incumbent upon the regulator to
explain the deficiencies of all existing data sets relative to its regulatory responsibilities and
intended uses for the data.
We fully support the discussions underway between TEQSA, DIISTRE and the sector with the long
term goal of minimising duplication and reducing reporting burdens through the establishment of a
single high quality Australian higher education sector data collection, accessible to TEQSA and
other users subject to appropriate privacy and other protocols. Nevertheless, it is not clear at
present how the collection of data about what are essentially ‘inputs’ to the delivery of higher
education activities is relevant to TEQSA’s core functions of registering providers and making
assessments against its risk and standards framework about the quality of the educational and
research outcomes of individual providers.
Office of the Provost and Deputy Vice-Chancellor
Room L2.22, The Quadrangle (A14)
NSW 2006 Australia
T +61 2 9036 5027
F +61 2 9036 5031
E dvc.provost@sydney.edu.au
ABN 15 211 513 464
CRICOS 00026A
Clarifying the purpose and intended future uses of data within the Collection would assist the
identification of shortcoming and gaps in the existing data. It would also provide a consistent
reference point for assessing the utility of suggested changes. In stressing these issues, we are
conscious that many of the proposals for reform of the reporting requirements for the Collection
would require substantial changes to our information systems, human resources policies and
business processes.
We note the absence of references in the Issues Paper to international trends, particularly in other
OECD countries, in the collection of data about staff in their higher education systems. While it may
never be possible to ensure complete consistency in data and definitions between jurisdictions,
there is often great value at the system-wide and institutional levels in comparing trends against
international benchmarks. This is particularly so with the rise of international ranking systems, some
of which (e.g. Shanghai Jiao Tong University) rely on publicly available data. We therefore urge the
Review to consider trends in higher education staff data collections in key countries and rankings,
and to adopt as a design principle for the new Collection the objective of enabling meaningful
international benchmarking of higher education staff data and trends. This would provide benefits
for government and across the entire sector.
We fully support the proposal to improve the consistency of data across the various elements of the
Staff Collection including the reference point for the submission of data. The options are point in
time or annual collection. While annual collection will likely incur greater expense in data collection
it is our preferred option so that a full year picture is captured. Point in time data collection could
skew the analysis. Nevertheless, given the scale of the changes proposed for the staff function
classifications and the inclusion of contractors and ‘affiliates’ who contribute to the activities of
providers, we stress the need for the Review to have regard for the highly varied and often
complicated nature of these relationships in large and diverse institutions in particular.
Arrangements for contractors and affiliates are invariably fostered at the local level or offsite in
clinical and other educational and research settings. As a result, consistency of data across all
institutions could be difficult to achieve. We see significant risk that the introduction of detailed
reporting requirements relating to affiliates could impose a heavy administrative burden on
providers and potentially on those who dedicate time to our activities even though they receive no
financial benefit from the University. We also feel it is essential that the Review considers the need
to maximise consistency of data and definitions across other collections and particularly those
relevant to university research.
For example, the Review should consider the potential implications for important research and
student data collections and programs of the proposed changes to the function classifications of full
time staff and the treatment of contractors and affiliates. The Excellence in Research for Australian
(ERA) initiative currently relies on the function classifications of academic staff provided for the
Staff Collection as a key criterion for determining the eligibility of researchers. Many other
categories of researchers either employed on a casual or fractional basis, or not employed but
nevertheless affiliated with the institution, are also included in institutional submissions subject to
meeting other requirements. The Higher Education Research Data Collection (HERDC) similarly
defines the circumstances in which the publications of affiliated researchers may be included in an
institution’s return. A second example is the current inconsistency between the staff and student
data collections in the definitions and scope of offshore teaching and controlled entities.
The Review also needs to consider the potential implications of the proposed changes to the
function classifications and the inclusion of contractor and affiliates, for the funding formula used by
DIISTRE to determine the allocation of Sustainable Research Excellence (SRE) block funds.
Currently, part of the SRE formula relies on a calculation involving institutions’ full-time-equivalent
and fractional staff numbers taken from the Staff Collection. Any changes to these data have the
potential to influence SRE allocations between institutions.
While our initial assessment is that the impact of the proposed changes on funding allocations is
likely to be small, we raise the issue because it again demonstrates the interdependencies between
the existing Staff Collection and other government programs. The Review needs to ensure that
changes to the Staff Collection do not have unintended consequences in other areas.
Related to the above points, we question the value of requiring the same data about staff and
affiliates from all providers regardless of type and risk profile. We can see value in achieving some
consistency in staff and other data collections across all registered providers for the purpose of
policy, analysis and workforce planning. However, an approach that recognises the fundamental
differences between providers, their operating and funding circumstances, would seem more
consistent with the Government’s goals for supporting diversity and ensuring that the regulatory
and reporting burden is proportionate.
In relation to the issues of the timeframes for implementation, for changes as extensive as those
proposed in the Issues Paper we believe that implementation in 2013 (2012 reference year) would
be impossible due to the changes that would be required to our systems and collection processes.
Even if the definitions were finalised this month, it would be challenging to complete the necessary
systems developments for 2014 submission (2013 reference year). We therefore urge the
Government to aim to specify the required changes by the end of 2012, with a view to achieving full
implementation in 2015 (2014 reference year). With some of the proposed changes clearly less
problematic than others, a phased approach to implementation might be one way that the
Government could achieve progress in advance of 2015.
Finally, on the question of the cost of implementing the proposed changes, we have not been able
to assess this fully. The costs would depend largely on the scope of the changes that are finally
decided as a result of the Review. Given the extent of the changes proposed for data relating to
casual staff, function classifications, contractors and affiliates, changes would not only be required
to IT systems, but to our collection processes and how we store and report data. The cost of
ongoing maintenance of this complex data set is likely to be considerable, both in terms of direct
overheads and opportunity costs. We also foresee potential flow on implications for our enterprise
agreement with staff, which relies on the current function classifications, our human resource
management processes, and our reporting of data for research collections if the proposed changes
have consequences for the ERA and HERDC as discussed above.
We trust this feedback is helpful and look forward to engaging with the Department as the Review
continues
Yours sincerely
[Signature removed for electronic distribution]
Stephen Garton