Chartered Accountants Australia and New Zealand (CA ANZ) has made three submissions to the Department of Education on its consultations to inform design and implementation of higher education sector reforms recommended in the Australian Universities Accord Final Report which cover the:

• Australian Tertiary Education Commission
• Managed Growth Funding System
• Needs-based Funding.

Needs-based Funding submission key points:

• The Final Report of the Australian Universities Accord (Final Report) found that current funding arrangements limit enrolment growth in student cohorts from under-represented backgrounds because they do not reflect the additional costs of teaching these students who, on average, need additional support to succeed. The Needs-based Funding Model responds to recommendations 13, 39, 40 and 41 of the Final Report.
• Eligibility – The needs of the four cohorts identified as eligible for Needs-based Funding (low SES students, First Nations students, students with a disability and students studying at a regional campus) should be defined. Needs-based Funding should apply to all regional and remote students to support needs regardless of their chosen campus location.
• Contribution amounts – The government should clearly state what the contribution amounts will be. To support transparency, the government should also outline the methodology that will be used to assess the contribution amounts. Needs-based Funding is set to include a per-student funding amount calculated based on equivalent full-time student load (EFTSL). However, needs are more likely to be linked with headcount rather than EFTSL and the allocation of Needs-based Funding should reflect this.
• Cumulative disadvantage – The contribution amounts should consider the concept of cumulative disadvantage (where a student belongs to more than one identified equity group) by defining the term ‘cumulative disadvantage’ and developing a common understanding on how to support students who are represented in more than one equity cohort.
• Potential scaling and proxy for academic preparedness – CA ANZ recommends that ATAR is not used as the sole or main indicator for determining academic preparedness and scaling funding as it is not the only indicator or the best one.
• Supports – The types of supports providers should be able to use the funding for should be determined in consultation with equity cohort students and higher education providers, allowing providers to direct the funding to where it is most needed. Consideration should also be given to allowing the funding to be used for curriculum improvement and teacher training to support all students. An outcome-based framework is preferable to a prescribed framework of activities for which funding can be used as this could stifle innovation and may lose currency over time.
• Encouraging completion – Institutions are best placed to implement initiatives that support the different stages of students’ learning. The New Zealand Government’s approach of making the final year of study free rather than the first year of study, to encourage completion, is worth considering for under-represented students.
• Improving data collection and measurement – To better understand student demographics and recognise eligibility, CA ANZ encourages adopting more direct measures of students’ socio-economic status, and considering how the measures should be disaggregated for funding and monitoring purposes.
• System-wide funding – The Final Report’s aspiration was for a  “system-wide” funding scheme. However, the proposed Needs-based Funding arrangements are a ‘bolt on’ which could be easily removed by future administrations and do little to support equity cohorts to access higher education. It is also separate from the Job-Ready Graduates Package and does nothing to address the well-aired concerns with those arrangements.
• Social equity goals – Social equity goals also depend on appropriate funding and supports being provided by Commonwealth, State and Territory Governments to assist student achievement at high school and prepare students for further study after year 12. This should be the starting point. CA ANZ advocates for introducing a senior secondary accounting curriculum which is more outcomes focused and improves students’ financial literacy, and targeted government investment in accounting, financial literacy, sustainability, digital and AI skills.