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.

Managed Growth Funding System submission key points:

1. Transitioning from a total funding cap to a new system based on a cap on equivalent full-time student load i.e. Managed Growth Targets (MGTs) - The new system for Commonwealth supported places (CSPs) may limit provider flexibility, create perverse incentives, and impose unnecessary restraints on enrolment growth by imposing a hard cap which will not allow for over-enrolments where institutions do not receive any Commonwealth grant but still receive student tuition fees.

CA ANZ supports maintaining flexibility for universities to enrol above their caps and extending CSPs to all Australian higher education providers to expand student choices.

2. Incentives for equity students - The new system continues demand-driven funding for Indigenous students and extends it to other equity cohorts such as those from regional and remote areas, and low socio-economic backgrounds. As the enrolment of other equity cohorts will count towards the institution’s MGTs, this may act as a disincentive and limit student choices.

CA ANZ supports incentivising providers to offer places to equity students by not counting their enrolments towards MGTs and providing extra Commonwealth funding linked to the number of equity students enrolled.

3. University degree fees and funding arrangements - The new system does nothing to alter subsidies or tuition fees under the Job-ready Graduates (JRG) package). Providers would receive an unspecified per student subsidy for students from disadvantaged cohorts. As a bolt-on to existing arrangements, it would be easy for future administrations to remove or reduce funding. In addition, there is no change in the tuition fees paid by disadvantaged students.

CA ANZ supports increasing access and attainment of equity targets by investing in new services and supports, reforming or replacing the JRG Package, and determining loadings for disadvantaged students that simultaneously top up the Commonwealth's contribution while discounting the tuition fee faced by disadvantaged students by the same amount.