Transnational Education Policy

1.    Purpose

The Transnational Education (TNE) Policy outlines the principles for the establishment, delivery, and management for the overseas delivery of ICMS’ courses, either in full or in part, often in collaboration with other educational institutions. The aim is to ensure high-quality education that meets the needs of students while ensuring compliance with ICMS’ legislative obligations, alignment with its strategic goals and financial viability.

In implementing this policy, ICMS acknowledges its legislative obligations to remain responsible and accountable in all aspects of offshore and third-party course delivery and support.

2.   Scope

This policy applies to the establishment, delivery, and management for the overseas delivery of ICMS’ courses, either in full or in part, often in collaboration with other educational institutions. It does not cover agreements solely based on articulation or student exchange.

3.   Definitions

See Glossary of Terms.

4.   Policy statements

Establishing an agreement

4.1   Third-party arrangements are supported by a clear business case, outlining the rationale and academic model, developed using the approved transnational education business case template.

4.2   ICMS conducts due diligence on partners and locations before entering contracts, ensuring they meet TNE delivery expectations and mitigate risks, as per TEQSA’s Transnational Education Toolkit.

4.3   The TNE agreement reflects the business case and academic rationale, with specific goals, responsibilities, and KPIs for each partner. ICMS ensures agreements meet its responsibilities as an Australian higher education institution, are enforceable in the relevant jurisdiction, and takes into consideration laws within different countries.

4.4   ICMS considers the national and local context of the TNE partner, while maintaining ICMS values’, including:

a. local higher education laws (e.g., Ministry of Education approval)

b. the local higher education system and the partner’s status

c. national and international recognition of awards

d. respecting local educational traditions

e. adapting student assessment practices to fit different cultural and regulatory contexts

f. national and local industrial relations laws

g. the partner’s ability to uphold professional and ethical academic standards comparable to the Higher Education Standards Framework (2021) (HESF).

4.5   ICMS protects student interests if compliance with regulatory frameworks cannot be assured or if the TNE partner breaches contractual agreements and benchmarks.

Course delivery

4.6   Courses, full or in part, in collaboration with other educational institutions, are delivered to ensure that students have equivalent opportunities for progression and success, regardless of delivery arrangements or background. This includes appropriate contextualisation for offshore delivery, for example through the use of local case studies, and consideration of impacts of copyright and/or internet restrictions on access to learning and teaching resources and any need to make alternative arrangements when compared to onshore delivery.

4.7   All activities required for the end-to-end delivery of a course, or part of a course, must be agreed before delivery commences.

4.8   Course delivery activity and responsibilities are outlined in the TNE agreement and the relevant compliance checklist. An operational manual or equivalent provides detailed instructions and guidance regarding the activities and responsibilities of each partner in managing the partnership.

4.9   ICMS is responsible for the development of all teaching materials, learning resources, and assessment items, including the moderation and validation of assessment artefacts. Any contextualisation of teaching materials and/or learning resources by TNE partner academic staff must be approved by the appropriate ICMS Program Manager. In circumstances where TNE partner academic staff undertake assessment the outcomes of their grading are moderated in comparison by Australian-based academics teaching in the same onshore course.

4.10  Staff are available to students throughout the course delivery and inducted into ICMS’ requirements, including:

• • orientation and transition support.
  • academic policy requirements (e.g., academic integrity, moderation, and assessment).
  • academic skills development, including English language support.
  • access to complaints resolution procedures.
  • student safety and wellbeing.
  • reporting of student conduct breaches, including sexual harm and misconduct.

Staff resourcing and training

4.11  Course delivery activity and responsibilities are outlined in the TNE agreement.

4.12  Staff resourcing and training meets the expectations of ICMS’ Academic Board, including appropriate staff qualifications to meet the requirements of the HESF.

4.13  Staff are adequately trained to detect, address, and routinely report academic integrity issues, including contract cheating and the unauthorised use of artificial intelligence.

4.14  Staff are provided with training and mentoring to meet delivery expectations. This includes access to ICMS’ learning management system (LMS) and the necessary training to use it effectively.

4.15  Where teaching staff delivering an ICMS award are employed by the TNE partner ICMS vets the appointment of all teaching staff to deliver its courses. This occurs through ICMS’ academic approval processes.

4.16  All TNE academic staff approved to teach ICMS’ courses must adhere to all applicable ICMS policies, procedures, frameworks and guidelines, including academic freedom, and to the applicable requirements of the HESF.

Governance and management

4.17  Governance arrangements are scaled to suit the nature of the partnership and delivery model but always include corporate and academic governance oversight by ICMS’ Board of Directors (BOD) and Academic Board.

4.18  ICMS establishes an in-country joint management committee (JMC) to ensure visibility, accountability, and clear lines of communication to support the partnership. The JMC reports to the Board of Directors. It comprises members from ICMS and the in-country partner.

4.19  ICMS establishes joint operational committee(s) that meet more regularly than the JMC to oversee and manage performance. The operational committee(s) report to the Executive Management Committee and Academic Board and comprises members from ICMS and the in-country partner.

4.20  ICMS regularly reviews the governance arrangements with the TNE partner to ensure it functions as intended. The BOD re-establishes regular oversight if the JMC does not meet as specified in the agreement.

4.21  ICMS’ Board of Directors, the Academic Board and the JMC receive regular reports detailing academic performance across the quality assurance cycle, especially during the commencing teaching periods for any new partnership.

4.22  The TNE partner adheres to all applicable ICMS policies, procedures, frameworks and guidelines when delivering and/or supporting the delivery of ICMS courses.

Quality assurance

4.23  ICMS maintains its established quality assurance cycle across each partnership, while responding to any in-country considerations that may impact reporting on course delivery.

4.24  ICMS ensures that evaluations of teaching, complaints, and student progress, moderation of assessment, completion and performance data, and student feedback are regularly analysed to monitor cohort performance. These metrics are compared with Australian-based cohorts to uphold a quality student experience. It regularly evaluates whether TNE students are performing to expected academic standards, and that risk are identified, and responsibilities and actions assigned in order to mitigate those risks.

4.25  The Boards of Examiners considers student performance across all teaching locations and modes of delivery.

4.26  Identify key risks and assign responsibilities and actions to mitigate these risks. Ensure the governance framework is reviewed regularly to ensure it functions as intended.

Stakeholder management

4.27  ICMS recognises the importance of strategic and coordinated stakeholder management for TNE partnerships. There is regular and adhoc communication across all groups involved in course delivery.

4.28  ICMS manages relationships with in-country governments via the JMC to build ongoing connections and manage any legislative changes.

4.29  ICMS leverages offshore activities to expand local networks, industry connections and community partnerships.

4.30  ICMS plans for time zone differences and provides lead time for in-country staff to receive and adjust assessment materials.

4.31  Students are made aware of key points of contact for all academic support and wellbeing. Adequate support staff are available during assessment periods to respond to queries.

4.32  The TNE partner must agree to cooperate with all ICMS review and/or audit activities, or with any review, audit or compliance assessments undertaken by TEQSA.

4.33  Students have the opportunity to articulate into ICMS courses subject to applicable policies and procedures.

Cyclical reviews

4.34  In collaboration with the TNE partner, ICMS conducts reviews of key activities on an agreed cycle. Reviews are conducted in accordance with an established terms of reference following consultation with the TNE partner. Results are shared with the TNE partner and reported to the appropriate governance committees.

4.35  ICMS reviews its third-party arrangements on a regular and agreed cycle (e.g., annually) to ensure it is functioning well and within the arrangements agreed in the agreement. It takes into account the outcomes of review activity outlined in paragraph 4.33, and due diligence to ensure the agreement continues to satisfy the needs of both parties. New TNE partnerships are reviewed annually as a minimum for at least the first three years of operation. Unscheduled reviews or audits may be conducted at shorter notice where concerns regarding compliance with the HESF or the quality of educational provision and/or the student experience come to the attention of ICMS and/or TEQSA.

4.36  ICMS conducts a separate, strategic review of the agreement every three years to consider if benefit to both parties remains. This review includes the consideration of the key performance indicators (KPIs) agreed to in the agreement, return on investment, changes in the region, and any necessary adjustments required.

4.37  ICMS maintains ongoing market analysis as part of the due diligence process to identify any issues, new obligations, or legislative changes early.

4.38  Academic Board’s consideration of the cohort performance data informs the cyclical reviews of course delivery.

4.39  Onsite, in-country visits are undertaken on an agreed cycle as an opportunity to validate existing provision and to develop and mature relationships between ICMS and third parties. All in-country visit are reported to the Board of Directors as part of monitoring the agreement performance. All annual review reports and other reports are reported to the Academic Board and Board of Directors.

5.   Roles and responsibilities

5.1   The President and Managing Director:

• is the responsible officer for this policy;
• responsible for all operational oversight of the TNE arrangement;
• has authority to sign agreements;
• is Deputy Chair of the Joint Management Committee.

5.2   The Board of Directors, via the Executive Management Group, is responsible for:

• approval and oversight of the partnership agreement and any supporting documentation;
• overseeing risk management and due diligence to ensure high-risk matters (e.g., cybersecurity, academic integrity) are effectively mitigated and managed via a risk register. Key risks are identified and responsibilities and actions assigned to mitigate those risks;
• receiving cyclical reports from senior management, including reviews of any education agents engaged by ICMS, and in-country visits;
• ensuring ongoing compliance with the Higher Education Standards Framework and any relevant in-country legislation; and
• evaluating revenue targets and assessing the viability of the agreement if targets are not met.

5.3   Academic Board is responsible for:

• receiving regular reporting on third-party arrangements, via the Learning and Teaching Committee, to ensure the teaching model meets its objectives;
• ensuring TNE related academic risks are identified, monitored and mitigated;
• regularly evaluate whether TNE students are performing to expected academic standards analysing performance data to identify areas of risk; and
• oversee the implementation of teach-out arrangements if a contract is dissolved.

5.4   Program Managers have overarching responsibility for their respective courses.

 6.   Related documents

Articulations, Agreements and Institutional Alliances Policy

Articulations, Agreements and Institutional Alliances Procedures

Transnational Education Compliance Checklist

 Approved by the Board of Directors on 3 December 2024