February 2019


As the peak body for Australia’s 39 comprehensive universities, Universities Australia acknowledges the need for more clarity and certainty regarding the allocation of Commonwealth supported places (CSPs) for enabling, sub-bachelor and postgraduate places. The higher education sector will operate in a more efficient and more effective way if allocations of places are aligned with demand.

However, UA also notes the unavoidable complexity of the allocation process, given the distinct mission and needs of each university and the various factors that currently need to be considered.

Australia’s higher education sector is a vital component of and contributor to Australia’s social and economic wellbeing. It is UA’s view that this review should consider any policy change with careful attention to maintaining:

  1. a strong and sustainable higher education sector;
  2. access and support for all students who wish to undertake higher education and have the capacity to succeed; and
  3. Australia’s current and future economic and social needs.

UA also notes that students should not be disadvantaged from one year to another during the allocation process.

UA also believes it would be more appropriate to align the reallocation process with funding agreements, to provide both universities and students with greater certainty. Annual reallocation would confuse both universities and students.

At all three levels, allocation methods should include a clear and transparent process for universities to apply for additional places. This will enable institutions to respond to changes in demand and will make it less likely that a university can be ‘locked out’ of allocations.

UA is not convinced that ‘geographic representativeness’ should be a criterion in allocation of places. In any case, this concept – as expressed in the discussion paper – is somewhat unclear. It is UA’s view that skilful design and rigorous application of other, more immediately relevant criteria on demand for places and participation by students from under-represented groups would deal well with issues of geographic representativeness.

UA does not believe it is possible to set thresholds for ‘minimum viable allocation’ of places across the sector. The minimum number of places needed to maintain the viability of programs will differ by level of education, by field and by institution.

UA welcomes the partial reallocation of places proposed in the discussion paper. A reallocation of this kind will enable meaningful effort to align demand and supply, without the very significant disruption and uncertainty that would necessarily be involved in reallocating all designated CSPs. A periodic partial reallocation will also enable Government to fine tune the process and respond to unexpected development and unintended effects. The paper’s proposal to reallocate a 5 per cent share of commencing places seems reasonable.

UA does not seek to prescribe how CSPs should be allocated. Instead, we outline suggested principles that should guide allocation of CSPs at the three different levels.

For the full report, click here (PDF 301.9KB)