As the Discussion Paper notes, it is timely to review the PCS to complete the process of reviewing the Higher Education Threshold Standards and ensuring they are fit for purpose and working well.

UA considers that the PCS are effective and appropriate and there is no need for major changes to the architecture. In particular,it is UA’s view that the ‘university’ categories are well designed and appropriately specified. We do not see that these categories are in need of revision.

On the other hand, there is merit in examining the large and undifferentiated ‘higher education provider’ (HEP) category. It may be beneficial to providers, employers and – most importantly – students to provide for differentiation of provider types within this grouping.

UA does not have particular views about exactly how the HEP category might be redesigned. Indeed, it would not be appropriate for universities to seek to impose categories or definitions on non-university higher education providers (NUHEPs). We would, however, be interested in engaging in further discussion with the Review Panel, providers and other education sector stakeholders on possible options to develop transparent and useful categories for NUHEPs.