The Higher Education Standards and their regulator, TEQSA, have had a major impact on the higher education sector in Australia. Nonetheless, the intended shift from the previous cyclical “big” audit regime to an ongoing “light-touch” regulatory regime is not evident. Substantial effort, time and cost remains associated with retrospective evidence-gathering, submission and assessment. Furthermore, there is no framework for demonstrating regulatory compliance at any point between submissions, despite the desired “culture of effective self-assurance being an integral part” of business-as-usual .
There is a lack of consideration in the literature of approaches to managing the submission cycle, and of alternate approaches to better achieving the intended ongoing regulatory regime. This paper presents one such alternative, namely, R3, a continuous, systems-based approach to establishing and maintaining the institution’s mapping from Regulations to institutional Responses to Records of evidence which demonstrate the deployment and quality assurance of that response. A potential fourth R, “risk”, is assumed to be handled by the institution’s risk management process.
The R3 mapping process requires structured documentation of comprehensive consideration of the institution’s responses to regulatory requirements; in essence, a compliance audit. The R3 system has been designed to help in capturing this mapping and then driving the continuous maintenance of the evidence base and its veracity. The system proactively tracks the work flow of such maintenance, escalating alerts when required evidence is not delivered in a timely manner.
An often-cited, aspiration for a standard is that it be “a tool that allows you to do more, rather than a grim necessity to which you must adhere.” . The R3 approach presented tackles current compliance “grimness”. It proactively and continuously drives keeping the evidence “in order”, creating the foundational assurance of regulatory compliance, that frees up capacity and courage to engage with improvement and innovation.