An entrance sign welcoming people to UOWs Wollongong campus in the local Aboriginal language.

Submission in response to the Australian Universities Accord Interim Report

Submission in response to the Australian Universities Accord Interim Report

The University of Wollongong (UOW) welcomes the Accord Interim Report. We have undertaken a broad process of consultation with key stakeholders.

UOW supports the commitment to reform of the tertiary education sector to ensure Australia’s future productivity and resilience. We recognise that increased participation from underrepresented members of our society, assurances for a fair, accountable, and sustainable sector, and planning for and addressing our future skills needs.

We appreciate the Panel’s commitment to delivering outcomes that ensure the sector has the necessary support, environment, and mechanisms to deliver growth for skills through greater equity and look forward to being a contributing member to this ongoing reform discussion.

Three biggest reflections on the Interim Report

UOW applauds the breadth of critical issues the Accord Interim Report seeks to address including equity participation and access, research support, full cost of research funding, and staff and student underpayment and wellbeing.

These issues are all symptoms of a system that is stressed and underfunded relative to our Organisation for Economic Co-operation and Development (OECD) peers and have driven the sector’s adaptation to these constraints (e.g., reliance on international student fees, cross-subsidisation, lean and fragile operating models as well as increasing costs of regulation and business systems).

Whilst short-term funding increases are unlikely, the Accord Interim Report lacks the inclusion of a roadmap to build a long-term pathway to achieve parity with our OECD peers in terms of the percentage of gross domestic product (GDP) allocated to higher education and research. A commitment to a modest year-on-year increase and a simpler, sustainable funding model would allow universities the opportunity to invest over a longer timeframe.

It is essential that there is recognition that support for equity students will incur additional costs to higher education providers and require additional direct support to students to ensure the laudable goals in the Panel’s final report are achievable.

The focus on under-represented student groups is applauded in the Accord Interim Report and we hope this continues through to the final report and implementation, including consultation and co-design of future higher education policies with these groups. Ensuring the broader voice of a more diversified student base in university governance should be considered.

In our consultation on the Accord Interim report, the impact of climate change on the globe and nation was raised as a gap and we hope that - as a matter of national priority - the impacts of climate change and the pivotal leadership roles that universities will play in dealing with this crisis will be central in the final report.

Areas of substantive agreement or disagreement

A larger fairer system

UOW strongly supports the Panel’s ambitious 2035 target of population parity, across all equity groups; however, to meet these ambitious targets, we suggest the current definitions of student equity be expanded to include Priority Learners to the groupings below:


Aboriginal and Torres Strait Islander Students

Students from low-income families and those experiencing financial hardship

Students from regional and rural areas

No parental experience of higher education (first in family)

Students who are racially, culturally and linguistically diverse

Students from remote areas

Care experienced students

Students with caring responsibilities

Students with disability, including medical conditions

Students who are part of LGBTIQA+ communities

Students transitioning from vocational courses

Students from refugee backgrounds and those seeking asylum

Students from Pasifika communities

Students from disadvantaged schools

Women in non-traditional areas


A reframing of student equity groups to Priority Learners recognises the systemic barriers to higher education affecting broader disadvantaged cohorts and assists the sector in applying universal design principles and inclusive learning frameworks to help us identify and address these barriers. This also signals a broad and inclusive strengths based model.

UOW strongly supports the Panel’s recommendation for student-centred, needs-based funding models, and we suggest a new funding model for the higher education sector should reflect the following principles:

  • Universities should have responsibility for the provision of a core set of services for all students that should be funded by their operating budgets and confirmed through mission-based compacts process. This is critically important to support universities who have already demonstrated a commitment to equity principles and lack the corpus of funds generated from philanthropy and investment profiles.
  • Additional ‘equity’ loading should be applied to provide additional, more personalised support directly to Priority Learners.
  • Student fees should be nuanced so that course costs do not drive student decision-making as seen with the Jobs Ready Graduates funding model.

In addition, a new funding model must aim to reduce student poverty in our higher education institutions by ensuring that Commonwealth Supported Places do not result in a student contribution that can adversely impact Priority Learners throughout their lifetime and limit participation.

The creation of a lifelong learning passport could provide students with an associated amount of funding across the lifetime of learning across VET and higher education (including pathways and enabling programs) and so that students can make informed choices free of debt aversion.

The provision of a national package of income support, including support for students on internship and placement, accommodation and travel costs, and co-curricular opportunities, in the form of a universal student income (Student Success Package) will be necessary to achieve the vision set out in the Accord Interim Report.

Meeting Australia’s future skills needs

UOW strongly agrees with the Panel’s recommendations to place an increased emphasis on work integrated learning and investment in the establishment of a national jobs broker system to assist students to find work placements and part-time jobs in their fields of study. We also support the consideration of the jobs and placement brokerage system being funded and managed nationally but integrated within each institution to reflect a university’s local context, relationships and community needs. Recognising the critical value of migration and internationalisation and the important value of international students should be considered.

UOW welcomes greater collaboration with industry to ensure the curricula reflect new knowledge in high-priority disciplines particularly and in the context of providing sustainable career pathways for students. This will also ensure that there is greater long-term alignment between dynamic industry needs, and the depth and breadth of skills-based learning and training developed by universities.

We also suggest that the government incentivise industry to work more closely with higher education providers through tax incentives and other strategies.

Equity in participation access and opportunity

UOW strongly supports the Panel’s recommendations to increase access to preparatory and enabling programs to provide more pathways into higher education and create portable, stackable credentials. We suggest that these enabling programs are free or at a very low cost.

Whilst expanding the Regional University Centre model, we suggest the Panel look to other examples of place-based higher education delivery, including UOW’s Regional Campuses in Bega, Batemans Bay, Shoalhaven and the Southern Highlands.

These campuses have a long history of aspiration building with regional NSW communities, through partnerships with schools, TAFE NSW, and industry to ensure pathways to higher education are accessible, supportive of the community, and delivering a holistic student experience and great outcomes. Local retention of graduates creates real social capital for the communities in which these campuses sit.

Excellence in learning teaching and student experience

UOW commends the Panel’s commitment to a student-centric and personalised approach to teaching and all factors that enable the delivery of a quality and innovative learning experience. We look forward to collaborating on pedagogy, curricula and tools that allow the sector to scale and innovate at the pace students and industry require - both here in Australia and at our global campuses. We also recognise the importance of digitalisation and the increased associated costs in leveraging this most important asset to increase and widen participation across the lifespan.

As research is a critical component of higher education as it informs teaching and learning, we hope the Panel keeps in mind the importance of research-informed teaching in the larger context of equity and student experience.

Fostering international engagement

With the shifting environment and rapidly changing expectations in the global landscape of recent years, UOW supports a review to ensure Australia’s agility and adaptability to ongoing uncertainty and the proposed considerations for change. UOW understands the challenges posed by international student growth while aspiring to deliver a positive student experience and quality outcomes for all people enrolled. UOW is well-placed as an institution to provide further guidance and comment in this regard, in the context of our well-established offshore campuses in the United Arab Emirates, Malaysia and Hong Kong.

Whilst we support the notion of a wealth fund to build sovereign capability and address sovereign risk, we cannot support a levy on international student fee revenue, so that it does not result in a perverse perception that negatively impacts students and the appeal of Australian higher education in a highly competitive global market.

Serving our communities

Recognition of the ‘heavy lifting’ role universities play in their local communities and the unique challenges they face is reassuring. Fundamental to UOW’s strategy and mission is its civic responsibility to the social and economic health of our communities, both here in Australia and overseas. Our work in regional medicine and nursing, with Indigenous communities and industry, is only a small example of the work in which we have been involved in for over 20 years on our campuses of the South Coast of NSW. We welcome any future investment to support these efforts and connections.

With the ongoing environmental impact of climate change affecting our regions, universities have played a significant role in our communities’ crisis response in times of flood and fires. Universities are also key partners in helping address the crisis of climate change.

Research, innovation, and research training

UOW welcomes the recognition of the role university research plays in national research and development, and the need to strengthen and protect our sovereign research capability and address sovereign risk.

UOW supports an increase in the specified percentage of GDP on research & development and the potential amalgamation of funding for the National Health and Medical Research Council (NHMRC) and Medical Research Future Fund (MRFF). Australian Research Council (ARC) funding could also potentially be amalgamated with National Collaborative Research Infrastructure Strategy (NCRIS).

As the Panel has expressed, the current funding arrangements are unsustainable to achieve the high– quality and high-impact research required to achieve sovereign capability and our position of strength in the region. UOW agrees that university research is significantly underfunded for the outcomes and innovations expected.

Although Australia’s research and development vision requires a multi-pronged contribution from industry, public and private organisations, and philanthropy, it is the government investment that will catalyse an immediate and greater impact and ensure sustainability. It is also important to recognise that the research enterprise of universities contribute to significant employment and productivity.

Embedding and promotion of First Nations led research and knowledge systems is welcomed by UOW, as is the investment into research training, support, and funding for PhDs. Both are critical to ensure Australia’s research workforce and leaders, particularly in areas of sovereign risk. In addition to the difficult issue of attracting, retaining and supporting PhD candidates, the government and industry should review how best to address the cost-of-living pressures through mechanisms such as tax incentives and, potentially, a universal living wage.

National governance: towards a coherent tertiary system

UOW welcomes the establishment of a Tertiary Education Commission to help steer the oversight of reforms to facilitate the alignment between VET and higher education at state and federal level. We recognise that the delivery of a single tertiary system is a complex undertaking; however, it could deliver a more streamlined, efficient, and simpler tertiary structure with opportunities for economies of scale that would support the progress of the Accord’s reform agenda.

Ensuring strong stakeholder representation and transparency of operations will be critical in achieving the ambitious goals of the Accord. Whilst the consideration of a second national university to support regional campuses is conceptually alluring, the pragmatic implementation may erode issues of community identity, engagement and ownership which we have found critical to success in our regional campuses.

Institutional and collaborative governance

UOW strongly supports efforts to strengthen institutional governance structures to address systemic issues of the underpayment of staff, student and staff wellbeing and safety. It is important to recognise that these issues are not isolated in the university sector. For example, consideration could be given to the simplification and standardisation of pay awards and schedules for the casualised workforce within the sector.

We support discussion and examination of governing body membership and review of the Code of Best Practice to ensure it is fit for purpose to facilitate a reformed higher education sector. Membership should be governed by an explicit skills matrix that matches the needs of the institution and is reflective of the diversity and culturalism pluralism of modern Australia.

UOW, through its Innovate Reconciliation Action Plan, is committed to amplifying the voice of First Nations peoples and students at all levels of the institution. In late 2021, UOW signed a ‘Students as Partners’ charter and developed a framework to ensure students had a greater voice in University governance.

Ensuring our communities feel safe on our campuses while studying, researching, or working is of the utmost concern to UOW. We have realigned our business areas responsible for support, advocacy, monitoring and reporting, with clear reporting lines to the Senior Executive. We welcome further guidance and collaboration on this important issue to ensure students are not faced with any impediments to their study and experience. Similarly, we support any additional guidance and mechanisms that assist us in eliminating workplace exploitation of our international students.

Sustainable funding and financing

UOW agrees that the only way forward to achieve the vision of the Accord and ensure Australia’s future productivity is to have a secure, sustainable and enduring funding system for the sector and for students, so they can complete their studies without unreasonable debt and for universities to receive sufficient funding to enable financial health and quality delivery of their mission.

We look forward to engaging in a redesigned compact process that supports a university’s commitment and connection to its local communities and regions whilst also addressing national priorities.


What measures of success could the panel propose to track the outcomes of accord recommendations?

Financial stability is central to the achievement of many of the goals of the Accord. Developing appropriate measures of university financial stability could be a key consideration. Moreover, any measures developed should be independently managed, objectively verifiable and the ability to reveal key trends.

As mentioned earlier, the percentage of GDP allocated to research and higher education would be an informative measure of success for Australia to attain the OECD average.

Regarding the measures of success in tracking progress of the student equity outcomes, we suggest an increased focus on student equity outcomes and the related measures of success as outlined in the Quality Indicators for Learning and Teaching (QILT).


We thank the Panel for the opportunity to respond to the Accord Interim Report’s proposals, and we look forward to ongoing discussion and consultation as the final report, the legislated instruments and implementation guidelines take shape.