02.2016 05 23 Takitimu Performing Arts School Trust Edumis 9847 Final....pdf

A1002112

Tertiary Education Commission
the

1982
Audit Report

Act

under

Te Wānanga Whare Tāpere O Takitimu

Student Achievement Component Funding

Information

Released
Official

Edumis Number: 9847
Audit Date: 19 - 20 April 2016
Draft Report Release Date: 13 May 2016
Final Report Release Date: 23 May 2016

1    Purpose

The purpose of the audit was to provide assurance that Takitimu Performing Arts
School Trust trading as Te Wānanga Whare Tāpere O Takitimu (Takitimu) is
meeting the Investment Plan Funding Conditions as referred to in the Tertiary
Education Commission (TEC) letters of approval dated 4 December 2014 and 21
December 2015.  The funding approved includes Student Achievement
Component funding.

2    Scope

The scope of the audit was aligned to the performance commitments in the TEC
Investment Plan and the associated funding obligations between the TEC and
Takitimu.  The scope was outlined in the audit arrangements letter.

The focus areas included:
  The reporting through the Single Data Return, including recording enrolments
and withdrawals.
  The Annual Maximum Fee Movement (AMFM) policy relating to  ees and
course costs.
  The refund of fees that have been overcharged.
  The financial support for the equipment infrastructure required to deliver the
approved qualifications.
  Whether inducements or benefits have been p ovided to students.
under the
  Responsibility for subcontracting arrangements.
  Compliance with the requirements in Part 18 of the Education Act 1989.
  Any other TEC funding ma ters.
An audit is a snapshot of an organisation’s performance at a particular point in
time and may not, as such, provide a view of ongoing compliance.  An audit is
based on samp ing and issues may remain undetected. The outcome of this audit
wil  contribute to decisions made by the TEC relating to current and future
funding.

Released
3    Background

This audit is part of the TEC’s ongoing monitoring of Tertiary Education
Organisations.

Takitimu is a Māori Private Training Establishment (PTE) based in Hastings
offering programmes in Māori Performing Arts.

The organisation receives Student Achievement Component funding for the
Official Information Act 1982
following qualifications:

  PC9004 Certificate in Māori Art (Advanced) (Level 7)
  PC9006 Diploma in Māori Performing Arts (Level 6)
  PC9005 Certificate in Māori Performing Arts (Level 5) (This is an exit
qualification for PC9006).

2

4    Findings

      The findings were:

  Takitimu commented that they last offered in 2003 a level 4 qualification in
Māori Performing Arts.  There is a discrepancy in the Investment Plan for
2015 Summary of Activity (NC0701) and the Mix of Provision Master
Template for 2016 that refers to the qualification, PC2882.  There were no
tauira (students) reported in either qualification in the December 2015 or April
2016 SDR.

  Funding was claimed for three tauira not reported as early withdrawals.

  Domestic status was not established for seven tauira.  Under funding
condition SAC3+018: TEO to confirm that each student is a va id domestic
enrolment there is a table of verification methods for a New Zealand citizen.
One method relates to the student’s NSN.  There was no evidence presented
during the audit that the student’s citizenship status was confirmed using the
student’s NSN for the seven tauira.

  Two tauira had been re-enrolled in 2015 without a re-enrolment form.  Both
tauira were previously enrolled in 2011 and 2012 respecti ely.

  Offer of placement letters were not provided to part-time tauira and evidence
of offer of placement letters was not retained in the student management
under the
system for full-time tauira.

  There was no documented policy covering no fee payment required for tauira
aged 55 years and above and studying part-time.

  Re-enrolment forms for tauira returning to study in a second year were
minimalist, consisting of one page.

  Funding was incorrectly claimed for one tauira for seven courses in 2011
prev ously funded.

  Staff development policy did not cover the waiving of fees for staff enrolled in
Released
Takitimu programmes.

  The NZQA Record of Achievement is not accessed during the enrolment
process to ascertain if tauira may be eligible for Recognition of Prior Learning.

Official Information Act 1982
4

5    Recommendations

The recommendations were:

  Review the 2016 Mix of Provision Template and confirm if the details are
correct.  If the Level 4 qualification is to be offered the TEC would expect to
be advised given that it was commented during the audit that it had last been
offered in 2003.

  Funding recoveries are sought for the three tauira not reported as early
withdrawals.

  Funding recoveries are to be discussed for the seven tauira where domestic
status was not established.  (The Manager, PTE and CE Investment has
reviewed this report and determined that the TEC wil  not seek recovery of
funding relating to this recommendation.  The details, on page 8 of this report,
are included to quantify the consequences if recovery of funding was to
occur).

  Funding recoveries are sought for the two tauira re-enrolled in 2015 without a
re-enrolment form.

  Offer of placement letters are provided to all tauira and evidence retained in
the student management system

under the
  Takitimu to provide a copy of their policy covering no fee payments required
for tauira aged 55 years and above and studying part-time.

  Review the enrolment process for returning tauira.

  Funding recoveries are sought  or the funding of one tauira in 2015 who had
achieved in 2011 all seven courses.

  Review the staff development policy including the waiving of fees and
appl cation process.
  Released
  Access the NZQA Record of Achievement during the enrolment process to
ascertain if tau ra may be eligible for Recognition of Prior Learning.

Official Information Act 1982
5

Enrolment Records
  Enrolment records in the sample of records reviewed held minimum
information and the overal  standard of recordkeeping was
unsatisfactory.
  Takitimu commented that there have been changes in
administrative personnel in the last two years; however, this does
not address the requirements of the TEO to keep enrolment records
(SAC3+016), verify student’s identity (SAC3+017) and confirm
domestic enrolment status (SAC3+018)1.
  The poor standard of recordkeeping has resulted in a number of
findings relating to ineligibility. This includes:
o  Funding claimed for three tauira not reported as early
withdrawals
o  Domestic status not being established for seven tauira and
o  Two tauira re-enrolled without an enrolment form

Funding claimed for tauira not reported as early withdrawals.
  There were three out of 19 records sampled where funding had
been claimed in the December 2015 SDR for tauira not reported as
early withdrawals.  In the three records the withdrawal date in the
SDR was reported th  same as the cours  end date. Funding in
the three cases sh uld not have been claimed.
  The following table details the th ee records and the funding
under the
claimed.
NSN and
Sta t
End Date and
EFTS
Dollar
Comments
Qual Code
Date
SDR
Delivered
Delivered
Withdrawal
(GST
Date
exclusive)
9(2)(a)
sed

28/07/14
06/04/15
0.4
$   2,406
Withdrawn on
(PC9004)
03/08/14 (7 days).
Withdrawal
approved by
CEO.
9(2)(a)

28/07/04
05/07/15
0.5398
$   3,246
Withdrawn on
(PC9004)
03/08/14 (7 days).
Withdrawal
approved by
Rele9(2)(a)  Information Act 1982
CEO.

27/07/15
11/12/15
1.001
$   6,020
Attended 1 full
PC9004)
day on 16/09/15.
Attendance on
first day 27/07/15
incomplete. No
other attendance
and no notes on
file. Should have
been an early
withdrawal.
Officia    Total  1.9408  $ 11,672


1 In 2015 the funding conditions were numbered SAC3+/017, SAC 3+/018 and SAC3+/019.
7

Domestic Status not established for seven tauira
  Under funding condition SAC3+018: TEO to confirm that each
student is a valid domestic enrolment there is a table of verification
methods for a New Zealand citizen.  One method relates to the
student’s NSN. There was no evidence presented during the audit
that the student’s citizenship status was confirmed using the
student’s NSN for the seven tauira.
  There was no evidence of domestic status recorded for tauira NSN
9(2)(a)
.
  Domestic status could not be established for three tauira where a
New Zealand driver licence had been submitted. The tauira NSNs
were: 9(2)(a)
, 9(2)(a)
and 9(2)(a)
.
  In the additional sample of four records, a New Zealand driver
licence had been submitted for two tauira. The tauira NSNs were:
9(2)(a)
and 9(2)(a)
.
  A whakapapa statement had been submitt d with the enrolment for
tauira NSN 9(2)(a)
; however, this was invalid as it had not been
certified by a kaumatua.
  The following table details the seven records and the funding
claimed.
NSN and
Start
End Date
EFTS
Dollar
Comments
Qual Code
Date
and SDR
Delivered
Del vered
Withdrawal
(GST
Date
exclusive)
9(2)(a)
under the

27/07/15
08/07/16
0.4608
$ 2,771
Withdrawn on
(PC9005)
29/10/15.  No
evidence of
domestic status.
9(2)(a)

23/02/15
11/12/15
0.417
$ 2,508
NZ Driver Licence
ed
(PC9006)
is not evidence of
domestic status.
9(2)(a)

23/02/15
1 /12/15
0.584
$ 3,512
NZ Driver Licence
(PC9006)
is not evidence of
domestic status.
9(2)(a)

27/07/15
08/07/16
0.4608
$ 2,771
NZ Driver Licence
(PC9005)
is not evidence of
domestic status.
9(2)(a)
Information Act 1982

23/02/15
11/12/15
0.584
$ 3,512
NZ Driver Licence
Rele(PC9005)
is not evidence of
domestic status.
9(2)(a)

23/02/15
11/12/15
0.459
$ 2,760
NZ Driver Licence
PC9005)
is not evidence of
domestic status.
9(2)(a)

23/02/15
11/12/15
0.584
$ 3,512
Whakapapa
(PC9005)
statement invalid
as not attested by a
kaumatua.
Domestic status
not confirmed.
Official    Total  3.5496  $ 21,346

8

Two tauira re-enrolled without an enrolment form
  There were no 2015 enrolment forms for two tauira NSNs 9(2)(a)
and 9(2)(a)
. Both tauira were previously enrolled in 2011 and
2012 respectively.
  As there is no evidence of a current contract for 2015 the two
enrolments are deemed invalid for funding purposes.

  The following table details the two records and the funding claimed.
NSN and
Start
End Date and
EFTS
Dollar
Comments
Qual Code
Date
SDR
Delivered
Delivered
Withdrawal
(GST
Date
exclusive)
9(2)(a)

23/02/15
11/12/15
0.417
$ 2,508
No 2015
(PC9006)
enrolment form.
9(2)(a)
23/02/15
11/12/15
0.417
$ 2 508
No 2015
(PC9006)
enrolment f rm

Total
0.834
$ 5 016

Offer of placement letters
  Offer of placement letters are p ovided to full time but not to part-
time tauira.
  A copy of the offer of placement letter is not retained.
  Al  tauira, regardless of part-time or full-time status, should receive
an offer of placement letter. Such letters record important
under the
information about an enrolment in luding the name of the tauira,
course start and end dat s, the programme the tauira is enrolled in
and, if fees apply, the amount required to be paid.
  The offer of placement letter template sighted records the relevant
info mation but a record for each tauira should be retained for audit
trails.

Fees waived fo  part-time tauira aged 55 years and above
  There was no policy detailing upon what basis part-time tauira aged
55 years and above had had their fees waived.
Released
  Takitimu commented that al  part-time tauira aged 55 years and
above do not pay fees.  Takitimu claims SAC funding for each part-
time enrolment.
  It is important that fee waivers are recorded because an invalid
enrolment for funding purposes is one where a tauira is required to
pay a fee and fails to do so. Refer to 2016 funding condition on
pages 7-9: SAC3+ Valid domestic enrolment sections 1(d) and 5
and for 2015 the corresponding sections in SAC3+/016.
Official Information Act 1982
  Takitimu is also directed to 2016 funding condition: SAC3+019:
TEO not to induce enrolment and for 2015 the corresponding
SAC3+020 and the section Definition of scholarship.
  Full-time tauira are charged fees and are eligible for loans and
allowances.

9

Re-enrolment forms
  Tauira returning to Takitimu to study in a second year complete a
simplified one page re-enrolment form.

  The re-enrolment form does not replicate the information contained
in the enrolment form including contractual obligations.
  Additionally, part-time tauira do not receive an offer of placement
letter.

  High EFTS claimed for one tauira – reporting error
  There was one tauira NSN 9(2)(a)
reported in the December
2015 in 14 courses. Seven of the courses in 2011 had been
previously funded. This is a reporting erro  and must be reversed.
  The details are included in the following table:

NSN and
Start
End Date
EFTS
Dollar
Comments
Qual Code
Date
and SDR
Delivered
Delivered
Withdraw
(GST
al Date
exclusive)
9(2)(a)

27/07/15
08/07/16
0 4608
$ 2,770
Reported in Dec
(PC9006)
2015 SDR in 14
courses at 1.2368
EFTS Delivered
($ 7,438)
under the

Total to
0 4608
$ 2,770
No funding to be
be
claimed for 7
recovered
courses (DMPA
101-107) in Year 1
of PC9006.

  Staff Development Policy

  In the s mple of tauira records reviewed there was one member of
staff r ported in a programme offered by Takitimu.
  There was no documentation waiving course fees.
  Th re was also no evidence on file of domestic status but this was
obtained and sighted during the audit.
Released
  Takitimu has confirmed employee NSN 9(2)(a)
, was not
teaching in the subject they were also studying.
  Fee waivers should always be documented and authorised. The
staff development policy should be reviewed and updated.

NZQA Record of Achievement
  Upon enrol ing tauira there is no check undertaken of the NZQA
Record of Achievement for prior learning. It is important that these
records are checked as some tauira may be eligible to apply for
Official Information Act 1982
Recognition of Prior Learning (RPL).

  Approved RPL potentially reduces the amount of funding paid by
the TEC. It may also lead to a reduction in fees and the amount a
tauira may need to borrow from Studylink if applying for loans and
allowances. The time a tauira requires to complete a qualification
may further be reduced.

  One example of potential eligibility is tauira NSN 9(2)(a) .
10

  This person holds 238 credits in unit standards to level 6 in 9(2)(a)
and 18 credits in unit standards to level 3 in
9(2)(a) .

  The tauira completed the form QA2 116 Application for Recognition
of Informal and Formal Learning towards a Qualification (but at the
end of the course).

  In discussions with Takitimu it was indicated the tauira was fully
competent for course CMPA 101 Te Reo / Tikanga. If the tauira
had prior learning approved then funding would not be claimed for
this course.

  In this case Takitimu was not complying with its own RPL policy
This subject is covered in more detail in section 8.

2.  The Annual
  Takitimu is complying with the Annual Maximum Fee Movement
Maximum Fee
Policy.
Movement

policy relating
Year
All Programmes
Increase
to fees and
course costs.
PC9004

PC9005
PC9006
2014
4,196.60

under the
2015
4,364 40
4%
2016
4,364 40
Nil

3.  The refund of
  There was n  evidence that tauira have been overcharged fees.
fees that have
been
overcharged

4.  The financial
  Tauira were not required to individual y purchase any item of
support for the
hardware or equipment necessary to gain the approved
equipment
qualification.
Released
infrastructure
required to
  Tauira are provided with a list of compulsory course costs that
deliver the
includes a piupiu (dancing skirt).
approved
  The tauira can also purchase materials for the making of Whetu
qualific tions.
Tātua and Poutama Tātua Korowai (which are the belts used

during performance). The tauira learn how to make these items
during their performance paper.

Official Information Act 1982
5.  Whether
  From the sample of records reviewed there was no evidence of any
inducements or
tauira being provided with an inducement or benefit to study.
benefits have
been provided

to students.



11

6.  Responsibility
  There was no subcontracting of education provision.
for
subcontracting
arrangements.

7.  Compliance
  The overal  standard of recordkeeping for enrolment records was
with
inadequate as detailed in section 1 above.
requirements
in Part 18 of
  Part 18 of the Education Act 1989 includes, but is not limited to
Education Act
student programme information and records.
1989.
  The organisation holds tauira records securely.
  The local qualifications offered by Takitimu are among the earliest
approved by NZQA and one approval letter was sighted that dated
back to February 1992.
  The most recent letter dated August 2006 from NZQA was sighted
that included PC9004 and PC9006.
  This was part of the NZQA Compliance Register Proje t   It was not
stated that PC9005 is an embedded qualification within PC9006
although the credit values match the rates at which the qualifications
are currently funded by the TEC. The NZQA letter did not break
down the learning hours to t aching hours weekly, work experience
and self-directed learning
  A review with Takitimu management of the teaching hours weekly,
work experience and self directed learning confirmed that full-time
programmes are being delivered as approved.
under the
  There was a slight under-d livery for tauira enrolled in PC9005 and
PC 9006 part-time.  A summary  f the discussion around hours
delivered is included in the f l owing table.
Part-time taui a enrolled in PC9005 and PC9006
Monday
Teaching hours
6.00 – 8.00 pm
2 hours (Only for
for Te Reo /
those that need it)
Tikanga
Tuesday
Teaching hours
6.00 – 9.00 pm
3 hours
Thursday
Teaching hours
6.00 – 9.00 pm
3 hours
Saturday

Not set

Total
Teaching hours

6-8 hours per
Released
week
Add
Self-directed

5 hours per week
learning
Add
Work
Recorded as 5 hours in STEO but
2 hours per week
experience
on average 2 hours per week
weekly
  The summary provides a range of 13-15 hours per week x 36 weeks
= 468-540 learning hours out of 600 hours required for a part-time
enrolment.
Official Information Act 1982
  This is an average under-delivery of between 12.8% and 11.1%.  The
under-delivery is not deemed to be material for funding purposes but
should be reviewed.

12

Level 4 qualification in Māori Performing Arts
  Takitimu commented that they last offered in 2003 a level 4
qualification in Māori Performing Arts.
     There is a discrepancy in the qualification included in the Investment
Plan for 2015 Summary of Activity (NC0701) and the Mix of Provision
Master Template for 2016 that refers to PC2882. In the 2016 Mix of
Provision PC2882 has activity indicated at 15.0 EFTS delivered
($90,210 GST exclusive).

  There were no tauira (students) reported in 2015 in either
qualification.

  Takitimu should review the 2016 Mix of Provision Template and
confirm if the details are correct. If the Level 4 qualification is to be
offered the TEC would expect to be advised given that it was
commented during the audit that the level 4  ual fication had last
been offered in 2003.

8.  Any other TEC
Recognition of Prior Learning
funding

matters.
  Takitimu has a Recognition of Prior Learning (RPL) Policy. The

policy does not detail th  administrative processes that should
follow once RPL has been approved.
    It is important to detail the process because of the funding
condition: SAC3+021: TEO not to seek SAC funding for recognised
under the
prior learning.

  Procedures are required t  ensure funding is not claimed through
the SDR where full RPL has been approved and the course EFTS
factor field needs to be reset to zero.

  In the case of partial RPL the course EFTS factor field should be
pro-rated.
    During the audit it was recorded on several academic Results
Sheets that RPL had been approved and tauira had also been
awarded a course Grade.  Complementing this were completed
RPL forms held in the enrolment file but curiously dated at the end
of the programme.
Released

  RPL (or Recognition of Current Competency) is an enrolment
process and not applied after a tauira has completed their studies.

  Takitimu explained that it undertook this retrospective analysis in
response to a 2015 Quality Improvement Plan action point
reviewing RPL assessments.

  Discussions during the audit indicated that some tauira may have
Official Information Act 1982
been eligible for full or partial RPL; however, without a full and
documented assessment it could not be established if RPL was
indeed applicable.

  Takitimu does not have a history of approving RPL but the
discussions indicated that some tauira could have been eligible
particularly those in the over 55 years of age category.

13

 Takitimu need to review their RPL policy and add a section detailing
the administrative adjustments to funding that are required when
RPL has been approved.

the 1982
Act
under
Released
Information
Official
14