CONCLUDING SUMMARY

It is quite clear from this report that the introduction of a mandatory Code has been beneficial, and extensively so. Institutions with some experience of IS, and

notably those who were already signatories to the earlier voluntary Code, almost universally saw the introduction of the mandatory Code as a positive move. Other institutions appear to have accepted the Code as a positive set of compulsory guidelines which would assist them to deliver quality programmes.

The above comments are borne out by each of the key result sections of this report.

First, the application process initially seemed to some to be both complex and highly fraught with "unnecessary difficulties" (primary school principal). The

evaluation evidence rejects this view. Most of those who applied to be signatories were positive about the benefits of working through their current (or new) policies and procedures. Some did very definitely complain about the time, effort and, in the case of PTEs and other programmes with a good deal of printed publicity, the compliance costs of the process. Yet even these institutions were able to report on the benefits gained. It is worth mentioning that some of the complainants from

the primary sector had perhaps not realised that they in fact financially benefited from the provisions of the December 2002 legislation (Education (Tertiary Reform) Amendment Act, 2002), following on from which the new 'Levy' proved to be significantly lower than earlier central charges for primary schools with just a few IS.

Second, the Code application process had a reportedly positive outcome in the majority of the institutions interviewed. This occurred in one of two ways: those with good systems made only minor changes but made comments like "We felt affirmed", or "It was great to find that we were doing it right!" Those with less or very little expertise commented about the usefulness of the application guidelines in terms of knowing exactly what they had to do.

Third, what can be concluded from the Code review process to date? As noted earlier, the Ministry are to be commended for seeking an extended consultation process. They went well beyond the statutory obligations in seeking industry comments. While the significance of the proposed changes may well have been a factor in this decision, the fact remains; the minimum period of review set out in the 2002 Code was exceeded by a factor of more than 100 per cent.

The above comments need of course to be put into perspective. Some of the revisions to the 2002 Code were legally required, as they arose from the

legislation passed in December, 2002. Also, several informants reported that the very contested area of change related to IS in primary schools was an issue driven by Government, and that the Ministry had responded by gathering initial data to assist in the decision-making process. The Ministry more recently responded to a significant number of primary submissions to the Discussion Document (Ministry of Education, 2003b), by seeking further evidence before going back to Government for their final decision.

Finally here, it is really important to emphasise that the number of complaints to

to IS about grievance procedures. The latter point could mean that complaints which never would have surfaced in earlier times have now been lodged (see Section 6.5). This - if correct - is to be applauded, as unrealised complaints are much more likely to have a negative effect on New Zealand as a destination, when disgruntled IS go back home and say that their concerns went unheeded.

7.3 RECOMMENDATIONS

A mandatory Code could be considered as something of a gamble. Primary

schools with the 'occasional' IS were in one sense justifiably angry that they had to become signatories and comply with what some felt were overly bureaucratic regulations. At the other end of the spectrum, most of the institutions with sizeable numbers of IS who were interviewed welcomed the introduction of a mandatory Code because they were much more aware of the international context of the IS market, and of the importance to their own institution in particular, and to New Zealand in general of the need for quality assurance.

Recommendation One: That the introduction of a mandatory Code of Practice by the Ministry is to be commended as a very positive move in the light of the current state of IS programmes in New Zealand.

An important issue explored in the interviews was the 'status' of the Code. While the interviewers were careful not to ask any leading questions, there were

sufficient questions and probes asked of key players to determine what the Code, and applications to be signatories might entail. As should be clear from earlier sections in the report, these key players were almost unanimous in their

responses. While they believed that only major changes should be signalled to the Code Administrator (cf. below), they also raised no objections to on-going changes to the Code.

Recommendation Two: That the Code be regarded as a 'living document', and that the Code Administrator (currently, the Ministry), make it clear that necessary and/or desirable improvements/changes are likely to

continue to occur; but that such changes will typically not require significant/new application procedures on the part of signatories.

The possibilities of a review of signatory status brought a mixed response from institutions interviewed in this evaluation. Some believed that a 'major change', as for example a change of owner or CEO, or the introduction of for example under-18 students, or an affiliated language school, should require a completely new application. Others disagreed. Some (from both camps) believed that a 'new'¹⁸ application every X years (the suggestions ranged from three to five), was

nevertheless a sensible move. As quoted in Section 6.3, one respondent simply remarked "things change". A further issue arose during the Code review process, where the possibility has been raised of a new owner/CEO formally required to signal their agreement to abide by the earlier Code application, or to lodge a new one. The Evaluation Team considers this a sensible addition for the private sector, but notes there are still some issues to resolve in the case, for example, of ownership being held by shareholders.¹⁹

Recommendation Three: That the Code Administrator urgently develop a mandatory set of procedures relating to the requirement of signatories to notify the Administrator of changes to the original Code application, and/or conditions under which a new application must be submitted;

and that a new owner/CEO of a PTE be required to accept the status of the previous Code application, or lodge a new one.

The Ministry is currently developing a document which will give clear guidelines on the Code requirements. This will be a major extension of the earlier document which gave guidelines on IS accommodation (Ministry of Education, 2002d). The Evaluation Team strongly endorses this new development, as the attempt to cover every base in a legal document (the Code), is inevitably going to leave loopholes and problems in a number of areas.

18 A 'new' application could of course be identical to the one sent in previously, if

Furthermore, the notion of this guideline document being a living document is strongly endorsed. This seems to be one of (two) important areas where 'best practice' guidelines can be regularly updated. The other (see below) is on the Ministry website.

Recommendation Four: That the Ministry is to be commended for the

decision to develop a comprehensive set of 'guidelines' to accompany the revised Code of Practice, and is encouraged to make this guide a 'living document', with best practice ideas inserted as they are

provided.²⁰

As hinted at in the paragraphs above, it is very important that best practice ideas are readily available to all providers of IS programmes. Realistically, while revisions to the Code guidelines should (must?) include information about best practice, this in itself is insufficient. Providers need to be able to access up-to-date information instantly from an appropriate website.

On the same line, some IS-related organizations already have best practice issues as a focus. It makes national sense for these issues to be shared. This suggests that groupings /organizations like ISANA, APPEL, NZAPEP and the International Managers in Polytechnics (IMPS) be invited to contribute. While it has also been noted by a few of those interviewed that the Ministry website access is not

currently optimal, it has also been argued that this needs to change. These comments lead to two linked recommendations.

Recommendation Five: That (currently) a specific site on the Ministry's International website be devoted to a regularly (e.g. monthly) updated listing of 'best practice' suggestions relating to IS programmes; and that relevant organisations, institutions and industry groups be encouraged to support such a site.

20 This in turn strongly suggests a ring-binder publication format, so that new pages can easily be inserted, and/or outdated pages removed.

Recommendation Six: That the Ministry develop a website protocol which clearly signals a 'best practice' link; and that the Ministry investigate ways of encouraging providers to visit their website on a regular basis (at least once a month) to see what new best practice and other IS-related ideas are available.

A further suggestion arising from one person interviewed was that key information from other Ministries/agencies should be available on the Ministry website, rather than having to work through links. Primarily this would involve NZIS, but relevant material from (for example), Health and ACC could also be very useful. Such a move may also serve to encourage more providers to visit the site, but it would mean that any changes on the part of other Ministries would need to be

immediately incorporated.

Recommendation Seven: That the Ministry investigate the possibility of adding to their International website relevant information from other Ministries, so that providers could access such information without searching through other sites.

The information and discussion offered in Section Five tend to show that there is a need for strong central administration and monitoring of industry developments at this stage. The Evaluation Team also does not consider that 'the industry' is sufficiently defined or established for it to be an easy matter to transfer the Code Administrator's position to any other body in the immediate future. There could be, for example, some real risks if a transfer of responsibility was made to one of the currently constituted sectoral organizations, given the complexity of the field and the differences among sectors.

Recommendation Eight: That the Ministry continue to manage the office of the Code Administrator for at least the next two to three years.