Determining Genuine Students and Managing Student Progression

1. Purpose

This policy outlines the processes and criteria for determining whether students enrolled in VET Student Loans (VSL) approved courses are genuine students and for managing student progression and engagement. It ensures compliance with the VET Student Loans Act 2016 (the Act), the VET Student Loans Rules 2016 (the Rules), and the VET Student Loans Provider Manual (September 2025). The policy aims to promote student success, protect program integrity, and ensure that VSL payments are only made for genuinely engaged students.

2. Scope

This policy applies to all staff involved in student enrolment, progression monitoring, and compliance activities for VSL-eligible courses. It covers all students accessing or potentially accessing VSL, including those studying full-time, part-time, online, or through blended delivery modes.

3. Definitions

• Genuine Student: A student who is reasonably engaged in their course, as determined by factors outlined in the Rules (s 5), including engagement, awareness of course requirements, study load, and communication.
• Progression Form: An electronic form issued via the eCAF system for students to confirm their ongoing engagement and status (e.g., continuing, deferred, withdrawn, or completed).
• Progression Point: A scheduled interval (typically every 4 months) where students must submit a Progression Form to demonstrate genuine study.
• eCAF System: The Electronic Commonwealth Assistance Form system used for loan applications and progression forms.
• Census Day: The last day a student can withdraw from a unit without incurring a VSL debt.
• HELP Balance: A student’s remaining entitlement to government assistance under the Higher Education Loan Program (HELP), including VSL.

4. Policy Statements

4.1 Student Progression and Engagement

• Students accessing VSL must confirm their genuine engagement at regular progression points to continue receiving loan support.
• Default progression points occur at 4-month intervals (February, June, October), starting approximately 4 months after eCAF submission. Alternative points may be requested via the department if they better align with course delivery.
• Progression Forms must be triggered for all VSL students, including those who have ceased study, to capture accurate status updates and survey responses.
• Students have 2 weeks to complete and submit the Progression Form after receiving the invitation email. Failure to submit within this period requires re-triggering the form.
• Providers must not direct or compel students on their responses; students must independently indicate their status (continuing, deferred/withdrawn, recommenced, completed, or never commenced).
• For students who defer or withdraw:
  • Trigger a Progression Form immediately upon notification.
  • If deferring, students note the deferral date; upon resumption, trigger another form with the resumption date.
  • No payments will be made for days between deferral and resumption.
• For completed courses, students must indicate completion to stop VSL access.
• Absence of engagement (e.g., failure to complete 2 consecutive Progression Forms) may result in the department determining the student is no longer genuine, leading to cessation of VSL payments.
• Course completion rates must be monitored and reported accurately to maintain provider approval. Unsatisfactory rates may lead to compliance actions.

4.2 Determining Genuine Students

• A student is considered genuine if they demonstrate reasonable engagement, as assessed against the following factors (not exhaustive):
  • Engagement in the Course:
    • The student satisfies course requirements and participates in assessments.
    • For online courses, the student logs in a significant number of times (e.g., not insignificant occasions up to and including census day).
    • The student accesses course materials regularly.
    • The student attends classes (e.g., no more than a specified number of consecutive absences without valid reason).
    • There is ongoing communication with the provider after enrolment.
  • Awareness of Course Requirements:
    • The student understands course content, duration, costs, and obligations (evidenced through pre-enrolment information provided and confirmed via interactions).
  • Study Load:
    • The student’s enrolments and course loads are realistic for successful completion, considering full-time/part-time status, contact hours (including practicums), assessment nature, employment commitments, and family/caring responsibilities.
    • Enrolment in multiple courses making completion impossible or improbable indicates non-genuine status.
  • Communication:
    • The student provides up-to-date contact details and responds to requests for agreement to continue using VSL.
• The department may withhold VSL payments if a student is deemed non-genuine (e.g., failure to complete a valid eCAF or 2 consecutive progressions).
• Providers must not enrol or continue supporting students who do not meet genuine criteria, and may cancel enrolments for insufficient progress or attendance, following required processes (e.g., 28 days for grievance procedures post-census day).
• Genuine student assessments inform re-crediting decisions; the Secretary may decline re-credits if the student is not genuine.

5. Procedures

5.1 Managing Student Progression

1. Set up milestones in the Higher Education Information Technology System (HITS) for progression points.
2. Trigger Progression Forms via eCAF at the student level (individually, by spreadsheet, or student management software).
3. Send invitation emails to students’ personal email addresses (update if changed).
4. Monitor submissions; re-trigger if not completed within 2 weeks.
5. Educate students pre-enrolment on the importance of Progression Forms, response options, and deadlines.
6. For status changes (deferral, withdrawal, resumption, completion), trigger forms immediately and update records.
7. Report unit completions and course data accurately to avoid contraventions.

5.2 Assessing Genuine Students

1. During enrolment: Verify eligibility, provide pre-enrolment information, and assess initial study load feasibility.
2. Ongoing Monitoring: Track engagement via attendance logs, login records (for online), assessment participation, and communication.
3. At Progression Points: Review form responses alongside engagement data.
4. If Non-Genuine Suspected:
   • Gather evidence (e.g., logs, communications).
   • Notify student and allow response.
   • If confirmed, cancel enrolment per procedures, inform the department, and cease VSL access.
5. Audits: Cooperate with departmental audits; maintain records for review.
6. Cancellation: Inform students of proposed cancellation, refund circumstances, and 28-day grievance period before finalizing.

6. Responsibilities

• Compliance Officer/Manager: Oversees policy implementation, triggers progressions, and conducts genuine student assessments.
• Enrolment Staff: Provides pre-enrolment information and verifies initial genuineness.
• Trainers/Assessors: Monitor engagement and report concerns.
• Students: Maintain up-to-date details, complete Progression Forms promptly, and engage genuinely.
• Senior Management: Ensures ongoing compliance and adequate completion rates.

7. Monitoring and Review

This policy will be reviewed annually or following legislative changes. Non-compliance may result in civil penalties (up to 120 penalty units) or provider revocation.

8. References

• VET Student Loans Act 2016 (ss 20, 45, 58-59, 71)
• VET Student Loans Rules 2016 (ss 5, 86-87, 98)
• VET Student Loans Provider Manual (September 2025) – Sections 41 (Student Progression and Engagement) and 42 (Genuine Students)
• Appendices: L (Checklist of Information to Students), M (Sample Statement of Covered Fees)