Student services higher education consulting is the work of designing, reviewing and evidencing the support a provider gives its students against Standards 1.3, 2.2, 2.3 and 2.4 of the Threshold Standards, which cover orientation and progression, diversity and equity, wellbeing and safety, and grievances and complaints. A consultant's contribution is to translate those standards into services a small provider can actually run, decide what can be outsourced, and make sure the record shows the services being used rather than merely offered.
This article explains what those four standards require, where private providers fall short, and how a review of support against the standards is conducted. It draws on fifteen years of TEQSA registration and compliance work with providers from single-campus colleges to multi-site institutions.
What the four standards require
Standard 1.3 requires that students are given orientation, that their progress is monitored, and that those at risk of not progressing are identified and offered support. Standard 2.2 requires that the diversity of the student body is recognised in admission, teaching and support, and that equity groups are not disadvantaged. Standard 2.3 requires a safe environment, wellbeing support and clear critical-incident arrangements. Standard 2.4 requires an accessible grievance and complaints process with an independent appeal stage, and it is one of the standards TEQSA reads most literally.
None of these requires a large student services department. What they require is a set of functions that exist, are reachable by every student regardless of mode or location, and leave a trace when used. The full text is in the Higher Education Standards Framework (Threshold Standards) 2021, and TEQSA's guidance note on wellbeing and safety is a useful companion, remembering that guidance notes are not themselves Threshold Standards.
Where small providers fall short
The failures I see most often are structural. Orientation is a single session on day one with no online equivalent. Progress monitoring is a spreadsheet the course coordinator keeps, with no trigger, no intervention record and no report to the academic board. Wellbeing support is a phone number for an external counselling service that no student has been told about. The complaints process is described in a policy, but the register is empty, which TEQSA reads as a process no student trusts, not as a provider with no problems.
The other common gap is international students. Providers on CRICOS carry additional National Code obligations that overlap with these standards, set out in supporting international students under TEQSA and ESOS. A support model designed for domestic students only will not satisfy either regulator.
What can be outsourced and what cannot
Small providers can legitimately outsource some services. Counselling and mental health support are routinely provided by an external employee-assistance-style provider under contract, and TEQSA accepts that if the arrangement is documented, promoted to students and monitored. Disability and learning support can be contracted. An external ombudsman or independent reviewer for the final stage of complaints is common and, for small providers, often the only way to make the appeal genuinely independent.
What cannot be outsourced is responsibility. Standard 5.4 requires that any function delivered through a third party is governed and monitored by the provider, and Standard 6.2 requires the governing body to oversee it. In student services higher education consulting, the consultant's job is often to build that oversight: a contract with service levels, a reporting line into the academic board, an annual review of the arrangement, and a record that students actually used the service.
Evidence of use, not existence
This is the point on which most support sections of an application turn. The standards are written in the present tense, so assessors want evidence of operation. For orientation, that means attendance records, an online completion log and a student survey; for progression, the at-risk report, the intervention record and the academic board minute that discussed it. For wellbeing, it means usage data from the external provider and a critical-incident register with at least the drill entries in it, and for complaints, a register with entries, outcomes and timeframes, and evidence that the independent stage is demonstrably available.
A prospective provider without students cannot produce all of this, but it can show that the systems are built and tested: the at-risk trigger configured in the student management system, the counselling contract signed, the complaints register created with its fields defined. It cannot submit the policies alone. I have described how consultants approach this in improving student affairs and services under TEQSA.
How consulting on student services works in higher education
A student services higher education consulting review follows the same sequence each time. First, map every service to the standard it serves and identify any standard with nothing against it. Second, walk the student journey from enquiry to graduation and record where each service is offered, by whom and in what mode, testing the online path as carefully as the campus one. Third, pull the operational records for the last twelve months and check that each service has been used and reported to governance, then write the gaps up for the academic board with a proposed action plan and a date.
The last step matters most. The board owns the outcome, and the record must show it deciding what to do, not receiving a consultant's report and filing it.
Support as an academic function
Providers should treat student support as part of academic quality rather than as an administrative service. Progression, integrity, wellbeing and complaints data are the early warning system for everything else in the Threshold Standards, and an academic board that sees them every meeting is a board that will notice problems before TEQSA does.
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— a list of the policies, procedures and registers a private provider needs across all seven domains, including the student support set, drawn from our TEQSA registration work. Get the index
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Frequently asked questions
Can a small provider outsource counselling and wellbeing support?
Yes, provided the arrangement is documented, promoted to students, monitored by the provider and reported to the governing body. Standard 5.4 requires that outsourced functions remain the provider's responsibility.
What does TEQSA look for in a complaints process?
An accessible process, a register that shows it being used, defined timeframes, and an independent final stage. An empty register is read as a process students do not trust, not as an absence of complaints.
How is progress monitoring evidenced under Standard 1.3?
Through a defined at-risk trigger, a record of interventions offered and taken up, and regular reporting of progression data to the academic board. A coordinator's private spreadsheet does not meet the standard.
Do the student support standards apply differently to online students?
No. Standards 1.3, 2.2, 2.3 and 2.4 apply regardless of mode, so every service must be reachable by online and offshore students, and the provider must be able to show that it is used by them.
Dr Brendan Moloney is CEO of Darlo Higher Education, Australia's largest specialist TEQSA consultancy. He holds a PhD from the University of Melbourne, is a Cambridge University Press author on governance in higher education, and has advised private providers on registration and course accreditation for more than fifteen years.