Work-integrated learning is assessed by TEQSA as a part of the course that the provider remains fully responsible for, even though somebody else hosts it: the placement is a third-party arrangement under Standard 5.4, the agreement with the host has to allocate responsibilities in writing, supervision and assessment remain academic functions the provider controls, insurance and student safety under Standard 2.3 follow the student into the workplace, and industry advisory input has to be evidenced rather than asserted. Meeting industry needs and meeting the Standards are not in tension, but they are two different jobs, and the application has to show both were done.
This article works through the work-integrated learning TEQSA assessors look for in a course application and at renewal, standard by standard. It draws on fifteen years of TEQSA course accreditation work with private providers, many of whose courses lead to professions where placement is compulsory and the placement is the part that goes wrong.
Why placements are a third-party arrangement under Standard 5.4
Standard 5.4 of the Higher Education Standards Framework (Threshold Standards) 2021 applies where a course of study, or part of one, is delivered with or by another party. A placement, practicum, internship or industry project in which a host organisation supervises the student and contributes to their learning is such an arrangement, and TEQSA reads it that way. The provider remains responsible for the quality of the student's learning experience, for the assessment, and for meeting the Standards throughout, and it must be able to show it exercises that responsibility.
In my experience this is the point providers most often miss. They treat placement as something that happens to the student off campus and treat the host as a benefactor rather than a delivery partner. Assessors ask the Standard 5.4 questions regardless: what is the written agreement, how does the provider know the host is delivering what was agreed, what happens when it is not, and how is the arrangement reviewed. TEQSA's guidance notes, including the one on work-integrated learning, are worth reading with the reminder that a guidance note is not a Threshold Standard and that the obligation comes from 5.4 itself.
The placement agreement: what it needs to allocate
The written agreement is the primary evidence and it needs to do real work. It should allocate responsibility for the learning objectives of the placement, the supervision the host will provide and the qualifications of the supervisor, the hours and activities the student will undertake, how the student's performance will be reported to the provider, health and safety obligations, insurance, confidentiality, intellectual property, and what either party does when a problem arises. It should also say who can end a placement and on what grounds, because someone eventually will.
Assessors read agreements for whether they were negotiated or merely signed. A template that every host signed unchanged, with no schedule specific to the placement, tells the regulator that the provider has not thought about the differences between hosts. A short master agreement with a placement-specific schedule for each site is the format I have seen work best, because it scales and because it forces someone at the provider to consider each host individually. The broader question of managing partners is covered in our article on partnerships and collaboration in higher education.
Supervision: who is supervising, and who is checking
Supervision in a placement is usually shared. The host supplies a workplace supervisor who directs the student's daily activity, and the provider supplies an academic supervisor who links the placement to the learning outcomes and assesses it. Standard 3.2 on staffing and Standard 5.4 together require that both roles be filled by people who are competent for them, and assessors ask how the provider knows.
For workplace supervisors that means a stated minimum in the agreement, a record that the provider checked it, and a briefing so the supervisor knows what the student is meant to learn and how to report. For academic supervisors it means a named person with the qualifications and experience the Standards require, a manageable caseload, and a schedule of contact with the student and the host during the placement, not just at the end. In my experience the RFI that most often follows a placement-heavy application asks for exactly this: the list of academic supervisors, their loads, and the record of site contact.
Assessing the work-integrated learning TEQSA expects the provider to grade
Standard 1.4 requires assessment that is valid, reliable and capable of confirming that learning outcomes were achieved. Placement assessment is difficult on all three counts, because the host's report is subjective, the tasks vary by site, and the student's work may be confidential. TEQSA does not expect the difficulty to disappear. It expects the provider to have designed for it.
The designs that satisfy assessors use several sources: a host report against defined criteria, a student portfolio or reflective account tied to the learning outcomes, direct observation or a viva by the academic supervisor, and moderation across placements so that a student at a generous host is not advantaged over one at a demanding one. The host's report should inform the grade, not determine it, because the academic judgment belongs to the provider. Our guide to course design for TEQSA accreditation covers how placement assessment should sit within the course's overall assessment map.
Insurance and student safety under Standard 2.3
Standard 2.3 requires a safe environment and the promotion of student wellbeing, and it does not stop at the campus gate. A student on placement is in a workplace the provider does not control, sometimes alone, sometimes with vulnerable clients, sometimes with a supervisor who has never had a student before. Assessors ask what the provider did before the placement began and what it will do if something happens.
Before the placement, the evidence is a risk assessment of the host, a check that the provider's insurance covers students on placement and that the host's covers them too, any required clearances for the student, and an induction covering safety, conduct, and how to raise a concern. During the placement, it is a contact schedule, a clear route for the student to report harm or harassment, and a record that reports were acted on. TEQSA's material change notification policy lists incidents significantly affecting student safety among the matters it expects to be told about within fourteen days, and a serious incident on placement can be such a matter.
Industry advisory input that can be evidenced
Providers describe their industry advisory boards warmly and evidence them thinly. Standard 5.1 requires course design to be informed by external input, and Standard 3.1 expects courses to be relevant to the field of practice. Placement-based courses lean on industry advice more than most, so assessors look for it.
The evidence is a terms of reference, a membership list with affiliations, minutes showing what industry members said about the placement component and how the course changed as a result, and a line from those minutes to the academic board that approved the change. In my experience an industry advisory board that has met twice, produced minutes with actual recommendations, and can show one of them adopted is worth more than a list of twenty impressive names who have never been in a room together. The collaboration theme is developed further in our piece on TEQSA Standards and the role of collaboration in accreditation.
Placements as a governance matter
Everything above lands on the academic board. It approves the placement design as part of the course, receives reports on placement outcomes and incidents, and reviews the third-party arrangements under Standard 5.4 on a cycle. The non-delegation principle applies: a placement coordinator can run the program and a consultant can draft the agreements, but the academic board decides that the arrangements are adequate and the minutes must show it did.
Evidence of operation is the test, as it is everywhere in the Standards. A provider that has run placements for three years should be able to show agreements executed and reviewed, supervisors checked and briefed, assessments moderated, incidents logged and acted on, and industry advice minuted and adopted. That is the work-integrated learning TEQSA reads as compliant, and it is also what a host organisation needs from a provider it is going to trust with its clients and its staff's time.
What I tell providers building a placement program
Write the agreement as if you will one day need to rely on it, and know who is supervising at every site. Assess the placement with your own academic judgment, informed by the host and moderated across sites. Treat safety as your responsibility wherever the student is. Get industry advice into the minutes, and put the whole thing in front of the academic board on a cycle. Do that and the placement program will satisfy both the industry that hosts it and the regulator that assesses it, which is the only outcome worth building for.
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Frequently asked questions
Is a student placement a third-party arrangement under TEQSA's Standards?
Yes. Where a host organisation supervises a student and contributes to their learning, Standard 5.4 applies, and the provider remains responsible for the learning experience, the assessment and compliance with the Standards throughout the placement.
What should a placement agreement include?
Learning objectives, supervision and supervisor qualifications, hours and activities, reporting to the provider, health and safety, insurance, confidentiality and intellectual property, problem resolution, and who may end the placement and why, ideally as a master agreement with a site-specific schedule.
Can the host organisation grade the placement?
The host's report should inform the grade, not determine it. Standard 1.4 requires the provider to make the academic judgment, using several sources such as a host report, a student portfolio, academic supervisor observation and moderation across placements.
Does TEQSA need to be told about a serious incident on placement?
It can. TEQSA's material change notification policy lists incidents significantly affecting student safety among the matters to be notified within fourteen days, and a serious incident involving a student on placement may fall within that category.
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.