Tertiary Education Commission
Te Amorangi Mātauranga Matua
National Office
44 The Terrace
PO Box 27048
Wellington, New Zealand
2
Contents
Whitecliffe Enterprises Limited (Edumis 8509)
4
Part one: Summary of Audit Results
4
Overall recommendation
4
Audit Ratings
4
Key findings and recommendations
4
Part two: Key findings and recommendations
6
Part three: Other Audit Findings
20
Financial Viability Assessment
20
Part four: Audit Process Overview
21
Purpose of the audit
21
Scope of the audit
21
Overview of Whitecliffe Enterprises Limited
22
Audit process overview
22
Part five: TEO Corrective Actions
24
Corrective Actions
24
Appendix 1 – discrepancies between fees invoiced and recorded in STEO
26
3
>
A review of the December 2019 and December 2020 SDR identified that Whitecliffe did not report
correct withdrawal dates. The PTE advised that this is due to some default setting in the SMS, which
has to be resolved.
>
The audit identified several instances in the December 2019 and December 2020 SDRs, where the
students were not reported correctly under source of funding code 31 (SoF 31). Whitecliffe needs to
review and resubmit the December 2019 and December 2020 SDRs to ensure that all the relevant
students are correctly reported under SoF 31.
>
For NZ2627 and NZ2629, fees increases for a few courses were more than the AMFM permissible limit
for 2019 and 2020. Whitecliffe advised that the fees increase beyond the set limit was mainly due to
rounding up. STEO should be updated retrospectively calculating the fees increases from 2019 to 2020
at 2%, and 1.1% from 2020 to 2021. This should be corrected before applying the fees increases for
2022.
>
For TAFL funding, no invoices were held for the purchase of USB, printers and software installation
because the amount was directly deposited into the student’s account on a good faith basis.
5
Part three: Other Audit Findings
Further findings of the audit are set out below.
Financial Viability Assessment
8509-Whitecliffe Enterprises Limited
Risk assessment
(Based on your financial statements for the years shown)
s9(2)(b)(ii)
20
Part four: Audit Process Overview
Purpose of the audit
The purpose of the audit was to provide assurance that your organisation is complying with the
Education and Training Act 2020 and conditions imposed on your funding. This audit is part of our ongoing
monitoring of tertiary education organisations (TEOs).
This audit used a sample-based approach and reviewed a limited scope of the applicable funding conditions
and other requirements. As such, despite our best efforts, some non-compliance may remain undetected
and the audit does not provide complete assurance of historical, current or future compliance.
Non-detection of non-compliance does not make that practice compliant, and will not restrict the TEC from
taking action under the Education and Training Act 2020 or from recovering funding in the future if non-
compliance is later detected. Please refer to the audit guidelines for more information on the inherent
limitations of an audit.
Our audit focus will be on assisting TEOs in achieving their objectives through well-reasoned audits,
evaluations and analyses of the business viability and education outcomes for students.
Scope of the audit
TEC’s monitoring function is set out in section 409(1)(h) of the Education and Training Act 2020, which
provides that the TEC's functions are to "
monitor the performance of organisations that receive funding
from the Commission including by measuring performance against specified outcomes”.
The scope of the audit was aligned to the performance commitments in the Investment Plan and the
associated funding obligations between the TEC and your organisation. The scope was outlined in the audit
arrangements letter. TEC Audit Guidelines were also provided to help you understand how TEC undertakes
audits and what to expect during the audit.
The scope of the audit was outlined in the audit arrangements letter. This included the following:
> Your current registration and accreditation status for funding eligibility
> Your organisation’s systems and processes for reporting student data through the Single Data Return,
including reporting enrolments, student achievement and withdrawals
> Compliance with your funding conditions for each fund:
-
Fees-free funding
-
Student Achievement Component – Provision at Level 3 and above
-
Hardship Fund for Learners
-
Technology Access Fund
> Compliance with the Annual Maximum Fee Movement policy relating to fees and course costs
> The refund of any fees that have been overcharged (if applicable)
> Compliance with the Compulsory Student Services Fee (if applicable)
> Whether your organisation has offered any inducements or benefits to students
> Responsibility for any subcontracting arrangements
> Your programmes and qualifications
> Your organisation’s process for maintaining student records as required by clause 13(1) of Schedule 18
of the Education and Training Act 2020 (for on-plan funding under section 425), and 25(1) of Schedule
18 (for off-plan funding under section 428).
>
Any other matters relating to funding provided by the TEC.
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There were 1092 students reported in the December 2019 SDR. This includes international fee-paying
students who are not funded by the TEC.
The December 2020 SDR reported 1045 students, again this included international fee-paying students.
Interviews – Interviews were held at Whitecliffe’s Auckland office with the following:
> s9(2)(a)
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Part five: TEO Corrective Actions
In addition to providing comments on the draft audit report, the TEO audited is requested to provide a list
below of any corrective actions to be undertaken on the audit.
Corrective Actions
Based on the recommendations in Part Two what corrective actions will be undertaken?
Focus Issue
Corrective Action
Date to be
Area
completed
1
STEO currently records delivery sites which This has been updated on STEO already Completed
are no longer active.
2
Update STEO with correct qualification
The error was on NZQA’s part, and we 31 December
titles for NZ2606, NZ2607 and NZ2608.
are working with NZQA to rectify this.
2021
(tentative)
3
The audit identified two instances (NSN
We have improved our processes to Completed
s9(2)(a)
and NSN s9(2)(a)
where
ensure
appropriate
evidence
is
there was no certificate of identity in the
obtained to verify learner’s domestic
learner’s file to verify their domestic
status.
status.
4
Funding has been claimed for prior
We have updated our processes to Completed
learning by virtue of the students being re-
ensure funding is not claimed for
enrolled in the courses that were recently
courses previously completed.
successfully completed at Whitecliffe.
4
Review all 2019, 2020 and 2021 student
We have identified students where 31 December
records to identify instances where the
funding has been claimed twice, 2021
funding has been claimed (through SAC3+
amounting to 0.3834 EFTS for 2019 and
and Fees-free) for students re-enrolled in
2020. We will correct this in the SDR
courses which have recently been
resubmission
successfully completed at Whitecliffe.
6
Ensure withdrawal dates are correctly
We have updated our processes to Completed
reported in the SDR going forward.
ensure
withdrawals/dates
are
correctly reported in the SDR.
6
The audit identified several instances in
We will work with TEC to resubmit our 31 December
the December 2019 and December 2020
2019 and 2020 SDR, with correct 2021
SDRs, where the students were not
reporting of SoF 31 funding. We have
reported correctly under SoF 31.
identified 5.2040 EFTS for 2019 and
2.5422 ETS for 2020 that will be re-
Whitecliffe should review and resubmit
coded from 01 to 31, despite there
the December 2019 and December 2020
being no funding recovery for 2020.
SDRs to ensure that all the relevant
students are correctly reported under SoF
31.
9
For NZ2627 and NZ2629, fees increases for Noted, we will correct the fee increases 31
January
a few courses were more than AMFM
when applying for 2022 AMFM 2022
permissible limit for 2019 and 2020
increase.
(details in Appendix 1). The fees increase
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beyond the set limit was mainly due to
rounding up. STEO should be updated
retrospectively calculating the fees
increases from 2019 to 2020 at 2%, and
1.1% from 2020 to 2021. This should be
corrected before applying the fees
increases for 2022.
10
For TAFL funding, no invoices were held for Noted
n/a
the purchase of USB, printers and software
installation because the amount was
directly deposited into the student’s
account on a good faith basis.
25
Appendix 1 – AMFM fees increases
s9(2)(b)(ii)
26
