UA supports the consultation paper’s aim to respond to the rapid advancements in AI technologies by promoting a comprehensive approach that combines diverse learning and assessment methods (which may include the use of AI technologies) whilst upholding academic integrity and quality. Importantly, the document emphasises the need to integrate AI technologies to equip students with informed and ethical uses of such technologies as part of their learning and work. However, UA has several concerns with the consultation paper, including the intent, audience, structure and content. These concerns and key recommendations are outlined below.
UA recommends that guidance documents would be better based on a sector-identified need due to the cost-recovery arrangements implemented by Government: costs for guidance documents are recovered from the sector; therefore, TEQSA should be responding to a sector need before commencing any work on such documents. Whilst AI technologies are changing functions of learning and teaching in universities, there is yet no need for a regulator to be involved in learning and teaching innovation.
UA recommends any discussion of AI technology be incorporated into existing guidance documents, such as that on Technology-Enhanced Learning, Academic Integrity, Academic Quality Assurance and/or Course Design (including learning outcomes and assessment).
UA recommends that TEQSA remove prescriptive terms such as ‘non-negotiable’. Under the TEQSA ACT, activities designed for the purposes of quality improvement; building communities of practice and providing advice on ‘best practice’ to the higher education sector do not affect a provider’s accreditation or responsibilities. Language that implies a compulsory or regulatory response from the sector is therefore misleading and beyond the powers conferred by the Act. TEQSA should make efforts to ensure these types of documents are clearly understood to be recommended/suggested approaches designed to assist providers in engaging with artificial intelligence.
UA recommends that any future discussion papers should not, wherever practicable, include jargon and non-specific nomenclature, such as ‘artefact’, and in papers. This language makes the document’s purpose and scope unclear to the reader.