The defunct private tertiary institution, International Academy of New Zealand (IANZ), was passing students it should have failed and gave the Qualifications Authority false information, documents show.
IANZ was recently sold and most of its students transferred to a new institution (EDENZ Colleges), two years after the Qualifications Authority started investigating the private tertiary institution.
Documents provided under the Official Information Act show the school was at risk of deregistration after the authority found evidence of dishonesty as well as poor governance and management.
"It is NZQA's view that IANZ has materially failed to comply with the requirements for maintaining registration as a private training establishment," the documents said.
The authority started investigating IANZ in 2014 after receiving information from a whistle-blower.
It conducted an external evaluation and review later that year, but IANZ contested its findings in court.
As a result of that case, the authority appointed a new review panel, which this year reconsidered the evidence gathered in 2014.
The new panel gave IANZ its lowest possible rating, saying it did not have confidence in quality of its education nor in its ability to monitor its own work.
Separately, NZQA conducted a focused review of the private tertiary institution assessments this year.
It included moderation of the materials the school used to assess four unit standards and found that none met the required standard.
When NZQA looked at 77 examples of students' work that IANZ said met those standards, it found all of them should have been failed. Some answers were unintelligible, and some work was not up to scratch even though IANZ tutors had described it as being of high quality.
In May this year, NZQA conducted monitoring visits to IANZ following information received by a whistle-blower in April.
The resulting report, dated August 2016, shows the authority had serious concerns about IANZ's management and governance.
It said there was lack of clarity about governance and management responsibilities, failure to ensure the school was properly managed, and failure to make and document governance decisions.
IANZ 'gave false declaration'
It found IANZ had failed to meet its obligations as a signatory to the Education (Pastoral Care for International Students) Code of Practice, which all institutions enrolling foreign students must sign up to.
IANZ had supplied a false declaration that it had assessed its compliance with the code, failed to respond to situations where students were unable to safeguard their own welfare, and had inadequate procedures for following up non-attendance by students.
Large portions of the monitoring report have been withheld under the Official Information Act.
However, the report states that the company's directors told NZQA they had had concerns about the school for some time.
They provided some evidence of this concern, but the report says other than that, there was no proof of effective oversight or management of the chief executive's performance.
The report says the authority told IANZ in December 2015 not to give students their results for a particular unit standard in the level six business diploma until NZQA had confirmed its assessment was satisfactory.
One of the company's directors told NZQA she was not aware of that compliance notice. However, documentation showed the chief executive had informed the board about it.
NZQA said it was concerning the director had said she was not aware of it.
The document said IANZ was not permitted to enrol students in the level six qualification, the National Diploma of Business Studies, until mid-January.
But communication from the chief executive on 6 January 2016 showed he was accepting combined enrolments in that qualification and a level five qualification that preceded it.
He said he might be "stretching the envelope" with that decision, but believed he was on the safe side of the law.
"It is of very serious concern to NZQA that while IANZ was assuring NZQA that it was strictly complying with the compliance notice, it was in fact, in contrast to this advice, intentionally "stretching" the interpretation of the requirements of the compliance notice.
"NZQA considers this as being evidence of not only non-compliant but also dishonest behaviour which the directors were aware of."
The report said any combined offers of places to students in the level five and six programmes between 6-14 January were a breach of the compliance notice.
The report said IANZ had refused to give some students their certificates until they paid insurance fees they were previously unaware of.
IANZ had told the review team that the fees were required because the students study visas were for a longer period than IANZ had expected when it enrolled them, and their insurance had had to be extended.
Students' certificates held back
NZQA said it was unacceptable that students were not told of the increased duration and cost of their insurance at the time that IANZ purchased it.
The report said students regularly complained to the student affairs manager at IANZ, but did not wish to make formal complaints.
It said the chief executive reported to the board in August 2015 that staff were not putting their training into practice, with continual reports that deans and tutors were unhelpful and uninterested.
Students' complaints included teaching staff yelling at them and being unprepared for lessons.
Tertiary institutions are required to ensure foreign students have insurance for the duration of their studies.
The report said scrutiny of 1728 insurance policies for IANZ students found 62 percent were issued after start date of the policy and for 222 of them, the policies were issued four weeks after the start date, meaning they were uninsured during their first month in New Zealand.
"In 80 cases, the policy has been issued after the end of the cover period, which suggests to NZQA that someone has retrospectively gone back through the students' files to ensure that the insurance period on file matches their study or visa dates."
The report says most of those redundant policies were issued on 19 April 2016 and it can be assumed that was done to "make it appear that IANZ had been fulfilling its obligations".