Equity, Governance and Policy

This blog post is part of the Gonski Institute for Education’s open access annotated bibliography (OAAB) series, a project led by Dr Sally Baker. OAABs offer a snapshot of some of the available literature on a particular topic. The literature is curated by a collective of scholars who share an interest in equity in education. These resources are intended to be shared with the international community of researchers, students, educators and practitioners. The literature has been organised thematically according to patterns that have emerged from a deep and sustained engagement with the various fields.

Many of the contributions that offer conceptual discussions are concerned with the theorisations and ideological models that underpin higher education/ equity policy. This literature broadly discusses the Australian education system, with strong connections made between the policyscape of the school and tertiary education sectors. This literature is deeply critical of the manifestations of neoliberal ideology in policy, with many authors tracking the impacts of globalisation and competition on policy and practice. Issues related to the expansion of higher education and the notions of quality and standards also feature significantly.

The discussions of equity in educational policy in this review are based on a context of marked and constant changes: new students, new courses, new modes of study, new stakeholders (Heagney & Marr, 2013). These changes are both results of, and catalysts for, policy change. As discussed early in this review, comprehensive overviews of equity in Australian higher education illustrate how although equity has remained a constant focus in educational policy. However, there have also been constant changes in the underpinning rationales and ideologies of maintaining attention on equity, from the strong social justice framing in the Whitlam reforms of the 1970s, which Whitlam asserted was “the first time for a generation Australia has a government dedicated to equal opportunity for all its citizens” (1974), to the ‘crisis’ need for expansionist, market-efficiency arguments of the Bradley review in 2008. Gale & Tranter (2012) describe this as a process whereby social policy became subsumed by economic policy. These ideological shifts have made the notion of equity notoriously difficult to ‘pin down’ (Savage, Sellar & Gorur, 2013). However, as Gale & Molla succinctly articulate, “With increased commodification of access to education and knowledge, championing social commitment to ensure education justice is timely and necessary” (2015: 822). Savage (2013), in exploration of whether equity can be tailored to educational institutions operating in different contexts of (dis)advantage, argues that because equity is a very flexible concept, such tailoring is difficult to undertake because this “reflect[s] a similar diversity in policy, where multiple versions of equity operate” (p.197). This confusion is evident in the ways that equity/education policies are enacted. In their review of equity policy between 1991-2002, Coates & Krause (2005) argued that the policy produced in that decade oscillated between generalisations and overt-specifications, which impaired the effectiveness of the policy and led to conflict in practice, as the need for generalizability at national/systemic level did not always help institutions be locally responsive and vice versa.

Savage, Sellar & Gorur (2013) offer three characterisations of equity in higher education: as distributive (based on notion of ‘fair’ distribution), as inclusive and recognising (so as to “ameliorate the negative influences of social and cultural difference”, p.162), and as equality of opportunity (‘sameness of treatment’). This multilayered view of equity could also include Savage’s (2013) definition of “a ‘market enhancing’ mechanism and melted into economic productivity agendas” (p.185). These multiple and competing understandings of equity are a part of the ‘assemblage’ of education policy (Rizvi & Lingard, 2011), whereby policymakers are required to “assemble, organise and order values, configuring them in such a way as to render them more or less consistent and implementable” (p.9), which necessitates the privileging of some values over others. This is clearly evident in the Bradley Review, where the neoliberal argument for expanding higher education to produce more ‘global knowledge workers’ to ‘future-safe’ Australia’s economic competitiveness is foregrounded over the imperative to recognise and improve entrenched social and educational disadvantage for particular groups. Thus, the Bradley Review exemplifies the ‘new neoliberal imaginary’ that redefines education in economic terms, related to notions of efficiency within the market (Rizvi & Lingard, 2011) and “rearticulates the meaning of equity in terms of an underlying focus on market efficiency” (p.19).

For Marginson (2011), equity can be understood through exploration of two assumptions about equity that guide enactments of policy: fairness and inclusion. Success of policy through the lens of fairness is based on growth in the total number of people from equity groups, while inclusion is based on proportional distribution of different groups of students Taking the same point in Australia’s higher education policy history, Marginson offers analysis of ‘Transforming Australia’s Higher Education System’ (2009) – the White Paper that was produced from the Bradley Review - as an example of policy that includes both fairness (evident in the 40% of 25-34 year olds participation target) and inclusion (seen in the 20% low SES participation target). Marginson argues that in this policy, fairness was given priority because there would be no change that “Would weaken the hold of existing social users of the system” (p.29), meaning that the target was unlikely to be met. In this case, Marginson argues that universities will likely be positioned as “villains” for not doing enough, thus warranting “a slackening of support for measures to strengthen the position of the disadvantaged” (p.29), which also happened in the 1980s. Marginson muses on how “equity policy in higher education is doomed to be the domain of perpetual unacheivement, in which equity programs are periodically tried and periodically fall away again” if fairness remains the dominant framing for equity (p.29). Similarly, Pitman (2015) problematises the massification approach to fairness (‘a rising tide lifts all boats’, p.20), because this notion is underpinned by the assumption that disadvantaged students will gain access only once the ‘traditional customers’ of higher education - the higher/middle classes - have been saturated (see also Chesters & Watson, 2013). Pitman agrees with Marginson’s call for significant ‘behavioural change’ towards an agenda of inclusion; as Pitman writes, “acts of redistribution occur when policy and action directly target disadvantaged students to increase their proportional representation within higher education” (2015, 20).

Similarly, Gale (2011a) argues that current notions of equity that are concerned with growth in numbers rather than proportional representation represents a view of  “social inclusion in its narrowest sense” (p.16).  Gale therefore argues for a new view of equity that asks what all students can bring/contribute to higher education, instead of the ‘narrowly imagined’ packages currently ‘sold’ to students from educationally disadvantaged backgrounds that focus on potential economic futures, which require the exploration of “new policy settings for equity in these emerging times, for governments, systems and universities” (2011a: 17). In order to enable such changes, in another paper, Gale (2011b) offers three propositions for shifting dominant policy views of equity: changing the relationship between demand and supply; more attention to students’ aspirations for post-school futures; and teaching for equity.

Critiques of neoliberalism

The economic theory of neoliberalism has become a dominant influence on the ways that education and equity are inscribed in policy and enacted in practice.  Much like equity, neoliberalism is also a term used widely in discussions of higher education – particularly in the context of equity – but it is often taken to be a commonsensical word - “a catch-all explanation for anything negative” (Rowlands & Rawolle, 2013: 261), despite the complex variety of meanings and discourses it captures. Indeed, in their 2013 paper, Rowlands & Rawolle present a review they undertook to examine how and why neoliberalism was used in education-focused literature. Through examination of 110 research articles with neoliberalism in the title, they found that 54 offered no definition of neoliberalism at all, despite using the term, and a further 27 offered a brief definition that totaled no more than one paragraph. This, they argue, is highly problematic, because when researchers use the term neoliberalism (and critique it) without detailed definition or explanation, they are “playing the neoliberal game and inadvertently demonstrating our belief that it is a game worth being played” (p.260).

The work of Raewyn Connell has offered much to discussions of neoliberalism and equity in higher education. In her 2013(b) paper, Connell offers a detailed overview of the beginnings of neoliberalism, from Pinochet to the Thatcher and Reagan years, working from an economic theory that by widening markets, new ‘free’ markets emerge and there is less need (desire) to rely on the state which in turn lowers taxes. As such, neoliberalism is synonymous with deregulation marketization, whereby, Connell argues, “The education system as a whole comes to stand, not for the common interest and self-knowledge of the society, but for ways to extract private advantage at the expense of others” (2013b: 106). The opening up of education to the market, and shift in responsibility for higher education from the nation state to the individual can be seen across the world (see Burke, 2012; Burke & Kuo, 2015 for more international perspectives). A further theory that underpins the dominance of neoliberal policy and practice is human capital theory, which posits that when an individual makes an investment in her/his education, they both profit in terms of future (individual) returns and increased (national) productivity and contribution to the knowledge economy. As Gidley et al. (2010) highlight, this investment theory is at the heart of the Bradley Review, so that ‘widening access’ to higher education is about creating higher numbers (to fuel economic production) from outside of ‘saturated’ populations. In order to create, sustain and grow educational markets, the twin ‘fuels’ of privilege and competition need to be at play (Connell, 2013a) because inequality is central to the success of the market; in order for someone to gain, someone else has to lose.  In education, “exclusion is vital. There need to be visible losers, if parents are to be persuaded to pay for their children to become winners” (Connell, 2013a: 282; see also Blackmore, 2009). Therefore, Connell argues, education is not – and can never be - immune to the pervasive need to create dichotomies between haves and have-nots. Moreover, neoliberal logic does not like or want to hear from practitioners’ experience/ knowledge; it is not interested in the grey areas of historical disenfranchisement and inequitable patterns of participation in higher education. Rather, “contrary to the rhetoric of ‘evidence-based policy’, neo-liberal policy-making proceeds as if it already knows the answer to policy problems… In a neo-liberal universe, the answer to a policy problem will always be expanded markets, more competition, more flexibility, more entrepreneurialism and more private ownership” (Connell, 2013a: 284).

A key consequence of the neoliberal logics that drive contemporary higher education systems is the heightened need for accountability and measurability (see the following section for discussion the competition agenda). This has resulted in new, mostly quantitative, ways of collecting data, measuring performances and efficiencies and recording access, attrition, retention, participation, and success. Lingard (2011): terms this the ‘contemporary policy as numbers phenomenon’, with the belief in numbers a form of ‘political arithmetic’ (p.356). The reduction of deeply complex sociocultural-historic patterns of disadvantage to numbers and statistics belies neoliberalism’s lack of interest in the complexities of human lived experience discussed above. As Lingard (2011) argues, numbers have become a ‘policy technology’ emerging from move from government to governance: both for and as policy. Moreover, beyond their power as a form of policing and policy, the dominance of numbers has arguably shifted what equity is taken to mean, while simultaneously working to protect (hide) policymakers from the messiness of lived experience of inequity. As Lingard, Sellar & Savage (2014) argue, “multiple layers of technical and numerical mediation to measure equity” serve to abstract complex set of phenomena that cause/represent (in)equity into “graphs, grids, league tables and indices” (p.711). While numbers may be more palatable than descriptions of what it is to be educationally disadvantaged, they are only ever a partial representation of a much bigger and more complex picture.

As alluded to in the review offered by Rowlands & Rawolle (2013) above, the language used is highly significant in terms of instantiating policy and framing institutional decisions on practice. Neoliberalism was never formally introduced as the new ideology underpinning education; instead, terms such as ‘efficiency’, ‘capability’, ‘merit’ and ‘fairness’ entered the educational lexicon. As Rizvi (2013) argues, the language used (indexing new discourses) is crucial for seeing the evolution of neoliberalism into every part of the Australian education system (see Connell, 2013b for a full discussion of ‘the neoliberal cascade’). Rizvi argues that, “Part of the success of neoliberalism lies in the fact that it continues to use such traditionally socially democratic notions as equity, but has been enormously successful in re-articulating their meaning into market terms” (2013: 276). Sellar, Savage & Gorur (2014) make a similar point when they note how ‘equity’ has replaced language of social justice and inequality in educational policy, so that “equity effectively becomes a ‘ market-enhancing mechanism" (p.464; also see Savage, 2011).  The (mis)appropriation of vocabulary that connotes with inclusion and social justice agendas acts as a vehicle for desensitising ‘users’ (teachers, students, parents) to the insidious creep of neoliberal logics and represents what Gidley et al. (2010) call “conceptual reductive integration” and lifeworld reduction; a form of  “cultural assimilation and stakeholder dominator hierarchies” (p.133). However, as several of the authors included in this review strongly advocate (see Connell, 2013a; Rawolle, 2013; Rowlands & Rawolle, 2013), it is our responsibility as educators and researchers to highlight these misappropriations and to increase awareness of the impact of neoliberalism, and its work to maintain deficit-thinking, to silence certain voices, and to devolve responsibility for equitable higher education to individuals, rather than institutions (which operate in the market of higher education).

Globalised education and agendas of competition

The transformation of education – at least discursively - into a global market is an integral part of the enduring dominance of neoliberalism. Lingard & Rawolle (2011) describe the shift towards a globalised higher education field as a rescaled policyscape, so that “within the domain of education policy there has emerged a global education policy field that has policy effects within national education policy and policy processes” (p.498). These policy effects play out in the creation of global ranking systems and transnational comparative tools of measurement, such as standardised literacy and numeracy tests (such as NAPLAN in Australia or the SATs in the UK), so that national HE systems now increasingly operate as localisations of a global higher education space” (Sellar & Gale, 2011: 1). For Armstrong, Armstrong & Spandgou (2011), the locus of critique exists because of deep and intractable global inequities. They argue that ‘contestable’ international inclusive education movements – such as UNESCO’s ‘Education for all’ – fail because of significant epistemological incongruences and power dynamics between the ‘global north’ and the ‘global south’. These authors make the point that the illusion that ‘fair’ comparisons can be made across the global field of higher education conceals the differing starting points of different countries – much like arguments made about diverse student groups in higher education.  Armstrong, Armstrong & Spandgou argue for more recognition of historical patterns of inequality when discussing ‘the global education market’, so that global inclusive education policies “should be placed in the more sobering context of the intersection between colonial histories and post-colonial contexts of countries in the developed and developing world” (p.32).

For the concept of a globalised higher education market to function, the conditions of competition – of winners and losers – have to be present. In the global field, rankings based on student numbers and satisfaction, research outputs, revenue and performance benchmarks, including equity, are the principal currency. Drawing another parallel with higher education student populations, the universities that rank highest in the world are also the wealthiest and most established, located in the global north. According to Connell (2013b), the influence of a globally competitive higher education market has radically transformed education into a regime of ‘competitive training’, so that students, staff, institutions and nations engage in “competition for privilege, social conformity, fear and corruption, while protest and rational alternatives are marginalized” (p.110). As has been discussed in earlier sections of this review, current ways of doing, knowing, being and feeling are unlikely to be sufficient to challenge the power of neoliberal, market-based policies and practices, or to restore what has been lost through its dominance. Sellar  & Gale (2011) argue that the new globalised academy requires new imaginaries of student equity that demand more nuanced and responsive analytics and frameworks. These new imaginaries should include an expanded conception of equity, resources for interrogating the production of policy or knowledge across multiple scales and – critically - attention to the lived experience of inequality in particular localisations of global higher education (p.3), so as to challenge the reductive ‘policy as numbers’ approach outlined by Lingard (2011).

What this competitive landscape means for equity is that it has become another criterion in the global competitive policy-practice landscape, another focus for comparative accountability agendas. Many authors included in this review have critiqued this reappropriation of equity, social justice and inclusive education policies (Connell, 2013a, 2013b; Lingard, 2011; Lingard, Sellar & Savage, 2014). Savage, Sellar & Gorur (2013) argue that in Australian education policy marketised ways of thinking “foster notions of meritocracy, competition and choice, which also claim links to ideals of fairness and opportunity” (p.162), meaning that equity and competition are presented as harmonious. However, as is clearly argued in Peacock, Sellar & Lingard’s (2014) analysis of outreach policy and practice in Queensland, competition can seriously erode the effectiveness of cooperation and collaboration between institutions “where there is a potential change in the allocation of academic and reputational capital within the field and a disturbance to the existing institutional hierarchy of the field” (p.390). Similarly, when it comes to equity and widening participation, while elite universities do not resist approaches that privilege fairness, they do oppose approaches that seek to erode their positional advantage (Marginson, 2011; Pitman, 2015).

Quality and standards

A key issue that is proliferated in discussions of equity – both in terms of policy and practice – is related to concerns about quality. The notion of ‘quality’ in relation to equity denotes a standard of performance in a globally competitive higher education field, with both constituting important policy devices in national education systems (Lingard & Rawolle, 2011). The push towards quality assurance and standardisation was fuelled by globalisation, particularly with the expansion of education as an import/export market (Blackmore, 2009).   In particular, tensions have been exposed between the notions of excellence – clearly outlined in federal policy – and equity. In his analysis of the relationship between quality, equity and ideology in education policy, Clarke (2014) describes equity and quality as problematic concepts that are heavy with political contestations. He terms the alignment of equity and quality/ excellence as ‘sublime’ because the two together “posit a ‘fantasmatically’ complete and harmonious world… in which the tensions between equity and a quality agenda premised on notions of choice and accountability are occluded” (p.587). However, others (Whiteford, Mahsood & Chenicheri, 2013; Buchanan, Southgate & Bennett, 2015) have argued that equity and excellence do not stand as mutually exclusive; that there are possibilities for compatibility.

Blackmore (2009) examines the use of student satisfaction surveys as “part of the web of quality assurance, performance management and promotion practices facilitated by new data management technologies” (p.866). She argues that set within a context of performance-based funding, such instruments do little to actually improve teaching and learning – contradicting their professed utility – because the unidirectionality of such surveys (whether quantitative or qualitative) “provide little substantive feedback to academics about what needs to improve, how or why, or what works well for some students and not others… These require academics to respond to poor results, often regardless of whether such evaluations are statistically meaningful, and without academics having the capacity to find out what exactly it is that students ‘like’ or ‘dislike’ or why”” (p.866). The neoliberal context of higher education is a key driver for both the implementation of, and responding to, such surveys. Within an increasingly-marketised sector, Blackmore argues that students are positioned as consumers (‘user pays’) and as such use surveys to express their feelings about their experience of their degrees. This, however, raises complex questions about the shape and purpose of higher education; as Blackmore asks, “Is teaching and learning in a university based on professional and pedagogical principles, or the contractual arrangements of a producer–consumer relationship? This question shines an uncomfortable light on the role, function and purpose of higher education, and the agency and assumptions of its key players – students and teacher-academics. Ultimately as Blackmore (2009) articulately summarises, there is a stark irony when the governmental-institutional response to increased diversity is standardization, accountability and surveillance via quality assurance agendas (p.869).


Armstrong, D.; Armstrong, A.; & Spandgou, I. (2011). Inclusion: by choice or by chance?, International Journal of Inclusive Education, 15(1): 29-30.

Blackmore, J. (2009). Academic pedagogies, quality logics and performative universities: evaluating teaching and what students want, Studies in Higher Education, 34(8): 857-872.

Buchanan, R.; Southgate, E.; & Bennett, A. (2015). Social justice in the enterprise university: global perspectives on theory, policy, ethics and critical practice, International Studies in Widening Participation, 2(2): 1-3.

Chapman, A., Mangion, A., & Buchanan, R. (2015). Institutional statements of commitment and widening participation policy in Australia. Policy Futures in Education, 13(8): 1-15.

Chesters, J. & Watson, L. (2013). Understanding the persistence of inequality in higher education: evidence from Australia, Journal of Education Policy, 28(2): 198-215.

Clarke, M. (2014). The sublime objects of education policy: quality, equity and ideology, Discourse: Studies in the Cultural Politics of Education, 35(4): 584-598.

Connell, R. (2013). Why do market ‘reforms’ persistently increase inequality?, Discourse: Studies in the Cultural Politics of Education, 34(2): 279-285.

Connell, R. (2013). The neoliberal cascade and education: an essay on the market agenda and its consequences. Critical Studies in Education, 54(2): 99-112.

Devlin, M. & O’Shea, H. (2011). Directions for Australian higher education institutional policy and practice in supporting students from low socioeconomic backgrounds, Journal of Higher Education Policy and Management, 33(5): 529-535.

Gale, T. (2011). Student equity’s starring role in Australian higher education: not yet centre field, The Australian Educational Researcher, 38(1): 5-23.

Gale, T. (2011). Expansion and equity in Australian higher education: Three propositions for new relations, Discourse: Studies in the Cultural Politics of Education, 32(5): 669-685.

Gale, T. & Molla, T. (2015). Social justice intents in policy: an analysis of capability for and through education, Journal of Educational Policy, 30(6): 810-830.

Gidley, J,; Hampson, G.; Wheeler, L.; Bereded-Samuel, E. (2010). From Access to Success: An Intergrated Approach to Quality Higher Education Informed by Social Inclusion Theory and Practice. Higher Education Policy, 23: 123-147.

Hattam, R. & Symth, J. (2015). Thinking Past Educational Disadvantage, and Theories of Reproduction, Sociology, 49(2): 270-286.

Heagney, M. & Marr, L. (2013). Policies in tension: Tales from two hemispheres, Widening Participation and Lifelong Learning, 15(1): 1-6.

Heimans, S. (2011). Education Policy, Practice, and Power, Education Policy, 26(3): 369-393.

Lingard, B. (2011). Policy as numbers: ac/counting for education research, The Australian Educational Researcher, 38(4): 355-382.

Lingard, B.; Rawolle, S.; & Taylor, S. (2005). Globalising policy sociology in education: working with Bourdieu, Journal of Education Policy, 20(6): 759-777.

Lingard, B. & Rawolle, S. (2011). New scalar politics: implications for education policy, Comparative Education, 47(4): 489-502.

Marginson, S. (2004). National and Global Competition in Higher Education, The Australian Educational Researcher, 31(2): 1-28.

Marginson, S. (2011). Equity, status and freedom: A note on higher education. Cambridge Journal of Education, 41(1): 23-36.

Morsy, L.; Gulson, K.; & Clarke, M. (2014). Democracy, ‘sector-blindness’ and the delegitimation of dissent in neoliberal education policy: a response to Discourse 34(2), May 2013, Discourse: Studies in the Cultural Politics of Education, 35(3): 444-461.

Peacock, D.; Sellar, S.; & Lingard, B. (2014). The activation, appropriation and practices of student-equity policy in Australian higher education. Journal of Educational Policy, 29(3): 377-396.

Pitman, T. (2014). Reinterpreting higher education quality in response to policies of mass education: the Australian experience, Quality in Higher Education, 20(3): 348-363.

Pitman, T. (2015). Unlocking the gates to the peasants: are policies of ‘fairness’ or ‘inclusion’ more important for equity in higher education, Cambridge Journal of Education, DOI: 10.1080/305764X.2014.970514

Rawolle, S. (2013). Understanding equity as an asset to national interest: developing a social contract analysis of policy. Discourse: Studies in the Cultural Politics of Education, 34(2): 231-244.

Rizvi, F. (2013). Equity and marketisation: a brief commentary. Discourse: Studies in the Cultural Politics of Education, 34(2): 274-278.

Rizvi, F. & Lingard, B. (2011). Social equity and the assemblage of values in Australian higher education, Cambridge Journal of Education, 41(1): 5-22.

Rowlands, J. and Rawolle, S. (2013). Neoliberalism is not a theory of everything: a Bourdieurian analysis of illusio in educational research. Critical Studies in Education, 54(3): 260-272.

Savage, G. (2011). When worlds collide: excellent and equitable learning communities? Australia’s ‘social capitalist’ paradox?, Journal of Education Policy, 26(1): 33-59.

Savage, G. (2013). Tailored equities in the education market: flexible policies and practices. Discourse: Studies in the Cultural Politics of Education, 34(2): 185-201.

Savage, G.; Sellar, S.; & Gorur, R. (2013). Equity and marketisation: emerging policies and practices in Australian education. Discourse: Studies in the Cultural Politics of Education, 34(2): 161-169.

Sellar, S. & Gale, T. (2011). Globalisation and student equity in higher education, Cambridge Journal of Education, 41(1): 1-4.

Sellar, S.; Savage, G.; Gorur, R. (2014). The politics of disagreement in critical education policy studies: a response to Morsy, Gulson and Clarke, Discourse: Studies in the Cultural Politics of Education, 35(3): 462-469.

Whiteford, G., Mashood, S., Chenicheri, S.N. (2013). Equity and Excellence are not Mutually Exclusive. Quality Assurance in Education 21(3): 299-310.

Dr Sally Baker is a lecturer for the School of Education at the University of New South Wales in Sydney, Australia. Sally’s research primarily focuses on equity in higher education, with her main interests being education policy, experiences of students from refugee and culturally and linguistically diverse backgrounds and educational transitions. She is currently the Co-Chair of the Refugee Education Special Interest Group and the educational focal point in the Forced Migration Research Network at UNSW.

The thematic organisation of the open access annotated bibliographies (OAABs) does not reflect the intersecting and complex overlaps of the various foci in the literature, so please keep in mind that this is an interpretive exercise and one that could easily be reworked by another set of authors. An important note to make is that these resources should not be read as ‘the reading’ of any piece — rather they reflect the interpretive lens of a small number of people and should therefore be used as a ‘way in’ to the academic and grey literature. Hyperlinks have been provided to each entry (where possible) so that you may be able to access the original texts (although many of these will be hidden behind pay walls, which we cannot override for copyright reasons).

Furthermore, it is important to note that these resources are not a ‘finished product’; rather, they are reflective of an on-going, iterative engagement with the inter/national literature that critically engages with issues relating to equity in education. As such, there are unintentional omissions in these resources — if you see a gap in the literature, please feel free to make this clear, or offer an entry for inclusion. This annotated bibliography will be updated every six months for the first year, and annually thereafter.