Streamlining lesson for Australian Universities: “be careful what you lobby for! “

My last blog gave an agent’s perspective to DIAC’s innovative streamlining and that it indicated my observation of “surrender” on part of the Universities. Now I attempt to cover the perspective of education providers. That blog generated a lot of interest and there were questions on “what is all this about?” and honestly, I needed to dig deeper to understand it myself. Not sure if I am ready with my predictions but somehow the gut feel is not one that is too optimistic.

I need to base this blog on material evidence and sources and hence will take help of publicly available information and tie-in my comments to the sourced quotes.

ALL 39 universities have finally opted into the government’s streamlined student visa processing system amid warnings of the serious risks they face if any eventually fall short of Immigration Department standards.

Although most universities are believed to have been rated by the department at the low-risk level 2, it is understood a few have been rated at the higher risk levels 3 and 4, meaning they will have to raise their performance to avoid dropping out of the system.

But they will have time to improve and will not be held accountable until a review in March next year, when those still rated at level 3 will have a further six months to improve.

This is what THE AUSTRALIAN reported this day. However interestingly, DIAC “has agreed to keep risk assessment levels confidential to avoid them becoming a proxy for quality”. But with more than two people knowing something, it cannot be confidential. Quoting THE AUSTRALIAN…

According to industry rumours, only two universities were rated initially at the lowest risk level 1, but both these were thought to have relatively small international student numbers. The university of Notre Dame is rumoured to be one of these.

I agree that it is easy for an University from Freemantle with hardly any recruitment activities in higher risk countries to have an AL1. The bulk of the Universities are in AL2 and once again “rumours” have it that two Universities that have figured lower in the AL are CQU and University of Ballarat. Some would say “understandably so!!!” as they chose to partner with private vendors to offer their programs who in turn worked like private businesses “alone” till they were forced to change (or have they!). These Universities, by themselves, are fine institutions otherwise.

My take is that the whole game of exposing the Universities to the Immigration’s AL mechanism is far too risky. It is now a done deal for DIAC that all the Universities have “opted in” and hence have become “participating” in the streamlining. Clearly this has not been an easy decision. Professor Dean Forbes, Deputy VC at Flinders University has been quoted by the newspapers today indicating that

For many Australian universities, the inevitable consequence of losing access to the streamline program will be a significant reduction in international students and a precipitous decline in revenue,”

Digging deeper, I come across the full arguments of Professor Forbes. In a paper titled ASSESSING AND MANAGING RISK IN INTERNATIONAL EDUCATION: A POST KNIGHT REVIEW INSTITUTIONAL PERSPECTIVE  that includes the thoughts influenced from his discussions at a recent meet and also discussions with members of the Universities Australia advisory group. I would assume that this is not an internal document as it is publicly available and will be quoting verbatim from this well structured article.

Last December DIAC informed universities about their Overall Risk Ratings (ORR) based on hitherto unseen student visa data. Measured on their international students visa performance universities were allocated into one of four bands.

The challenge crystallized.

  • Optimists wondered how to get promoted to a higher level
  • Pessimists were concerned with how to avoid relegation
  • And some of us were thinking, we must do this, but what are the risks, and will I lose my job if I get it wrong?

I seem to be agreeing to most of what Professor Forbes writes when he indicates…


The initial area of risk for universities was about the decision to opt in or opt out of the streamlined visa program. Where they had a real choice by being classified as AL1 or AL2, this was a relatively straightforward trade-off between risks and rewards. It was more complex for universities categorised in AL3 or AL4.

For those that opted into the streamlined program, the area of risk shifted to the performance of the university. This centres on the ORI, which will be calculated on a six monthly basis. This is a short period; too short in my view. A rolling figure over 24 months would even out the impact of short-term blips.

Deterioration in the visa performance of international students would see the university drop down the AL range and lose access to the streamlined program.

Now for people such as us he interprets the factors that could precipitate a slide down the AL…

So what are the specific factors that could precipitate a slide down the Assessment Levels? Essentially, universities have greater responsibility for enrolling only bona fide students. That sounds straightforward: right? Well, no. DIAC’s assessment of students will be at the AL1 level, which is less rigorous than it is for AL2-AL4 countries. If there is a mis-judgement of an international student by either DIAC or a university it will affect the university’s ORI, and hence jeopardise their access to the streamlining process.

Universities are not required to do anything, but will still be held accountable. At the same time, they will need to manage the risks around the interpretation of visa requirements and of the information they have access to, and the risks of seeking out and assessing private information that may contravene privacy legislation.

There are five specific risk areas for universities that need to be managed. They must:

1. Undertake a financial assessment of students in order to be sure that students can meet their obligations. Some universities may outsource this function or work with banks on assessments

2. Ensure the students meet the appropriate English language requirements. DIAC has identified what it believes are appropriate levels of English for university study

3. Deal only with student recruitment agents that have a high level of integrity and success with the students they recommend. Coincidentally, DEEWR/DIISTRTE has recently released a Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants

4. Where visas are packaged with partner education institutions, ensure the partners standards are at the same level as the universities

5. Be confident that students are Genuine Temporary Entrants (GTE). That is, they are not intending to stay in Australia on a long-term basis

Universities have for some time dealt directly with four of these five areas. The exception is the judgment call about whether a prospective student is a Genuine Temporary Entrant. The real difference is that the risks for universities is significantly higher. Some of the risk previously taken by DIAC has been shifted to the universities. These are risks by proxy.

Under the current regime, if a university misjudged a student it was dealt with on an individual basis, as for any other student issue. DIAC managed the consequences. If the national visa data demonstrated that there was a pattern in a particular country, and students were not complying with the visa requirements, DIAC adjusted the AL for the country. Under the streamlined process the adjustment will be based on the university with which the student is involved. If a negative pattern emerges, as measured by the ORI, the university will be penalised.

While I can say BEST OF LUCK to the Universities and say it with a lot of sincerity and a little sarcasm, I was drawn to the newsletter of ANU where they have informed that the University has decided to “opt in” to the streamlining. I guess they thought that some will “opt in” and some will not. The fact that all have had to “opt-in” could actually be another interesting scenario. Just wait for two years and get ready for another Knight Review into the whole process that may just summarise that only those who take the hefty visa fee that includes costs for verification and manpower need to spend it too. I am not the only one saying this.

The University of Adelaide’s pro-vice-chancellor (international), Kent Anderson, said although streamlined processing was positive, the government was effectively shifting responsibilities and costs on to universities.

The documents quoted extensively above can be of big help in understanding the new innovative visa mechanism from an insider’s perspective. (The Australian article is on this link and  You can access the  paper of Professor Forbes on this link) Can’t agree more with Professor Forbes when he concludes…

Overall the next 12 months promise interesting times for international heads in universities. The lesson of all this for universities: be careful what you lobby for! 

Categories: Tags:


  1. Hi Ravi, the universities have their work cut out and most of us are entering a zone we have never been in before. Be rest assured that we will be relying on our agents more than we ever did before and the one’s who have the right internal systems in place to recruit students for us will come out winners in the long run. Some of them are already making the kind of noises we want to hear. A great opportunity for the established agents to cement their market position and push out lot of fly by night operators.


    1. I agree that the Universities will have to work far closer with their agents now… In my previous blog on the same theme I had mentioned…”Finally, the immigration is indirectly telling Universities that there are some good agents and that some agents do good work and that good Universities need to work with these good agents.”


  2. Ravi – Big companies representing major Australian Univ will blossom and small companies representing a few Australian Univ in a niche market will perish……


    1. Rahul-Lets put it this way… The number of agents operating in India will come down. Only those who are contracted by Universities and have a track record will continue. I guess this is what is desired by the system too. Now, I actually fear for some large agencies too whose model has been loose and who have primarily worked through franchising where they have little contact with the students directly… I also feel that regional agents will do well. The idea is to remain niche.


      1. A very difficult situation for the agents and universities. 1st year will be Happy days for the Universities, we will get to see the side effects later. But, as you said ,all Universities will work with only ” Few Quality Agents” only.


        1. @Venu: by the time side-effects appear, be ready for a full review of this initiative. I believe that the full life cycle of the new AL system in the current form is only 2-3 years. Be ready for private campuses of the government Universities to face closure by 2013. We also expect some streamlining for TAFE and maybe some Pvt Providers too within a year. It is going to be such a confusing visa system in one year that the “quality agents” will be indispensable.


    2. Rahul, not all big companies are doing the right thing. I have seen big companies doing the wrong thing to survive the last 2 years slump. So, Uni’s have to be careful about some big agents and take inputs from DIAC about the quality of applications lodged by them.


  3. I don’t know why all these changes. The rules in place under Howard Govt when I was on a 574 visa were absolutely fine.


    1. The reason for the change is in the title of the blog and in the closing remarks. The Universities lobbied the government for easier visas for their students over the others. Now all the Universities have opted in and the Immigration has involved them in screening of the students. More than what they bargained for…


  4. Ravi, What I see happening is agents are now going to try working with other destinations (countries), as well as with Australia, so as to supplement their income. International education recruitment becomes cyclic. One day Australian visa’s are “easy” to get, then they “tighten” up and UK looks attractive, and so on. I do hope unscrupulous agents are pushed out, as they give the whole sector a bad reputation.


    1. The tough thing is to find out as to who is unscrupulous and who is not. Big renowned trend setters sometimes do things that make them so too. They could franchise and the franchisee or subagent could cut corners… Its a difficult world.


  5. Institutes need to work closely with agents, not only closely but they need to be cautious as to who is their agent. Looking for “numbers” from agents should change

    The Knight review is a sincere attempt to explore ways to assist the OZ education industry to recover. The main emphasis is also on maintaining the integrity of the Australian student visa system which earlier was misused and raped.

    The introduction of GTE criterion was highly essential. All students need to undergo an interview with the visa officer. The conditions to gain a student visa are very clear. Students need to prove to the visa officer in an interview that their intention is genuine and it’s for further studies only.

    In addition to the above Australia is adopting the streamlining policy for education providers. My understanding about this is that it will make every institution fully accountable for the students that they recruit themselves. If their students breach visa conditions, the institution itself should find it more difficult to gain visas for subsequent students through an increased risk profiling. If an institution demonstrates that their students are complying with visa conditions, it should find it easier to recruit students via a lower risk assessment profile

    Such changes will always lessen the student numbers; I think many some smaller providers’ including their agents will collapse.

    Institutes that were offering migration pathways as their key outcome will be wiped out. Some TAFE providers too that did this are / will face further difficulties.
    Agents who operate with private providers will “die”

    As an education agent myself I can say that “The industry” is taking a new turn, a new direction for a better tomorrow”


  6. One of the main point is that DIAC has shifted almost all of it’s responsibilities to Universities, it is left with a little work at hand in “Day TO Day” processing. Why then it should be cherging huge money for fee. It is understandable that they can never shre this money with Universities/agents, then why penelise the “Genuine Students” with such a high fee.

    During this week I have dicussed with many delegates of The Super Victorian Trade Delgation. They have all agreed that they are confused about the this new process, as they are expected to open offices in the country, but have been forced to sign up because of the Copetetion signing up. Moreover they dont seem to have choice and see this as the only Ray of light during these bad times and are happy to go ahead with the trials.



    1. I think monitoring the institutes will be tougher task for DIAC and that’s why the fee is also high


Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s