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 RISKS FOR UNIVERSITIES

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!