Now that more information on SSVF is available, my July 2015 blog was not totally off the mark: New SSVF still offers a type of SVP and for the non-streamlined, AL2 criterion applies. The dreaded and subjective GTE remains, eVisa extended for all as was intended and concern on course-hopping increases. This blog is from my notes on the SSVF to be implemented from 1st July 2016.
Disclaimer: These are only my notes and thus may only be my accurate/inaccurate interpretation. Please don’t plan your strategy on these notes.
- Institutions and the Countries will have an AL.
- The AL of the Institution is now communicated to the institutions and though not publicly listed on the DIBP website, it is expected to be publicly known to education agents through their partner universities.
- India, Nepal and Bangladesh are expected to be AL3. This is an expectation considering the non-compliance levels and the general discussions. Bhutan is expected to be AL2.
- The follow matrix will indicate how the system will work and the cases that will continue to be streamlined:
- Thus we may assume that for India, Nepal and Bangladesh, the applicants for Institutions that are under AL1 will have their cases streamlined and for Bhutan both AL1 and AL2 students will be streamlined. This is based on my calculated assumption that India, Nepal and Bangladesh are under AL1 and Bhutan is under AL2. If this assumption turns out otherwise, please change the interpretation based on the matrix.
- Of approximately 1100 CRICOS institutions (Language Provider, Schools, VET, Higher Education… all together), DIBP has indicated that at the start of SSVF, the following breakdown applies:
- 8% are in AL 1 (about 85): My guess is that about 15 of the 85 are Universities and bulk of the AL institutions are Elicos providers, Schools and hardly any popular VET provider though some institutions that have not been doing much recruitment from High Risk markets in recent years may still qualify as AL1.
- 86% are in AL 2 (about 950): My guess is that almost all Universities and TAFE will be in AL2.
- 6% are in AL3 (about 65): This may have only high risk private providers.
- Irrespective of the AL of the Institution, each of the providers has streamlined evidentiary requirement for at-least some of their students depending on the AL of the country where the students are from. In the Indian/Nepalese/Bangladeshi context (assuming them to be AL3), only the AL1 institutions will be able to have their students streamlined.
- Streamlined means that the students will be able to satisfy financial and English requirement by a declaration and a COE. It will remain for the institution to be able to set their English or Financial requirement.
- I have been informed that despite this general streamlining, the DIBP has the right to request this information if they desire and if requested, the student will need to provide the specified evidence, e.g. 12 months of funds or annual income etc. etc.
- If “General Evidence Requirement” applies which will be with bulk of the institutions in the India/Nepalese/Bangladeshi caseload, the English and the financial requirements have been greatly simplified.
- DIBP would require a minimum IELTS of 5.5 irrespective of the level of studies. An IELTS of 5 with 10 weeks of Elicos and IELTS of 4.5 with 20 weeks of Elicos may also meet this requirement. Institutions may have higher English requirements based on the program of study though DIBP has this minimum requirement. Some students may be waived this English requirement based on the parameters such as number of years of study in certain countries. Such provisions existed earlier too. In the Indian sub-continent almost all the students who are not being streamlined will need to have the English Language Proficiency through the IELTS/PTE/CAE/TOEFL or OET.
- The financial requirements likely to be similar to what is for AL2 countries currently: 1 year of living, tuition and travel and which will need to be of parents, self or spouse. The DIBP will not require this financial funding evidence if the family income is more than $60K per year ($70K per year if student travelling with spouse) as evidenced from official Income Tax returns only. The government aid/scholarship or such sponsored students will be considered as exempt from showing the funding. No requirement for the funds to be 3 or 6 months old though the funds should be accessible to the student in Australia and should be genuine. Genuine Access Requirements will apply.
- Funds will only need to be demonstrated for the applicant and thus if the applicant is travelling without spouse, the funds to cover for spouse is not required.
- If the student chooses to pay the tuition fees and that is shown as prepaid on the COE, then that is sufficient evidence for the amount being available. Only remainder will need to be demonstrated to be available.
- Streamlined means that the students will be able to satisfy financial and English requirement by a declaration and a COE. It will remain for the institution to be able to set their English or Financial requirement.
- Irrespective of the AL, GTE criterion will continue to apply and the new online visa form will ask specific information about GTE and the applicants will also have the option to upload supporting documents. This is a change from the current eVisa process where the online form doesn’t ask GTE questions. In the paper based visa form, there is a specific question though. I expect the same question to be asked in the online form.
- The data analytics will enable the form to trigger them as “high risk” or “low risk” and that will determine as to the processing arrangements. However with simpler and clearer guidelines, it will be a smoother process.
So, all this is about the SSVF and what we are beginning to learn from various sources and from institutions that have attended briefings by DIBP. However some of you will recall that when SSVF was announced in 2015, I had done a blog and had predicted SSVF to be OLD WINE IN NEW BOTTLE WITH HIGHER PRICE TAG . Today I feel that I was not totally off mark. While there is a new version of streamlining for institutions based on their AL and the country’s AL, all non-streamlined are simply being applied the current AL-2 requirements. This is fine too.
There are some positives, such as:
- There is now one way to apply the visa: eVisa.
- There is now the same treatment to VET and Higher Education and thus the same treatment to all applicants who pay the same application fee for the student visa.
- Students on shorter programs can also have their spouse travel with them as on dependent visas.
- Visitors to Australia on other visas may not have the “No Further Stay” condition (except in some cases) and thus can apply for a student visa onshore.
- Students dropping to a lower level of study (based on AQF) will need to apply for a fresh student visa onshore.
- Institutions will be under pressure to rationalise their international fees or subsidise through bursaries.
- Processing time may improve and increased workload may be moved around processing centres through the online system.
However the new framework has one major unease too:
- I get a strong feeling that course hopping will increase. Students entering Australia say with a higher priced degree will be able to course hop after the first semester to another course at another institution provided it is at the same or higher AQF. Earlier there was a clear provision barring movement from SVP to non-SVP even at the same AQF. I understand the logic of DIBP to encourage market forces at play and protecting the right of the student as a customer but…
- This is thus going to work against the interest of the recruiting institution that has spent money in travelling to markets and also against offshore education agents. We can also expect unethical practises from onshore migration and education agents who will encourage students to switch from higher cost and academic-intensive institutions to lower priced and flexible-study options.
- Universities may start asking for one year fees to be paid in advance and may tighten their refund policies. However I doubt that any institution can hold on the fees for the period that the student is not studying and thus the student may be able to take that as refund.
- There are also rumours that the ESOS requirement for students to study at least six months of the principal program may also be removed.
A lot remains to be seen. It would have been ideal had the condition 8206 been re-instated. This condition used to prohibit switch of provider for one year and was replaced with the ESOS driven condition that stopped the switch till six months of principle program. I have blogged earlier and demonstrated how the changed ESOS condition was really not helpful as it was not a visa condition. Further in the case of packaged students, it worked against the interest of the student itself.
DIBP has delivered a new policy and it now remains for the client servicing end at the various visa posts around the world to implement efficiently. Increased reliance on IT too can be a little issue in the initial stage. The requirement of visa fee to be paid only using a credit or debit card (possible even Paypal) can be an issue in certain countries.
Where there’s a will; There’s a way.
This saying applies to students and agents finding a way to implement the new changed system and this saying also applies to students and agents finding a way around the new changed system. Fingers Crossed.
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