My musings about DIBP’s new SSVF. Is it really OLD WINE IN A NEW BOTTLE as I had blogged last year when it was announced…

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.
  1. Institutions and the Countries will have an AL.
    1. 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.
    2. 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.
    3. The follow matrix will indicate how the system will work and the cases that will continue to be streamlined:IMG_9868
    4. 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.
    5. 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:
      1. 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.
      2. 86% are in AL 2 (about 950): My guess is that almost all Universities and TAFE will be in AL2.
      3. 6% are in AL3 (about 65): This may have only high risk private providers.
  1. 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.
    1. 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.
    2. 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.
  1. 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.
  2. 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.

23 Comments

  1. I fully agree at this point of time based on the updated information.
    On-shore Business will be bigger then off-shore business and to my information the Onshore Agents who were either based in Sydney or Melbourne have already started having offices across major cities in Australia and approaching all those low fee high commission paying colleges to tie up with them.

    The Business Matrix will revolve in 2017 probably which may not be in favour of Universities.;

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    1. Yes Narayanji, this is my immediate concern. Not just the agents offshore but even the quality institutions who invest in travelling and marketing overseas, will lose out. The other perspective is that the student can opt to study in the low cost institution right from the beginning and those going to premium institutions should understand the value that they are going to get. Not just marketing but reality.

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  2. Dear Ravi, informative blog, thank you, you confirmed my suspicions as well. I have two questions for you: you say ‘I get a strong feeling that course hopping will increase’, change of provider is prevented under standard 7 of the National code, are you saying that providers are deliberately ignoring this standard? and is there a conflict between standard 7 and visa condition 8206?

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    1. The ESOS restrictions that I referred to was actually the restriction under Standard 7 of National Code. It does require a release letter from the institution for another institution to issue the COE. However that is only if the student is moving within the first six months. Currently the student beyond six months were also restricted to move from SVP to non_SVP. Visa Condition 8206 was ideal as it restricted change of provider for one year. Also the standard 7 talks of 6 months of principle course which is against the student. A student packaged with a diploma leading to degree, is not able to change institution for any reason till 2 years of the 3 years degree (if it is 1.5 years of diploma and 1.5 years of degree in package… as an example).

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  3. Are we going to see lot of students applying visitors visa for holidays during sports events and once onshore, convert their Visa into student and stay in the countries. Will this be termed as a “back door entry”.

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    1. I think DIBP will still apply “exceptional circumstances” to approve/refuse visa application from AL3.

      AL1 were already safe and getting visas on visitor visas here. AL2 had higher approval rates.

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      1. Possible Jag. You are referring to onshore grant of visas to those with visitor visas. I also find that it is more difficult to refuse a visa onshore on vague reasons as there is the provision to appeal a decision onshore. Offshore, the ammunition to refuse visas is GTE which is totally subjective and subject to differing opinions.

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  4. Thanx Ravi for such a detailed explanation to let us know about the new development with regards to the new SSVF. Not sure if this is the pragmatic approach DIBP has come up with and only time will tell. On the onset the problems of Waka jumping will continue and perhaps take a larger leap making the onshore agents busier than ever. However, business wise the VET providers will also get more business which will make them happy. Let’s see…..

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    1. Yes Bubbly, every few years, we experiment with something new. SVP clearly failed and the reason for that was that the Education Providers were being asked to undertake the role of Immigration for which they were simply not armed. Now the Education Providers who make efforts and invest in marketing by travels to distant markets around the world could find that their quality students are poached after six months of their studies onshore. I find this very distressing as an offshore recruiter. The interest must be protected.

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  5. It is a fact that any student who wants to change the course or provider is not a genuine student( Period). Under this GTE and SVP , when we send an application for admission the institutions/universities are doing their best in making the student understand about Australia, the costs, the course, the course outcomes, the visa conditions, his future plans ( almost everything) that one can expect before buying a product. Each institution is making them sign loads of agreements and documents and making them write SOP’s ( which is a joke, and you should do a blog on this Ravi later), and after all these precautions if the student wants to Hop the institution, then surely it is a misuse of thew system and such students should be asked to apply for a visa. I think the AL1 universities and higher fee universities, be prepared for this hopping business.

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    1. Venu, There are some exceptions to this. I have come across students who have very genuine reasons to change a course or provider after arrival. It can happen by going upward in the AQF. I would also like to share that a genuine statement of intent can be simple, less flowery and honest. With several tools available, one can read through a fake SOP. The DIBP current paper form in Q33 asks specific questions pertaining to SOP and those are fairly direct. For example the student has an opportunity to explain any gaps in education or even reasons for a change of stream. The student can give genuine reasons for low academic grades. We meet students of all kinds and I have come across several cases where a genuine SOP has helped the student convince the visa officer especially in absence of interviews. Now that SVP is going to be history, the responsibility of doing the checks (or the detective work) is going to be lessened. This is good.

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      1. That is exactly my question, what can be a genuine reason to change a course. And don’t blame the agent for giving incorrect information. I think a student going for a masters degree and who can write an un plagiarized sop is an adult who can do some research on Google before spending 10 lakhs. The only genuine reason he is allowed to give is that there are no teachers in the universities or the course he opted for is no longer offered by the uni. It is time to stop blaming the agents when the students are issued visas under GTE /SVP.

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        1. No Venu, there are genuine students. A student applies to multiple institution and say his first preferred institution which refused him admission in first instance issues him an acceptance based on the performance in the first semester of his study at the other institution. This is totally genuine. Secondly sometimes a student of hospitality studies realises the same Bachelors done at a TAFE is more hands-on as compared to at the University which is more academic. He has a reason. I also know of students who are studying IT and find programming to be beyond their abilities. Because they had not experienced it earlier, they are within their right to move to another program that they can handle. However, I know that there are many instances where the student’s reason is cooked up and often fuelled by advise of rogue onshore agents. That remains my unease.

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          1. Good students changing from AL2 unis to AL 1 is never a concern. We are looking at larger numbers who change because of reasons like high fee, higher academic commitment when they knew and signed everything before coming to Australia . These students should be asked to reapply for visa even if they are shifting between same AL levels. All agents are good, they are just doing their business, in Australia I think anyone over 18 is considered as an adult and does not require supervision. One cannot blame an agent of fuelling. It’s like saying ” I robbed a bank because someone fuelled me.
            P. S. This is just a friendly discussion about the topic and not an argument.

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            1. There are agents onshore who are into all kinds of activities… This is the reality. The activities include paying students to change and they work “hand in gloves” with certain institutions. This is the area of concern and sooner than later, DIBP will need to crack-down on them.

              I take your point that they are businesses operating because the loop holes exist. The aim will be to find the loop holes and plug them. However as my last para in the blog indicate: Where there is a will, there is a way. It applies to all.

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  6. As the rules are already in place, lets see what happens for the next 2-3 years and I will be looking forward for a new blog from you when a new model arrives.
    Happy recruiting till then.

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  7. I think AL1 institutes will try to jack-up their fees again, just like some SVP institutes (especially privates) did when they had the SVP status. They were hoping that the advantage that came with SVP (easy visa grants), will allow to have higher fees (for offshore students only) and higher profits. Plan didn’t work because SVP was a failed policy for day 1. Most private institutes had higher refusal rates whereas students who got visas granted, later on changed to other SVP institutes (who were offering lower fees to onshore students).

    Same thing might happen with Universities but at a lower scale. Students in other programs won’t have much option to move around as the price difference will be $2000 max. Again, its a competitive industry and everyone has their own business model.

    Offshore agents who are only enrolling in Accounting and ICT are doing the same thing as onshore agents; offering course that sells! It’s an easy sale! Plenty of rogue offshore agents will lay the foundation of “course hopping” by suggesting students that they can change after 6 months.

    The cheapest Bachelors/Masters we have seen is around $14,500 per year for courses like Accounting or IT. These institutes do not have wide array of courses either, so will appeal to small section of students.

    In the recent workshop at Vic Uni, out of about 30 students, I found only 1 student doing Accounting and 2 students doing ICT. Rest were from MBA, Banking and finance etc. Obviously they wanted to know their migration options considering they were not in SOL.

    Ravi, you are right about onshore agents. There are a few in Melbourne who are actively distributing flyers around the city, offering to change institutes. But these are mostly changing from Unis to pvt institutes (MBA to hospitality, automotive types). These students will not change to another Bachelor or Masters program (even at lower prices). Theses students were advised by rogue offshore agents that only way to get visa was to enrol into Masters program at expensive unis and often packaged with expensive ELICOS and foundation courses.

    Now, the reality is that most students work and pay fees from Australia. Imagine the situation with these students; they cannot pass ELICOS (let alone the foundation or masters), don;t have fees for next semester, fear that their visas will be cancelled anyways (academic progress).

    So what do they do? They take the next best option… change to something that they can do.. and something that is allowed by DIBP. Where they go? The first person who hands them the flyer offering cheaper course leading to PR!

    I’ll be worried about these students under SSVF. They will have to apply for student visas again and most likely get refusals. So what? (the rogue agent will say). What options do you have? At least you can apply for AAT and Federal appeal and stay here. If you are lucky, you might find an Aussie partner..etc etc.

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    1. Your last para says it all. That’s the strategy of onshore rogue agents. However the aspect of students being able to easily move provided the next program is at same or higher AQF is interesting. I have found huge price difference for international students for the same degree say in accounting and IT between universities and this can become a reason for the change. Market pressures should alert such universities to keep their prices in check.

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      1. I have seen that lot of bigger and expensive universities don’t have good support services for students. There are too many procedural steps but without a human touch. I think there is a lack of empathy or understanding of differing situations of a new arrival, who probably at 19-20 years of age is immature and prone to getting misguided by friends/agents. Getting a release letter for a genuine student is a nightmare because they are putting everyone in the same group and treating them like “course hoppers”.

        Comparatively, smaller and cheaper institutes know the pulse, when dealing with international students (because they usually deal with more international students than bigger Unis). Their support services are designed for international students. They usually rely on 1 or 2 big markets, so very specific services are provided.

        A lot of students were misguided from offshore, when they were sent to do MBAs with 5 band in IELTS. Universities should have cancelled Agent agreements and withheld their commissions. Again, it was Universities who offered COEs in the first place. Does that mean that Universities have no idea what level of English is 5 bands? or they thought they could suddenly turn them into 7 bands on doing a 10-20 week ELICOS, which IMHO is a crap course. I haven’t seen a single student benefiting from it. IELTS tutors and coaching centres are doing much better than ELICOS.

        Let’s not forget: $20b industry! And more than half comes from “not so genuine” students (looking for migration outcome).

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        1. The University is the one who issues the offer letter. I am not sure as to how can an agent send a student for an MBA with mere 5 in IELTS unless the institution has that as the entry requirement.

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          1. Right. So another institute offering Dip COE to a student coming from Uni is doing exactly the same. Knowingly. With or without the agent. So to blame an agent entirely is not correct. Agents are selling what’s offered by unis n colleges.

            There’s no simple fix for it as long as there are monetary gains for everyone involved. Govt is aiming for 700,000 students in future. They know better.

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