Australian “first in the world” initiative of listing student outcomes “publicly” for recruiting agents is likely to be misdirected since it has missed differentiating between offshore and onshore recruitment objectives of education agents.

Immigration NZ began listing agent’s visa success rate publicly last year and now Australia (not DIBP) wants to go one step further by listing “student outcomes” by education agents. Forgetting conveniently that the role of offshore agents are limited to offshore recruitment and there can be onshore influencers that have a greater role to play in the student outcome.

I am not against onshore agents at all. Even my company is an onshore agent. I am thus talking more on the counselling and recruitment objectives of offshore agents vis-à-vis onshore agents. I had in an earlier blog even made the case for differing commissions for the two types of recruitments.

Offshore education counsellors and agencies give a more comprehensive advice to the student based on the student’s aptitude, educational/experience background, career objectives and would hand hold the student through months (even years) of pain-staking process of which even the parents would often be part of.

Once the student is onshore, they are often in contact with other students and other influencers who purely focussed on migration outcomes hand hold the “already onshore” student to alternative institutions and courses. Not surprisingly, the onshore “so called education agents” are actually “registered migration agents”. I am not against this too. Student’s being able to tailor their career to immigration outcomes is legal and often justifiable.

Now let us see what the Department of Education and Training plans to do:

Australian Government Department of Education and Training now plans to make the data on student outcomes associated with international education agents available to the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) registered providers, and eventually publicly.

Since 2012, providers have had the ability to record education agent details for each enrolling student in the Australian Government Department of Education and Training’s Provider Registration and International Student Management System (PRISMS).

This will be the first time that outcome based reporting associated with the enrolments of overseas students by international education agents will be available to international education providers.

PRISMS also contain data on the outcome of each overseas student enrolment. The Australian Government Department of Education and Training has analysed the outcomes data for each student enrolment against the education agent listed for that student. 

For example, the department is able to show, as a percentage by country and sector for each education agent, where a student they assisted did not complete their study as planned because they did not commence, meet attendance requirements, ceased study early, misbehaved, failed or did not pay their fees.

For more information please visit internationaleducation.gov.au/Regulatory-Information/Pages/Education-Agents.aspx.

Universities around Australia are aware and understand the fact that “offshore recruitment” can’t be pinned to the “student outcome” that has been influenced by “onshore migration agents” and by the decision of the student to move for “migration reasons”. Changes to SOL and migration regulations have immediate impact on the international students and they immediately try to move from one to another institution.

Universities and experienced recruiters are also aware that “offshore agents” can’t be blamed if the students don’t meet attendance requirements, ceased study early, misbehaved, failed or did not pay their fee.

It will be unfair on the quality offshore education agencies to be ticked off for the above reasons. The job of the offshore agency ends with the student enrolling and commencing at the institution. If the documents are found to fraudulent, they can be held responsible. If the counselling advise is incorrect, they can be held responsible but not for the fact that the student moved institutions during the 2-4 years of study onshore or that he or she failed or “misbehaved”.

It just doesn’t make sense since the education agents are not kept “in loop” by the institutions on the student’s conduct or performance in studies simply due to strict privacy norms.

If the Universities tighten their refund policies, don’t entertain onshore recruitment and understand the difference between the first recruitment and subsequent agents, this initiative will be justified.

Universities have begun rewriting their contract and getting the agents to agree to their records be made public under enforced guidelines of the DET and interesting the communications being received indicate the following:

Education agents are an important part of the Australian international education industry.  They are generally highly valued and respected by Australian education providers and the students they assist to enrol and study in Australia.

This Government initiative to disclose the outcomes of students by the agent they are associated with is the first of its kind in the world and will see quality agents recognised for their high standards and levels of service.

Quite an irony indeed considering the arguments made by me above.

I am relieved in the fact that it is not just me (or some of us) who are seeing through this mis-directed shot but also several education providers and industry bodies. I quote from the thought process of an industry group:

The major sticking point, in this ‘world first’ initiative relates to the following DET statement that agent performance information and “personal information” (such as name, phone number, business email, address) will be…
“….disclosed by the Commonwealth Department of Education and Training to other Commonwealth entities (including, but not limited to ASQA and TEQSA), education institutions and publically. The Commonwealth Department of Education and Training will share individual agents’ performance publically as aggregated data (but will not identify agent – provider relationships). Agent-provider relationships will only be identified when data is shared with education institutions and other Commonwealth entities.”

This includes the following information for agents:

• Student transferred – Transferred to course at another provider, notified cessation of studies.
• Cancelled – Provider Decision – Non-payment of fees, disciplinary reasons, Student no longer holding student visa.
• Non Compliance – Non-attendance at classes, failed to meet course requirements.
• Deferment/Suspension – Compassionate/compelling circumstances, student misbehaviour

Additional concerns and views relating to sector and ‘industry’ context for these developments, include:

• Rather than CoE completions, the conversion of CoE to visa granted would be a better measure of agent performance. (Visa success rate is what Immigration NZ has started listing publicly by agent names for India already.)
• Calculating the number or volume of CoEs proves little.
• There is little logic to drawing a link between a student transfer or provider decision to cancel (or others to do with student non-compliance noted above) with agent performance.
• While providers are heavily regulated, onshore agents are not… with voluntary participation only being sought for offshore agents in this or other efforts at best practice guidelines.
• Participation should be legislated, rather than requested. Voluntary mechanisms are essentially pointless.
• There are issues with the integrity of the data when agents use sub-agents and/or another name or ImmiAccount to lodge for dubious students.
• Agents are their own industry now and control much of the broader international education industry, so regulation is more necessary than ever.
• This new system should have been tested with reputable agents. Many good agents would support greater transparency and exposure of dodgy competitors. But, unless this is formally regulated (as opposed to voluntary opt-in/out) it won’t work.
• Any impact on global market competitiveness should also be tested.

AAERI, “one of its kind” Agent self-regulatory association in India with active support of the Department of Education and Training too has expressed its reservation and has desired that the department understands that the role of the offshore education agencies end with successful recruitment. Student’s onshore experiences and influences are beyond the control of the offshore education agent.

Before I close I want to remind that it is the very same department that insisted on removing the “change of education provider clause” in ESOS as it treated the students as a “customer” with a right to move easily from one institution to another. Only when the institutions lobbied against this that the draft of the proposed changes has been modified.

I really wonder who pens these policies and how far removed from the reality they are!