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AIEC Submission Knight Review Student Visa Program Department of Immigration DIAC


Click to hee to see AIEC and other submissions to Hon Michael Knight AO Strategic Review of the Student Visa Program Department of Immigration & Citizenship DIAC.

AIEC QUEST Australian International Education Centre.

In Australia international education and immigration have been under domestic attack due to politics, media campaigns, issue of genuine versus non genuine students and related “wedge” issues, yet everyone, including Australians, aspire to social and economic mobility through (internationally recognised) education, followed by an occupation or professional career.

It is neither illegal nor illogical for international students and prospective immigrants to desire social and economic mobility through a system developed in Australia, and for Australia to benefit from a diverse community (and conversely about 1 million Australians doing the same offshore).

These same students, like those who came through the “Colombo Plan”, whether they remain or return home (or nowadays known in EU as “turnstile migrants”, residing in multiple locations), should be ambassadors for Australia. Instead, they find themselves being admonished, and accordingly have become communicators of negative word of mouth about the Australian education and immigration system, where Australia governance at best appears overly bureaucratic and uninformed, at worst incompetent, and a bit racist.

This submission will address issues according to terms of reference with summarising qualitative and anecdotal feedback to illuminate social issues that are generally ignored or missed through formal administrative processes, and then appear in the media which has been informing Australia most on this subject.

1. An effective partnership framework that considers the respective roles and responsibilities of key stakeholders, including education providers, the Department of Immigration and Citizenship (DIAC), the Department of Education, Employment and Workplace Relations, and state and territory education departments.

Australian governance and administration of, and responsiblity for, international education and immigration, is diluted amongst organisations and departments at different levels of government, and lacks any cohesive or holistic approach. There seems to be no formal framework linking the plethora of federal, state, Quangos and industry bodies to ensure integrity in the system for purposes of education quality, marketing (this does not mean recruitment and international travel), student welfare, visas, immigration and feedback.

An example is where most within industry onshore could see oversupply of skill demand occupation study places growing, with potential to apply for permanent residency (PR) some years ago, but there was neither a process to monitor nor adapt, e.g. caps on places, public warnings to institutions, students, education and MARA agents.

Lack of communication is understandable due to Australia’s “Kafkaesque” Migration Act which precludes Australian citizens within industry onshore, who have a good overview (discounting constant changes in regulations) from discussing immigration and visas with prospective students and immigrants. Further, many in industry may feel “gagged” where they complain privately but will not air their grievances publicly, especially when the Australian public view international education and immigration so negatively (through conflation of proxy issues e.g. refugees, population growth, integration, identity, house prices etc.)

An example was where everyone knew that there was a significant oversupply of study places in TAFE and private colleges, and graduates seeking PR from e.g. cookery and hairdressing, but no timely systematic cooperative action was taken. The present occupation facing an oversupply of study places and potential PR applicants is accounting which remains on SOL, and universities have benefited from a significant transfer of existing onshore VET students, in an environment of falling student commencements and enrollments.

Solution: A forum, occasionally physical meetings, but preferably online, where onshore/offshore stakeholders interact and share information to be informed and allow proactive actions to be taken. From this an attempt could be made to match demand with supply through various means e.g. capping maximum number of study places available for SOL occupation study pathways.

Presently good example, and one of the most informative forums is independent and offshore e.g. “PomsinOz” http://www.pomsinoz.com where prospective immigrants, temporary workers, students, new residents and MARA agents can interact sharing information, advice (including from DIAC), giving a qualitative picture (apparently forum visitors included DIAC personnel trying to gauge what prospective immigrants have been thinking).

International education regulation in Australia via DEEWR, state governments and self regulating institutions tends toward top down paper based processes (i.e. “box ticking”), not active intrusive evaluation of stakeholders’ experience from classroom learning/teaching through to socialisation, employment and return home or PR. Fact is no “private college” has been closed except due to bankruptcy, as they are merely following Australian and state regulations, but connotation that e.g. private VET college bad, TAFE less bad, university best confirms there is an education class system in Australia.

Key issue is that clients or users of the system, i.e. international students (and families) have few if any avenues to raise concerns, nor are the asked. Good example is how student welfare became an issue where everyone, except the industry in Australia, seemed to be aware of? Compounded further in Australia by CRICOS which leads to separation of international (i.e. “foreign”) students from mainstream domestic Australian students, treated differently with more conditions, leads to a form of “apartheid”, which may preclude socialisation and integration.

Solution: Implementation of compulsory (qualitative) evaluation processes to highlight issues before emerging in the media (onshore and offshore), which could track the student life cycle. Further, one stop shop or ombudsman where students and stakeholders can highlight issues concerning their welfare, education quality, visa anomalies etc.

Australia’s international education and immigration system have been compromised by what appears to have been an orchestrated campaign in media for short term political gain, and appeasing the “anti immigration” lobby.

This has been conducted through conflation with other issues (refugees, environment, house prices etc.), outright misinformation (students are “given” visas, all students automatically gain PR etc.), racism (Asians cannot learn English nor adapt to “our way of life”) and suggestions that Australia is being overwhelmed through massive population growth.

Fears about population growth have been the mantra, but most Australians, including media, do not realise that international students as temporary residents (studying more than 12/16 months) are included in population data whereby industry success (and mooted immigration changes) caused significant spikes in new commencements, which in turn increase future population projections. This was used to alarm the public in debates about population growth, sustainability, environment, infrastructure etc. (and the real estate industry to stimulate interest in property investment)

Message to the world is that Australia does not want international students nor prospective immigrants, especially from Asia and the Middle East (as complaints about British or Europeans coming through the same system are non existent?).

Solution: Firstly have ABS revert back to original definition of “population” and do not include temporary residents? Then Australia must send a constant and positive message reclaiming our brand as a “tolerant diverse first world democracy”, through effective international channels to relevant audience, that we welcome international students, visitors, travellers and immigrants. This also requires leadership and avoidance of appealing to misinformed notions in the Australian electorate and our psychology of blaming “foreigners” for integrity issues in education and immigration systems that are planned, legislated, regulated and managed by Australia.

2. The appropriateness of existing threshold requirements for Student visa applicants including English language proficiency, financial capacity and educational qualifications.

IELTS was appropriate when introduced for prospective students but not perfect, e.g. not designed to assess workplace communication proficiency (many native speakers with university education would find it challenging to attain high scores). IELTS test system can be coached and outside of Asia supply issues and difficult to access tests, yet alternatives such as (independent non profit) TOEFL are readily available.

In Australian media and society, many monolingual English speakers complain about English levels, workplace proficiency etc. but language ability is not an exact quantitative science but only one aspect of “communication”. Communication is affected by many social factors e.g. class mix, teaching quality, social/work opportunities, and level can deteriorate through VET or university study, if not socialising in English outside class (often even within). Further, the visa system caps the number of weeks that international students can study English, therefore precludes school, VET or university students from returning to English study, thus remedial impossible.

Monash University’s Centre for Population and Urban Research conducted a study (even though CPUR appears to have expertise in demography, but neither linguistics nor workplace skills) that propagates the myth that it is entirely an issue of (predominantly overseas trained “Asian” doctors in this example), who do not have sufficient English language skills. Within medical health care industry where many overseas trained personnel are employed, the issues are that IELTS may not be an appropriate test, new employees “dropped in at deep end”, lack of orientation e.g. workplace language training, cross cultural skills, etc. while from employers’ side short term outlook, lack of resources, monolingualism, lack of cross cultural skills and limited empathy in communication from Australian personnel and clients.

Further, emphasis and focus solely upon English language skills sends a “neo colonial” message not just internationally, but to all Australians that one does not need to study other languages nor appreciate the benefits of communicating with our major trading partners in their language.

Solution: IELTS monopoly to cease, and allow other tests to be used asin the past e.g. TOEFL, Cambridge etc., as all language centres have comparison systems that can equate English levels for study admission from pre IELTS monopoly times (and for visa assessment levels 1 and 2 for whom IELTS is not compulsory). With regard to workplace proficiency, research which communication tests and evaluation methods are used internationally would be apt, no need to “reinvent the wheel”.

3. Approaches to more effectively gauge and manage immigration risk in the Student visa caseload, including considering the suitability of the Assessment Level model.
4. Approaches, including compliance measures, to prevent misuse of the program and deter breaches of visa conditions.

Migration intentions, supply demand via study not monitored e.g. no caps nor estimates of likelihood of PR, even if approximate? Australia, or more specifically DIAC is “Kafkaesque”, i.e. cannot offer truly independent nor certain immigration advice unless through rejection, the advice letter explains, or appeals process divulges further information.

There are too many MARA agents, majority only have quantitative knowledge while lacking qualitative skills, nor can they possibly keep abreast of constant changes. International students main contact and information point responsible to DIAC, and indirectly their social welfare, i.e. their institution, cannot offer any immigration advice.

Solution: Through any potential forum develop visa and compliance solutions and give institutions responsibility, and monitor their compliance systems.

5. The suitability of separate visas for Schools, Vocational Education and Training (VET), Higher Education, Postgraduate Research, AusAid or Defence, Non-award and Student Guardians.

When new visa system was first introduced and put into practice, it was a significant improvement, and obviously for DIAC, gave accurate quantitative feedback for each sector. However, in recent years the political environment and the following of (push) opinions polls in media by government, has led to constant changes and confusion.

Further, higher education institutions, namely universities, have been given an unfair competitive advantage when a Diploma or Advanced Diploma, same as in VET system under the AQF, if studied through a higher education institution, is given a lower or more advantageous visa assessment level. This appears to be a conflict of interest of universities (and their preparation or pathway partners) or simply better at lobbying or accessing government (while domestically message is now higher education is better and more important than VET based occupations, although most skill shortages are VET?)

Solution: Rather than increasing the number of categories and visas, decrease them, and give more responsibiity to institutions for oversight.

AIEC QUEST Australian International Education Centre.

2 Responses to “AIEC Submission Knight Review Student Visa Program Department of Immigration DIAC”

  1. An effective partnership framework that considers the respective roles and responsibilities of key stakeholders, including education providers, the Department of Immigration and Citizenship (DIAC), the Department of Education..

  2. Further, emphasis and focus solely upon English language skills sends a message not just internationally, but to all Australians that one does not need to study other languages nor appreciate the benefits of communicating with our major trading partners in their language….


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