Over recent days the Senate inquiry into the ESOS amendment bill has published submissions. International education sector submissions are, for understandable but predictable reasons, very critical. Less expectedly, submissions from government departments and agencies also raise concerns.
The most positive government submission is from the Department of Education, which is responsible for administering ESOS.
Education adds detail to how international student enrolments caps on institutions and courses will be enforced. It will be done using the confirmation of enrolment process. Once the relevant cap is reached, no more confirmations of enrolment will be processed that year.
The Department of Home Affairs submission, however, says that the government’s systems are not yet up to this task. It warns that:
“Successful implementation will also be dependent on the interagency sharing of data across core systems which is likely to require significant development for both the Department and the Department of Education. The Department notes that additional processing systems changes will be required to give full effect to these amendments.”
As long-suffering higher education providers know, from their experience of the Department’s troubled TCSI enrolment system, government IT changes do not always go smoothly.
If the IT does not work, the Australian Skills Quality Authority worries about its capacity to enforce the rules:
“It would be very inefficient if manual monitoring was required by ASQA to maintain the caps across 979 providers and would result in the diversion of a significant number of resources away from activities addressing compliance and integrity risks in the sector.”
It would be ironic if integrity measures for international education, a key objective of the ESOS bill, were undermined because the vocational education regulator was too busy trying to enforce unnecessary enrolment caps.
Both AQSA and the Department of Employment and Workplace Relations recognise that government policy is likely to force education providers out of business. In some cases, providers that have acted improperly, that will be deliberate. But in most cases provider exit will be a policy side-effect. Visa changes will trigger some provider failures, with enrolment caps the last, fatal, blow for others.
Both ASQA and DEWR are concerned about the impact of provider exits from the system on students, domestic as well as international.
ASQA points out that domestic students are most vulnerable:
“While international students may be eligible to access some assistance from the Tuition Protection Service (TPS), the scheme is generally only available to domestic students with a VET Student Loan (VSL), and the potentially available assistance differs.”
Like international students, domestic higher education students can get help from the Tuition Protection Service.
But as AQSA says domestic vocational education students are vulnerable. Strict VSL rules mean that few students take out its loans, with only 30,000 borrowers in 2022. Non-VSL domestic students in collapsed RTOs risk losing paid fees.
The ESOS amendments are unprecedented in many ways but remind me of another government reform – VET FEE-HELP.
While the two policies start with opposite goals – VET FEE-HELP to increase enrolments, ESOS amendments to decrease enrolments – their consequences could be similar. Poorly thought-through policy ends with provider collapse, out-of-pocket students, and reputational damage to Australian tertiary education.
Only the Senate can prevent this outcome.
Andrew Norton: Professor in the practice of higher education policy at POLIS: The Centre for Social Policy Research, Australian National University.
The Koala thanks Professor Norton for his contribution. You can view more of his writing here.
