The release of a wide range of provider-level international student enrolment data last Friday, along with indicative caps for both higher education and vocational education and training providers, is unprecedented and led to a weekend of questioning, analysis and the shaking of many heads.
The data in the tabled documents reveals deep flaws in the methodology used to calculate indicative enrolment caps for new international students. There are multiple questions about how some of the 2025 caps have been calculated, with anomalies and inaccuracies identified. Providers have been arbitrarily advantaged or disadvantaged based solely on timing; and, in some cases, providers appear to have been rewarded for what could be considered poor practice.
What data was tabled?
On Tuesday 17 September, motions were tabled on behalf of Senator Sarah Henderson seeking:
“That there be laid on the table by the Minister representing the Minister for Education, by no later than midday on 19 September 2024, the document or documents which include the following:
(a) for each higher education provider (being publicly funded universities and private providers):
(i) the new overseas student commencements in the years 2019, 2022, 2023 and 2024,
(ii) the indicative international student profiles as proposed for 2025,
(iii) the number of onshore international students for 2019, 2022, 2023 and 2024,
(iv) the total number of onshore (domestic and onshore international) students for 2019, 2022, 2023 and
(v) the onshore international proportion of enrolments for 2019, 2022, 2023 and 2024; and
(b) the selected higher education statistics for 2023.
That there be laid on the table by the Minister representing the Minister for Skills and Training, by no later than midday on 19 September 2024, for each vocational and education training provider with a Commonwealth Register of Institutions and Courses for Overseas Students registration:
(a) the new overseas student commencements for 2019, 2022, 2023 and 2024;
(b) the indicative international student profiles as proposed for 2025;
(c) the number of onshore international students for 2019, 2022, 2023 and 2024;
(d) the total number of onshore (domestic and onshore international) students for 2019, 2022, 2023 and 2024; and
(e) onshore international enrolments as a proportion of total onshore enrolments for 2019, 2022, 2023 and 2024.”
The Higher Education tabled documents are available here.
The VET tabled documents are available for download here.
What did it tell us?
This contributor did not spend her weekend doing a detailed analysis of the data. However, Claire Field did, and you can find her excellent and detailed analysis of the data here.
My not-as-detailed analysis, noted the following:
- VET providers with caps that are higher than their CRICOS limit
- VET providers who only commenced delivery in 2024 being advantaged in comparison to those who commenced delivery in 2023 or earlier
- 150 VET providers have been given an allocation of 30 NOSC, despite not having enrolled any new international students in 2023 or 2024 (likely to be new providers), calling into question their ability to fulfil this number
- The spread of caps allocated to private VET providers will almost certainly impact the financial viability of some, with 195 VET providers having a New Student Overseas Commencements limit of 10 or fewer
- Some universities are doing exceptionally well in 2024 in comparison to 2023, considering that the 2024 data is only until June
- Sixteen universities have a 2025 cap that is lower than their 2024 enrolment data to June, all members of the Group of Eight are in the sixteen, and the top four are Group of Eight members
- The University of New South Wales cap for all of 2025 is about 45% less than what it has recruited June 2024 YTD
Data accuracy
Although the Department of Education officials denied in the Senate Committee hearings that there are any errors in the data that has been used, providers have told The Koala that some of the published data for their institution is not correct or at least they have not been able to replicate the Department’s data.
Minister’s rebuff of Vice-Chancellors
On the same day (18 September), a motion was moved on behalf of Henderson requesting the tabling of “a copy of the letter or letters sent to each public university by the Minister for Education regarding the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024 and Ministerial Direction 107 on 16 September 2024 or any other applicable date”.
These letters are included in the tabled documents, and have been characterised by the AFR as Clare telling Vice-Chancellors that they should “shut up on caps or suffer the consequences”, while others have told The Koala that this is akin to holding the sector to ransom.
In part, the letters say: “I can confirm that Ministerial Direction 107 will be lifted upon Royal Assent of the amendments to the Education Services for Overseas Students Act 2000 currently before the Parliament.
Any delays to Royal Assent will delay the lifting of Ministerial Direction 107. Should the bill
not pass, I can also confirm that Ministerial Direction 107 will remain in place to allow the
Government to achieve its goal of reducing the level of migration.”
The Koala noted that there seems to some movement in the Government’s position. Clare had previously indicated that MD107 would not be revoked until 1 January 2025. Whereas these letters indicate that MD107 will be revoked once (if) the Bill receives Royal Assent. Although, this may be a hollow victory as it is probably only a matter of weeks’ difference.
Did the data have to be made public?
Minister Clare has previously said that the Government would make public the 2025 caps “in due course”, which was probably short for, ‘after the ESOS Bill had passed through Parliament’.
What about the rest of the data, did it have to be made public?
The short answer is ‘no’.
Senator Henderson has repeatedly called for more detailed international student data to be provided to the Senate Committee since the inquiry into the Bill commenced. Keen observers will recall Group of Eight CEO, Vicki Thomson, copping a spray in the first session on the first hearing day for not having data to hand about her members.
During the third hearing on the 6 September, Senator Henderson again requested data be provided from the two government agencies, Department of Education (DoE) and Department of Workplace Relations (DEWR). Officials from both agencies raised concerns about providing confidential data and were informed by the Senate Committee Chair, Senator Tony Sheldon that recommendations could be made that the data be provided in camera.
Obviously, the two agencies hadn’t followed through on the provision of the data through these channels, or at least not fast enough for Henderson, leading to her motion.
It’s certainly true that higher education data is published through the higher education statistics, but there’s a significant time lag in the release of the data, with some 2023 data being released this month, and the remaining data due to be released this coming week according to the DoE website. However, private VET provider data is not available, and none of the data is published in this format.
It has certainly raised eyebrows if communication to The Koala over the weekend is anything to go by.
What to watch out for
In the Senate Hansard for 18 September there was a notice of the intention for Henderson to table a motion on the next sitting day (ie 19 September) seeking student visa and other data by 5pm, 23 September. According to Hansard on 19 September, the motion was not put forward, for reasons unknown. But it’s something to watch out for.
The motion was to have sought the tabling of:
“(a) the number of student visas applied for, issued and rejected in the years 2019, 2022, 2023 and 2024 by number, broken down into each sub-category of visa (ie school, public university, private higher education provider, private vocational and education training (VET) provider etc.);
(b) the number of student visas applied for, issued and rejected for each such month in the years 2023 and 2024, broken down into each sub-category of visa (ie school, public university, private higher education provider; private VET provider etc.);
(c) the number of current or former student visa holders who have lodged a protection visa application for each month, for each of the calendar years 2019, 2022, 2023 and 2024;
(d) the number of current or former student visa holders who have lodged an appeal to a refusal or cancellation for each month, for each of the calendar years 2019, 2022, 2023 and 2024;
(e) with respect to net overseas migration (NOM) as forecast in the 2024-25 Federal Budget, the sub-components which make up the NOM forecasts being overseas migrant arrivals by visa and citizenship group as well as the overseas migrant departures by visa and citizenship group; and
(f) within the ‘student—higher education’ category of the NOM forecasts as set out in the 2024-25 Federal Budget, the breakdown between the students attending public universities, private higher education providers and private VET providers.”
There may be some consternation in the sector about this data being tabled in a way that everyone can see (including competitors inside and outside Australia). Ultimately, however, it has allowed for the public exposure of flaws, anomalies, inaccuracies and consequences. The Koala is certain that the Senate Committee is not only reviewing the tabled documents but will also be reviewing the comprehensive analysis of the data by sector experts. This can only be a good thing.
