Catching the sector by surprise on Saturday, the government released a draft International Education and Skills Strategic Framework setting out a future direction for Australia’s international education and training sector. The draft Framework was included in a joint media release, Next steps in ensuring the integrity and sustainability of the international sector, from the Minister for Education, The Hon Jason Clare MP, the Minister for Skills and Training, The Hon Brendan O’Connor MP, and the Minister for Home Affairs, The Hon Clare O’Neil MP (for more information about what was included in the rest of the release, check out the TKN piece here).
In the analysis below, I cover what the government has said about the Framework, the initial responses from the sector, the mixed messaging about consultation, and then I unpack the Framework.
WHAT THE GOVERNMENT SAYS ABOUT THE FRAMEWORK
The rationale given by the government for the Framework is the need for sustainability, quality and integrity of the international education sector in Australia, with the government taking an active role to achieve this. The joint media release states that “Through the new Framework, the Albanese Government is taking an active role in supporting:
- a sector built on quality and integrity
- a managed system to deliver sustainable growth over time, and
- Australian providers to take our high-quality education and training to the world.”
WHAT THE SECTOR SAID
The International Education Association of Australia Member Alert from CEO, Phil Honeywood, is critical of the range of measures announced by the government, arguing that there is a “real danger of Government overreach in this new policy approach”. He will be meeting with four Federal Ministers today to “clarify and flesh out more details of what they have planned”.
English Australia expressed “significant concerns that the approach of the current government is causing lasting damage to the sector and the reputation of Australia as a destination for international students”. In an email to members, CEO Ian Aird, also criticised major policy and legislative changes being announced on a Saturday and with no prior notice. English Australia will be reviewing the Framework in the coming days.
Universities Australia’s statement took a more politically-sensitive approach, initially focussing on the success of Australia’s international education sector, its contribution to the economy, foreign policy objectives and fostering greater international collaboration. CEO Luke Sheehy also states that “We will be working closely with the Government to co-design the policy settings needed to give the international education sector a strong and sustainable footing from which to grow into the future.”
The Group of Eight CEO, Vicki Thomson, supports an education sector underpinned by quality and integrity, and notes the release of the Framework and the planned consultation process. She also says that the “Framework consultation process will be extremely important as we seek to get the right balance of outcomes for the nation and our international students”.
CONSULTATION
This leads us to consultation, or lack thereof. The lack of consultation in the initial drafting of the Framework will only fuel what is becoming a cacophony from the sector about the need for the government to be more transparent and consultative. Speaking about the sector, without prior consultation is also hard to swallow: “This Strategic Framework reflects the shared commitment of the sector and Government to embracing these opportunities…”.
The sector is also unlikely to be satisfied by the mixed messaging about what consultation can be expected.
The Ministers’ joint media statement gives the impression that wide consultation will take place, stating:
- The draft Framework will support consultation with the sector on how to implement a system of sustainable, managed growth in international student enrolments.
- The Government will consult with the sector on all aspects of the Framework over the coming months and release the final Framework later this year.
The Department of Education appears to be managing expectations, however, with its website indicating that consultation will be limited to “targeted consultation with key international education stakeholders, including the Council for International Education”.
One reason may be that the final Framework is expected to be released later this year, which is a very tight timeframe for anyone familiar with government processes.
UNPACKING THE FRAMEWORK
The introduction to the document covers the negative issues that have impacted the sector in recent times, laying on thick its justification for a new Framework. Words such as ‘unscrupulous’, ‘exploitative’, ‘poor practices’, ‘subverted’ are used on repeat, leaving you in no doubt of the government’s intent.
This Strategic Framework sets a new direction—for a sustainable, high-quality, and diverse international education and training sector, founded on integrity.
There are three objectives covered in the Framework, including proposed actions or actions that have already been taken. A range of questions is posed at the end of each objective for sector consultation. The three objectives are:
- A sector built on quality and integrity
- A managed system to deliver sustainable growth over time
- Taking Australian education and training to the world
Objective 1: A sector built on quality and integrity
This objective is central to the entire Framework. The narrative to this point makes it clear that strengthening the quality and integrity of the sector is its most important objective, given its impact on student experience, Australia’s reputation and delivering graduates to meet Australia’s skills needs. The government has already undertaken a range of measures, which are repeated in the Framework, including changes to working hours caps, banning commissions for onshore switching, and the increase in the savings requirements.
The action that is likely to be one of the most complex for the government to tackle with the sector is this one, and it is almost inevitable that it will leave parts of the sector very unhappy:
…the Government will work with the sector to consider the optimal make-up of the onshore international education sector. This will take into account integrity and quality issues at a provider, location and course enrolment level and determine whether the composition of the sector is optimised to deliver the skills Australia needs.
Other actions that are proposed under this objective include:
- Providers seeking to enter the international education market will be required to have delivered courses to domestic students for 24 months in most circumstances.
- Where a provider has not delivered a course to international students for a period for 12 months, their registration will be cancelled.
- The Government will enact a stronger fit and proper provider test, to prevent collusion between education agents and providers.
- Legislative changes to provide government with the power to prevent providers from delivering courses which have significant quality and integrity issues, or which have limited value to Australia’s skills needs.
- Introduce the ability for the Minister for Education to stop accepting or processing applications for registration of new providers and new courses.
- Prospective providers will need to demonstrate to a higher level that they are ready to deliver courses to overseas students.
- Provider relationships with agents will be scrutinised.
- Increasing transparency of agent commissions and performance data.
- Development of evidence-based risk indicators.
Questions for sector consultation
- Are there further reforms governments should consider that will improve the quality and integrity of the sector?
- What more can providers do to improve the integrity of the international education sector?
Objective 2: A Managed System to Deliver Sustainable Growth Over Time
‘Managed’ is the key word in this objective, with the government’s desire to actively manage the growth of the sector. Protecting Australia’s reputation and maintaining its social licence are at the heart of this objective.
The government is proposing to amend the Education Services for Overseas Students (ESOS) Act that will impose a cap on the number of international students a provider can enrol and manage the courses that providers deliver. This approach will be limited to higher education and VET:
- Allow Government to set limits on enrolments at a provider level, including over a set time period, within specific courses or locations. With the Minister for Education determining levels for both public and private higher education providers and the Minister for Skills and Training for VET providers.
- Limit or cease the ability of providers to deliver courses which have persistent quality and integrity issues, or those in areas which the Government determines have limited value to Australia’s critical skills needs.
In what will be one of the most contested points in the Framework is the suggestion that enrolment limits will be influenced by a university’s supply of purpose-built student accommodation (PBSA), including an increase in quota where a university establishes additional, newly built PBSA. To quote Phil Honeywood in the IEAA Member Alert: “reliance on universities providing more PBSA student accommodation would take years to put into place. Housing is a state and local government policy with little scope for Federal Government effective intervention unless it’s entirely on campus.”
Expect to hear more from Vice-Chancellors about this issue!
Other action items include:
- Consulting with the VET sector on a mechanism to distribute VET international student enrolments in accordance with the Government’s objectives for managing the system.
- Consideration of settings for postgraduate research enrolments, schools, short courses, non-packaged short English courses, and non-award courses, and the appropriateness of excluding these from new settings to manage growth.
This section also discusses a range of other issues but is light on providing any specific action items, with ‘could’, ‘should’, ‘need’, ‘more can be done’ used liberally. The issues include: stewardship of the sector; diversification; student experience; good employment outcomes; promoting regional Australia; and working with our region. Meeting Australia’s skills needs is also covered and is tied back to a managed approach to student growth.
The importance of alumni engagement and researcher networks is covered in a similar vein to above, although one sentence does appear to flag some changes to how students who are on an Australian government scholarship will be managed: We will continue to build on and refocus existing programs to bolster on-award engagement with students and alumni engagement by posts.
Questions for sector consultation
- What factors should inform government’s approach to allocating international student enrolments across sectors, providers, and locations in Australia?
- What considerations for government should inform the overall level of international students in Australia?
- How will this approach to managing the system affect individual providers?
- Should sectors other than higher education and vocational education and training, such as schools, ELICOS and non-award be included in approaches to manage the system for sustainable growth?
- How should government determine which courses are best aligned to Australia’s skills needs?
- How should government implement a link between the number of international students and an increased supply of student housing?
- What transition arrangements would support the implementation of a new approach?
Objective 3: Taking Australian Education and Training to the World
Transnational education (TNE) and the opportunities that it provides for managing future growth is the focus of this objective. This section highlights why TNE in all its forms is desirable, as well as how the government’s offshore networks support this area. There is also a discussion of what the government does to expand the recognition of Australian qualifications internationally.
However, no concrete actions are provided in the Framework, other than what the government is already doing, to assist the sector in taking advantage of the so-called (I am a sceptic) plethora of opportunities that exist.
Questions for sector consultation
- What are the barriers to growth in offshore and transnational delivery of Australian education and training?
- Where can government direct effort to support transnational education?
Next Steps
This section is largely a repeat of the broad statements that have been made throughout the document, about government’s commitment to managing the sector, and the need for quality, integrity and sustainability. Although it does invite views “from the sector and interested parties”, see above re consultation.
Appendix
The four-page Appendix at the end of the document covers twelve different reviews and reforms with strategic implications for the international education and training sector!
WHAT DOES IT ALL MEAN?
The actions that the government is proposing to make as part of the Framework are largely about compliance, punitive measures and restricting access. This is probably unsurprising for most, given the recent actions of the government and its focus on quality, integrity, sustainability in the Framework.
The disappointment, though, is that opportunities are discussed throughout the Framework but very few of the action items have been designed to address the opportunities. There is no discussion of government investment to support the sector in a positive way, by creating an environment to take advantage of these opportunities.
I look forward to being able to contribute some of my ideas during the consultation process…
The Ministers joint media release is available here.
The Draft International Education and Skills Strategic Framework can be found here.
Tracy Harris is a former employee of the Department of Education, Employment and Workplace Relations and the Australian Trade and Investment Commission.
