A cap-and-trade system for international student places

In an earlier post I argued that the government’s plans to cap international student numbers, including by education provider and course, would cause actual enrolments to fall well below the official maximum number.

This is due to the inherent weaknesses of bureaucratic systems of student place allocation. Even when meeting demand is a goal the limited information held by central planners, and the long time lags between allocations and enrolments, will cause student places to remain unused.

This post proposes a partial remedy to this problem, a cap-and-trade system for international student places.

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The legal detail of the government’s plans to cap international student numbers

In an earlier post I criticised the government’s plans to cap international students by education provider and course.

This post goes through the capping legal detail of the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024, which if passed would amend the Education Services for Overseas Students Act 2000.

The amending bill contains other provisions on education agents and education providers designed to limit misconduct in the international student market. This post does not cover these provisions, but Tracy Harris discusses them here.

In this summary, unless specified otherwise, the sections mentioned refer to the amending bill but use the section number as it would appear, if passed, in a revised compilation of the ESOS Act 2000. I also refer to the bill’s explanatory memorandum, which explains the intent behind some provisions. It can be downloaded from the bill’s webpage. The Parliamentary Library’s bills digest is also helpful.

Italicised phrases other than section headings highlight powers that give the minister wide discretion. I see this as a significant problem over-and-above the direct consequences of capping.

On what can international student enrolment limits be imposed?

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2024 funding by university for Commonwealth supported places

The Universities Accord final report noted the problem of ‘no consolidated source of government expenditure by higher education provider and program (such as the Commonwealth Grant Scheme)’. It is one of the many reporting and data availability issues that make understanding Australia’s higher education system unnecessarily difficult.

CGS revenue by higher education provider

In January, after a laborious process of transcribing information from funding agreements, I published the ‘higher education courses’ and ‘designated courses’ funding allocations. To this I have now added funding determinations information on demand driven Indigenous funding, the medical student loading, estimated HECS-HELP lending as of May 2024 and estimated upfront student contributions, also of May 2024. You can download the spreadsheet here. [Update 17/06/24: with revised funding agreements, 15 universities have increased higher education courses funding. The updated spreadsheet can be downloaded here.]

The chart below aggregates the programs into their two main categories, the CGS and student contributions, and ranks them from the largest recipient of funds, Monash University at $722.4 million, to the smallest, Charles Darwin University at $157.8 million.

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Limits on international student numbers could reduce enrolments to well below the official cap

I am not opposed to changing international student migration rules and education provider requirements to moderate problems long associated with international education, including “dodgy” colleges, inadequate student preparation, student poverty, student exploitation and “permanently temporary” migration.

Multiple steps towards minimising these problems have already been announced or taken, with increased financial requirements for a student visa added last week. Most changes announced before last Saturday are justifiable.

But capping international student numbers including down to a course level, as announced over the weekend, is a bad move.

The caps will face all the problems I have identified with bureaucratic allocation of domestic student funding. Because numbers will be allocated between universities and courses according to a politician or bureaucrat’s view of where students should enrol, rather than where students want to enrol, actual enrolments are likely to be well below the capped level.

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