Accord implementation proposals, part #2: The distribution of student places to universities and the folly of hard caps

An earlier post looked at the government’s plans for the Australian Tertiary Education Commission. This post examines the government’s proposals for setting the number of student places and distributing them between universities. This includes a hard institution-level cap on student places, so that universities would get zero funding for enrolments above their allocated level. This post explains why a hard cap is unnecessary and counter-productive.

Overall number of CSPs

The government will determine the total number of CSPs. For ‘fully funded’ places – places for which universities are paid both a Commonwealth and student contribution – this is similar to the current system of the government deciding on total CGS funding, other than the small demand driven system for Indigenous bachelor-degree students (which will be retained). However,

  • because universities will have flexibility in moving EFTSL between disciplines (discussed in a later post) the maximum dollar amount the government pays will be less predictable than now.
  • because of the first point and hard caps on student places at each university (discussed below) the maximum number of CSPs the system provides will be more predictable than now.

It is not clear whether ATEC will advise the government on the number of CSPs, as opposed to contextual factors such as demographics, demand, and skills needs.

And if ATEC does provide advice on system-level numbers, it is not clear whether this will be published or not. The consultation paper mentions the state of the sector report recommended by the Universities Accord final report, but this is framed as a ‘report on higher education outcomes’, not future higher education needs.

Former higher education commissions provided detailed public advice on likely student demand and the sector’s capacity to meet it. For an education minister there is a trade-off. Public and quality advice gives leverage in Cabinet when arguing for money and a semi-independent justification for the government’s overall policy direction. But if the minister does not get the money the sector, and opposition MPs, will use ATEC reports against the government.

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Did bachelor degree enrolments decline significantly between 2016 and 2022?

This is a post I started writing several months ago, before the Accord final report and other major higher education policy announcements pushed it aside. I have completed it as a companion to my census attainment post on data issues in higher education.

Late last year several media outlets, using data from the ABS Education and Work survey, reported declining bachelor degree enrolments. In November 2023, bachelor degree enrolments were said to be down 12 per cent between 2016 and 2022. Another newspaper rounded the drop to 13 per cent. In December 2023 bachelor degree enrolments were said to be at their lowest level since 2011.

This post explains why these media stories exaggerate enrolment decline. The most important reason is that Education and Work does not count offshore international students. But comparing Education and Work results with enrolment data shows that it typically undercounts onshore international students and overcounts domestic students, particularly those in bachelor degrees. It also has occasional rogue surveys that produce misleading comparison years.

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How much difference will stopping student visa applications from people on visitor visas make?

The bad news for international education keeps coming. On Wednesday the government announced that onshore visitor visa holders would no longer be able to apply for a student visa. It also announced a 1 July 2024 implementation date for the ban on temporary graduate visa holders applying for a student visa. The temporary graduate visa policy was announced last December.

How big is the visitor visa change?

The government’s media release says that 36,000 onshore visitor visa holders applied for a student visa in the financial year to May 2024. However the number of visas granted will be much lower than that. As of the end of April 2024 13,733 primary applicant student visas had been granted to onshore visitor visa holders in 2023-24. Secondary visa holders – partners and children – take the number to 17,729.

These numbers are for all levels of education. Higher education primary applicants are about a quarter of the total for this time period. In 2023-24 up to April 3,332 higher student visas grants were made for primary applicants, with secondary applicants taking the total to 4,742.

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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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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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Reducing the number of ‘permanently temporary’ former international students

While I agree with the goals of today’s big migration policy changes, they will make life more difficult for universities relying on migration-motivated international students. In most cases, former international students will be able to stay in Australia on temporary graduate visas for less time than now. Other options for remaining in Australia, such as returning to a student visa, will become more difficult.

These policy changes aim to reduce temporary migrant numbers. The pressure temporary migrants place on accommodation and other services made this an urgent policy and political issue. But prior to this there were also significant concerns about temporary migrants themselves, in their vulnerability to labour market exploitation and prolonging their time in Australia in the often false hope of eventual permanent residence, as ‘permanently temporary’ migrants. The Parkinson migration review, released in March this year, set out an agenda for change.

Future policy on permanent residence is still under development, with some signals discussed below. Whether the number of former international students getting PR will go down remains to be seen. But clearer rules will mean PR aspirants can cut their losses at an earlier point. Fewer will delay important career and family events and decisions due to uncertainty about their long-term country of residence.

Shorter-stay temporary graduate visas

In September 2022 the government announced its decision to add two years to the sub-class 485 temporary graduate visa for graduates with degrees in areas of ‘verified skill shortages’. In the critique I wrote at the time I was ‘far from convinced that a 485 time extension is a good or ethical policy’, and so I am glad that this policy will be abolished.

As the chart below from the migration plan shows, they will also cut the base time period for a masters by coursework from three years to two years, and for a PhD from four years to three years. The regional extension, however, will remain.

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Mapping Australian higher education 2023 – official release

Update 20/12/2025: More recent data here.

Mapping Australian higher education 2023 is now available from the ANU Centre for Social Research and Methods website.

Update 30/10/2024: There is a later version of Mapping 2023’s data here.

Update 26/10/23: A reader has pointed out that list of FEE-HELP NUHEPs is incomplete. A column of names from the original Excel file was omitted during production. The full list is available here. This list also includes three non-FEE-HELP providers registered by TEQSA since the pdf version was finalised. A corrected version of Mapping with the full list of NUHEPs, as of mid-2023, is here.

If anyone has noticed other errors please let me know.

For universities the Accord interim report proposes a more extreme version of Job-Ready Graduates

The Australian Universities Accord interim report recommends overturning the most controversial Job-ready Graduates policy, using student contribution price signals to guide student course choices.

But overall the Accord interim report and Job-ready Graduates have strong parallels. They both take a utilitarian view of higher education, that its purpose is to provide benefits to others rather than being of any intrinsic value. Universities exist to meet skills needs, find practical uses for research, contribute to their local communities, and promote equity. The main difference is the interim report proposals are, with student contributions the main exception, more extreme and interventionist than Job-ready Graduates.

Substantially reduced university autonomy

Historically universities in Australia and other western countries have operated with a significant degree of autonomy from government. But despite using the word ‘autonomy’ a few times the Accord interim report shows little interest in this idea.

On my count at least 25 interim report proposals would reduce the scope of university-level decision making or are new reporting requirements that set universities up for future regulation. In my list these cover general mission direction, student admissions, the mix of disciplines and courses, curriculum and teaching, use of funds, and accountability.

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Conflicting visions of higher education’s purposes

I blurbed Mind of the Nation, Michael Wesley’s new book on universities in Australian life, with the statement that it ‘shows how rising and conflicting expectations of universities create controversies that will not go away’. His book is about the cultural and political position of universities rather than higher education policy as such, although policy provides evidence of how politicians and voters see universities.

University administrators – Wesley is a deputy vice-chancellor – are at the centre of these controversies, blamed by all sides for whatever is wrong with universities. Mind of the Nation explores why universities receive so much critique and so little love or (from a university perspective) public funding, despite many successes and contributions: life-changing experiences for students, moving from an elite to a mass higher education system, creating a new export industry, large increases in research aimed at solving practical problems, and engagement with local communities.

Wesley asks why Australians admire the successes of their sporting teams, musicians and actors but not universities.

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