The COVID-19 pandemic has had major impacts across every aspect of our professional and personal lives. Because of this, we have rapidly learned to quickly adapt and adjust; respond to events and situations in new ways; and find solutions for issues we have never had to consider. The word ‘pivot’ has been widely adopted in our daily vernacular as we continue to navigate the ongoing impacts of COVID-19 and the ‘new normal’.
The interpretation and application of ESOS legislation in its current state and the use of PRISMS is an area worthy of further discussion.
This disruption has provided challenges to IEAA Members who work in admissions and compliance, and has fundamentally changed the study patterns of onshore international students. The interpretation and application of ESOS legislation in its current state and the use of PRISMS is an area worthy of further discussion.
At the virtual AIEC held last October 2021, presentations by the Department of Education, Skills and Employment (DESE)’s Director of ESOS Policy and Legislation and the Director of PRISMS, ESOS Systems and Support focused on this discussion point. They acknowledged the challenges faced by providers in interpreting and applying ESOS, as well as the current functionality and limitations of PRISMS.
In summary, the PRISMS presentation focused on:
- Quick facts on PRISMS users and providers, volume of COEs created and updated and visa grant messages
- An explanation of regularity of exchange of data between DESE and Department of Home Affairs (DoHA) regarding visa status
- A discussion around agent functionality in PRISMS including screen shots about data visualisation and guidance, as well as examples of best practice
- That PRISMS is a 20 year old system, where incremental improvements have been introduced largely followed legislative changes
- That there is an opportunity to open a discussion about ‘what's next’ for the future including:
- Links with other agencies including DoHA;
- Development of online server to server links (such as APIs) to other agencies including the regulators; and
- Development of such direct links and APIs to education providers’ systems such as student management and admissions systems.
Recommended amongst these will be a requirement that providers achieve an optimal mix of international and domestic students at both course and provider level.
The recent release of Australia’s new National Strategy for International Education 2021–2030, flagged significant possible changes to the ESOS Act. Recommended amongst these will be a requirement that providers achieve an optimal mix of international and domestic students at both course and provider level. It should also be noted that it is becoming evident that there is a shift from consultation to action regarding potential changes to the PRISMS systems. The sector has been advised by DESE that meaningful consultation will commence in early 2022.
It should be noted that an announcement has also been made via PRISMS News that changes will be made to the PRISMS system with consultation starting early in 2022. The ESOS presentation at AIEC began with some questions and followed with some thought provoking considerations for the future, such as:
- How can online delivery be accommodated by ESOS?
- Should full online delivery be available to students onshore?
- Does ‘quality’ mean the same thing in every market and to every student?
The ESOS presentation also highlighted that the current ESOS framework is built for onshore international students studying in face-to-face learning contexts. The notion of an onshore ESOS for Australian enrolments and an online ESOS to cover distance enrolments was raised.
- Could this differentiation work? With this separation ensure that the sector was supporting quality online offerings to students, whilst also making sure that ESOS continues to support all international students enrolled with Australian providers both onshore and offshore?
Key features of the current model include how it can take into account aspects of digital delivery, such as entry points, product offerings and participation. The current regulations ensure lots of checks and balances such as CRICOS and ESOS as well as GTE for visas, and the AQF, ELICOS and FS standards and frameworks provide protection and quality.
Can Australia create a process that supports the expansion of online delivery whilst also continuing to focus on quality?
With tuition protection, we must ensure that student payments are protected in a similar way to the Tuition Protection Scheme (TPS). There are different risks for online delivery, but these can be included for consideration and review. As well, there should be consideration of the regulated relationships with students and the regulated support for students. For onshore students, current written agreements provide clarity for mandated practices and complement the overall quality of offer with clear guidelines.
- Can Australia create a process that supports the expansion of online delivery whilst also continuing to focus on quality?
- With provider registration, who is delivering what and what are their quality claims?
- With data and reporting, what should be collected and when? What is the value of these collection points? (Note, this point is closely linked to the discussion regarding PRISMS reporting and data collection)
- With oversight and regulation, what are appropriate boundaries for online delivery and the roles of ASQA and TEQSA?
How to contribute
These AIEC sessions provided us with a fantastic opportunity to engage in meaningful and useful discussions with our regulatory agencies and an opportunity to positively contribute towards shaping changes that will have an impact on Australian international education, our students and our day-to-day work.
Now, IEAA’s Admissions and Compliance Network leaders want to embrace the opportunity and the invitation to engage in a meaningful discussion with DESE. To do this, we want to know more about your opinions, ideas and thoughtful considerations. Our network has members from all sectors and a diverse range of roles, and we want to be able to capture feedback at all levels to know how these matters impact you.
We have designed an anonymous survey to collect your responses and we hope you can answer honestly and openly about the changes you would like to see and the challenges you face. Once collected and summarised, we will seek ways to present this feedback to DESE.
This survey can be completed by anyone in your team that uses PRISMS and/or works with ESOS. A respondent can only fill out the survey once but it can be completed by multiple respondents from the same provider.
The survey should take around 10 minutes to complete and will close on Friday 11 February 2022.
Begin Survey
The opinions expressed above are those of the author and do not necessarily reflect the views of the International Education Association of Australia (IEAA).