Managing Your CRICOS Assessment Level and Impact on your Business.
About the Author: Lazar Petkantchin is an Australian Registered Migration Agent (1688444). Lazar has served, amongst other things, as a Senior Student Visa Case Officer at the Department of Immigration and Border Protection (DIBP). He also served as an Advisor on the design, testing, and implementation of DIBP's automated Risk Assessment Systems and Assessment Level designation for countries and CRICOS providers.
Managing Your CRICOS Assessment Level and Impact on your Business. As experts in the international education sector, you undoubtedly know that your institution's CRICOS Assessment Level (AL) is pivotal. It directly impacts:
Visa Grant Rates: Your institution's refusal-to-grant ratio.
Profitability.
Operational Efficiency: The better your AL is, the more you will be able to reduce manual vetting hours. And conversely, the higher your AL is, the more vetting hours will be spent on each applicant as both scrutiny and requirements are stricter for your students' visa applications.
Processing Times: A lower AL will result in faster application processing from submission to decision (all else remaining equal). Conversely, higher AL will result in longer processing times as scrutiny increases.
Administrative Burden: A lower AL will minimise time and resources spent refunding failed visa applications.
Understanding Assessment Levels and the Department's automated risk systems is complex. However, drawing on my experience as a former Senior Student Visa Case Officer, Information Officer, and a consultant (as part of the Digital Transformation Taskforce within the Department of Immigration, I was involved in the Design, Testing, and Implementation of these very Risk and Assessment Level systems), I offer insights that can be invaluable, if applied to real-life situations. In this article, I'll share actionable strategies to address your AL challenges.
What Determines Your CRICOS Assessment Level? Your CRICOS Assessment Level is calculated by weighting various factors. Some of the main contributors include:
Rate of Refusals (excluding fraud): This is a primary focus, driven by numerous factors within visa applications themselves. We will cover
Rate of Visa Cancellations: Students having their visas cancelled after arrival.
Rate of Refusals Due to Fraud: Applications identified as fraudulent.
Rate of Student Visa Holders Becoming Unlawful Non-Citizens: Students overstaying or breaching visa conditions.
Rate of Subsequent Protection Visa Applications: Students switching to protection visas after commencing study.
It's crucial to understand that these factors are often interrelated, and a country's Assessment Level also plays a significant role. Higher country ALs often correlate with increased non-compliance instances, higher levels of protection applications and higher rates of fraud. Understanding country ALs is a complex topic in itself, but itโs critical for risk management โ a topic we can delve into in a future article.
Strategies to Manage CRICOS Assessment Level Risks: The following information offers a high-level overview of key strategies. The intricacies of the system mean detailed guidance extends beyond this article's scope, but I will explore these topics further in future posts.
1. Target and Develop Low-Risk Markets: While some low-risk markets are well-known, advanced statistical analysis can reveal other untapped low-risk markets, potentially with less competition. We use analytical tools to determine low-risk markets.
2. Navigating Ministerial Direction 111 & Prioritisation: The recent Ministerial Direction 111 aims to ensure "fairer access" to offshore student visa processing through a new prioritisation approach. However, if your institution has a low allocation of levels, this can feel far from fair, especially for small and medium-sized providers.
There are, however, effective strategies and workarounds being employed by some providers, particularly in the Aged Care education sector. Just one obvious example, some providers target offshore students who initially come on a Working Holiday (WH) visa to study shorter courses like Certificate III in Individual Support. While this can be effective, it also presents considerations regarding:
Optimal Enrollment: Usually, WHV eligible passports are lower risk. Lower-risk WHV countries are generally better enrolled within your designated 80% of the New Overseas Student Commencements (NOSCs) for the year to maintain or even improve your AL. The reasoning behind this approach is that if a passport holder is a low AL, their chances of visa grants are higher. The more visa grants a CRICOS provider obtains, in relation to visa refusals, the better their AL will generally become, providing all else remains static.
Visa Conditions: Some providers refuse to enroll students for certificate 4 and Diploma studies because of fears that the 80 percent threshold will be passed. However, provided that the student does not study in breach of their WH visa conditions and subsequent BVA conditions, it should not make a difference if the same student is studying on a BVA. There is interesting interplay in policy regarding this approach but this is outside the scope of this article. โ PLEASE NOTE THAT THIS IS NOT IMMIGRATION ADVICE โ each school and each applicant have unique circumstances that need to be taken into consideration, before the above-mentioned approach is utilised**.** For higher-risk applicants, applying from Australia (where possible) is often advised. Applications and Genuine Student (GS) Statements should be thoroughly reviewed by professionals, with supporting documents exceeding basic Department requirements. Any refusals should also be appealed to rectify potential negative impacts on your CRICOS provider's AL as per the "Methodology for calculating evidence levels."
3. Optimize Vetting and Genuine Student Statements: While Education and Migration Agents are not permitted to write Genuine Student Statements on behalf of students, it is best practice for experienced agents to guide potential students. The basic information available on the Department's website does NOT cover all considerations assessed by Student Visa Case Officers. For CRICOS providers serious about maximizing their Assessment Level and Grant Rates, partnering with Migration Agents highly familiar with the student visa migration regulations, Policy, Ministerial Directions, and the basic risk levels is essential.
4. Utilise the Appeal Process to Reverse Refusals: Appealing refusals can rectify potential negative impacts on your Assessment Level, as per the "Methodology for calculating evidence levels." There's a crucial "feedback loop" at play:
Positive Feedback Loop: Strong GS Statements and a robust application process lead to grants, improving your AL.
Negative Feedback Loop: Weak applications lead to refusals, negatively impacting your AL. While appeals can interrupt a negative feedback loop, it's always better to address issues proactively at the GS Statement and visa application stages. The next best approach is to interrupt the negative feedback loops at both the GS Statement and Appeal stages.
Why this matters for YOUR CRICOS College: Optimising your CRICOS Assessment Level isn't just about compliance; it's about safeguarding your institution's future, attracting genuine students, and enhancing profitability. With constantly evolving policies and automated risk systems at play, having an insider's understanding is more critical than ever.