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Go8 Submission: Consultation on draft methodology for review of Skilled Migration Occupation Lists

The Group of Eight (Go8) welcomes the opportunity to provide comment on the methodology for reviewing the Medium and Long Term Strategic Skills List (MLTSSL) and the Short Term Skilled Occupation List (STSOL). Please note this submission represents the views of the Go8 network, and member universities may make their own, more detailed submissions.

The MLTSSL and STSOL are used to inform eligibility for the new category of Temporary Skill Shortage (TSS) visas, which will replace the existing Temporary Work (Skilled) visa (subclass 457) by March 2018. TSS visas will exist in two streams: a short term stream (up to two years), to be informed by the STSOL, and a medium term stream (up to four years), to be informed by the MLTSSL. Critically, only the medium term stream will provide a pathway to permanent residency.

As Australia’s leading research intensive universities, the Go8 are deeply engaged in a fierce competition for global talent. We are chasing the best researchers, the best teachers, the best thought leaders across all disciplines. Our business is hugely leveraged by global talent, which then has flow on effects to the Australian industry, economy and the wellbeing of all Australians.

For example, the Go8 currently has six of its members listed in the Top 100 institutions in the highly prestigious Academic Ranking of World Universities (ARWU). This places us third in the world, behind only the US (50 institutions), and UK (8 institutions). For a country with a population of only 24 million this is a truly outstanding achievement, that would not have been possible without a supply of global talent choosing to come to Australian shores.

While we recognise the reality that the government needs a mechanism for regulating the flow of people into Australia, it is critical that this mechanism recognises the fact that high performing universities such as the Go8 rely on being able to recruit the best and brightest researchers and academics, wherever they are in the world.

As the key tools informing the new TSS visa process, it is therefore critical that the methodology behind the MLTSSL and the STSOL are able to support our international education sector, recognised by Deloitte as one of Australia’s five ‘super-growth sectors’ underpinning our post-mining boom future. [1]

We therefore offer the following commentary:

  • Oversight of the MTLSSL and the STSOL

The Go8 noted with interest the announcement circulated by the Department of Education and Training on the 3 October 2017, that the responsibility for review of the MLTSSL will be moved from the Department of Education and Training to the Department of Employment.

This means that the Department of Employment will now hold responsibility for reviewing both the MLTSSL and the STSOL.

While the Go8 appreciates that this may offer certain administrative advantages, we are concerned that this change removes any higher education expertise from the review of the medium term list. It also represents a narrowing of the visa perspective from three departments (including the Department of Immigration and Border Protection) down to two.

Recommendation: The Go8 seeks clarification for the rationale behind this decision, and reassurance that sufficient consideration will still be given to the sector-specific higher education and research needs in the reviewing of these lists.

  • Six Monthly Review Schedule

The Go8 recognises that, in today’s fast changing world, a regular review cycle is necessary to ensure that Australia’s visa framework remains as current as possible with changing circumstances. However, based on our experience with the annual review cycle for the now outdated Skilled Occupation List (SOL), we contend that a review period of six months is likely to be too short. It takes time for the full impact of any changes to the skilled migration policy framework to filter through into the international community, and a six month review cycle could result in considerable confusion amongst high quality candidates for skilled migration, with resultant impact on Australia’s welcoming reputation and potential loss of talent to competitor nations.

It also encourages a very short term outlook when considering Australia’s workforce needs. While this may be appropriate for the STSOL, it does not represent the “medium and long term” perspective necessary for the MLTSSL.

Finally, it creates the potential for considerable burden on stakeholder organisations to provide evidence to this review process every six months.

Recommendation: that the Government restore the 12-month review framework for the MLTSSL.

  • Australia’s Scientific and Innovation Agenda

The Go8 welcomes the provision included in the consultation paper that “The ‘traffic light bulletin’ will also identify occupations… which have been identified as supporting Australia’s science and innovation agenda”. We are delighted that the importance of this government initiative has been recognised in the new framework.

However, it is not clear from the information provided in the consultation paper as to how this recognition mechanism will work in practice, or how the occupations will be identified.

We are also concerned that, although we agree with the need to support Australia’s Science, Technology, Engineering and Maths (STEM) expertise, this should not occur at the expense of our performance in the Humanities, Arts and Social Sciences (HASS) subjects.

The latest release of the Times Higher Education university rankings revealed that China’s Peking University now ranks higher in tertiary level arts and humanities than Australia’s highest ranked university, the Australian National University.[2] Without continued support for these key subject areas, we risk continuing to be left behind by our Asia Pacific rivals, which in turn undermines our overall reputation and our $28.6 billion international education industry. [3]

The Go8 seeks clarification as to:

  • How the occupations that support Australia’s science and innovation agenda will be identified;
  • How they will be flagged by the traffic light system; and
  • How the research and higher education sectors can have input into this process. 

In terms of the specific consultation questions:

  1. Is there any other advice or evidence that the Department should consider in its review of the methodology? We are particularly looking for research, surveys or modelling that is Australian based, recent and aligned to ANZSCO occupations.

The Go8 is concerned that a strong and robust system of review for the skilled occupation lists will need to take both an immediate and longer term perspective, beyond just the consideration of current local skills shortages for given existing job positions.

The speed with which technological developments are driving the creation of new products and new industries means that it is also increasingly necessary to predict where Australia may be in danger of falling behind – or even completely lacking – knowledge in new and emerging fields.

In these instances, academia will need to be enabled to import high quality international talent to shape and train a new generation of local born Australian expertise.

Similarly, it is important to recognise that vacancies will continue to arise in Australian universities as our own domestic talent seeks periods of employment overseas to build their expertise in the global marketplace. It is in our interests to allow this free flow of talent, as they can be expected in many cases to return home, better qualified and more experienced, in due course.

The Go8 is not aware of any current robust methodology designed to capture these areas of emerging and innovation-led industries. Instead, we propose to commission some new survey-based evidence, designed around issues such as:

  • The number of Go8 academics planning to seek career development outside Australia in the medium term (3-5 years);
  • On the number and level of academic vacancies requiring international experience or for which international experience is highly desirable;
  • On the experience brought to Australia by recent appointees from overseas which could not be gained in Australia.

The Go8 would be happy to share the evidence gained from this research with the Departments of Employment and Immigration and Border Protection, if it would be useful input into the MLTSSL. We look forward to receiving advice as to whether this would be the case.

Recommendation: that the Go8 help to inform the review of the MLTSSL with the results of a bespoke survey exploring areas of developing innovation or technology led expertise.

[1] http://www.afr.com/leadership/deloitte-names-the-five-supergrowth-sectors-set-to-add-250bn-to-australias-economy-20131007-jz1ud?logout=true

[2] http://www.theaustralian.com.au/higher-education/china-overtakes-australia-in-university-humanities-ranking/news-story/75fe35d4025e5073aa1ec93d24c3b9d6

[3] ABS statistics, 2016-2017.