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International Education Agents are often the first point of contact between prospective students and the Australian international education industry. Their activities and ethics are important to Australia’s reputation as a desirable destination for students. The University is therefore committed to ensuring its agents act ethically and appropriately when recruiting students to study Federation University courses/qualifications.
To this end, the University requires agents to have an appropriate knowledge and understanding of the Australian international education industry, Australian International Education and Training Agent Code of Ethics, and to act honestly and with integrity.
This procedure aims to ensure that the actions of appointed agents recruiting students for Federation University courses are ethical and comply with the University's obligations under the:
- Education Services for Overseas StudentsAct 2000 (ESOS Act);
- Education Services for Overseas Student (ESOS) Regulations 2019;
- National Code of Practice for Providers of Education and Training to Overseas Students (the National Code);
- Migration Act 1958; and
- Migration Regulations 1994.
This procedure applies to:
- Agents of the University; and
- Staff at Federation University; and
- Appointment, accreditation and monitoring of agents.
| Term | Definition |
| Agent | An accredited person or organisation with the authority to promote the University's courses/qualifications and services to students or intending students in nominated regions. |
| Agent Agreement | Agreement between the agent and the University or Partner Provider, including the schedules. |
| Agent Code of Ethics | Australian International Education and Training Agent Code of Ethics |
| Applicant | A person applying to the University and who intends to hold an Australian student visa and is an 'overseas student' as defined by the ESOS Act |
| Ascent One | Software used by the University for displaying agent details on the website. |
| Business Days | Monday to Friday excluding public holidays. |
| CoE | Confirmation of Enrolment - A document provided electronically which is issued by the University to intending international students and which must accompany their application for a student visa. It confirms the student's eligibility to enrol in the course/qualification of the University, at a specific teaching location. |
| Course | Course of education and training for HE. |
| CRICOS | Commonwealth Register of Institutions and Courses for Overseas Students |
| Deferrals | Deferred commencement of studies for students who have not commenced studies yet; or leave from studies for enrolled students. Referred to as deferral, deferring or deferred in the ESOS Act. |
| ESOS Act | Education Services for Overseas Students Act 2000 of the Commonwealth of Australia, as amended from time to time |
| Evidence Level | Outcomes of the University’s students visa applications that determine the evidence required by a student to be submitted with a student visa application as set by the Department of Home Affairs. |
| fdlGrades | Computer system which the University uses to monitor the progress of students through their courses/qualifications. May be abbreviated to FDL. |
| GSR | Genuine Student Requirement – Criteria set to determine that an applicant is a genuine student in accordance with the Department of Home Affair’s requirements. |
| HE | Higher Education. Students studying in a higher education course by coursework or research. |
| Incompletion |
Enrolments which are terminated due to the following and are considered "Incompletions" in PRISMS:
* Non-commencements, cessations, deferrals, or suspensions where a new enrolment is recorded in PRISMS for the same course/qualification, provider and agent within 1 day of the termination being reported will not be included in Incompletion statistics in PRISMS. |
| National Code 2018 | National Code of Practice for Registration Authorities and Providers of Education and Training to Overseas Students 2018, as amended from time to time. |
| PowerBI | Software which collates data from multiple sources to display it in ways that make trends easier to spot |
| PRISMS | Provider Registration and International Student Management System. |
| Prospective Student | A person who intends to become, or who has taken any steps towards becoming, an 'overseas student' or 'intending overseas student' as defined by the ESOS Act |
| Qualification | Qualification of education and training for VET. Defined as Course in the ESOS Act. |
| Student | A person who holds an Australian student visa and is an 'overseas student' as defined by the ESOS Act |
| StudyLink | The online application system currently used by the University |
| Teaching Location | Where Federation University courses/qualifications are delivered. May be a University campus or a Partner Provider location. |
| Teaching Period | A period of study within a course/qualification. May be a semester, trimester or term. |
| University | Federation University |
| Vendor Panel | University’s contract management database. |
| VET | Vocational Education and Training |
| Activity | Responsibility | Steps | |
| A | Sending Agent Application Form to prospective agent | Coordinator, International Education Agents; or Global staff. |
|
| B | Completing the Agent Application Form | Agent |
|
| C | Checking available information to determine whether the agent is suitable to appoint | Coordinator, International Education Agents |
|
| D | Contacting referees for completion of Agent Reference Check form | Coordinator, International Education Agents |
|
| E | Complete Agent Onboarding and Renewal Checklist and assess suitability to appoint, in light of all available information | Coordinator, International Education Agents |
|
| F | Prepare Agent Agreement | Coordinator, International Education Agents |
|
| G | Send Agent Agreement PDF to agent | Coordinator, International Education Agents |
|
| H | Sign and return the Agent Agreement | Agent |
|
| I | Countersign the Agent Agreement | Coordinator, International Education Agents; and Executive Director, Global. |
|
| J | Returning the countersigned Agent Agreement to the agent | Coordinator, International Education Agents |
|
| K | Update appropriate files and databases | Coordinator, International Education Agents |
|
| L | Inform agent of negative outcome of application | Coordinator, International Education Agents; or Global staff. |
|
| Activity | Responsibility | Steps | |
| A | Review agent performance | Coordinator, International Education Agents |
|
| B | Send Agent Audit form | Coordinator, International Education Agents |
|
| C | Complete and return Agent Audit form | Agent |
|
| D | Review Agent Audit form, supporting documents and other information | Coordinator, International Education Agents |
|
| E | Monitor semester’s agent data on an ongoing basis | Coordinator, International Education Agents |
|
| F | Provide ongoing feedback on agents | Global / Coordinator, International Education Agents |
|
| Activity | Responsibility | Steps | |
| A | Conduct an audit of the Agent | Coordinator, International Education Agents |
|
| B | Send the Renewal of Agent Agreement Form to the agent | Coordinator, International Education Agents |
|
| C | Complete the Agent Onboarding and Renewal Checklist | Agent |
|
| D | Review the Renewal of Agent Agreement Form, Agent Onboarding and Renewal Checklist and documents | Coordinator, International Education Agents |
|
| E | Prepare a new Agent Agreement | Coordinator, International Education Agents |
|
| F | Send Agent Agreement PDF to agent | Coordinator, International Education Agents |
|
| G | Sign and return the Agent Agreement | Agent |
|
| H | Countersign the Agent Agreement | Coordinator, International Education Agents; and Executive Director, Global. |
|
| I | Returning the countersigned Agent Agreement to the agent | Coordinator, International Education Agents |
|
| J | Update appropriate files and databases | Coordinator, International Education Agents |
|
| Activity | Responsibility | Steps | |
| A | Send Agent Warning Letter or Agent Corrective Action Letter to agent | Coordinator, International Education Agents |
|
| B | Respond to Agent Warning Letter or Agent Corrective Action Letter | Agent |
|
| C | Consider the agent’s performance |
Coordinator, International Education Agents; and Executive Director, Global. |
|
| D | Take the required action in light of the agent’s performance |
Coordinator, International Education Agents; and Executive Director, Global. |
|
| E | Disclosure of decision |
Coordinator, International Education Agents; and Executive Director, Global |
|
| F | Advise relevant parties of the decision to terminate the appointment |
Coordinator, International Education Agents; and Executive Director, Global |
|
The Agent Performance Measures below are best-practice guidelines for agents. Ultimate decisions on the quality of agent performance may also take into account local conditions in different countries, and/or other factors as determined by the Global team.
- Agents should maintain strong application-to-offer conversion rates of 40% or higher.
- Agents should maintain strong offer-to-CoE conversion rates of 30% or higher.
- Agents should maintain strong CoE-to-enrolment conversion rates of 80% or higher; subject to change dependant on visa refusal rate at the time.
- The Global team may choose to set specific targets for numbers of studentsenrolled by a particular agent, as discussed with the agent and as appropriate on a case-by-case basis.
- Where there are mitigating factors that advance the University’s strategic goals, such as building up a new market, building up a new course, or providing a diversity of nationalities, some discretion may be applied to the above targets.
All agents, of the University must meet the Agent Compliance Measures below. These override any performance measures listed in this document or elsewhere.
- Agents must maintain a visa refusal that is in line with the University’s strategic goals and that does not negatively impact the University’s ability to achieve or maintain the desired Evidence Level. The ideal visa refusal rate is below 10%, however discretion may be applied. Agents will receive a warning if it is observed that their refusal rate has risen above 5% and may be issued with corrective actions if the refusal rate persists at a rate that does not align with this Compliance Measure.
- Any visa refusal for reasons of fraud will be investigated thoroughly. If the University determines that the agent is encouraging, facilitating, or allowing their students to provide fraudulent documents to the University or to the Department of Home Affairs, the agent’s appointment will be terminated. This includes where an agent submits documentation to the Department of Home Affairs for a student’s visa application that is different to the document that was submitted for assessment against the University’s GSR criteria and approved by the University.
Where the different documentation submitted to the Department of Home Affairs only consists of an un-approved Statement of Purpose, at the discretion of the University, a request may be made for the agent to explain their actions.
- Agents must maintain an Incompletion rate below 20%. Agents will receive a warning if it is observed that their Incompletion rate has risen above 10%. Incompletion rates will be calculated from PRISMS data and/or internal Federation University systems such as academic progression data. The University will use discretion where Incompletion data is represented by factors outside of the control of the student or agent causing the student to defer their commencement to a future intake; eg. visa processing delays with the Department of Home Affairs.
- Agents must maintain a rate of below 10% of students whose CoE is cancelled for non-payment of fees. Agents will receive a warning if it is observed that the rate has risen above 5%.
- Agents must provide accurate and comprehensive information to prospective students.
- Agents must only recruit students in the territories approved in their Agent Agreement.
- Where an agent’s low overall student numbers mean that one-off incidents have an outsized impact in percentage terms, discretion may be applied.
- Where an agent has received multiple warnings or corrective actions for visa refusals, Incompletions, and/or non-payment of fees, but not reached the threshold for any of these metrics, these combined warnings may still be grounds for termination of the appointment.
- Where significant mitigating factors such as the COVID-19 pandemic have negatively impacted the students recruited by the agent, leading to a higher Incompletion rate and/or rate of students whose CoE has been cancelled due to non-payment of fees, discretion may be applied.
- The University retains the right to veto any agent activity that in the University’s opinion is not compliant with:
- The Agent Agreement; or
- Any relevant legislation or
- Any information provided to the Agent by the University.
- Global Partners and Community Engagement Policy
- Agent Agreement (only available from Quality and Accreditation)
- Student Post Arrival Appraisal of Agent (online survey)
- Agent Termination Letter
- Agent Warning Letter
- Agent Corrective Action Letter
Forms
- Agent Application Form (PDF 236.0kb)
- Agent Reference Check Form (PDF 250.1kb)
- Deputy Vice-Chancellor, Global, Engagement and Quality (as the Approval Authority) is responsible for monitoring the implementation, outcomes and scheduled review of this procedure.
- Dean, Quality and Accreditation (as the Document Owner) is responsible for maintaining the content of this procedure as delegated by the Deputy Vice-Chancellor, Global, Engagement and Quality.
- Policy Editor: Coordinator, International Education Agents
This procedure will be communicated throughout the University community via:
- A FedNews announcement and on the ‘Recently Approved Documents’ page on the University’s Policy Central website.
- Distribution of e-mails to all current agents of the University.
- Notification to University staff in the Quality and Accreditation, Global and Admissions and Scholarships.
This procedure will be implemented throughout the University via:
- A FedNews announcement and on the ‘Recently Approved Documents’ page on the University’s Policy Central website.
- Staffinduction sessions.
- Training sessions.
| Document title | Location | Responsible Officer | Minimum retention period |
| Agent Application Form | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Agent Reference Check Form | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Agent Agreement | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Agent Audit Form | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Agent Warning Letter | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Agent Termination Letter | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
| Investigation communications to and from agents addressing compliance concerns | Agent file on SharePoint | Coordinator, International Education Agents | Seven years after contract has expired or been terminated |
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