REVIEW OF THE GENERAL SKILLED MIGRATION POINTS TEST

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1 REVIEW OF THE GENERAL SKILLED MIGRATION POINTS TEST Discussion Paper, February March 2010 Contact: Andre Kaspura Policy Analyst, International & National Policy, Engineers Australia 11 National Circuit Barton ACT 2600 Tel: Fax:

2 1. Introduction Engineers Australia is the peak body for engineering practitioners in Australia, representing all disciplines and branches of engineering. Membership is now approximately 86,000 Australia wide and Engineers Australia is the largest and most diverse professional engineering association in Australia. All Engineers Australia members are bound by a common commitment to promote engineering and to facilitate its practice for the common good. Engineers have a vital role in all manner of projects that are critical to Australia s future. This includes building and construction of economic infrastructure, manufacturing and industrial development and the large scale minerals developments that have been a key driver of economic growth. In the 6 years prior to the global financial crisis, skilled engineers were in short supply in many industries and in over half of new engineers joining the Australian workforce were migrants. Engineers Australia believes that over the coming year shortages of skilled engineers will increase. Engineers Australia believes that all prospective visa applicants for occupations on the SOL should first and foremost meet minimum criteria relating to the competences relevant to the SOL occupation, english language proficiency and the overall age limit. Applicants who satisfy these criteria could be awarded points in a points test for english language capability above the minimum required, for younger age groups, work experience and for the completion of a formal Professional Year. Family sponsorship and sponsorship by State and Territory Governments should not attract points but should be dealt with through the streamed management of demand in visa classes established for these purposes. Base level competencies should be closely related to the occupation on the SOL and no additional points are warranted for higher and/or additional qualifications. Confusing occupational competencies and degrees from top world universities should be avoided and no additional points should be allocated. Engineers Australia believes that the points test should be used to rank prospective visa applicants. Unless applicants meet minimum criteria for skilled migration, no points test can overcome obvious deficiencies. 2. Points for Occupation From April a new Skilled Occupations List (SOL) will become the basis for Australia s skilled migration programs. Skills Australia has not yet released the SOL but has indicated that it will be based on the concept of specialised occupation discussed in its recent Report 1. A specialised occupation is defined as one where specialised skills, learned in formal education and training, are needed at entry level and the impact of market failure is potentially significant. Providing the criteria identified by Skills Australia are applied to occupations on the SOL, Engineers Australia sees no reason why points should be allocated to occupations. This view assumes that the qualifications claimed by all permanent visa applicants for occupations in the SOL have those qualifications assessed by an appropriate assessment authority. Engineers Australia believes that the integrity of skilled migration programs depends on this arrangement. 1 Skills Australia, Australian Workforce Futures; A National Workforce Development Strategy, March 2010, pp20-21, ENGINEERS AUSTRALIA 12 March 2010 Page 1

3 Engineers Australia notes that applicants for temporary 457 visas do not have their qualifications assessed. In , there were 8,992 migrant engineers, of whom 4,580 entered Australia under 457 temporary visas. This compares to 8,924 new engineering graduates from Australian universities and TAFE colleges. It is a matter of some concern to Engineers Australia that about one quarter of new engineers are able to join the engineering profession without their base level competencies being assessed. Engineers Australia believes that it is vital that holders of 457 temporary visa who apply for a permanent visa undergo skills assessment as is presently the case. 3. Points for Overseas Qualifications The issues raised in this Section of the discussion paper confuse several important issues. First, there is the matter of whether points should be allocated for Australian study. Engineers Australia agrees that Australian education is of general high quality and there is value in the exposure to Australian cultural norms and colloquial language. However, these are not necessarily arguments in favour of explicit recognition in a points test. So far as engineers are concerned, skills assessment is undertaken against the competencies required for entry level to the occupation concerned. Typically, the main focus of examination are the competencies associated with Bachelors degrees and Diplomas (in the case of engineering associate occupations). In some cases additional and/or clarifying information may be obtained from an examination of a higher qualification. Whether a prospective visa applicant has a Masters or PhD degree per se does not play a major role in assessing entry level competency. This means that additional points for holding qualifications at this level are not material to assessing an individual s competency as an engineer. The second matter is exposure to colloquial english in the teaching process and in the individual s social life. Engineers Australia has consistently argued that the standard of english language offered by a prospective visa applicant is critical. Exposure to colloquial english is helpful in that it advances an individual somewhat further down the path of adaptation to Australian life but it is not a critical factor. Engineers Australia would prefer to see a single high level english language requirement as the minimum requirement for all prospective visa applicants under the SOL related process. Engineers Australia would prefer this standard to be a minimum of IELTS 6 in each module. Bonus points could be considered for superior outcomes. The third matter is whether points should be allocated to prospective visa applicants from top international universities. Engineers Australia notes that the overall ranking of a university does not necessarily indicate that the quality of its engineering courses are consistent with that ranking. Irrespective of the ranking of the international university, Engineers Australia believes that a competency based assessment of the overseas engineering qualifications held by permanent visa applicants is essential. In many cases this is assisted by either the Washington Accord (agreement by 17 countries (4 provisional) to recognise sunstantial equivalence of each others 4 year degree qualification in engineering) and the Sydney Accord (agreement by 8 countries to recognise substantial equivalence of each others 3 year qualifications in engineering). The countries involved host a large proportion of the world s top universities. Work is also underway on the Dublin Accord which aims at similar arrangements for engineering associates (associate degrees and the equivalent of AQF Diplomas and Advanced Diplomas). ENGINEERS AUSTRALIA 12 March 2010 Page 2

4 The fourth matter is the level of qualifications held by a prospective visa applicant, especially one whose qualifications are from a top world university. If the SOL is based on specialised occupation, as foreshadowed by Skills Australia, the association between an individual s qualifications and the occupation on the SOL is defined. In the case of engineering, the skill requirement is the competencies consistent with entry level engineering qualifications as discussed above. There may well be occupations on the SOL for which different qualifications are required, for example, a university research academic in engineering. There may also be situations where experience beyond that required for entry level or relatively junior occupations is required. This experience will need to be demonstrated by examination of an individual s career record. Whether the individual holds a higher degree from a top university may be relevant in some cases, but what the individual has done is far more relevant. Engineers Australia believes that that the SOL should clearly and appropriately define the relationship between occupation and skill requirement. To allocate points for higher qualifications from top universities when selecting visa applicants to supplement domestic graduations from Australian universities for entry to the engineering profession is not relevant. In summary, Engineers Australia believes that engineering competencies are the most appropriate basis for selecting applicants for permanent visa capable of joining the engineering profession in Australia. Engineers Australia accepts that there may be some additional value associated with holding Australian qualifications, providing the course was of sufficient duration to achieve the language familiarity discussed above. However, Engineers Australia sees no relevance in awarding additional points for qualifications above the competencies necessary for entry level, except where higher qualifications are necessary to comply with the requirements of a specific occupation on the SOL. 4. Other Factors for a new Points Test English language ability Consistent with the comments made above it may be appropriate to allocate bonus points for english language capacity above IELTS 6. Work experience and age Research into engineering skills shortages undertaken by Engineers Australia shows that consistently over the past 4 years that employers have experienced greatest recruiting difficulties in respect of engineers grade 3 and grade 4 2. There are no hard and fast rules about how long it takes an individual to achieve these grades, once again it is a matter of acquiring competencies, many on the job. However, the average years of work experience of individual engineers at these grades provides an indication of the degree of work experience expected. In the private sector, engineers grade 3 have average work experience of 12 to 13 years and engineers grade 4 have an average work experience of 17 to 20 years. The average work experience is higher for public sector engineers at 16 to 17 years for grade 3 and 21 to 24 years 2 See the desciptions of engineering grades in APESM, Professional Engineer Remuneration Survey, December 2009, pp8-9, ENGINEERS AUSTRALIA 12 March 2010 Page 3

5 for grade 4 respectively 3. The average work experience for engineers grade 2 are 6 and 10 years respectively. These figures suggest that about 15 years work experience is the norm for an engineer grade 3 and up to 20 years for an engineer grade 4. Entry to these levels can be expected to be nearer the average work experience for the grade below and the majority of new engineer grade 3 would have 8 to 10 years experience and the majority of new engineer grade 4 would have about 15 years work experience. These levels of work experience can be accomodated within the current age limit for skilled migration programs. The current points test provides limited recognition of work experience (up to 3 years). Engineers Australia believes that if work experience is to be recognised in the points test, the length of work experience should reflect the actual experiences of employees and have an eye to balance in the work experience structure of the engineering profession. This latter point is particularly important in the case of engineers because skilled migrants have outnumbered domestic graduates in recent years. Engineers Australia notes and understands the rationale for favouring younger migrants. However, the points allocated are disproportionate and fully offset points now included for work experience. Engineers Australia has no wish to challenge the argument that younger migrants ameliorate population aging, but it believes that a simpler way to do this is to award some points (for example, 10 points for applicants 35 years of age or younger) and to balance this with slightly more points for significant work experience directly relevant to the assessed occupation (for example, 15 points for at least 10 years work experience). Points for higher degrees Consistent with the views expressed above, Engineers Australia believes that no additional points should be allocated for qualifications above entry level. Points for well qualified partners Engineers Australia offers no comment on this matter. Family and/or State and Territory sponsorship Engineers Australia notes that there are separate visa classes providing for family sponsorship and for sponsorship by a State or Territory government. In view of this prospective visa applicants should be streamed by visa class and no additional points awarded for sponsorship. Consistent with the design of a demand driven approaches, numbers for different visa classes could be geared to demand. Points for regional study Regional study is important so far as Australia s export of education services is concerned. Engineers Australia believes that this policy objective should be clearly differentiated from skilled migration policy. Separate visa classes provide for migration to regional areas and Engineers Australia sees no further need to favour these locations. 3 See The Engineering Profession: A Statistical Overview, Sixth Edition, 2009, pp76-77, ENGINEERS AUSTRALIA 12 March 2010 Page 4

6 Points for community languages Engineers Australia sees little relevance for community languages in engineering and offers no further comment. Points for Professional Year Comments made above acknowledge the value of favouring skilled migration of younger people. Consistent with this view, and the importance of adding practical competencies to academic credentials, Engineers Australia believes recognition of completion of a formal Professional year is a satisfactory basis for allocating points to a prospective visa applicant. 5. Overview position Engineers Australia believes that all prospective visa applicants for occupations on the SOL should first and foremost meet minimum criteria relating to the competences relevant to the SOL occupation, english language proficiency and the overall age limit. Applicants who satisfy these criteria could be awarded points in a points test for english language capability above the minimum required, for younger age groups, work experience and for the completion of a formal Professional Year. Family sponsorship and sponsorship by State and Territory Governments should not attract points but should be dealt with through the streamed management of demand in visa classes established for these purposes. Base level competencies should be closely related to the occupation on the SOL and no additional points are warranted for higher and/or additional qualifications. Confusing occupational competencies and degrees from top world universities should be avoided and no additional points should be allocated. Engineers Australia believes that the points test should be used to rank prospective visa applicants. Unless applicants meet minimum criteria for skilled migration, no points test can overcome obvious deficiencies. ENGINEERS AUSTRALIA 12 March 2010 Page 5

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