SUBMISSION 2016-17 Pre Budget Submission
The Migration Institute of Australia (MIA) is the national professional organisation for Registered Migration Agents (RMAs). The MIA welcomes the opportunity to provide this submission regarding the priorities of the 2016-17 Federal Budget. The MIA is aware of the Government s commitment to repair the Budget, to pay down debt and to build a stronger and more prosperous economy. The MIA believes that Australia s migration programme is a vital factor in the strength and prosperity of Australia and that the 2016-17 Federal Budget should ensure that the Department of Immigration and Border Protection is sufficiently funded to enable it to efficiently and effectively perform its functions. This submission is therefore mainly concerned with funding of the Department of Immigration and Border Protection processes and programs. The recommendations in this submission are designed to enhance the ability of the Department of Immigration and Border Protection to provide efficient services and programs, to support consumer protection and support employers who depend on migration programs to provide sufficient workforces. Yours faithfully, Kevin Lane Chief Operating Officer 5 February 2016 P a g e 2
MIA Recommendations The MIA provides the following recommendations: MIA Recommendation 1 The MIA recommends that funding for the Department of Immigration and Border Protection be increased in the 2016-17 Budget. MIA Recommendation 2 provide increased Humanitarian places in the migration program. MIA Recommendation 3 enable it to decrease the delay in processing Partner, Parent and Carer Visas. MIA Recommendation 4 The MIA recommends that specific funding be allocated to the Department of Immigration and Border Protection in the 2016-17 Budget to pursue and prosecute unregistered migration practice. MIA Recommendation 5 The MIA recommends that visa charges be set at a reasonable level and that the revenue from these go to the Department of Immigration and Border Protection to improve its service provision. MIA Recommendation 6 The MIA recommends that application fees and charges be increased equally across all visa classes. MIA Recommendation 7 The MIA recommends that no change be made to the current taxation arrangements for working holiday visa holders. P a g e 3
Funding for the Department of Immigration and Border Protection Australia s migration programme is vital to Australia s economy becoming stronger and more prosperous. The work of the Department of Immigration and Border Protection (DIBP) in policy-making and visa application processing is crucial to the success of the migration programme. Government funding of DIBP must be adequate to allow to efficiently and effectively perform its functions. For a number of years the DIBP has been facing an increasing number of visa applications and a decreasing budget. There is a limit to being able to do more with less and still maintain integrity in the programme. The amalgamation of the Department of Immigration and Customs included the retrenchment and redundancy of large numbers of both senior officials and long term employees. This has been to the detriment of Departmental migration systems, processes, and client services. There are lengthy delays in many areas of visa application processing. These delays are often to the detriment of Australian businesses trying to sponsor employees and Australian citizens trying to sponsor family members. They also cause great stress to partners and families who are separated and waiting in excess of 12 months for their applications to even be allocated. The waiting time for the decision on second stage partner permanent visas and contributory parent temporary visas is running close to two years. In its 2015-16 Pre-Budget submission the MIA warned that the decrease in sufficient funding to the DIBP would have the negative effects and this has been confirmed over the last financial year. Client service provision by the Department has suffered, Large scale redundancy has resulted in the employment of case and other service officers who have required extensive training to deal with complex legislation and difficult cases. The complexities of Australia s migration legislation and policy are such that the assessment of visa applications in many cases cannot be an exercise in simply ticking boxes. Professional knowledge and judgement are required. This is slowing visa processing, P a g e 4
Poorer decision-making as case officers are pushed to make quick decisions and lack in-depth knowledge of migration legislation. An increase in poor and incorrect decisions by case officers has been observed over the last year. Poor decision-making resulting from lack of resources also impact on the integrity of visa programmes. The Budget allocation for DIBP must enable it to be run efficiently, as a business, while also providing an acceptable level of service to its clients. MIA Recommendation 1 The MIA recommends that funding for the Department of Immigration and Border Protection be increased in the 2016-17 Budget. Increased funding for specific purposes Apart from a general funding increase, the DIBP needs increased funding for the following specific purposes: to increase the number of places in the Humanitarian Programme to enable Australia to assist more of the ever-growing number of refugees world-wide to facilitate the processing of applications in the excessively long queues for family visa applicants, particularly Partner, Parent and Carer Visas to prosecute those providing immigration advice without registration. The MIA is extremely concerned about the amount of poor quality unregistered immigration assistance being provided, both onshore and offshore, which is a danger to consumers MIA Recommendation 2 provide increased Humanitarian places in the migration program. MIA Recommendation 3 enable it to decrease the delay in processing Partner, Parent and Carer Visas. P a g e 5
MIA Recommendation 4 The MIA recommends that increased specific funding be allocated to the pursue and prosecute unregistered migration practice. Application Fees and Charges The MIA believes that application fees and charges are now unacceptably high in some visa classes and often target those with least ability to meet these fees. Sponsorship of partners and families, and particularly for humanitarian visa holders sponsoring family members, has become almost impossible to afford for some potential applicants. These applicants should not be unfairly burdened with providing funding towards DIBP service provision or as a means of bolstering Consolidated Revenue. Where visa application charges are increased, this should be equitably spread across all visa classes, rather than targeting specific visa classes, as previously occurred with the doubling of partner visa application fees. Unaffordable increases in application fees and charges can result in potential applicants becoming unlawful, rather than be separated from their families, because they cannot afford these fees. MIA Recommendation 5 The MIA recommends that visa charges be set at a reasonable level and that the revenue from them go to the Department of Immigration and Border to improve its service provision. MIA Recommendation 6 The MIA recommends that application fees and charges be increased equally across all visa classes. Changes to taxation arrangements of Working Holiday Visa holders. The MIA has concerns that the reported changes to taxing arrangements for those on working holiday visas (commonly known as the Backpacker Tax ) could have severe repercussions for agricultural, regional and remote economies. Employers in these economies are often very reliant on the seasonal labour provided by P a g e 6
backpackers, as sufficient labour is not available in these areas in peak seasons. Similarly, these economies are the beneficiaries of the backpacker spending and could be adversely affected if these backpackers no longer come to work in these locations. MIA Recommendation 7 The MIA recommends that no change be made to the current taxation arrangements for working holiday visa holders. P a g e 7