Non-government schools have a significantly different overseas student enrolment profile to that of the other education sectors. We have large numbers of CRICOS registered providers with relatively small numbers of students in each school. The enrolment of overseas students is therefore not a question of financial viability. Rather it is one of choice. Our schools choose to engage in this arena for a variety of reasons, but always for the cultural and educational benefits to the school community and its members (Independent Schools Council of Australia (ISCA) Report to the Productivity Commission (2015)).

In a School Governance Article earlier this year, we raised the issue of 'cultural comparatives’ and the importance of schools seeking to develop world views and align with the requirements of the Melbourne Declaration on Educational Goals for Young Australians and the Australian Curriculum. Schools are often keen to take on full fee paying overseas students (FFPOS) if they have Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) registration or, as many do, take on international exchange students through registered exchange organisations. However, the actual student numbers enrolled are comparatively small and the associated costs can be disproportionately high.

The secondary student exchange programs in each state or territory are specific reciprocal programs whereby students from another country are enrolled as full-time students in an Australian secondary school for a period ranging from three months (or one full school term) to one year. Under similar program conditions students from Australia are eligible to enrol full-time, in a recognised course of study in an overseas country. Secondary exchange students participating in approved exchange programs are generally not required to pay tuition fees. This is an important consideration if a registered exchange organisation approaches a school to host a student and to complete the Acceptance Advice for Secondary Exchange Students (AASES) form.

It is apparent from Department of Immigration and Border Protection (DIBP) data and, as noted by ISCA, that the number of full fee overseas students enrolling in Australian schools is not high. They also advise that many non-government schools with CRICOS registration usually take on only one or two FFPOS students each year, with a total average enrolment of seven (7) or less in a school being the norm. ISCA also noted in a submission to the Department of Education regarding the review of the ESOS Framework that with ‘most schools enrolling relatively small numbers of overseas students, the current regulatory environment creates a disproportionate workload on schools with limited administrative resources’. One school quote from within this text was: “We only have one or two FFPOS enrolled at each site. This is not a money-making exercise for us as we set our fees to just cover our costs. The regulatory burden placed on the provider is so arduous that if we hadn’t already had the registration we would have made no attempt to seek registration.” In addition, it was noted by the Association of Independent Schools of WA within the same document that “There are fees associated with ongoing CRICOS registration, fees for the Department of Education Services to check on the school’s compliance with both the State and Federal Acts and a massive fee if a school fails to maintain its CRICOS Registration and then chooses to re-new."

So, schools are left with a budgetary conundrum. If, through the enrolment of FFPOS, they wish to meet some of the outcomes of the Melbourne Declaration on Educational Goals for Young Australians and support the Australian Curriculum imperatives for international education through intercultural understanding and cross-curricular priorities, then they may well need to review the costs associated with having ongoing CRICOS registration or perhaps limit themselves to enrolling international exchange students. There is no doubt that to host Full Fee Paying Overseas Students (not exchange students) in a school can be costly. Initial set up costs can be in excess of $15,000. For example, in Victoria, the fees to register a school are $4756 as a minimum. CRICOS registration with the Australian Skills Quality Authority (ACQA) commences at $9,000.00.

All CRICOS providers are also subject to the Tuition Protection Scheme (TPS) Levy. The 2016 TPS Levy comprises:

• an Administrative Fee Component, of $106 and $2.12 multiplied by the total enrolments for the previous year; and
• a Base Fee Component, of $212 and $5.31 multiplied by the total enrolments for the previous year.

If a school is only enrolling one or two FFPOS per annum, it would take many years to recoup this initial outlay.

In addition, there are HR and labour costs associated with the preparation of policy documents that meet the National Code of Practice, preparing for and attending a formal registration process with a state or territory regulator, development of specific documents for overseas students that are a requirement of the ESOS Act and the National Standards  and the training of staff who will be responsible for the students. There are also other requirements associated with health insurance, accommodation and student welfare.

Under Section 5, Evidence Requirements of the VRQA Application for approval or re-approval for registration on CRICOS, the VRQA identify that it is necessary to create or amend existing school policies to ensure compliance with the National Code 2007. Combined, it is expected that the relevant policies will incorporate all relevant standards of the National Code 2007 for the school sector. However, regardless of the cost, it seems that, wherever possible, non-government schools seek to encourage an interchange of overseas students either through formal CRICOS registration or through a registered student exchange program.

Schools have identified the immense personal value and gain for each student participant (and their peers), the value added to the programs of teaching and learning, the cross cultural relationships developed and the development of a world view amongst staff and students resulting from the attainment of some of the outcomes of the Melbourne Declaration on Educational Goals for Young Australians and the Australian Curriculum imperatives for international education.

So, what price does a school put on having overseas students learning alongside domestic students? ISCA make it clear in the opening statement; ‘Our schools choose to engage in this arena for a variety of reasons, but always for the cultural and educational benefits to the school community and its members.’