‘The Practical Perspective’: Addressing Common Challenges in Practically Managing Overseas Students

Published
16 August 2018

The new National Code of Practice for Providers of Education and Training to Overseas Students 2018 (the 2018 Code) is well in effect now after commencing on 1 January 2018. Many schools are now preparing to go through CRICOS re-registration and are considering the practical application of key additions or amendments to the Code.

School Governance has previously reported on the changes in the 2018 Code and its 200+ points of compliance CRICOS-registered schools are required to meet in our article: Compliance Checks Loom for Schools with Overseas Students.

This article will briefly discuss some of the key practical challenges that schools are facing in applying the 2018 Code.

It also includes links to a series of short videos from an informal discussion between Jill Forsyth, Risk and Compliance Manager at Korowa Anglican Girls’ School and Jonathan Oliver, a director of international students at a leading New South Wales private school for over six years and now a Senior Consultant at CompliSpace. The two sat down to discuss the 2018 Code and other issues relevant to CRICOS-registered schools in these first videos from a series called The Practical Perspective.

Academic Performance and Attendance Monitoring

While schools’ obligations in the 2018 Code relating to academic performance and attendance monitoring have not significantly changed, it continues to be an area that produces practical challenges for schools.

In the previous 2017 Code, Standards 10 and 11 dealt with monitoring course progress and monitoring attendance. The 2018 Code has combined these standards into a new Standard 8 – Overseas student visa requirements.

Reporting unsatisfactory course progress or attendance to PRISMS is a significant escalation for any school to take if a student isn’t meeting the required progress or attendance as it may lead to the student's visa being cancelled.

It is critical for schools to have strategies in place to identify why students may not be meeting the school’s course progress and attendance thresholds, and pre-empting potential triggers that would prevent a student from achieving satisfactory progress and attendance and supporting students accordingly.

To view a short 7 minute video of Jonathon and Jill discussing the 'Practical Perspective' on this topic click here.

Overseas Student Transfers

The 2018 Code adds to schools’ requirements in relation to overseas student transfers to another school, including significant additions to what is required in a school’s overseas student transfer policy.

Additionally, schools may now only assess an overseas student’s transfer request after the first six months of the student’s course, unless certain exceptions are met, including if it is in the best interests of the student. Other key changes include that schools must record transfers in PRISMS and must allow the student to access the school’s complaints and appeals process before finalising transfer requests.

Transfers between providers aren’t as common in schools as they are in other providers such as Vocational Education and Training (VET) providers or higher education providers. However, when a student is struggling or unhappy and wants to transfer, how can schools manage this and support the student through the challenges of studying in Australia?

To view a short 6 minute video of Jonathon and Jill discussing the 'Practical Perspective' on this topic click here.

Managing Younger Overseas Students Who Turn 18

The welfare of younger overseas students (under 18 years of age) must be maintained for the duration of their stay in Australia. To maintain their welfare, students can either stay with a nominated guardian approved by the Department of Home Affairs, or receive accommodation, support and general welfare arrangements from the school. In the case of the latter, the school issues a Confirmation of Appropriate Accommodation and Welfare (CAAW) letter.

However a CAAW will automatically expire when a student turns 18 – who ensures their welfare while they’re still a student at the school past their 18th birthday?

To view a short 3 minute video of Jonathon and Jill discussing the 'Practical Perspective' on this topic click here.

An Overseas Student Wants to Get a Part-Time Job

Getting a job as a student can be a great thing for students generally – they can learn about responsibility and the value of money. However, the school is ultimately responsible for the safety and welfare of students and must consider the interests of the student, their parents and their homestay family in these circumstances.

What should schools consider when an overseas student wants to get a part-time job at the local takeaway shop?

To view a short 3 minute video of Jonathon and Jill discussing the 'Practical Perspective' on this topic click here.


The first five videos in The Practical Perspective: on Schools with Overseas Students can be accessed here. The complete video series will be published shortly.

Cara Novakovic

Cara is a Content Product Manager at CompliSpace. She works predominantly with education clients to ensure ongoing compliance with the myriad of laws, regulations and guidance notes that apply to schools across Australia. Cara’s key area of expertise is Child Protection governance, risk and compliance. Cara holds both a Bachelor’s Degree in Communications (Journalism) and a Juris Doctor from the University of Technology, Sydney.