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31 October 2023
Draft Best Practice Principles and Standards for Skilled Migration Assessing Authorities
The Australian Society of Medical Imaging and Radiation Therapy (ASMIRT) is the peak body representing medical radiation practitioners in Australia. Our aims are to promote, encourage, cultivate and maintain the highest principles of practice and proficiency of medical radiation science, always mindful that the welfare of the patient should be at the centre of everything we do.
Please find some additional feedback on the explanatory memorandum:
Page 3
' The department is currently reviewing the requirements and assurance framework for the assessing authority sector. Through an enhanced assurance model, government will monitor and manage the assessing authority sector more effectively, ensuring skills assessments are migrant-centric and being delivered optimally in terms of process, standards, timeframes, industry requirements and cost.'
This statement would appear to hint at the department potentially assuming a more controlling influence over assessing authorities and their roles. If all skills assessments are required to become migrant-centric, ASMIRT seeks surety from the Department that public safety specifically for healthcare professionals has been considered and monitored.
Page 7,
1.1 ASMIRT seeks to clarify whether the Department can offer a standard platform template that can be adapted to suit Assessing Authorities? That way there is consistency and standardisation of formatting, requirements etc, however also provides Assessing Authorities the ability to include their own professional requirements.
Page 7,
1.2 ASMIRT endeavours to provide timely, informative outcomes to applicants. If applicants are unable to provide requested supporting information, this leads to a lengthened assessment timeframe. Whilst it is appreciated that applicants seek updates regarding the status of an application, to design and build an online platform to facilitate this will require project capital cost. ASMIRT seeks clarity from the Department on the cost benefit model associated with this process for assessment, for Assessing Authorities that only see less than 200 applications per year.
Page 7,
1.3 ASMIRT suggests that there will be significant costs associated with funding these initiatives subsequently being absorbed by each Assessing Authorities. This will lead to fee increases in applications, for website development, platform development, reviewing, updating etc.
Page 8,
2.2 ASMIRT sees this as an opportunity to revisit what other assessing authorities charge for their various assessments, to benchmark against them.
Page 8, example box
ASMIRT concurs that transparency for applicants relating to application fee structure is important.
Page 10,
4.1 ASMIRT seeks to clarify whether the Department can offer a standard guideline document that can be adapted to suit Assessing Authorities? This will enable a consistent and standardised approach from Assessing Authorities.
Page 11,
5.2 ASMIRT concurs that that the use of technology will assist in monitoring and maximising assessment efficiency. ASMIRT seeks clarity from the Department on the cost benefit model associated with the introduction of new technology and database integration for Assessing Authorities that only see less than 200 applications per year.
Page 12,
6.1
ASMIRT does not believe that this is within the scope of Assessing Authorities.
ASMIRT are keen to understand who will be responsible for funding these new initiatives; Is this the role of migration agents and other employment or support agencies?
6.2
ASMIRT does not believe that this is within the scope of Assessing Authorities.
ASMIRT suggests that for professions that are registered with the regulatory authority Ahpra, direct collaboration with the Assessing Authorities to produce material and information sheets may support the applicant further.