Best Practice Principles and Standards for Skilled Migration Assessing Authorities

Envisaging better Skilled Migration Assessment Authorities
Response to the Department of Employment and Workplace Relations
Discussion Paper on Draft Best Practice Principles and Standards for Skilled
Migration Assessing Authorities | October 2023

Introduction
AMES Australia (AMES) welcomes the opportunity to provide input into the development of a more user-friendly and migrant-centric Skilled Migration Assessment Authority. As an experienced and long-standing provider of settlement services delivering contracts including
HSP, AMEP, SEE, Workforce Australia employment services, and our Settling into Work social enterprise – AMES submission is based on the organisation’s history of supporting new arrivals to Australia into employment commensurate with their skills and experience.

AMES offers two ideals to best direct new principles and standards for maximum positive impact on skills assessment outcomes. These are a focus on:
1) accessibility; and
2) mitigating the risk of disengagement.

Because barriers to accessing skills assessments remain, and a succession of obstacles
(e.g. inflexible bureaucracies, language barriers, financial costs) are present throughout the process, skills assessments remain under-used.

While there are applicants achieving a successful skills assessment outcome, particularly those with experience navigating bureaucratic processes, many who might benefit most continue to be isolated from these services. For example, highly qualified refugees working within the ‘gig’ economy currently face substantial institutional obstacles to accessing and successfully completing the skills assessment. As a result, their skills are formally unrecognised, and they are locked into employment that is not commensurate with their skills, experience, and education.

A service delivery model that is client-centric at its core will create a better environment for accessibility and lower the risk of disengagement. Any principles and standards the
Department of Education and Workplace Relations is looking to implement should aim to improve accessibility and reduce the risk of disengagement.

In responding AMES references the Questions for Stakeholder Feedback in the Discussion
Paper to guide our organisational response. Please see these targeted responses below.

For more information, please contact Cath Scarth, AMES Australia CEO – scarthc@ames.net.au

AMES seeks consideration of the following matters
1) Which standards will improve outcomes? Why/why not?
Applying these standards could, in principle, result in improvements in the sector. However, these standards in their current form are imprecise and open to interpretation. For maximum positive impact, standards should be robust and prescriptive.

A ‘Code of Practice’, written so that it makes clear how the standards would be implemented in the skills assessment process, may assist in improving outcomes.

2) Which standards are achievable and why/why not?
With sufficient institutional commitment of time and resources, all standards are achievable.

However, given some proposed standards do not represent current or routine practice, they will require a longer timeline to implement e.g. Standard 6.2.

Standards focused on administrative processes and policies are likely already in place with most assessing authorities, and may simply need a review with minor updates. For example, AMES expects most assessing authorities will have a policy in place regarding transparency of fee structures, meaning a short review and revision should achieve compliance with the new standard (2.1).

3) What have we missed?
AMES does not consider that anything has been missed. Our responses to other questions capture any challenges and have proposed responses that address any identified shortcomings.

4) What changes are needed to improve skills assessment processes to make them simpler and more migrant centric?
Any skills assessment process that seeks to be more migrant-centric must recognise that currently, applicants themselves are expected to initiate and drive the assessment accreditation process. This creates an increased risk that applicants will disengage in the course of an attempt to seek a skills assessment.

A more responsive program design would incorporate a case management service delivery model with individual case managers assigned to applicants to ensure engagement and help them manage the process. This is particularly important for those individuals (such as refugees) who often require additional English language and administrative support.

5) Are skills assessments appropriately aligned with domestic employment, visa, and
licensing/registration requirements? Why/why not?
Presently many licensing and registration requirements must be undertaken externally to the skills assessment process. This creates complexity and increases the risk of disengagement.

Any opportunity to integrate external licensing and registration requirements into the skills assessment, or to link them more seamlessly, would be of benefit to migrants.

6) How could skills assessment processes be streamlined with occupational licensing and registration schemes?
As noted above, rolling external processes into the skills assessment would be of benefit.

Where this is not feasible, data sharing arrangements which can be opted into while recognising privacy concerns, should be considered. This would allow assessing authorities to make direct bookings/referrals on behalf of applicants, accelerating their progress and reducing the chance of disengagement.

7) What other functions could assessing authorities deliver to support employment and migration outcomes?
Consideration of the promotion of skills assessments with targeted partnerships. For example linkages with AMEP and other English language training providers who could host information sessions. Regular tailored promotion of the skills assessment scheme in a trusted environment and with sufficient support available to ensure attendees understand the intentions of the scheme and how to access it may be more impactful.

Aside from occupational licencing and registration processes, AMES does not recommend assessing authorities deliver additional services. There is no value in assessing authorities attempting to deliver, for example, employability skill programs and other such complementary services when a field of specialist providers is already available and equipped to offer these services.

8) Should there be more than one assessing authority appointed to assess an occupation? Why/why not?
AMES believes that the existence of multiple assessing authorities provides applicants with greater choice.

Assessing authorities offering a client-centric service will develop a positive profile, modelling practices for other authorities to learn from.

9) Should English language testing be a skills assessment requirement? Noting English levels are tested as part of the visa application stage.
Where applicants can produce evidence of English proficiency, testing should not be required as part of skills assessment.

However, AMES recognises that many applicants, including those from refugee backgrounds may not have had their English language skills tested as part of the visa application process. As a result, English testing will need to remain part of the skills assessment process for some applicants.

10) Is there anything else you want to tell us about skills assessments?
AMES encourages a systematic rethink of the skills assessment process to situate the migrant at the heart of the journey, recognising that migrants have much to contribute to the Australian economy.