Best Practice Principles and Standards for Skilled Migration Assessing Authorities

Tuesday, 31 October 2023

Assessing Authority Policy and Assurance
Migrant Skills Assessments Branch
Department of Employment and Workplace Relations
Australian Government

Lodged online

Dear Assessing Authority Policy and Assurance Team

Submission on Best Practice Principles and Standards for Skilled Migration Assessing Authorities

Chartered Accountants Australia and New Zealand’s (CA ANZ) submission on best practice principles and standards for skilled migration assessing authorities (the consultation) answers all of the consultation questions, except for question 8, which is addressed in a separate joint submission with CPA Australia and the Institute of Public Accountants.

CA ANZ is the leading peak body for the accountancy profession. We represent more than 136,000 accounting and financial professionals. CA ANZ is also a professional accrediting body and a TEQSA registered provider of higher education. We make this submission in the interest of our members and in the public interest.

Key points
CA ANZ’s views are:

• The seven draft best practice principles and standards outlined in the consultation paper will improve outcomes and are achievable. They should be specific, measurable and achievable but also broad enough to be relevant to all assessing authorities and consistent with Department of Home Affairs requirements.

• Accounting skills assessments are aligned with industry and membership. The accounting assessing authorities have jointly developed accreditation standards against which the quality of higher education accounting programs and their providers will be assessed.

• Supporting employment and migration outcomes for accounting is critical. CA ANZ provides a range of services to do so including an International Pathways Program, careers engagement activities to supportdomestic and international students and graduates of accounting, including migrants, and advocacy with governments to build the talent pipeline. There is scope for the government to support work readiness by expanding the Professional Year Program to recent and prospective migrants and other professions.

• The accounting assessing authorities request that DEWR and the Department of Home Affairs provide early notification to us of any changes that may impact application volumes, timelines or policy. We would also like to see the Department of Education continue to update Country Education Profiles.

If you require further information or would like to discuss the views shared in this submission, please contact Roberta Santos, Migration Manager at CA ANZ on 02 9080 5832 or roberta.santos@charteredaccountantsanz.com.

Sincerely,
Simon Grant FCA Sarah Davidson
Group Executive, Advocacy and International Policy, Thought Leadership, Education, Skills and Migration Leader

© Chartered Accountants Australia and New Zealand
ABN 50 084 642 571 (CA ANZ). Formed in Australia. Members of
CA ANZ are not liable for the debts and liabilities of CA ANZ. charteredaccountantsanz.com

Appendix A
Q1 Which standards will improve outcomes? Why/why not?
The seven draft best practice principles and standards outlined in the consultation paper will improve outcomes for the reasons provided in the consultation paper, which is based on feedback from stakeholders including CA ANZ.

The principles and standards are aligned with the objectives and principles outlined in the independent review of migration policy led by Dr Martin Parkinson AC PSM and the draft migration strategy released by the Minister for Home Affairs, the Hon Clare O’Neil MP, on 27 April 2023.

The government has proposed five core objectives will underpin the migration system and form the foundation of Australia’s migration strategy for the next two decades:

• Building Australia’s prosperity by lifting productivity, meeting workforce needs, and supporting exports.
• Enabling a fair labour market, including by complementing the jobs, wages and conditions of Australian workers.
• Building a community of Australians.
• Protecting Australia’s interests in the world.
• Providing a fast, efficient and fair system.

Q2 Which standards are achievable and why/why not?
All seven draft best practice principles and standards are achievable for CA ANZ for the reasons provided below.

Principle 1 – User-friendly and migrant-centric experience
Clear, accessible, and user-friendly skills assessment processes, guidelines, and communications enhance migrants’ overall experience and understanding of the system. This supports more efficient and higher quality outcomes.

CA ANZ has improved the digital experience for skills assessment and now offers a new user dashboard/ portal to applicants and agents that:

• Is easy to navigate.
• Provides information about the assessment process in simple language.
• Offers a secure payment process to minimise the risk of data privacy breaches.
• Allows supporting documentation to be uploaded to each section of the application.
• Flags missing or inadequate documentation and offers application status tracking for transparency and efficiency.
• Allows additional information or documentation to be uploaded, if required.

CA ANZ has a user-friendly website for migration skills assessment which includes a frequently asked questions section that contains clear information about the assessment process, fees and outcomes.
Guidance is provided on how to prepare an ‘assessment ready’ application. The online application form and website display a contact us link for applicants to submit an enquiry.

Principle 2 – Reasonable and justified fee structures
Fees are commensurate with the cost of conducting high-quality skills assessments, do not impose an unreasonable barrier for prospective migrants, and represent value for money for applicants.

CA ANZ’s fee structure for skills assessment is reasonable and justified. Our website outlines a range of service offerings applicants can choose from based on their needs. Applicants can benefit from selecting discounts for standard processing times and combined assessments (such as qualification and skilled employment) if more than one assessment is required. Please refer to point 6 on fees and processing times on our skills assessment website.

Principle 3 – Evidence based occupational assessment standards
Well informed assessment standards that are fair, sensible, and relevant, ensure prospective migrants have the the requisite skills to secure meaningful employment and contribute to Australian society.

Accounting skills assessments are aligned with industry and membership requirements.

The accounting assessing authorities are committed to ensuring excellence in accounting education throughcooperation with higher education providers via the process of professional accreditation.

The accounting assessing authorities have jointly developed accreditation standards against which the quality of higher education accounting programs and their providers will be assessed (accreditation standards).

Each accounting assessing authority will assess technical competency areas based on the accreditation standards to determine coverage of the core competency areas required for entry to their respective professional program or for migration purposes.

Principle 4 – Fair and equitable assessments
An objective and unbiased assessment of an applicant’s skills promotes consistency and fairness, regardless of a migrant’s background.

CA ANZ conducts assessments to ensure that a prospective migrant’s skills meet the industry standards required to work in an accounting occupation.

We are committed to the principle that good assessment promotes learning and is fair, coherent, transparent, non-discriminatory and provides useful formative feedback.

CA ANZ’s assessment outcomes are clear and also advise how to seek a review or appeal of an assessment.

We offer clear and fair complaints, review, and appeals processes.

Principle 5 – Timely and efficient skills assessment delivery
The assessment process is optimised to reduce duplication and maximise efficiency.

CA ANZ offers an efficient and streamlined end-to-end assessment process to minimise unnecessary delays.

We have internal guidelines, processes and work instructions to support a fair and transparent application process.

CA ANZ uses internal reports and dashboards to monitor caseloads and systematise and simplify administrative tasks.

Principle 6 – Meaningful employment outcomes are enabled
Post-assessment assistance is provided to help migrants obtain meaningful employment, including vulnerable cohorts such as partners, migrant women, and international graduates.

CA ANZ’s Careers Engagement team engages with, inspires and develops domestic and international students and graduates of accounting, including migrants, to help them obtain career advice, find work experience, connect with employers and realise the value of being a Chartered Accountant (CA). Further details are provided on our You unlimited website. We can also explore with our Careers Engagement team the potential for CA ANZ to provide further post-assessment assistance or advice such as:

• Delivering end-to-end information and after care for migrants to support their post-assessment migration and employment journey.
• Leading or participating in ventures that proactively educate employers and industry on the benefits of a migrant workforce and the hiring of international graduates.
• Building an understanding of applicants’ visa and employment outcomes post-assessment to inform continuous improvement of skills assessment processes and standards.

Any such additional employability support CA ANZ may be able to provide could be included in our migration skills assessment outcome letters with a link to an employability support webpage.

Principle 7 – Integrity and transparency in operations
Integrity and transparency in the operations of assessing authorities facilitates quality migration outcomes.

CA ANZ collaborates with government and third-party providers regarding fraud detection and awareness. We provide assessors with clear guidelines for handling suspected or confirmed fraudulent cases.

Q3 What have we missed?
Best practice principles and standards for fraudulent claims aligned with Principle 7 on integrity and transparency should be consistent with Department of Home Affairs requirements.

Assessing authorities should be informed of Department of Home Affairs best practices principles and standards for fraudulent claims so that these can be applied to any fraudulent claims identified in the migration skills assessment process.

Q4 What changes are needed to improve skills assessment processes to make them simpler and more migrant centric?
Skills assessment criteria should be consistent and aligned with Department of Home Affairs requirements, including risk management on fraudulent claims.

Best practice principles and standards should be specific, measurable, achievable and aspirational but also broad enough to be relevant to all assessing authorities.

Q5 Are skills assessments appropriately aligned with domestic employment, visa, and licensing/ registration requirements? Why/why not?

As outlined in question 2 under Principle 7 on evidence based occupational assessment standards, accounting skills assessments are aligned with industry and membership.

The accounting assessing authorities have jointly developed accreditation standards against which the quality of higher education accounting programs and their providers will be assessed (accreditation standards).

Each accounting assessing authority will assess technical competency areas based on the accreditation standards to determine coverage of the core competency areas required for entry to their respective professional program or for migration purposes.

However, the accreditation standards assess qualifications only, and not work experience or prior learning.

The alignment of skills assessments with domestic employment, visa, and membership requirements could be improved through better integration of skilled migration assessments and skilled employment assessments or combining the two assessments. This would create more consistency between the way accounting assessing authorities measure migration skills and employment skills.

Migration skills assessments focus on assessing formal qualifications, subjects and syllabus details. Skilled employment assessments include assessment of prior work experience, duties and responsibilities and references.

CA ANZ’s website encourages applicants who have completed an Australian or New Zealand qualification to use our Accredited Tertiary Course (ATC) table to ensure they have completed all mandatory competency areas required for their nominated occupation before submitting a migration skills assessment application. Applicant may wish to complete bridging subjects in the mandatory competency area by undertaking additional studies through CA Foundations Pathway or CA ANZ's Accredited Tertiary Courses.

During an application process, when it has been established that an overseas qualification is comparable to at least the level of an Australian bachelor’s degree, CA ANZ will examine the individual subjects to determine coverage of the mandatory competency areas for each ANZSCO code. Applicants need to demonstrate they have obtained a pass in each of the approved completed subject areas to evidence they have met the mandatory competency areas. CA ANZ requests further information/ clarification from applicants if a competency area is not met before issuing a "not suitable” outcome.

If a mandatory competency area for an applicant’s nominated occupation has not been met, CA ANZ’s outcome letter provides advice on which mandatory competency areas are required and guidance on how the outstanding areas can be completed through the CA Foundations Pathway or a recognised University listed on our Accredited Tertiary Courses Table. We also attach a pdf information sheet to the assessment outcome letter.

The vast majority of CA ANZ’s migration skills assessment applicants (87%) reside in Australia and hold an accredited Australian qualification.

Improving recognition of work experience and prior learning
Initial discussions between CA ANZ, CPA Australia and the Institute of Public Accountants suggest recognition of work experience and prior learning (RPL), in lieu of a qualification/ competency area for migration skills assessment, would be a challenge to do in a formal and consistent way. However, the accounting assessing authorities would like to do so, and we recognise the value in such recognition.

Recognising professional work experience and prior learning provides an opportunity to consider the value that may be contributed to the profession from skills and knowledge obtained outside of formal qualifications, including experience gained from working in other industries or overseas.

The challenge of recognising work experience and prior learning lies primarily in verification – proving a claim of work experience or prior learning is true, accurate and justified. Ensuring objectivity, integrity and consistency in how work experience and prior learning is measured and recognised is also important.

At CA ANZ, we do not currently recognise work experience in lieu of qualifications for entry into the CA Program. Entry is all based on academic qualifications. However, if a candidate has relevant work experience, they can demonstrate their competency through our foundation exam, which is a measurable tool to verify knowledge gained from experience. For example, if a candidate is missing a tax subject, CA ANZ would not give them credit for that based on work experience alone. The candidate would need to demonstrate their competency through an exam.

Q6 How could skills assessment processes be streamlined with occupational licensing and registration schemes?

At CA ANZ, applications for migration skills assessment and applications for entry into the CA Program (membership) are completed by separate teams. However, there is regular, ongoing communication between the two teams to ensure CA ANZ’s processes are streamlined and consistent given the same technical competency areas and learning outcomes apply for both migration purposes and professional accreditation (membership).

Q7 What other functions could assessing authorities deliver to support employment and migration outcomes?
Supporting employment and migration outcomes for accounting is critical.

Accounting, audit and finance professionals continue to be in shortage nationally in Australia. Jobs and Skills Australia’s 2023 Skills Priority List found a national shortage of tax accountants, external auditors and internal auditors. Future supply is expected to fall well short of our estimated demand for an additional 6,000 professionals per year1.

Treasury’s Employment White Paper released on 25 September 2023 found, “There is also scope to better use the skills that migrants bring to Australia. Nearly a quarter of permanent skilled migrants are working in a job beneath their skill level…Some occupations exhibit particularly poor results for migrant skills matching. Migrant engineers and accountants stand out among the occupations not matching well into their nominated occupation.”2

Employment and migration outcomes can be improved by providing international graduates of accounting and migrant accountants with pre-employment services and work-readiness programs to help them find work matched to their qualifications and skills in occupations in shortage in Australia, such as in audit and accounting.

Pre-employment services could include providing applicants with a direct match into a role in their nominated occupation, where there is a skills shortage in that occupation, such as exists in audit and accounting.

Where an applicant’s nominated occupation is not in shortage, the services provided could include re-directing them to roles where their skills can best be utilised, aligned with the needs of the labour market, and avoiding where possible placement in roles beneath their skill levels.

1 CA ANZ submission to the Department of Education on the Australian Universities Accord,11 April 2023, pages 19-20.
2 Treasury (2023) Working Future: The Australian Government’s White Paper on Jobs and Opportunities, Chapter 5 page 103.

How CA ANZ is supporting employment and migration outcomes
CA ANZ’s International Pathways Program (IPP) helps prepare candidates for the Australia and New Zealand labour market and provides cultural training. For Australian candidates, the IPP focuses on the role of the Chartered Accountants in the current Australian business and regulatory environment, encouraging participants to evaluate and demonstrate the ways in which they may apply their technical knowledge and professional skills to add value to their clients or employer as a business partner.

The IPP workshop:

• Enhances previous and current accounting and business experience but in an Australian context.
• Provides networking opportunities.
• Presents case studies about genuine Australian business challenges.
• Examines solutions to business problems based on Australian commercial realities.

CA ANZ’s Careers Engagement team engages with and develops students and graduates of accounting, including migrants, connecting them with top employers and industry leaders to hear about vacation, graduate and cadetship positions, and gain career advice and inspiration to realise the value of being a Chartered Accountant (CA). Our You unlimited website provides access to CA ANZ’s careers engagement services and resources.

CA ANZ’s Achiever program, which runs in two cohorts each year, allows tertiary students to gain valuable paid work experience for a duration of 3 to 12 weeks with one of our participating employees. Open to penultimate and final year domestic and international students who are currently undertaking university studies in accounting, the program runs across both Australia and New Zealand. In the 2023 Winter cohort we had 106 successful placements from1099 applications and in the summer cohort we have had 1,113 applications with the selection process underway. In 2022, 200 students were successfully placed with 220 employers.

CA ANZ’s advocacy team has also developed a policy plan for governments to address the ongoing shortage of accountants and auditors and build the talent pipeline in Australia. Key elements include:

• Recognise accountants and auditors on the 2023 Skills Priority List.
• Shift the focus of skilled migration from occupations to skills by transitioning from occupation lists to a core skills list;
• Feature accounting and audit professionals prominently in the skilled migrant intake;
• Reform the migration system to make better use of migrant and international student talent;
• Extend post-study work rights to graduates of accounting and extending the list of eligible occupations to include accounting and audit;
• Refrain from introducing a levy on international student fees;
• Recognise accounting and audit as national priorities for education, skills and migration funding;
• Reform higher education funding and financing.

Work readiness programs
One of the ways the accounting assessing authorities are supporting employment and migration outcomes is assisting the work readiness of international graduates of accounting by making available the Accounting Professional Year Program (Accounting PYP).

The Accounting PYP, which is currently available to international students with an accounting degree from at least two years of study at an Australian university, has been shown to deliver superior employment outcomes.

Please refer to Figure 1 below which was included in the migration system review joint submission made by Chartered Accountants Australia and New Zealand and CPA Australia to the Department of Home Affairs on 15 December 2022 (pages 29-30).

Figure 1: Accounting PYP candidates enjoy superior employment outcomes
Share in employment, per cent

"PICTURE VISIBLE IN DOCUMENT"

Sources: Social Research Centre, Graduate Outcomes Survey for years shown, with data for years prior to 2020 sourced via a special data request, and Accounting PYP, destination survey outcomes for quarters shown.

Notes: The outcome for Accounting PYP is the number of respondents who responded ‘Yes’ to a question on whether they are currently employed relative to all responded either ‘Yes’ or ‘No’.

Developed in February 2008 by the Department of Immigration and Border Protection (now the Department of Home Affairs), the Professional Year Program (PYP) provides recent accounting, IT and engineering university graduates with an alternate pathway to gain relevant job‐readiness skills and work experience in their chosen Australian profession.

By completing the PYP, participants gain 5 points toward a Skilled Visa application, supporting an international student pathway to permanent migration and potential industry employment.

The PYP is delivered over 44 to 52 weeks and is comprised of two core components. The first component is delivered in class for 32 weeks with participants generally attending class one day per week. The second component is a 12 week internship with an approved host employer. In the IT stream, a third component is delivered online.

The peak professional bodies responsible for governance of the PYP for Accounting, IT and Engineering, submitted a paper to the Migration System Review Panel in February 2023 outlining several recommendations to ensure the future and continued relevance of the PYP:

• Introducing flexibility by removing some of the time constraints and shifting to a more adult-learning approach that offers participants and employers experiential learning over 300 to 400 deliver hours followed by six months of opt-in employment and transition services.
• Identifying talent early by promoting the PYP as the first step after university graduation to mitigate the 'permanent temporary’ problem and accelerate the skilled migration journey. PYP bodies recommend commencement within two years of graduation.
• Expanding the scope of the PYP to recent and prospective migrants and other professions.
• Supporting regional communities by utilising the PYP to assist and sustain the transition of migrants into regional areas by using remote learning and virtual work technologies to provide access and ongoing engagement with regional employers, communities and small businesses.
• Empowering local employers by utilising existing business relationships and internship placement expertise across PYP delivery and expanding the program’s emerging career mentorship, employer outreach and post-program employment opportunities.
• Educating and empowering employers and industry to engage with and consider skilled migrants as well as showcase PYP graduate skills, capabilities and work readiness.

Q8 Should there be more than one assessing authority appointed to assess an occupation? Why/why not?
Please refer to the joint submission made by CA ANZ, CPA Australia and the Institute of Public Accountants in response to question 8.

Q9 Should English language testing be a skills assessment requirement?
Noting English levels are tested as part of the visa application stage.
If English levels are tested as part of the visa application stage, English language testing should not be done as part of the migration skills assessment requirements.

If English language testing is a requirement for skills assessment, this should be aligned with visa and industry standards to reduce inconsistencies and confusion for migrants.

Q10 Is there anything else you want to tell us about skills assessments?
Early notification of changes request
As noted in the joint submission provided by CA ANZ, CPA Australia and IPA in response to question 8 of this consultation, the accounting assessing authorities request that DEWR and the Department of Home Affairs provide early notification to us of any changes that may impact application volumes, timelines or policy. This would give us more time to prepare for the changes and enable us to meet Principle 1 of the draft standards – provide a user-friendly and migrant-centric experience. Being prepared to resource unexpected surges in demand will also help minimise or avoid unnecessary strain on our staff and delays in processing times.

Country education profiles update request
The accounting assessing authorities would also like to see the Department of Education continue to update Country Education Profiles. No longer providing this valuable service is a source of frustration for applicants and assessing authorities.

Appendix B
Chartered Accountants Australia and New Zealand (CA ANZ) represents more than 136,000 financial professionals, supporting them to build value and make a difference to the businesses, organisations and communities in which they work and live.

Around the world, Chartered Accountants are known for their integrity, financial skills, adaptability and the rigour of their professional education and training.

CA ANZ promotes the Chartered Accountant (CA) designation and high ethical standards, delivers world-class services and life-long education to members and advocates for the public good. We protect the reputation of the designation by ensuring members continue to comply with a code of ethics, backed by a robust discipline process. We also monitor Chartered Accountants who offer services directly to the public.

CA ANZ is also a professional accrediting body and a TEQSA registered provider of higher education.

Our flagship CA Program, the pathway to becoming a Chartered Accountant, combines rigorous education with practical experience. Ongoing professional development helps members shape business decisions and remain relevant in a changing world.

We actively engage with governments, regulators and standard-setters on behalf of members and the profession to advocate in the public interest. Our thought leadership promotes prosperity in Australia and New Zealand. Our support of the profession extends to affiliations with international accounting organisations.

We are a member of the International Federation of Accountants and are connected globally through Chartered Accountants Worldwide and the Global Accounting Alliance. Chartered Accountants Worldwide brings together members of 13 chartered accounting institutes to create a community of more than 1.8 million Chartered Accountants and students in more than 190 countries.

CA ANZ is a founding member of the Global Accounting Alliance which is made up of 10 leading accounting bodies that together promote quality services, share information and collaborate on important international issues.

We also have a strategic alliance with the Association of Chartered Certified Accountants. The alliance represents more than 870,000 current and next generation accounting professionals across 179 countries and is one of the largest accounting alliances in the world providing the full range of accounting qualifications.

© Chartered Accountants Australia and New Zealand
ABN 50 084 642 571 (CA ANZ). Formed in Australia. Members of
CA ANZ are not liable for the debts and liabilities of CA ANZ. charteredaccountantsanz.com