Increased clarity on what is included in the benchmarks
- HELA Submission
4. Providers will be required to supply certain types of non-academic services to students. These services are detailed in the proposed National Access to Services Benchmarks (the Benchmarks) and the National Student Representation and Advocacy Protocols (the Protocols).
5. The proposed compulsory student services and amenities fee (the fee) must be used for purposes that are over and above services listed in the Benchmarks and Protocols. That is, none of the fee may be used to fund services listed in the Benchmarks and Protocols.
6. Our view is that there should be greater clarity on which services may be funded by the fee and which services may not be funded by the fee.
7. For example, the Benchmarks list ‘welfare services’ inclusive of services to assist with ‘accommodation, financial matters, legal concerns and employment’ but the Guidelines on the allowable uses of the fee also list services to assist with ‘accommodation’, ‘financial services’, ‘legal services’ and ‘employment’. The dividing line between which services may be funded and which services may not be funded, is unclear.
8. We consider the lack of clarity as to which services may be funded and which services may not be funded will make it difficult for Providers and other stakeholders to know whether or not they are in compliance with the legislation.
9. The services listed in the Benchmarks and Protocols have some overlap with but are not identical to the services listed in Standard 6 Student Support Services of Part D of the National Code of Practice 2007 (the National Code) under the Education Services for Overseas Students Act 2000 (the ESOS Act).
10. The international students are already charged compulsory amenities and services fees to cover services listed in the National Code.
11. The lack of clarity between what constitutes a service to an international student under the National Code and what constitutes a service to an international student under the Benchmarks and Protocols has caused the peak body for the international students to raise the concern that they will be subject to a discriminatory double charge under the provisions of the proposed Bill and its instruments. See page 5 of the National Liaison Committee (NLC) submission (number 24) to the Senate Inquiry and which is available on the Parliament House website referred to at paragraph 2 of this submission.
12. We consider the Guidelines, Benchmarks and Protocols should all explicitly state in unambiguous terms that the fee may not be used by Providers to fund any services which are required under the National Code. The present clarification at paragraph (q) of the Guidelines does not in our view address this issue in a completely satisfactory manner.
13. A further matter the Government should have regard for when clarifying the boundary between which services may be funded by the fee and which services may not be funded by the fee is the emerging increased demand for student welfare services in the context of the current global financial crisis (GFC).
14. We estimate from the Universities Australia Student Finances 2006 report1 and from enrolment statistics provided by DEEWR for the 2008 academic year that the total after-tax earnings of full-time higher education students in Australia counting both domestic and international students from paid (mostly casual) employment was of the order of $8 billion. We consider this source of income, upon which an unprecedented number (estimated at 470,000) of full-time students now depend, to be highly vulnerable in the current economic circumstances.
15. A severe contraction, for example a reduction of in excess of $2 billion in the total national after-tax earnings of full-time higher education students from paid and mostly casual employment, is a scenario the Government should consider. If this were to occur the current student welfare services in the higher education sector would struggle to cope with the numbers of students in financial distress.
16. We estimate the Government’s one-off $900 bonus payments under the $42 billion economic stimulus package will apply to about 220,000 full-time and about 140,000 part-time current year (2009) domestic higher education students and will provide total cash benefit of about $200 million to the full-time students. The direct benefit to students from the $900 bonus payments, whilst welcome, will do little to arrest the adverse consequences for the full-time higher education students of any severe contraction in earnings from paid and mostly casual employment.
17. The campus services sector itself provides part-time and/or casual paid employment to students. Based upon surveys conducted as part of the AUS/ACUMA 2007 VSU Impact Studywe estimate that pre-VSU about 30 per cent of the part-time and/or casual jobs in the campus services sector were filled by students, providing paid employment to about 3,000 students nationally.
Many of these students lost their jobs following introduction of VSU. Passage of the Government’s Bill is likely to restore casual and/or part-time student employment levels in the campus services sector back to or nearly back to the levels that existed pre-VSU. Whilst not wishing to understate the useful source of paid employment provided to students by the campus services sector, it is relevant to note that the campus services sector provides less than 1 per cent of the total after tax earnings derived by full-time higher education students from paid part-time and/or casual employment in the context of the broader economy.
Increased employment of students by the campus services sector will not, of itself, do much to stem the rising tide of students in financial distress cases that are likely to engulf the sector if there is a severe contraction in the earnings of full-time students from casual employment at the national level.
18. If the Higher Education sector and the Government more generally do not move to implement more robust student welfare services in circumstances where there is a severe contraction in the earnings of full-time students from casual employment there is the risk of reduced student retention rates and/or longer time taken for students to complete their degrees.
19. Full-time students who cannot afford to remain at university in circumstances where they have lost their earnings from casual employment and who then discontinue or suspend their studies or who drop down to part-time enrolment, will no doubt in many cases end up applying for Newstart Allowance.
20. An important area of student welfare services support presently provided by many universities and/or campus services organisations is expert advice to students on what entitlements the student has to government benefits such as Youth Allowance, ABSTUDY, AUSTUDY, Newstart Allowance, Rent Assistance and Health Care Card.
The advantage of delivery of this type of support by universities or campus services organisations directly is that these organisations (perhaps more so than Centrelink) will typically have better access to the student and in addition are able to specialise in the special needs and entitlements of the higher education student. If there is to be a material increase in the number of students experiencing financial distress then Government should perhaps consider inclusion of this type of student welfare support within the Benchmarks.
21. More generally, in the context of the GFC, we would suggest it is appropriate for Government to mandate via the Benchmarks and Protocols a relatively robust and well-defined level of student welfare services overall – not to be funded out of the $250 capped fee.
22. The Commonwealth Government’s Regional University Sport Funding Programme (RUSFP) currently provides $2.5 million annually to assist funding of sporting services staff at 27 universities nationally. This programme is currently scheduled to terminate at the end of the 2010 year and the proposed Bill does not make any provision for continuation of the programme.
23. The RUSFP has provided a critical lifeline to preserve employment in regional university sport positions during the VSU years. Students at regional universities are still in most cases at a significant disadvantage in terms of the sporting services they may access, relative to students at the capital city and metropolitan universities. Many regional campuses still lack basic student sporting and recreational infrastructure such as swimming pools and aquatic centres. The proposed Bill will not fully redress the disadvantage experienced in this area by
the regional students. We would urge the Minister to reconsider the 2010 scheduled termination of the RUSFP programme.
24. As it is proposed that the new legislation permitting a capped, compulsory amenities and services fee will take effect from 1 July 2009, which is 18 months before the scheduled termination of the RUSFP, we consider the Guidelines should state explicitly that the fee may not be used by Providers to fund those parts of the student sporting services which are funded by the RUSFP.
25. Finally, the Benchmarks, Protocols and Guidelines should be clarified to ensure the fee may not be used to fund services which prior to VSU were typically not funded out of compulsory amenities and services fees. Services such as but not limited to career and/or psychological counselling and assisting students to find accommodation and/or graduate employment were prior to VSU, in most cases, not funded out of compulsory amenities and services fees. The Government should take a broadly based and prudent view of the services that should be
covered by the Benchmarks.
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