Overseas student attendance

Standard 8 of the National Code requires ESOS providers to monitor an overseas student’s course progress and attendance. This is to ensure overseas students can complete the course in which they are enrolled within the expected duration specified on their Confirmation of Enrolment (CoE).

This guidance material is designed to assist providers registered under the Education Services for Overseas Students Act 2000 (ESOS Act) to understand their responsibilities in monitoring course progression and classroom attendance as required by the:

• National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code),
• the Standards for Registered Training Organisations (RTOs) 2015 (for VET providers), and
• the ELICOS Standards (for ELICOS providers).

Ensuring courses are appropriately registered

Overseas students are required to be enrolled in a full-time registered course to undertake study.

• For VET courses, a full-time course is a minimum of 20 scheduled course contact hours per week, unless otherwise specified by ASQA.
• For ELICOS courses, a course must have a minimum of 20 hours face-to-face scheduled course contact per week.

Scheduled course contact hours for overseas students allow them to develop the knowledge and skills required by the Training Package (for VET students) or the English language requirements (for ELICOS students).

Student who do not attend scheduled course contact hours as identified as required to complete the course are at risk of not progressing and completing the course within the duration of their Confirmation of Enrolment (CoE) as recorded in the Provider Registration and Student Management System (PRISMS).

Information about course duration and contact hours is available to students

If a course is delivered to overseas students, you must ensure:

• that the course is offered on the basis of full-time study
• that the course is for a suitable course duration based on a minimum of 20 scheduled course contact hours per week including scheduled classes, course-related information sessions, supervised study sessions, mandatory and supervised work-based training, and examinations
• that at least two-thirds (inclusive of 20 scheduled course contact hours per week) of the VET units of competency or modules being delivered to an overseas student will be provided face-to-face (that is, not through online or distance learning)
• that in each VET course study period, at least one unit is offered face-to-face
• a suitable course duration and amount of training, based on each learner’s English language capabilities and their existing skills, knowledge and experience.

When you apply to ASQA to register a course on CRICOS, you must submit timetables and you may be required to demonstrate at performance assessment (audit) how course requirements will be met. ASQA may assess how you have implemented these plans for the delivery of registered courses.

Amendments to course structure must be approved by ASQA

To change the approved structure of a course, you must apply to ASQA using the ‘Application to change scope of CRICOS registration’ form on asqanet. Until ASQA approves your application, you cannot make changes to the:

• course duration
• delivery location of the course
• a work-based training component for a course (VET)
• course fees.

Any amendments need to:

• ensure that the course is set for the minimum duration based on 20 scheduled course contact hours per week
• meet all other National Code requirements, for VET courses – the Standards for RTOs, and for ELICOS courses – the ELICOS Standards. 

Keeping students informed – written agreements

A written agreement includes information about the course. The written agreement must provide information about how the course in which they are enrolled will be delivered to enable the student to meet the requirements and successfully complete within the course duration.

• Before your overseas students start their course, your written agreement must tell them:
  • the duration of their course and the modes of study (including campus locations and facilities)
  • that they must participate in scheduled classes in accordance with course timetables to make satisfactory course progress
  • that if they don’t attend scheduled course contact hours and maintain appropriate course progress and/or attendance, they will be in breach of a condition of their visa conditions
  • if a student does not maintain satisfactory course progress and/or attendance, they will be reported to the Department of Home Affairs, which may impact their student visa.

ASQA has published guidance material to assist providers in understanding their obligations when negotiating and recording Written agreements with overseas students.

Provider policies and processes to monitor student course progress

Students are expected to progress through their course so that they complete the course within the registered course duration.

It is your responsibility to make sure each overseas student progresses through their course and meets the requirement to undertake full-time study (unless an approved intervention strategy has been implemented).

You need to ensure every student is being taught and undertaking assessment, as per your timetables and documented training and assessment strategy (VET)/curriculum documents (ELICOS), in a way that will enable them to complete their course within the nominated duration identified in their written agreement.

Students who cannot show that they are meeting the requirements of the qualification, accredited course, or ELICOS course are at risk of not progressing in their course (that is, they are at risk of not completing the course within the nominated duration).

You must monitor student progression in accordance with documented intervention strategy and notify students if they are at risk of not progressing.  When you monitor a student’s course progress to assess if that progress is satisfactory, you must ensure the student has:

• participated in scheduled classes, course-related information sessions, supervised study sessions, and mandatory and supervised work-based training (where relevant)
• completed all required assessment up to that point of time.

As part of a performance assessment (audit) or compliance assessment (audit) you may be asked to demonstrate how students are progressing in their course in order to show that:

• your practices are consistent with your training and assessment strategies (VET)/curriculum documents (ELICOS)
• the amount of training/teaching being provided is suitable based on the needs of each student
• your students are participating in training/learning and assessment activities
• your students are satisfactorily progressing through their course.

The evidence you retain to demonstrate that students are attending scheduled classes could include marked student attendance records.

You must also document and implement a range of policies and procedures, to monitor course progress including:

• the requirements for achieving satisfactory course progress (including attendance of scheduled course contact hours) which promote and uphold the integrity of the course
• how to address misconduct and allegations of misconduct
• processes for recording and assessing a student’s course progress
• processes to identify, notify and assist overseas students who are at risk of not being able to complete their course within the nominated duration (including from their participation in tuition activities)
• details of an intervention strategy to assist students who are at risk of not meeting course progress requirements
• processes for determining the point at which a student has failed to meet satisfactory course progress.

Students not attending, but making satisfactory progress

If an overseas student is not attending scheduled classes, but is making satisfactory progress in their VET course, then the course duration set is not suitable for that student—because they may already have the skills, knowledge and experience to progress in their course without receiving structured training.

In this case, you will need to reduce the duration of the course to the minimum duration required given the student’s existing skills and knowledge, while maintaining a minimum of 20 scheduled course contact hours per week.

If multiple overseas students are not regularly attending scheduled classes for training and making satisfactory progress in their course, this is indicative of a systemic problem. This can indicate that your organisation:

• is not able to determine a suitable course length and amount of training for your intended student cohort
• does not have a valid, sufficient or authentic assessment system to assess a student’s existing skills and knowledge or progress towards attaining competence.

Monitoring attendance

ELICOS providers (and if ASQA, as the ESOS agency, requires a VET provider) must monitor overseas student attendance. You must have and implement a documented policy and process for monitoring and recording attendance of the overseas students.

You must also document and implement a range of policies and procedures, to monitor student attendance including:

• a method for working out minimum attendance for the course (for ELICOS providers, this must be a minimum of 80 per cent of the course)
• processes for recording course attendance
• appropriate interventions strategies for identifying, notifying and assisting overseas students who have been absent for more than 5 days without approval or who are at risk of not meeting attendance requirements prior to their attendance falling below 80 per cent
• processes for determining the point when the student has failed to meet satisfactory course attendance.

Reporting students that do not meet course progress and/or attendance requirements

If you are required to monitor attendance and it is identified an overseas student is not meeting their course progress and/or attendance requirements, you must take appropriate action to report the student in PRISMS.

Prior to reporting an overseas student, you must:

• have undertaken an intervention strategy to assist the student at risk of not meeting course progress, in sufficient time for the student to achieve satisfactory course progress and/or attendance
• tell the student of the intention to report them and the reasons why you are reporting them
• tell the student how they can access an internal complaints and appeals process
• advise them on their external appeal rights.

You may decide not to report an overseas student for breaching the attendance requirements, only if the student is:

• attending at least 70 per cent of the scheduled course contact hours and
  • for ELICOS students, they demonstrate and provide evidence of a genuine compassionate or compelling circumstance
  •  for VET students, they are maintaining satisfactory course progress.