International Student Program (ISP)

9. Administrative requirements

This section covers: refunds, complaints and appeals, school record keeping, fees, invoicing and disbursements.

Purpose

There are a number of administrative functions required under the ESOS framework that serve to enhance the consumer protection and welfare of international students as well as protect the integrity of the student visa system. The majority of these requirements relate to natural justice provisions and record keeping.

Important requirements

Refunds

• All parents sign a written agreement (DOCX) with DE when they enrol in the International Student Program (ISP). This is a contract between the parents (and student, if over 18 years old) and DET. This Written Agreement sets out the fees to be paid by the student, and the circumstances in which they will be refunded.
• Where parents believe they are entitled to a refund, they should complete and submit the ISP refund request form (DOCX).

Complaints and appeals

• The ISP complaints and appeals policy (DOCX) and the ISP complaints and appeals procedure (DOCX) provide guidance on the complaints and appeals process for students and parents in relation to the ISP. For complaints not related to the ISP, parents should refer to the department’s Parent Complaint policy.
• In the first instance, students and parents should attempt to resolve their complaints informally.
• If the matter cannot be resolved informally, students and parents can raise the matter with DE (IED) using the ISP complaints form (DOCX).
• If students and parents believe DE (IED) has made an error in relation to the outcome of a complaint or they wish to appeal a decision made by DE (IED), they can request an internal appeal using the ISP appeals form (DOCX).
• Students and parents can make a complaint to the Victorian Ombudsman at any time. However, the Victorian Ombudsman may ask students and parents to first access the department’s complaints and appeals processes.

School record keeping

• Keeping accurate and complete records is an essential part of maintaining ISP quality and integrity. Schools must keep records for each international student as outlined in the ISP student file checklist (DOCX).
• Schools must also maintain up-to-date contact information in CASES21 for students, parents, emergency contacts, and homestay hosts (if applicable), including name, address (in Victoria), email and mobile phone number.
• In addition to ongoing updates, schools must ensure each international student completes and signs the International student contact confirmation form (DOCX) in the presence of the ISC every 6 months (ideally at the start of Term 1 and Term 3).
• Completed international student contact confirmation form must be retained by schools and placed on the student’s file for record keeping purposes.
• Schools should be aware that students and parent are also required to advise school staff within 7 days if their contact details change, including who to contact in emergency situations.
• Schools must update any changes in contact information in CASES21 within 3 working days of becoming aware.

Fees

• International student fees are published online at Brochures and Forms. Fees are subject to review each year.
• All fees charged by DE (IED) must be paid to DE (IED), not to schools.
• It is a legal requirement that international students holding certain visa subclasses pay fees. Schools do not have the authority to waive international student fees.
• If a student participates in VCE language studies with a community language school, the school is expected to pay any associated fees from the funds DE (IED) disburses to the school.
• Tuition fees do not include the costs of books, uniforms, stationery items, electronic devices, extra-curricular activities such as non-VCE language studies with a community language school, optional school excursions, optional camps, or VCAA enrolment fees. This is outlined in the written agreement signed by parents.

High-risk financial environment

• International students represent a higher risk financial environment for schools.
• Schools must ensure that all existing financial controls and oversight in the school are applied to prevent misuse of money of international students and families and to protect schools from reputational damage. This includes:
  • appropriate oversight by the Principal and School Council
  • following Departmental policy requirements set out in the Finance Manual, Fraud and Corruption Control Policy, Conflict of Interest Policy and Gifts, Benefits and Hospitality Policy.
• The key factors which contribute to the heightened risk environment are that international students and their families:
  • pay relatively large amounts of monies to DE (IED) and schools, for example, payments to homestay hosts approved by the school
  • may have cultural expectations which exacerbate financial risks, for example, families may have inappropriate expectations regarding the giving of gifts, benefits and hospitality to school staff, or with regards to the carrying and use of cash
  • may have lower English capabilities, which can increase their dependence on school staff and decrease their ability to understand financial risks and seek help
  • may perceive that school staff have the ability to adversely influence the student’s visa or future academic prospects, given the school’s role in monitoring and intervening regarding the student’s visa conditions (for example, course progress and attendance).

Invoicing

• Once commenced, families are invoiced twice per year, usually in May for Semester 2 and November for Semester 1 the following year.
• Semester 1 and Semester 2 invoice amounts differ as there are a different number of weeks in each semester.
• Invoices are sent by email to 2 email addresses — one to the family and one to the school’s generic email address. DE (IED) cannot change the school email to a staff member’s email address.
• DE (IED) must always have current email addresses for invoicing purposes.
• DE (IED) follows a fee collection process if fees are not paid by the invoice due date. Schools cannot grant an extension to the due date.
• Non-payment of fees may result in the student being expelled from school for non-payment of fees once DE (IED) has followed the fee collection process. Please note, this is a legal requirement. Schools will be notified if a student is at risk of being expelled for non-payment of fees.

Distribution of fees to schools

• Ministerial Order 819 (PDF) outlines the proportion of fees that are disbursed to schools.
• DE (IED) distributes funds to schools towards the end of each school term. Schools receive an itemised statement that outlines the student/s included in the distribution and the date the payment will be made to the school. The statement is sent to the school's generic email address and the International Student Coordinator.
• If a student participates in studies with the Victorian School of Languages (VSL), Virtual School Victoria (VSV), Victorian Virtual Learning Network (VVLN) or the Centre for Higher Education Studies (CHES), DE (IED) will distribute a proportion of the school's funds to these schools directly. The amount distributed is outlined in Ministerial Order 819.

School re-accreditation

• Victorian government schools must be accredited by DE (IED) to enrol international students.
• Schools are accredited for a specific period of time, and have a maximum international student enrolment cap.
• DE (IED) works with schools to build their ISP capability and to monitor school compliance. Where DE (IED) identifies serious and/or repeated non-compliance, DE (IED) may take actions to improve school compliance.

School responsibilities and guidance

Refunds

1. Support and provide advice to the student and parent, if requested.
2. Direct students/parents to the ISP refund policy (DOCX) and ISP refund request form (DOCX).
3. Principals should sign the withdrawal form (PDF), where required.

Complaints and appeals

1. Schools should refer to the ISP complaints and appeals policy (DOCX) for guidance on the ISP complaints and appeals process.
2. In the first instance, schools should try to resolve the matter informally if the matter relates to the ISP at the school.
3. Schools should refer students and parents to DE (IED) to lodge a formal complaint or appeal if an ISP matter was not able to be resolved informally. The ISP complaints and appeals procedure (DOCX) provides an overview of the complaints and appeals process and who to contact depending on the issue.
4. Schools may be asked to assist with a formal ISP complaint or appeal by providing DE (IED) with any information or documentation related to the matter.

School record keeping

1. Collect and manage personal and health information in accordance with relevant information and privacy policies.
2. Create and manage records of all decisions, actions, outcomes and business activities in accordance with relevant policies.

Fees, invoicing and disbursements

1. Forward a copy of any relevant invoices to the parent/s to ensure they have been received by the family.
2. Follow up outstanding fees with families to help facilitate payment. DE (IED) will notify schools when a family receives a final notice from DE (IED) and when schools are required to contact families regarding outstanding fees.
3. Check disbursement statements for accuracy. For example, whether the student’s year level is accurate. This information can affect disbursement amounts.

Compliance evidence

Schools must ensure the following documents are retained for audit purposes:

1. an accurate and up-to-date ISP student file checklist (DOCX) for each international student
2. completed International student contact confirmation form (DOCX)
3. all contact details in CASES21.