What is 'complete' and what is an 'incomplete' application for the 457 in the eyes of the case officer?

Even though RMAs can think that they are submitting a 'complete' application, any DIBP case officer can ask questions about the 'genuineness' of any part (nomination, 457 visa) of an application. This is despite the application/s being lodged in complete form, online. 

Migration Agents (registered ones) report repeatedly receiving requests for further information, which  have already been attached to the online application.  Case officers often don't look at or read the information which has been submitted by an agent.  If a case officer neglects or forgets to look at what has been lodged, and then requests further information that is already available to them, does this trigger a 'incomplete application' in the DIBP system and go towards the 60% of 'incomplete' applications?

Has the DIBP considered auditing the accuracy and performance levels of its own staff first, by creating statistics on the rate at which DIBP officers make 'requests for information already on file'?

The checklists for 457 visa applications on the DIBP website are incomplete if one considers what a complete application 'might be' in practical reality.

Migration agents consider a complete application to be:

'Provide the required and relevant form and fees plus relevant documents to meet the legislative criteria for the grant of the visa'.  Section 46.  Valid Visa application.

Sometimes there are grey areas with 457 sponsorships or nominations.  This means that the DIBP can request further information AT THEIR DISCRETION, which falls outside the scope of the 'complete application' as per their own checklists.

For example, sometimes a sponsorship application can be approved when receipts are provided for Training Benchmark B ONLY.  However other case officers request documents such as evidence that the actual training was actually completed by the Australian staff of the business.  There is no standardisation within the DIBP and too much personal discretion.  Does all of this 'discretion' get added into the 60%?

Another example would be that to satisfy the genuineness of the position, a bigger organisation may not need to provide extra documents, but a smaller businesses may be requested by a case officer to provide things such as:

• Evidence of lease agreement
• Photos of business premises
• Menus of the restaurants
• Evidence of invoices and purchases and other supporting evidence to show that the business is operational

'Genuineness' goes beyond the DIBP checklists.

Documentation and evidence can be requested at whim by a DIBP case officer in order to satisfy their individual and personal requirements, and be personally satisfied that a nominated position fits within the scope of the business and is 'genuine'.  Is this calculated into the 60%?

Maybe it is about time the DIBP developed a whole new 'decision ready' application checklist which covers nominations from following business types:

1/ Large

2/ Medium

3/ Small

4/ Start-up

That way everyone is clear on exactly what is required. That way, percentages like 60% can be better measured against relevant checklist criteria.

Question: Would it be considered an 'incomplete application' by a DIBP 457 case officer if the RMA retrieves the medical referral letter and HAP ID after submission of the client's 457 application? Why does the DIBP allow persons to obtain the medicals after the application after the application is submitted on the ImmiAccount if the DIBP doesn't want the medical to be done after the submission?  It might be on the checkilist that the medical can be done beforehand but it could potentially waste the client's money because they might not be required to do a health check (eg British).

What if the DIBP waits until the client completes the medical examination and waits for the results?   Medicals can take a few weeks from the date of application.  Clients have a host of issues which may prevent them from obtaining an instant medical (pregnancy, menstruation, TB, HIV).  Are these 'incomplete' applications and contribute towards the 60%?

It is time for the DIBP to update their Schedule 1 requirements and stop complaining that RMAs are only meeting 40% complete application rates.  That is pretty high considering the goal posts are hazy.

The DIBP should show us the statistics on this and how they pulled the 60% together.  Othwerise, with all due respect, DIBP should stop complaining.  My request is that DIBP be grateful that RMAS are even able to reach 40% 'complete applications' (whatever that is).  RMAs end up with the majority of difficult cases and do most of the work that would otherwise be done by DIBP before it even reaches their desks.

The checklist: 

http://www.immi.gov.au/Visas/Pages/checklists/457-nominate.aspx