The Capstone complaint letter sent to the Minister and others

Posted by Migration Alliance on Wednesday, 27 March 2019 in General

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The Capstone complaint letter sent to the Minister and others

The following email has been copied to Migration Alliance today, and has been sent to various Ministers and Senators in Australia. Migration Alliance has not been part of the construction of this letter, nor in assisting the participants in the Capstone in any way. Permission has been granted by the author to publish.

The Office of the Migration Agents Registration Authority

Department of Home Affairs

GPO Box 9984

SYDNEY NSW 2001

Australia

Re: Capstone Assessment as a requirement to register with OMARA

Dear Sir/Madam,

We as recent Migration law graduates who have completed Graduate Diploma in Migration Law and Practices (GDMLP) and preparing to register with your office, together with continuing students who are in the process of completing this Diploma, jointly write to you in this letter regarding the above mentioned assessment.

We strongly believe that Capstone assessment is unnecessary and unfair. Introduction of this assessment raises serious questions over the abilities of Australian Institutions involved in the delivery of Graduate Diploma in Migration Law and Practices (GDMLP), that includes the Ministry of Education itself.

The introduction of Capstone test raises serious questions over the abilities of Australian Universities to teach and test their students .

Capstone assessment was introduced last year (2018) for Migration Law Graduates or candidates who seek to register with OMARA to become Registered Migration Agents (RMA). We understand that this assessment has been introduced to maintain high standards of professional knowledge among Migration Agents and to maintain the quality of service they provide to their clients. We also understand the fact that in the past many or some Migration agents have exploited their clients and caused issues for authorities in the past because of their unethical practices and lack of professional knowledge. We believe these types of Migration Agents are still there involved in unethical and unprofessional practices.

Many students who graduated last year with Distinction/High Distinction from different universities took this exam in February this year and have failed Capstone assessment due to, what we believe, is unrealistic testing and its environment.

We all candidates mentioned at the bottom of this letter, request you to address the issues raised below to make Capstone assessment fair for everyone.

1. Time frame: The exam is divided into written and oral exam. The oral exam is held for 1.5 hours while the written part is held for three and half hours and is divided into Part A - Multiple choice questions, Part B - Short answer questions and Part C - Practical writing task, Client letter and submission letter. The time frame for part A is 36 minutes, Part B is 60 minutes and Part C is about 2 hours. The reason of failure for most of the candidates is the unrealistic and unfair time frame of part C. Most of the candidates found that the time frame is not enough for completing a letter to the client and submission to the Department of Home Affairs in about 90 minutes which is the approximate time left after completing other parts of exam and reading the case scenario. Most of the candidates found that addressing the complexity of the case scenario and writing letters need at least another half an hour.

The candidates who started with part-C could not complete one or the other parts of the assessment.

Compulsory parts and passing marks: The passing mark in the exam is 65% which is much higher than the other exams conducted in various other fields. We think it is unfair but still that is not an issue for most of the graduates to get 65% overall who have passed with good marks from Universities. The main issue is getting 65% in Part- C is compulsory to pass the assessment, which seems impossible due to the time frame given to complete part-C. Our request is to either increase the time frame to complete Part- C or decrease the passing percentage to 50% in part C.

To comment on ‘Oral assessment’ of the capstone exam, it seems that the college of law has failed to comprehend the depths of the migration law. The duration of the oral exam was for 1.5 hours where students were provided with on the spot scenario and were asked to prepare for it in 15 minutes. The real challenge was to assist the client for 50 minutes with complicated queries. The college of law assessors played the role of very difficult clients who demanded the students to provide the maximum visa options of at least 6 - 7. Students were put under immense pressure throughout the oral exam because the assessors were pushing the students to rush in. The worst part was where students were only allowed 15 minutes to write a file note, which is impossible in the real-life scenario, given that students are inexperienced and the speed that ‘The School of Law‘ wants to see, comes with the combination of experience plus time.

Capstone assessment is not a requirement for existing agents: The new Capstone assessment was not imposed on existing Migration agents which is totally unfair on the new candidates. The existing agents have only completed Graduate Certificate which used to be 6 months while the new candidates have completed Graduate Diploma which is of 1-year duration. The old agents only paid about $12000 while existing candidates have paid $25000 to get the qualification. Most of the candidates have left full time work to complete this intensive study and have struggled to pay Capstone exam fee of $2750 and now they are being made to sit in the exam again for $2200.

It would be absolutely fair if all existing Migration agents are required to pass this assessment to continue their registration with OMARA, including the one who assisted OMARA in preparing the structure of Capstone assessment.

Money making Drive: We believe that Capstone assessment is a money making drive. New aspirants who want to become registered migration agents are financially burdened as the application fee to sit in the test is unrealistic. To sum up, we would like the College of Law to justify the amount of fees ($2750) students have paid to enroll in this Capstone assessment. It appears to us that “this assessment is a money-making strategy for the college of Law or whoever is involved in deciding the assessment fee structure, as the application fee is exorbitantly high”. We really question the structural fairness of this capstone assessment in terms of fee, amount of support provided to the students by the college of law, exam content and the duration of the exam.

For students Capstone testing fee of $2,750 is unrealistically high and by considering the number of fails The College of Law is making it won’t be one off. Even $2200 to re-sit in the exam is not justified at all.

As we all are aware that in the first year of registration, RMA’s must meet the criteria of required CPD points that allow the newly registered migration agents to enhance their legislative knowledge and hone their skills. There is no denying that the migration law is a dense subject and require experience to provide expert and in-depth advice on complex issues. On the contrary, it’s unfair to assess fresh graduates against such rigorous criteria. Rather, volunteer work experience could be a choice or compulsory hour of training can be introduced or attending Tribunal session could be made compulsory which may make a positive impact to student’s knowledge and practical developments.

Students could go and attend the Tribunal in their own time and could have applied for volunteer positions within AMIS Australia.

Furthermore, we strongly believe that the purpose of the Capstone assessment in the present structural format is to stop entering new Migration professionals into the business than maintaining or raising professional standards. The clear evidence we see here for that is, not including existing Migration agents in this so called rigorous Capstone assessment.

We urge the OMARA to investigate the issues raised in this letter against the college of law and check the structural flaws of Capstone assessment in order to make the assessment fair for everyone so that the new graduates could pursue their career as registered Migration Agents.

We look forward to hear from you soon.

We students have also started an online petition . Please find the link below where 375 students have already signed the Petition.

https://www.change.org/p/office-of-the-migration-agents-registration-authority-remove- capstone-test-for-migration-students

Yours sincerely,

Migration Law Students 2018-2019 group

Arnab GHOSH ROY