- Submitterʼs name
- Submitted on behalf of
- Immigration law firm
About the submission
- Please select the industry your submission is in relation to. If required, you may select multiple industries.
- Professional, Scientific and Technical
- Please identify which occupations your submission relates to:
- All 670 occupations
1. Are there additional labour market factors, for which there are national datasets available (ideally aligned to 6-digit ANZSCO occupation level), that are relevant to future refinements to the Departmentʼs analysis and methodology?
What is the frequency of data release?
- Emerging and Unique Skills: To be responsive and adaptive to changing labour market needs, the methodology should include measures which identify emerging and uniquely specialised occupations; notably in occupations that are NOT in ANZSCO. For example, the digital revolution has created jobs for highly skilled workers in entirely new occupations and industries such as “Big Data” architects, digital marketing specialists, and data scientists – all occupations that did not exist five years ago. The proposed methods utilise conventional best practices using traditional statistical data sources. The use of emerging analytical methods from the field of cognitive computing and artificial intelligence would allow the inclusion of non-traditional data sources to capture new and niche skill sets well before they become detectable through conventional labour market studies. We would be pleased to provide further information and material in relation to analytical cognitive data technology and systems available.
International Comparisons and Stakeholder Consultation: The operation of an effective and responsive review methodology would benefit from international comparative studies of similar programs. Proactive engagement with relevant bodies such as the Migration Advisory Committee, universities and others would assist the Department to appreciate the challenges in various locations.
2. The Department is also seeking submissions on suitable datasets that are disaggregated by region. Please provide details if you are aware of such a dataset, including whether it is aligned to ANZSCO occupations and how often the dataset is updated.
- No response.
3. Is there any other advice or evidence that the Department should consider in its review of the methodology?
- Points Test System: Public and business confidence in the system would benefit from stakeholder consultation regarding:
• the weight given to different sources
• the points attaching to particular factors
• how occupations are scored
• what grading will be applied
• what each grade score looks like.
Stakeholders: The parties able to make a submission should not be prescribed. A transparent responsive list review process are best served by being open to any interested party. If the Department intends to place limitations on the parties able to make submissions, this should be articulated clearly and referred for further consultation.
Accessible Resources: A decision-making process which involves the examination of evidence by multiple parties will arrive at the best outcome when all parties refer to the same material. We recommend that relevant resources should be available either to download or by hyperlink on one central web page.
Published Guidelines: The required structure and content of submissions should be published in guidelines. Optionally, a proforma could be used with the facility to upload supporting documentation (eg: https://dbei.gov.ie/en/Consultations/Call-submissions-Highly-Skilled-Eli...).
Caveats: The methodology should include consideration of whether restricting access to occupations is better managed through the imposition of a caveat rather than placement on STSOL or removal.
Published Outcomes: Summary Sheets similar to those previously released by the Australian Workforce and Productivity Agency would assist business in understanding the methodology and the reasons for decisions ( eg: http://industry.gov.au/Office-of-the-Chief-Economist/SkilledOccupationLi...)
List distribution: Lists should be published regularly and consistently on the same dates, on the same website as the reference material.
Notice Period: A 6 month period between an occupation’s placement on the red list and its removal from the program is a tight timeline for:
• Notice of the impending removal to be published
• Formulation of submissions
• Consideration of the submissions
• A reasonable period of notice of removal
A 12 month period would allow a 6 month period for submissions and their consideration. If the decision is that the occupation is to be removed, the second 6 months serves as a notice period for the next occupation list next release, during which migration regulations could limit access to these occupations to incumbent subclass 457/ TSS visa holders nominated in that occupation; and allow visa periods of only 6 or 12 months. This would prevent a spike in visa applications by new entrants; ensure that all incumbents in such roles drop out of the labour market within 12 to 18 months; but provide a more appropriate amount of notice for visa holders and their employers to make alternative arrangements.
- Do you have any supporting material for your submission?