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Cap on foreign student numbers needed

Media Release 19 November 2002

Cap on foreign student numbers needed

A cap on the number of foreign fee paying students in New Zealand secondary schools is crucial if the sector is to overcome serious staffing problems, the PPTA says.

In its submission to the Ministry of Education’s discussion document on Developing Export Education - the Export Education Industry Development Fund and Levy, the PPTA recommends that schools be allowed no more than five per cent of foreign fee paying students on their rolls.

It also recommends more research to establish the subject specific demands foreign students place on secondary schools and the sector’s ability to meet these demands.

PPTA president Jen McCutcheon said successive governments’ failures to adequately resource secondary schools had driven many schools to supplement their income with foreign fee paying students.

However, she said the financial benefits did not outweigh the strain put on certain secondary subject areas and she was disappointed that the discussion document did not acknowledge the huge staffing problems caused partly by high foreign student numbers.

PPTA analysis of the latest Education Gazette shows 502 secondary teacher vacancies - up from 389 in the same Gazette last year. Of those, 410 are permanent vacancies. Based on last year’s figures, secondary schools could start the 2003 school year up to 300 teachers short.

“The dramatic rise in foreign student numbers is exacerbating the staffing problems that already exist, particularly in areas such as Auckland and in the subject areas that are hardest to staff - maths, the sciences and increasingly, English.”

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Mrs McCutcheon said using the term “export education' masked the wide range of impacts that importing foreign fee paying students had on the domestic education system.

“Education is a social good for the community, not an industry. Foreign students who study here are entitled to the best quality provision, but the government’s primary obligation is to resource the system so New Zealand students get the best possible education outcomes.”

She said PPTA thought the proposed export education levy - to be used to fund an independent body to manage the importation of foreign students - seemed to reflect the government’s wish to distance itself from export education at a time when it should be closely monitoring its potential and real negative impacts.

The association was also concerned that the discussion document talked about the internationalisation of educational institutions, with no mention of how this would benefit New Zealand.

“Is the government saying it would be a good thing for our educational institutions to be internationalised? On the contrary, the commercialisation of education in New Zealand created by this trade may expose our public education system to the harmful effects of the General Agreement on Trade in Services (GATS).”


Submission on

Discussion Document

Developing Export Education - The Export Education Industry Development Fund and Levy

November 2002


NZPPTA welcomes the opportunity to make a submission on the Discussion Document.

NZPPTA represents approximately 15,500 teachers who are members of the union, working in secondary, area and composite schools throughout New Zealand. This submission reflects the views of these members as they have been expressed through Annual Conference papers in 1995 and 1997, through the union’s consultation mechanisms and through ongoing correspondence with national office. Our comments focus on the issues for the secondary school sector.

While the discussion document appears to expect only written submissions, NZPPTA would be very happy to make an oral submission as well.

This submission addresses the Key Questions, but first raises some general issues about “Export Education’. At the end, it makes a number of recommendations.


NZPPTA considers the use of the term “Export Education’ for the provision of education in New Zealand to foreign fee-paying students to reveal a flaw in thinking. The use of this term masks the very real impacts, mostly negative, which this commercial enterprise has on the domestic education system. Rather than exporting education, this “trade’ is in fact importing into New Zealand a whole set of educational issues and problems, most of which the document simply ignores.

The strongly commercial thrust of the document shows very little recognition of these educational issues. For anyone committed to the principle that New Zealand’s children should be the top priority of the New Zealand education system, this report makes chilling reading. Education is a social good for the community, it is not an industry. Furthermore, education is a process, not a product, a process which occurs within the context of a mainly state education infrastructure. New Zealand students are required by law to be in those schools, and the government has an obligation to resource the system adequately. It is the government’s failure to adequately resource the system which has driven schools to import students to supplement school incomes.

A further area which the document ignores is the potential for negative impacts on the education systems of the students’ countries of origin through our unfettered importation of their students. While NZPPTA is not familiar with any research in this area, we wonder whether countries which import foreign students are setting up competitive pressures on the systems these students come from. Research into such impacts needs to be done.

NZPPTA is also concerned that the commercialisation of education in New Zealand which is engendered by this “trade’ may expose our public education system to the effects of the General Agreement on Trade in Services (GATS).

The main reason for the discussion document is to seek views on the scale and use of the proposed Export Education Levy. This Levy and the Development Fund which it will support reflects the government’s wish to distance itself further from this “trade’ in education. It is NZPPTA’s contention that in fact the government should be taking a much greater interest in “export education’ because of its potential and real negative impacts on domestic education.



In section 3 this submission discusses research which is needed to establish the impact of the importation of foreign fee-paying students on domestic education. NZPPTA believes that researching and addressing this impact is a key strategic issue which needs to be prioritised before such issues as improving promotion or developing new markets. The “export education’ industry should not exist unless it is in a position to give an absolute assurance to the parents of New Zealand students that their children are not in any way disadvantaged by the industry.

The discussion document refers to managing risks such as those relating to capacity, yet on page 15 under “Capability Building’ there is no reference to the huge staffing problems facing secondary schools in New Zealand. The rapid rise in foreign students has greatly exacerbated this problem, with, for example, over 2,000 extra students appearing unexpectedly in Auckland at the beginning of this year causing shortfalls in Auckland and having a flow-on effect on supply in the rest of the country.

Furthermore, these staffing shortages are distorted by the foreign fee-paying student influx in two ways: firstly because, as the document acknowledges, foreign students are not evenly spread across the country, and secondly because foreign students in secondary schools are not evenly spread across the subject choices, and appear to place their greatest demands on the very subjects which are currently hardest to staff, such as Maths and Sciences and increasingly English. The minimal amounts of taxpayer funding which go into attempting to improve reticulation and supply, through staffing incentive allowances, teacher training scholarships and the like, can have their impact wiped out by this unfettered trade in foreign students.


NZPPTA asserts that government’s primary role is to protect the domestic education system from any negative impacts from the import of foreign students into New Zealand. They must ensure that education is adequately resourced and delivered to domestic students. The document implies that government’s priority is to ensure quality provision for foreign students, and while this is important, it is not the highest priority.

This is quite the wrong time for government to step away from involvement in the foreign students issue. If “providing the framework for the industry to operate within’ included research into and elimination of any negative impacts on domestic students and the exercise of controls on the quantum and distribution of foreign students, NZPPTA would be happier, but at the moment it appears that government is reluctant to impose any controls on this “trade’.


The discussion document raises on page 9 the idea of co-operation between institutions in order to distribute the benefits. The context in which this is raised is one which focuses on maximising benefits to the institutions, not on maximising benefits to the New Zealand education system. NZPPTA agrees entirely that “national co-operation can add ¡K value”, but the value we would wish to see added is to the national education system. This would imply work to even up the distribution of foreign students across all New Zealand schools, or where this was not possible, to find a way to redistribute the financial gains, such as through the levy (see below).

„« Promotion and Communication

NZPPTA does not believe that there should be a significant boost in promotional activities directed at the secondary sector until satisfactory supply of teachers to meet the needs can be guaranteed (see below). At the same time, we do not dispute the need for any promotion and marketing which is done to be factual and effective.

„« Industry Capacity Building

NZPPTA is amazed that there is no reference to staffing in the table on Capability Building. In the case of the secondary sector this is critical. In fact, the union’s statistics on secondary teacher recruitment and retention suggest that there must be no increase in international students in secondary schools between now and at least 2008 when the current “bulge’ is predicted to begin to pass. Continued increases of the scale which have been experienced in the last few years can simply not be sustained.

Unfortunately, because of the tendency of foreign students to choose schools in large urban areas, their impact on staffing is somewhat masked because they are going to areas which traditionally have had less difficulty recruiting staff than rural and provincial schools. Consequently the increased demand in Auckland was largely met in 2002, but at a cost to other areas.

NZPPTA warns, however, that shortages are becoming chronic in Auckland as well, with previously easily staffed schools reporting very reduced numbers of suitable applicants.

The uneven distribution geographically of students, and their tendency to select higher decile schools, raises serious equity issues. Schools are keen to participate in the trade because of the financial benefits it brings, but schools are not equally able to participate. The government’s priority should first be to ensure that all schools are adequately funded and staffed to deliver quality education to all New Zealand students. If no mechanism can be found to ensure that foreign students are evenly distributed between schools, then a mechanism should be found to redistribute the financial benefits between those schools which can attract them and those which cannot. This could be via the levy - see below.

NZPPTA supports, however, the need for Institutional and Professional Development and Resource and Information Dissemination. Schools range from those which have managed their international programmes well, managing to educate carefully controlled numbers of foreign students at no cost to their core work of educating domestic students, to those which in maximising the financial gains of foreign students have risked the education of domestic students. The distribution of examples of best practice would be useful. The need for professional development for teachers will be ongoing as long as the “trade’ lasts, because the teacher population is fluid.

Problems with the supply of quality TESOL/TEFL teachers are raised in the document at p.16, but mainly in relation to language schools. NZPPTA is aware that secondary schools are having trouble recruiting such teachers in sufficient numbers, and that the traditional source of such teachers, English specialists, is also drying up fast. In the Census of Providers of ESOL Programmes for International Students, 37% of schools reported difficulty in recruiting teachers with TESOL qualifications, and on average only about half of the ESOL staff in schools were TESOL qualified.

NZPPTA has concerns about the paragraph in the document at the bottom of p.17 which refers to work around curriculum-related issues. The implication here that the trade in education might influence the way curriculum is delivered in schools raises the spectre of “globalisation of curriculum’. Students who choose to study in New Zealand must be exposed to a curriculum which reflects New Zealand culture and values. Our sense of national identity must not be compromised in the interests of this trade.

„« Quality Assurance

NZPPTA has no difficulty with the idea that those foreign students who do study here are entitled to quality provision, as long as it is not at the expense of domestic students. In fact, we find it disturbing that the report acknowledges that there is very little hard data on whether foreign students receive a quality education here, or whether it produces for them academic results which are any better than they could have achieved at home. The suggestion that work be done in this area is a good one. It concerns us that schools could be vulnerable to court actions from foreign fee-paying students for failure to meet an implied contract to deliver quality education, particularly if future research were to indicate deficiencies.

NZPPTA policy, established back in 1997, is that the number of foreign fee-paying students in a school should not exceed 5% of the total student roll. This is to ensure that they are not present in classes in sufficient numbers to adversely affect the learning and teaching programmes. We note that in the recent Census of Providers of ESOL Programmes for International Students, 80% of schools indicated that their numbers were below 5%. This is good news, although this figure may be biased by the number of primary schools with very small numbers, and we would like to see a secondary school-specific figure on this. Even at 5% of the total roll, of course, given that most foreign students arrive in Year 13 or Year 12, this can still be considerably more than 5% of the average Year 13 class. NZPPTA believes that this percentage limit should be mandated by government. It would improve manageability in schools and improve reticulation of foreign students throughout the system.

NZPPTA also notes the suggestion that research be done to establish what subjects foreign students are choosing to study. This is essential as part of establishing the impact of this trade, because if, as we contend, they are tending to choose subjects for which New Zealand cannot supply enough teachers, then decisions need to be made about whether to continue to give them unfettered access to our secondary schools. It concerns the union that the reference to this in the report (p.20) is largely around eliciting information “on which to base planning, academic advising, and marketing”, not around capacity to provide the education they require while protecting delivery of education to domestic students.

The issue of whether schools are providing quality ESOL programmes is raised again in this section (p.21), and the report of the Census of Providers of ESOL Programmes for International Students also raises causes for concern. We agree with these concerns but extend our concerns to the full range of students who require ESOL programmes. Schools need advice as to best practice in setting up ESOL programmes that will meet the needs of both refugee and migrant students and foreign fee-paying students. This is not an area of settlement policy about which New Zealand can feel particularly proud compared with other countries which receive large numbers of migrants and refugees from different language backgrounds, and there is a need for review of the government support for such programmes and the ability of schools to provide good programmes. As an example, there has been concern for many years that the extra funding for NESB students ends after three years, despite evidence that NESB students usually suffer language deficits which adversely affect their achievement for many more years than that. While most such students would not choose to be in ESOL classes for more than three years, there are other forms of ongoing support which could be provided if the funding was there.

The section on p.21 headed “Internationalisation of education institutions’ worries NZPPTA immensely. Because of the context, we read it as being underpinned by a belief that it is a good thing for our educational institutions to be “internationalised’. There is no evidence given as to why this would be a benefit to our domestic students, nor to what is actually meant by the term. While the union does not disagree with the concept that New Zealand students should emerge as confident members of the international community, this confidence is first grounded in a clear sense of their identity as New Zealanders and as members of their particular communities. If “internationalisation’ of schools is at the expense of this, then we would oppose it vigorously.

„« Research

A significant omission from this list is any reference to research into the impact of the “trade in education’ on the education of New Zealanders. There is anecdotal evidence of teacher and student stress as a result of having large numbers of students from different language and cultural backgrounds in their classes, but there has not been any comprehensive study made of the educational impact at class and school level. NZPPTA believes that these stresses derive from an increased complexity in the duty of care which teachers have to their students in curriculum and pastoral care when their classes contain a significantly wider range of students. There needs to be research to provide the evidence for such examples of best practice as the ratio of domestic to foreign students which should not be exceeded before negative impacts are felt, and services which are needed so that foreign students can be included without negative impacts.

This submission has also made frequent reference to the need to obtain detailed information about the system’s capacity to provide sufficient teachers in the right subjects to ensure that the education of domestic students is not endangered by the importation of foreign students.

The union is concerned at the admission that there is only very limited information available on what international students think about the “product’ we provide. Such research is long overdue.


It does not make sense to comment on whether the programme is balanced without looking at the various budget allocations. When we do this, NZPPTA has to say that the programme is not balanced.

Research, quality assurance and capability are being allocated minimal amounts compared with promotion: in 2005, the last year in the budget, Promotion is budgeted at $1,879,000, compared with $696,000 for Capability, $524,000 for Quality Assurance and $101,000 for Research, in other words 29% more than all the other categories combined. If this is a reflection of the industry’s priorities, it worries us.


NZPPTA has no comment to make on the rate of the levy, but we support the idea that it will be paid by all institutions, not just state schools. This has been most unfair. The union would not support the use of the regulations to set the levy differently for different classes of provider, or certainly not differently within the school sector. A percentage amount of the fee received seems a fair way, fairer than the current flat rate system which applies to state schools.

The unpredictability of the quantum that will be generated will no doubt be a problem, but it mirrors one of the big concerns we have about the importation of students, the unpredictability of roll numbers and subject requirements caused by the patterns of enrolment of foreign students. Because of visa issues and different school years in their home countries, foreign students arrive in secondary schools over the whole year and constant adjustments to school timetables and class lists can result. Their expectations about gaining qualifications despite their late arrival can be quite unreasonable and may reflect inadequate information prior to coming. Furthermore, the “trade’ is very exposed to fluctuations in the economies of the countries from which students are recruited, as was seen, for example, when the Indonesian economy nose-dived. This makes it a very risky business for schools to rely on to fund quality delivery for their domestic students, but this is the reality when schools are under-resourced by government.

It may be that the levy needs to be higher so that it can serve the purpose described above, to redistribute the financial benefits of the trade between schools which can attract such students and those which cannot.


NZPPTA does not support the distancing from government responsibility that is implicit in Education New Zealand working under a purchase agreement arrangement. We wish to see the government taking a more “hands on’ role. It is also our contention that rather than further commercialising this “trade’, the government should be ensuring that policy development about the importation of foreign students is done in consultation with a wider range of groups which have a genuine interest in it, such as teacher, student and parent organisations and the tangata whenua.

We are happy to see a review of industry organisation, but would like to see its brief broadened to include consideration of the relative benefits and costs of the trade on the education of New Zealand young people.

There is a need to prioritise and strategise, and NZPPTA would like to be involved as a teachers’ union in that work. We also believe that there needs to be wider consultation with teachers and with the community to establish what their vision is for New Zealand as an importer of overseas students.


1. That until adequate secondary teacher supply can be guaranteed to meet the needs of domestic students, there be no further increase in the number of foreign students imported at secondary level.

2. That schools be allowed to enrol foreign students only up to a limit of 5% of their total student roll.

3. That mechanisms be found to ensure the equitable distribution of foreign students across New Zealand secondary schools.

4. That research be conducted urgently to establish the subject-specific demands imposed by foreign students on secondary schools, and the system’s ability to meet these demands for both domestic and foreign students.

5. That any funding generated by the Export Education Levy be redistributed equitably to state and integrated secondary and area schools.

6. That the review of industry organisation and governance to be conducted in 2003 identify a mechanism to involve a wider range of interest groups in policy development and monitoring.

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