IHEA Letter to Minister Butler regarding capping OSHC commissions

Dear Minister Butler,
I am writing to you on behalf of Independent Higher Education Australia (IHEA), which is the peak body representing independent higher education providers.
We wanted to express our concern about the Australian Government’s proposal to cap commissions earned by providers and agents from Overseas Student Health Cover (OSHC) at 12 per cent from 1 July 2026.
We think there are a number of issues with this proposal, in particular, a lack of recognition of the important work providers and agents do to support students in obtaining OSHC, which is likely to be lost once the new arrangements take effect.
While we understand that there are some exemptions to the cap on commissions, they are limited to the following:
•Outsourcing of marketing activities by the insurer to a third party.
•A platform to provide OSHC product sales.
•Payments to an organisation to provide training and support to agents is considered as a form of outsourcing of services.
•Insurer staff located on campus to manage policy changes and claims processing where no payments were made to the university (please note that international students also attend non-university higher education providers).
•Payments to students and their families for traumatic events and repatriation when it is made directly to the organisation providing the service (e.g., funeral transportation) or reimbursement to the consumer for payments made. This is provided as part of the product.
•Health promotion and prevention events such as sexual health awareness, sun and swimming safety where payments are made directly to the organisation providing the service or the insurer reimbursing the university (please see above) for costs incurred (e.g., expert speaker).

Please see the full letter in the attached document.