New Zealand Qualifications Authority (NZQA) staff have serious misgivings about the English language testing some tertiary institutions are carrying out on prospective foreign students.
Only the most trusted institutions are allowed to conduct their own English tests and only for students coming from countries where fewer than 20 percent of student visa applications are declined.
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In May the authority proposed tightening the rules but an internal memo shows just two months earlier its staff wanted to ban the practice altogether.
The memo obtained under the Official Information Act shows NZQA staff agreed internal testing was an ongoing concern.
"It was agreed that internal testing presents a high quality assurance risk, which potentially outweighs the benefits. All attendees were in favour of removing internal testing altogether."
It said some institutions were not administering tests in the manner they were supposed to and some were asking their overseas agents to do the testing.
The memo said it was difficult for NZQA to monitor the administration and genuineness of tests, noting a case in 2016 where tutors at a private institution said they had completed English tests for their students.
It also indicated internal testing could be used to increase student enrolments from countries such as China, where there was not currently a problem with high visa application failure rates.
"Potential for this type of testing to be increasingly used as a marketing tool in markets that currently have high visa approval rates, such as China.
"TEOs [tertiary education organisations] may turn to these markets to fill the void left by the drop in Indian students."
The authority later told RNZ sector feedback had been that "internal testing is used as a marketing tool by New Zealand Tertiary Education Organisations as they can provide an alternative English language proficiency test at a lower cost than an overseas equivalent and within faster timeframes".
The authority has jurisdiction over non-university tertiary institutions such as polytechnics, wananga and private institutions. Those in NZQA's top-quality 'category 1' can do their own testing, while those in category 2 must get NZQA permission.
The authority proposed requiring institutions in category 1 to also get permission for their testing to ensure they were using an appropriate method.
It said 13 category-2 institutions had clearance to do their own English testing, but did not have figures on the number of category-1 educators that ran their own English tests.
It said it had refused some category-2 applications for the right to test students for reasons including: "lack of expertise in English language delivery and assessment, assessment materials not meeting the standard, lack of benchmarking against an internationally-recognised test, and lack of safeguards ensuring security of the tests and testing environment".
The authority said it did not propose banning internal English language testing "at this stage" as it considered the proposed changes "to be appropriate in the current context".