Part 4: The quality management system is designed to support improvement

4.1
In this Part, we look at the effectiveness of Immigration New Zealand's quality management system for skilled residence visa decisions. The "quality management system" includes processes for quality control (which takes place before a decision is communicated to an applicant) and quality assurance (which takes place on samples of applications after decisions have been made).

4.2
We discuss:

• how the quality control process focuses on individual applications;
• how reporting from the quality assurance process supports learning and development;
• the vulnerability of the quality management system to pressures elsewhere in the immigration system;
• the need for Immigration New Zealand to clarify the role of the Risk and Verification Team; and
• the commitment Immigration New Zealand shows to managing quality in a difficult working environment.

4.3
We expected to see that the quality management system was working to promote fairness and consistency, so applicants could have confidence in Immigration New Zealand's ability to achieve its aim of making quality decisions quickly.

Summary of findings

4.4
We found that frontline staff take pride in their roles and their responsibilities as decision-makers, understand the limits of their delegated authority, and want to do the best that they can for applicants and for New Zealand.

4.5
This is in keeping with MBIE's Promise (see paragraph 2.15), specifically that people interacting with MBIE should feel "Safe – Haumaru: We help keep people safe through consistent application of the law."

4.6
Quality control and quality assurance are clearly defined processes that work together to support improvement and staff development. There are clear roles and responsibilities for quality management, and the staff who have these responsibilities are experienced and committed to continuous improvement.

4.7
However, staffing pressures and the pressure to work quickly create risks to the quality management system. Immigration New Zealand needs to carefully manage these risks.

Quality control focuses on individual applications

4.8
Immigration New Zealand staff carry out quality control for every application for a skilled residence visa before the final decision is communicated to the applicant. In our view, this appropriately reflects the complexity and unique nature of each application.

4.9
Technical Advisers based in application processing teams carry out quality control. Technical Advisers check and score applications against four quality domains, using a set of questions specific to the type of visa being processed. They look at how well the Immigration Officer processing the application:

• complied with immigration instructions;
• identified and mitigated risks;
• followed processes, including those for communicating with applicants; and
• wrote the decision rationale (the Immigration Officer's reasoned explanation of their decision).

4.10
Figure 5 sets out the domains that Technical Advisers assess the quality of a decision against.

Figure 5
Domains that the quality of a decision are assessed against

* Applicants for residence visas are given an opportunity to comment before a decision is made to decline a visa because of any potentially prejudicial information, which the applicant might not necessarily be aware of. The Technical Adviser checks whether communication with an applicant about potentially prejudicial information should have been and was carried out and whether the Immigration Officer followed the correct procedures.

** If an applicant for a visa has not met the requirements of the relevant immigration instructions (the criteria that visa applicants must meet), an Immigration Officer may grant an exception to instructions in certain instances. The Technical Adviser checks whether the Immigration Officer followed the appropriate process.

*** The assessment process requires that Immigration Officers or Technical Advisers have identified and outlined any risks associated with an application. This process includes checking whether any alerts or warnings have been appropriately assessed during the decision-making process.

Reporting from the quality assurance process supports learning and improvement

4.11
Quality assurance complements quality control. It is a separate process from quality control and assesses quality retrospectively, using samples of decisions made in the previous three months. Immigration New Zealand told us that quality assurance is completed on random samples of decisions. The quality assurance process is designed to monitor trends in the quality of application processing and alert management to any issues.

4.12
Quality assurance uses the same four domains as quality control, but it has a separate set of questions. A team of staff carries out the quality assurance process for all the processing branches. Senior staff in Immigration New Zealand receive detailed reports from the quality assurance process.

4.13
We saw evidence that Immigration New Zealand is using information from the quality assurance process to support continuous improvement. Analysis of quality assessments for the Skilled Migrant Category Resident Visa showed the reasoning for the visa decision (the rationale domain) scored the lowest of the four domains from April to June 2023, although it had been improving over the year.³⁴ Staff managing the day-to-day quality of decision-making in the Manukau office told us that this was a current focus for improvement.

4.14
Although the quality assurance process usually works on decisions from the previous three months, it can be adjusted when new visas are introduced.

4.15
We carried out our fieldwork during the early stages of the new Skilled Migrant Category Resident Visa. At this time, staff in the quality assurance teams were carrying out checks of the new visa category known as "fast follows". These were designed to give timely advice and guidance to staff processing the new visas.

4.16
In our view, the quality control and quality assurance processes, taken together, support improvement and staff development well.

4.17
They apply consistently to processing applications for all visas, but also support analysis by visa type. This means that information about processing performance, including performance over time, can be compared specifically by visa type.

4.18
Managers can also use the detailed information about what is working well and what is working less well to support day-to-day improvement in processing teams.

4.19
Staff are also encouraged to use information from the quality management system to improve their decision-making. For example, they hold "quality circles" in their processing teams to share lessons from the quality management system.

Quality control is vulnerable to pressures elsewhere in the immigration system

4.20
The current quality control process for the skilled residence visa system is well suited to working with the individual nature of every application and decision. It takes account of each applicant's circumstances and the wide range of evidence they must provide to support their application.

4.21
However, checking every application before communicating the decision (100% checking for quality control) is resource intensive and time-consuming.

4.22
Making decisions about individual applications is complex. We heard that, at times, there can be pressure to process decisions more quickly or redeploy staff to other work priorities at short notice. Immigration New Zealand needs to carefully manage the risk to the quality control process that the pressure to work quickly can create.

4.23
When Immigration New Zealand introduced the Green List Tier 1 Straight to Residence Visas in 2022, it decided to do more targeted quality control checking for these visas (that is, it decided to check fewer than 100% of applications).

4.24
Because Green List Tier 1 Straight to Residence Visas were intended for highly skilled migrants in hard-to-fill occupations of importance to the country, Immigration New Zealand was expected to process this type of visa quickly.

4.25
Immigration New Zealand decided that it could apply a high-trust approach to occupations where a professional body required registration or certification.

4.26
When Immigration New Zealand decided to do quality control checks on only a sample of an Immigration Officer's applications, some staff expressed concern that this could be a risk to quality. Immigration New Zealand was not able to easily produce a random sample of applications, which meant that it was possible for an Immigration Officer to select decisions to put forward for checks.

4.27
To mitigate this risk, Immigration New Zealand agreed that it would move to sampling only after an Immigration Officer had achieved an acceptable quality assessment on nine out of 10 of their previous decisions. From then on, only two quality assessments of that officer's decisions would be conducted each month. However, all decisions to decline an application would still be quality checked before the final decision was communicated.

4.28
In contrast, Immigration New Zealand decided to do quality checks on 100% of applications when it developed the quality control system for the new Skilled Migrant Category and Work to Residence Visas in 2023. Immigration New Zealand considered that it was appropriate to treat quality checks differently for these categories of visas because they did not have the same skills requirements of the Straight to Residence Visa.

4.29
In March 2024, Immigration New Zealand changed its approach and also started carrying out quality checks of all applications for the Green List Tier 1 Straight to Residence Visa. Immigration New Zealand told us it did this because changes to the Green List had increased the complexity of some applications.

4.30
We encourage Immigration New Zealand to continue to take this risk-based, case-by-case approach to decision-making when it is deciding how to manage quality risk for new visa types. It is important that any decision to move away from carrying out quality control checks for 100% of applications balances speed against the complexity of the decision-making process for a particular visa type.

4.31
For the current quality control process to work well, Immigration New Zealand needs to get this balance right each time it considers a change.

Immigration New Zealand needs to clarify the role of the Risk and Verification Team in the decision-making process

4.32
Immigration Officers follow specified triage processes to help them assess whether they need to seek advice from a separate Risk and Verification Team. The Risk and Verification Team is not part of the team that processes visas and manages quality control. It assists the decision-making process for visa applications by providing advice and guidance on issues that might present an immigration risk.

4.33
Immigration risk includes a wide category of concerns. It ranges from risks to security, such as false identities and fraudulent documentation, to the risk that migrants will be exploited in their workplaces. If the initial checking of an application indicates that any of these risks might be present, staff in the Risk and Verification Team provide Immigration Officers with advice on how to address these risks.

4.34
However, staff in the Risk and Verification Team told us they sometimes feel "out of the loop". They cannot easily see how Immigration Officers apply their advice in practice, nor is there a way for them to learn how to improve their advice to make it more useful.

4.35
These staff felt that involving them in the decision-making process more systematically would help them to be more proactive in offering advice.

4.36
Staff in the Risk and Verification Team working on some temporary visa categories carry out risk monitoring reviews to assess completed applications. These reviews report on whether Immigration Officers appropriately mitigated risk during the decision-making process. The reviews are not targeted at individual officers. They are designed to help increase understanding about how to improve practice in general.

4.37
The lessons learned from these reviews also help staff in the Risk and Verification Team to understand how Immigration Officers receive and use their advice.

4.38
In our view, there is an opportunity for Immigration New Zealand to build risk monitoring reviews into its assurance processes for skilled residence visas in the same way that they are already used for other visa types.

Staff showed commitment to managing the quality of decision-making in a challenging working environment

4.39
As part of understanding Immigration New Zealand's quality management system, we wanted to understand what challenges staff face in managing quality day to day. We also wanted to know whether Immigration New Zealand is managing these challenges effectively.

4.40
Staff talked to us about the specific challenges of working on applications for skilled residence visas. These included the pace of recent policy changes, the responsibility involved in making a decision because of all that it implies for an applicant's future, and the attention to detail that is needed to do the work well.

4.41
Some managers described themselves as "the meat in the sandwich" or the "tectonic plate", taking the strain of pressure to manage change and still make good decisions quickly. We also heard about change fatigue and the additional pressures of recruiting and retaining staff in what was, when we carried out our fieldwork, a competitive local job market.

4.42
Recruitment and retention issues present challenges for managing the quality of skilled residence processing because staff need experience to take on specialist roles, such as Practice Lead or Technical Adviser. Both these types of roles are best filled by people with previous processing experience who are well placed to advise others on best practice.

4.43
Despite these pressures, we heard that staff at all levels are working hard to manage change and support each other. People talked about their loyalty to careers at Immigration New Zealand, the close relationships they have with people in their teams, and the support that they provide each other with.

4.44
We also heard that Immigration New Zealand provides tools and training to help staff with their work and that these are well regarded. These tools and training include:

• templates for assessing an application for a visa;
• standard operating practices for the process's key steps;
• desktop guides for verifying overseas documents, with examples and recommended websites to consult; and
• a classroom-based training programme for new Immigration Officers that combines theory with desk-based exercises.

4.45
In 2023, Immigration New Zealand introduced new senior leadership roles with responsibility for leading application processing operations in the processing offices, under the operational direction of the Chief Operating Officer of Immigration New Zealand.

4.46
Two Operations Director roles are based in New Zealand, and their responsibilities are split between the Northern/Pacific and Central/South regions. We were told that these leadership positions are responsible for working with staff to build a culture of continuous improvement in visa operations and for implementing new ways of working, including better connecting the Senior Leadership Team with frontline staff.

4.47
These roles were new when we carried out our audit. We consider that, as these roles develop, they could increase the understanding of senior managers of the specific challenges facing staff working on skilled residence visas.

4.48
These new roles will be particularly useful for improving Immigration New Zealand's use of staff feedback (see paragraphs 3.103-3.106). The roles should also help in developing operational policy, including managing the quality of decision-making.

34: The rationale domain of the quality assessment looks at whether the reasons for the decision were well written, accurate, logical, and complete. A low score does not necessarily mean that a decision was incorrect.