Student Visas - Home Affairs Committee Contents


Written evidence submitted by the London School of Business and Finance (SV22)

EXECUTIVE SUMMARY

The London School of Business and Finance (LSBF) is pleased to assist the Home Affairs Committee in its inquiry. In this submission, we make the following points:

Now is the time to introduce a single regulatory body governing both public and private educational institutions, focusing on establishing and maintaining high academic, administrative and regulatory standards. The new higher education funding environment has significantly reduced real differences between public and private organisations, and a new holistic, unifying regulatory regime could bring consistent standards across the entire educational system. In terms of student visa issues, the new system would facilitate cooperative, effective, efficient relationships between the sponsors and the authorities.

  • The government's proposed changes to the student visa system could have significant adverse implications for the British higher education industry and UK plc more generally. We believe that an economic impact assessment must be conducted before proceeding.
  • The government needs to stay focused on the fact that the problem is the abuse of the existing visa system. The system itself is not necessarily the problem; what we need is smart enforcement of it across all routes, with the UKBA being given proper resources.
  • The Minister for Higher Education Rt Hon David Willetts MP has called for an open market in higher education, without prejudice to whether the institution is public or for-profit. The proposals put forward by the UKBA, however, would make the market less open. Indeed, while the Department for Business, Innovation and Skills wishes to encourage a flourishing private sector, these proposals serve as a massive disincentive for growth.
  • Every effort should be made to ensure that the UK higher education system attracts the world's 'brightest and best'. The consultation paper published by the UKBA seems to assume that those individuals coming to the UK for sub-degree courses are not the "rightest and best" However, the "rightest and best"must start somewhere. Albert Einstein was once a patents office clerk. They should be positively incentivised to come to the UK system early in their academic careers, before they opt to pursue studies and then remain elsewhere.
  • UK plc needs access to the best talent; but closing down the Post Study Work route pushes that talent away. For the brightest and best, the world is their classroom and their office. If they do not see employment prospects in the UK, they may opt to study in other, very grateful, countries.

INTRODUCTION

1.  The London School of Business and Finance (LSBF) is a privately financed, global leader in high performance learning solutions. We are the fastest-growing business school in Europe, with 16,000 students and over 20 offices worldwide. Students come from over 150 countries to study in Manchester, Birmingham, and London. About 80% of our students come from abroad, mostly from non-EU countries.

LSBF programmes

2.  LSBF is a market leader in developing learning solutions that meet the needs of students and employers. LSBF takes a problem-solving approach to education, identifying skills shortages and gaps in the market and developing the most up-to-date and relevant courses for students and trainees. We provide a unique bridge between the formal education system and the ever-changing financial industry, working with three of the 'Big Four' accountancy firms and some of the world's top 10 banks to develop bespoke training solutions. LSBF's educational programmes range from professional qualifications to undergraduate and postgraduate degrees.[7]

3.  In October 2010 we launched the groundbreaking LSBF Global MBA™, which gives people anywhere in the world access to high-quality academic material at no cost, via a Facebook portal.

Highly Trusted Sponsor status

4.  LSBF has been awarded Highly Trusted Sponsor (HTS) status by the UKBA, and therefore we would be less affected by the UKBA's proposed changes than would many other private providers. Indeed, the increased importance that the proposals would place on having HTS status would actually work to our competitive advantage. Nonetheless, we feel it important to highlight the significant negative impacts the proposals could have on the British educational system and indeed all of UK plc.

The student visa system

5.  We urge the government to stay focused on the fact that the problem is the abuse of the existing visa system. What we in the UK need is smart enforcement across all routes, with the UKBA being given proper resources.

6.  The government's proposed changes to the student visa system could have significant adverse implications for the British higher education industry and UK plc more generally. We believe that an economic impact assessment must be conducted before proceeding.

POTENTIAL IMPACT OF THE GOVERNMENT'S PROPOSALS

Impact on the British educational brand

7.  The UKBA's main focus is on reducing net migration. However, to pursue that by reducing the numbers of student visas may affect perceptions of the entire UK educational sector.

8.  It is well known that the UK's educational brand is among the most respected in the world. According to the Times Higher Education World University Rankings, the UK is home to five of the top ten universities in Europe, and three of the top ten universities globally.[8]

9.  However, the message being sent out by the government's proposals is that it does not see the value that many foreign students bring, and this message harms the reputation of the British brand generally. The "brightest and best" will increasingly choose to pursue their studies in more welcoming countries, such as Canada or the US. Ireland, for example, has set itself a goal of increasing the number of foreign students by 50% in the short term, recognising that the country will see a return on its investment in becoming an international centre of educational excellence.

10.  The UK should consider the experience of Australia, whose $17 billion education sector is experiencing a crisis resulting from a number of developments, including stricter immigration controls (for financial and English-capability standards). Enrolments of Chinese students, worth about $5 billion to the Australian economy, are down 10-20%.[9]

11.  Throughout the business world, the UK accountancy and other professional qualifications are well respected. One can commence the qualification in the UK and complete it anywhere in the world. But if immigration rules make it more difficult for individuals to conduct at least part of their coursework in the UK, it may damage the excellent reputation that British accountancy and other professional qualifications currently have.

Quality of the British education experience

12.  Foreign students make a huge contribution to the quality of higher education in the UK. They bring different perspectives and innovative approaches. They bring energy and passion for learning that is often lacking within the British institutions, thereby introducing healthy academic competition. They bring diversity, and help ensure that the British system does not regress into a white, middle-class, Anglo-Saxon model. Therefore, reducing the number of foreign students would make the UK education sector less vibrant and competitive.

Impact on public services

13.  One of the overarching rationales for the government's commitment to reduce net migration to the tens of thousands is based on the need to ensure that public services are not over-stretched. Indeed, some pressure groups have been vociferous in sounding alarms about the cost of migration to state-provided services. However, the consultation paper does not present any evidence that foreign students who enter and remain in the country legally have a negative net impact on public services. The points-based system's requirement for students to have adequate funds for maintenance is designed to minimise any negative impact on public services, and this requirement needs to be enforced. LSBF's students are predominantly young and healthy, making significant investment in the communities where they work through rent and living costs.

Impact on UK plc

14.  Higher education is one of the UK's most highly respected industries; any negative impact on it will have drawbacks for all of UK plc. Business education institutions, in particular, serve as seedbeds for entrepreneurship and innovation, and by providing essential skills to the working population they are engines for economic growth. Changes to the student visa system must consider broader economic impact.

15.  We are surprised that no economic impact assessment has been conducted on the UKBA's current proposals.

16.  Foreign students educated in the UK go back to their country of origin familiar not only with our culture and our system but also UK brands. These transnational relationships not only boost trade and enterprise opportunities for British companies, but also serve to solidify diplomatic relations.

KEY ISSUES RAISED BY THE GOVERNMENT'S PROPOSALS

Differential treatment of private providers

17.  Based on "indicative" figures, the government has suggested that most abuses of the student visa system take place with private sector institutions, and accordingly, the proposed guidelines would impose greater restrictions on all private providers. Notwithstanding the greater freedoms granted for those private institutions with Highly Trusted Sponsor status, there is still a differential treatment that effectively tars all private providers with the same brush.

18.  The government needs to stay focused on the fact that the problem is the abuse of the existing visa system. The system itself is not necessarily the problem; what we need is smart enforcement of it across all routes, with the UKBA being given proper resources.

19.  LSBF does have Highly Trusted Sponsor status. And as such, the proposed policy would allow it to continue to offer most courses as it does currently. However, the principle that private providers can be treated differently from publicly-funded ones is troublesome. Essentially, the government's proposals would require many private schools to gain Highly Trusted Sponsor status—a very burdensome administrative process—or go out of business.

20.  As David Willetts MP said in his speech on 9 September 2010, "The acid test for HE providers is whether they offer excellent teaching and a high-quality experience for students. If they can do that, at a fair price, then it doesn't matter whether they are old universities or new ones; for profit or not for profit. They have something to contribute and should have the chance to do so. That is the case for a more open market."

21.  The proposals put forward by the UKBA, however, would make the market less open. Indeed, while the Department for Business, Innovation and Skills wishes to encourage a flourishing private sector—expanding more into areas such as under-graduate degrees—these proposals serve as a massive disincentive for growth.

22.  Accordingly, LSBF offers this solution:

  • (a)  Now is the time to introduce a single regulatory body governing both public and private institutions, focusing on establishing and maintaining high academic standards. The new higher education funding environment has significantly reduced real differences between public and private organisations, so the previous rationale for maintaining two different regulatory schemes is no longer valid.
  • (b)  But the current situation with regard to student visas demonstrates that there is a need to hold all academic institutions to the same high standards. A valuable paper by Universities UK[10] notes that there is already substantial agreement by publicly funded universities as well as private institutions around convergence of the existing regulatory schemes. This entails improving the sharing of information across regulators, regular consultation between government and the private sector, conducting a strategic overview of developments, and monitoring of national and international trends.

Impact on Innovation

23.  Driven by the competitive need to meet the needs of students and their future employers, indeed in order to stay afloat, private institutions must innovate and respond rapidly to changing economic circumstances.

24.  There is a symbiosis and cross-fertilisation between public and private education providers, with private schools creating innovative learning solutions and complementary course offerings. For example, private providers have worked with the public institutions in developing sub-degree courses that help prepare British students for University. These courses, generally at the NQF 5 level, are offered mainly in essential fields such as mathematics, business, engineering and nursing. They are an essential bridge for many young people to reach university. And yet if private providers are not able to offer them to the foreign student market, the courses would not be financially viable for British students.

Limits on courses for which Tier 4 visas are available

25.  In its attempt to restrict Tier 4 visas to the "brightest and best", the UKBA recommends raising the level of courses Tier 4 students can study, placing restrictions on sub-degree level study for those who do not have Highly Trusted Sponsor status. There are numerous issues with this.

26.  The professional qualifications offered by LSBF and other private schools map to a wide range of NQF levels. Many students come in at an NQF level below the threshold permitted for non-HTS schools but subsequently advance. Would the proposals mean that students could pursue the sub-degree courses if they booked a course of study taking them through NQF 5 (eg, papers 1-8 of ACCA)?

27.  The consultation paper published by the UKBA seems to assume that those individuals coming to the UK for sub-degree courses are not the "brightest and best". There is no data (in fact, no logic) to support this. The brightest and best must progress through the various levels of study, just like anyone. They, too, take sub-degree courses. Should we not make a special effort to attract the 'brightest and best' specifically at the sub-degree level, and encourage them to remain through the duration of their studies?

28.  There is no mention of the need to positively incentivise bringing the 'brightest and best' to the UK. The way to do this is not to impose restrictions, but to continue to build the attractiveness of the UK educational system so that it competes effectively for those individuals it wishes to attract. Indeed, Canada, New Zealand and the United States are already picking off Australia's market share with their strong incentives.[11]

Post Study Work Route

29.  There are numerous problems entailed in restricting (not to mention eliminating) the Post Study Work Route (PSWR). Eliminating the PSWR tells potential employers that they will not have access to the best talent coming through our schools. UK plc needs access to the best talent; but closing down the PSWR pushes that talent away.

30.  For the 'brightest and best', the world is their classroom and their office. They choose where they pursue their education based on a holistic assessment, taking into consideration (a) the quality of the educational programme itself, (b) the benefits of being in the particular location, and (c) prospects for employment. By damaging this last criterion, the balance is significantly tipped towards other, very grateful, countries.

31.  The UKBA paper considers whether an exception may be made for those obtaining PhDs in UK schools. If so, an exception should be made for other terminal degrees, such as the MBA.

32.  More analysis of the potential effects of eliminating the PSWR should be done to evaluate these potential effects.

CONCLUSION

33.  LSBF would be keen to discuss the points we have made in our submission further with the committee.

34.  Our recommendation for the creation of a single regulatory regime across private and public sector educational institutions goes beyond the topic of student visas (and therefore the committee's scope of inquiry), but the challenges of immigration policy are broad and cover the full gamut of government policy.

35.  We recommend that the Home Affairs Committee work alongside its other colleagues in Parliament—such as the select committees on Education, Foreign Affairs, and Business—to take a cross-departmental approach.

January 2011



7   More information about LSBF's programmes is available at www.lsbf.org.uk/ Back

8   www.timeshighereducation.co.uk/world-university-rankings/2010-2011/europe.html

www.timeshighereducation.co.uk/world-university-rankings/2010-2011/top-200.html Back

9   Sainsbury, Michael, 'Decline in China numbers to Persist', The Australian, 15.12.10. Back

10   www.universitiesuk.ac.uk/Publications/Pages/Privateandforprofitproviders.aspx Back

11   "Indian students ditching Australian education plans", Hodge, Amanda, The Australian, 29.11.10. Back


 
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Prepared 25 March 2011