Written evidence submitted by INTO University
- INTO University Partnerships is concerned that
changes to the Tier 4 component of the Points Based System could
do unintentional and irrevocable damage to one of the UK's most
successful export industriesjeopardising UK jobs and revenue
at a time when the country most needs them.
- International students are temporary migrants,
wealth generators and not resource consumers. With no recourse
to public funds and no settlement rights attached to their visa.
They bring £10 billion to the UK economy and our estimates
suggest up to 15,000 jobs are connected to their revenue.
- The figures used to justify the UKBA recommendations
lack statistical rigour and are based on an inappropriate methodology.
The real impact of students on our net migration figures ought
to be calculated on the basis of the volume of students coming
in minus those leaving from study in the UK combined with those
leaving to study.
- We support the use of the Highly Trusted Sponsor
programme as a mechanism to provide quality control to the Tier
4 system. It has been operational for less than one year and has
already been subject to major revision.
- There is a large and vibrant pathway sector at
NQF 3, 4 and 5 which should be classified as Pre Degree rather
than sub degree - and afforded the same visa privileges as NQF
6 higher education delivered by HTS.
- Secure English Language Tests are neither an
appropriate nor accurate discriminator of student intent to abuse.
We would recommend that HTS are afforded the autonomy to make
their own academic judgements on a student's suitability for study.
- Raising the English Language entry level to CEFR
B2 has the potential to deliver a fatal blow to the pathway element
of higher education.
- Students ought to be allowed to extend and renew
their visas in the UK under a Highly Trusted Sponsor without having
to return to their home country. Students on Student Visitor Visas
ought to be allowed to transfer to a Highly Trusted Sponsor in
the UK so long as they hold an unconditional offer.
- The removal of post study working privileges
will undermine the UK's competitiveness in the international student
- We endorse the UKBA's proposals to introduce
simpler procedures based on the level of risk a student or demographic
presents. In particular we would recommend the introduction of
stringent financial measures - including large deposits.
- INTO also supports the tightening up of accreditation
processes but believes standards should be applied evenly across
all education sectors and with the involvement of the accrediting
ABOUT INTO UNIVERSITY
1. INTO University Partnerships are 50/50 legally
binding long term joint ventures with leading internationally
focused universities. The joint ventures operate large-scale high
quality NQF Level 3, 4 and 5 level programmes to support university
international student recruitmenta core element of the
internationalisation strategy of partner universities. We have
welcomed and educated almost 21,000 students from more than 138
countries and territories to the UK and provide direct employment
for close to 1,000 people in the UK alone. Universities retain
control over quality standards and academic matters whereas INTO
delivers investment in overseas marketing infrastructure, investment
in facilities and oversight of day-to-day operational matters.
1.1 The INTO partnership model combines the best
of public and private sector skills to provide the highest levels
of quality assurance, delivers investment in world-class provision
and resources to manage international recruitment networks. It
has the following features:
- Full sponsorship of all students for PBS by partner
universitiesand Highly Trusted Sponsor status for our centre
- Students on programmes are students of the University.
- £250 million investment programme in infrastructure
to create world class international on campus centres - completed
at the University of East Anglia - Norwich and London, Queen's
University Belfast, the University of Exeter and underway at Newcastle
- 50+ in-market staff monitoring and quality assuring
the performance of sales agents.
- University quality assurance of all academic
- Highly developed student tracking systems to
monitor and respond to student attendance issues.
- According to HESA, our pathways were responsible
for 200%+ student growth between 2005 and 2008 entering the Universities
of East Anglia, Exeter, Newcastle alone.
INTO and our university partners fully support the
on-going review of immigration and visa policies to ensure that
economic and other forms of abuse are eliminated.
Appropriately targeted measures thoughtfully implemented can enhance
the current visa regime and contribute to significant reductions
in net migration without risking the viability of our international
education industryan industry that currently represents
the UK's 8th largest export business and supports approximately
150,000 jobs across the national economy. International higher
education related business is a major economic contributor in
many university towns and cities already struggling with the effects
of the recession. INTO does not support policies, aimed at reducing
net migration of high quality employment generating international
students, studying at Highly Trusted Sponsors. These students
have no recourse to public funds, no settlement rights and pose
a low risk of system abuse. There is little evidence of public
or even pressure group support for measures targeting reductions
of high quality international students.
2. The value of international students and
our operations to the UK economy
2.1 International students
bring approximately £10billion to the UK economy. At the
University of Exeter alone they are responsible for the injection
of £57.6 million into the wider economy and for 2,100 jobs.
A recent University of Strathclyde study estimates that for every
£1 million in HE revenue a further £1.38 million is
generated for the wider economy. As important, each job created
in the sector as a result of international student income creates
and supports a further 1.27 jobs in the wider economy.
2.2 UK education is widely
regarded as the UK's 8th largest export industry. Implementation
of measures which restrict this flow of the "brightest and
the best "into the UK will undermine the UK's economic recovery
and threatens much needed jobs and export revenue.
2.3 UUK estimate that upwards
of 40% of all international students in higher education have
come through a pathway programme such as those offered by our
own centres. Within the INTO network alonemore than 7,000
student commencements in 2009/10 and 4,000 students progressed
to partner universities.
THE UKBA CONSULTATION
3. Students and Net Migration
3.1 International students
are rarely economic migrants and certainly do not fall within
definitions of Long Term International Migrants. While we accept
that longer-term students have access to the NHS, they are employment
and wealth generating and not resource consuming. Immigration
policy should support economic recovery and wealth generation
and the country would be better served by a policy focus seeking
to control economic migration rather than net migration. This
policy focus on net migration is much wider than, and runs contrary
to, statements made within the Coalition Commitment of May 2010.
3.2 A more appropriate methodology
would be to calculate the total number of students entering the
UK for study and subtract those leaving or returning from studysomething
which at present can only be guessed at. This would more accurately
reflect the reality of the situation. International students generally
leave the UK to return home/take up careers and not to pursue
further studies. It is our view and widely accepted, that the
current statistical methodology distorts dramatically the impact
of students on net migration.
3.3 The data used to support
the assertions made in the consultation document draws from conflicting
data sets. UKBA estimates of student impact on net migration figures
need to be justified by making unscientific assumptions where
data is missing. Migration experts themselves express little confidence
in the data and especially the International Passenger Survey.
We support therefore, measures aimed at enabling the UKBA to record
and report accurate figures that would better inform policy formulation
by reflecting the true position.
4. The Highly Trusted Sponsor SchemeA
quality control and abuse monitoring mechanism already in place
4.1 We broadly support the
robust implementation of the HTS scheme as the key mechanism for
controlling the quality of students coming into the UK to study
without risking the viability of an export industry worth up to
£10billion to the UK economy.
The Scheme has been operational for less than a yearand
has already been reviewed and revised on three occasions. It has
already resulted in the removal of 2,000 colleges from the Register
of Sponsors. The Sponsor Management System introduced in March
2010 enables much greater levels of control and the HTS (especially
at University levels) operates at less than 2% non compliance
ratesaccording to the UKBA's own research. We believe it
should have a full operational cycle before we review and implement
yet more changes to an over-stretched and under resourced UKBA.
5. Pre-Degreesa discrete category
5.1 Universities UK identify
that 40% of international students enter higher education via
a pathway programme. This is a strategically vital pipeline to
our universities. It is critical that we protect this if the country
is to maintain its position as a world leader in attracting the
brightest and the best. Within the NQF 3, 4 and 5 sub-degree category,
there is a large, vibrant and strategically vital pre-degree pathway
elementwhich could more appropriately be defined within
a higher education framework.
5.2 The UK operates a 13-year
schooling system, which contrasts with the more widely adopted
American model of 12 years. This together with the requirement
to improve language competence creates a need for pre degree pathway
courses that facilitate the transfer of students between the different
UUK estimates 46% of all international students in
higher education have come through a pathway. other estimates
put this figure as high as 70%. Pathway operations are the largest
single source of international students to the UK university sector
and high quality officially designated programmes need to be afforded
5.3 Approximately 50% of
pathway provision is operated by five organisations in partnership
Defining pre-degree pathway courses
5.4 A course of pre university study up to 18
months duration, (but only 11 months if on a Student Visitor Visa),
including English and other academic study, either formally validated
or otherwise officially recognised by a partner university, which,
on successful completion and attainment of prescribed grades,
provides a student assured progression to a specific university
course at the 'recognising or validating' partner institution.
6. English Languag The use of
6.1 The evidence on visa abuse and the submission
of fraudulent documentation outlined in the consultation document
demonstrates clearly that English Language competence is not a
reliable indicator of students' intentions.
SELT should not be compulsory for HTS and there is little rational
justification for its introduction elsewhere either. We understand
the Government is committed to reducing unnecessary bureaucracy
and wishes to preserve the academic independence and autonomy
of our universities.
The current availability of SELT is restricted in
key marketsincluding China and India. If blanket SELT is
introduced, our direct experience from key source markets is that
it will need to be accompanied by a commensurate increase in availability
of SELT testing and a wider range of acceptable tests.
A SELT may not only be inappropriate but its implementation
could distort unhelpfully the focus of pathway and pre-sessional
courses delivered in the UK. They will become test-prep activities
rather than courses preparing students for university study.
7. Raising the English Language entry level
to B2 on the Common European Framework
7.1 The UKBA proposal to
raise the entry level to CEFR B2 would have a disastrous effect
on the pathway industry and concomitant impact on jobs and downstream
revenue for our universities. We estimate that up to 70% of our
current students would have been denied access under new proposals.
Further, given that IELTS is not even benchmarked
against the CEFR. We do not understand how the UKBA believe this
can be achieved
8. Requiring student to return home to renew/extend
8.1 The obligation to return
home, while engineering an artificial drop in net migration figures,
will be a competitive disadvantage for the UK and deter many students
from commencing and continuing their studies in the UKat
precisely the time that our major competitors in the United States,
Canada, Ireland and elsewhere are making strenuous efforts to
8.2 So long as students remain
under the sponsorship of a Highly Trusted Sponsorthey ought
to be able to renew their visa in the UK. There is often little
time between coursesas little as four weeks. It would be
impractical and unnecessarily expensive.
8.3 We would further recommend
that students on 11 month Student Visitor Visas should also be
allowed to transfer to Tier 4 within the UK - so long as they
remain under the sponsorship of an HTS.
8.4 As is the case in Australia,
we recommend that students on Pre-Degree pathway programmes are
awarded a visa for the duration of their study plan (eg Foundation
9. Working in the UK and post-study work privileges
9.1 Our own research clearly
indicates that international students choose the UK as much for
the experience as for the international qualificationas
this enhances their employability on their return to their home
Further surveys of employers conducted by AGCAS et al regularly
identify the value of international experience as well as internationally
recognised qualifications among their graduate hires.
9.2 Competitor countries
all offer this option to studentsVthe removal of this asset to
international students will have a negligible impact on job displacement
but will deliver a major blow to the attractiveness of the UK
as a premier overseas study destination.
Restrictions to working in the UK while studying
were introduced in March 2010. We see no need to introduce further
restriction. In particular the suggestion restrict students to
on-campus working strikes us as unenforceable.
10. Introducing differential processes according
to risk level
10.1 We support the introduction
of differential mechanisms based on the level of risk a student
or particular nationality presents. In particular we would favour
the use of financial mechanisms such as the introduction of full
advance fee payment obligations, large pre-visa course deposits
or surety bonds recoverable on departure.
10.2 We would also support,
as we have stated elsewhere in this submission, the use of the
Highly Trusted Sponsor mechanism to control and monitor abuse.
In order for this to work most effectively, HTS should also be
provided with visa usage data allowing them to work constructively
with the UKBA in supporting the elimination of abuse.
11. Raising accreditation standards
We support more robust accreditation standards. However,
instances of poor practice are by no means limited to the private
sector. Compliance standards and sanctions should be applied evenly
throughout the sector.
12 INTO university partners: City University London,
The University of East Anglia, The University of Exeter, Glasgow
Caledonian University, The University of Manchester, Newcastle
University, Queen's University, Belfast. INTO also runs pathway
programmes on behalf of the Northern Consortium group of 11 universities. Back
"The number of non-EU students given leave to enter the
UK in 2009 was 274,000 This is a huge number but it is important
to realise that genuine students are not an immigration problem;
most return at the end of their courses (to be replaced by others)."
Source www.migrationwatch.org - accessed 10 January 2011. Back
INTO, Study Group, Kaplan International Colleges, Navitas and
the Cambridge Education Group. Back
Table 1 and 2 of The Student Immigration System: A consultation
- December 2010 identify high-risk missions and nationalities. Back