Student Visas - Home Affairs Committee Contents

Written evidence submitted by INTO University Partnerships (SV27)


  • 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 industries—jeopardising 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 market.
  • 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 bodies.


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 recruitment—a 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 universities—and Highly Trusted Sponsor status for our centre in Manchester.
  • 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 University.
  • 50+ in-market staff monitoring and quality assuring the performance of sales agents.
  • University quality assurance of all academic matters.
  • 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.[12] 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 industry—an 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.[13]

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.[14] 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 alone—more than 7,000 student commencements in 2009/10 and 4,000 students progressed to partner universities.


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 study—something 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 year—and 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 rates—according 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 within Sub-Degree

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 element—which 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 systems.

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 special status.

5.3  Approximately 50% of pathway provision is operated by five organisations in partnership with Universities.[15]

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 SELT tests

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.[16] 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 markets—including 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 their visas

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 UK—at precisely the time that our major competitors in the United States, Canada, Ireland and elsewhere are making strenuous efforts to welcome students.

8.2  So long as students remain under the sponsorship of a Highly Trusted Sponsor—they ought to be able to renew their visa in the UK. There is often little time between courses—as 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 plus degree).

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 qualification—as this enhances their employability on their return to their home country.[17] 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

13   "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 - accessed 10 January 2011. Back

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15   INTO, Study Group, Kaplan International Colleges, Navitas and the Cambridge Education Group. Back

16   Table 1 and 2 of The Student Immigration System: A consultation - December 2010 identify high-risk missions and nationalities. Back

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Prepared 25 March 2011