Supplementary memorandum submitted by
the London School of Economics and Political Science (LSE)
Thank you for your letter requesting further
comments on the new points based immigration system.
The School has engaged fully in discussions between
the Home Office and UUK on the arrangements for Tier 4: so in
this submission we are confining ourselves to the main outstanding
points where we think input from the Select Committee might be
useful.
I have included, as an appendix to this letter,
the submissions regarding Tier 4 of PBS the School sent to the
Home Affairs Committee in July. My comments below fall into two
parts, firstly an update on this original submission and secondly
detailed comments on aspects of the employee Tiers 2 and 5.
TIER 4
I am pleased to be able to write that UKBA have,
in response to concerns raised by us and others in the HE sector,
amended several elements of the original Tier 4 proposal. In particular
we welcome the move to a phased implementation, development of
functionality to upload student data into the Sponsor Management
System (SMS), the system of attendance monitoring based around
points of contact and acceptance of the principle of multiple
CASs.
There is however one substantial outstanding issue
central to the operation of the Tier 4, which we originally raised
in our submission to the committee in June. This is the procedure
and timing of when a university vouches' for a student.
Along with other HEIs LSE had proposed a PBS
model whereby a CAS is generated (or validation occurs) only when
the student applies for a visa once he/she has finally decided
which HEI to attend. This validation model eliminates multiple
data entry, retains the student's freedom of choice, and is least
expensive for UKBA to develop and maintain (according to UKBA's
own IT developers); it is also the least expensive for universities
to resource. While LSE see the revised multiple CAS approach as
an improvement on the original proposal the failure to adopt the
validation model outlined above is a lost opportunity. I would
therefore ask the Committee to explore with UKBA the rationale
behind favouring the multiple CAS approach over the less expensive
more efficient validation route.
TIERS 4 AND
5
Academic Visitors
UKBA have created a new business visitor route
with an exceptional provision for up to 12 months leave. UKBA
has not clarified if academic visitors will be able to routinely
obtain up to 12 months leave or whether special cases will need
to be made for periods up to 12 months.
Annual Document Checks
It is a bureaucratic burden for the Sponsor to have
to do annual checks on those employees with visas ending after
the twelve month period.
Sponsored Researchers
UKBA want a third party to sponsor the migrants under
this category and wants their mobility to be linked to government
objectives. We would argue that universities should be allowed
to sponsor their own staff and that the link between government
objectives should be removed from their application. We believe
it would be more useful if sponsored researchers could submit
proposals on how they will spend their time in the UK as part
of their application.
This category of migrant can only apply for a certificate
for up to two years. This can create difficulties for universities
who have "named researchers" on grants who are required
to stay for longer than the two year period specified by the Home
Office.
Working Students
The School actively promotes work to its students
in order to help them financially.
UKBA need to give Sponsors clear guidelines on what
monitoring means, in particular under which tier the students
employment should be monitored.
15 October 2008
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