Supplementary memorandum submitted by
Universities UK
Thank you for the opportunity to give evidence
to the Home Affairs Committee inquiry on "Managing Migration:
the Points-Based System" on Tuesday 3 March 2009. You kindly
invited us to send you any further comments and you also asked
for some specific information on issues raised during the evidence
session. Please find below some further comments and the specific
information requested by the Committee accompanies this letter.
This reply comes from Universities UK, but a draft has been shared
with Simeon Underwood, Academic Registrar at LSE; and he has contributed
to its content.
SPONSOR MANAGEMENT
SYSTEM
In reply to a question about the new Sponsor
Management System, we expressed nervousness about whether it would
work to the level of delivery required. As this is a crucial and
major concern to us, we thought we should amplify our comments.
There have been significant problems with the use
of the Sponsor Management System (SMS) by universities seeking
to register as sponsors for Tiers 2, 4 and 5 and problems with
the use of SMS to bring international staff into the UK through
Tier 2. The SMS for Tier 2 was not tested by universities and
universities have reported a lack of training and advice in the
use of the new system as well as problems in gaining access to
the system and using it to produce certificates of sponsorship.
The SMS for Tier 4 is due to start operation
in the autumn. It has been delayed by UKBA following pressure
from the sector to adjust the system to reflect the differences
between employment andstudent recruitment, but we remain concerned
about a lack of time for testing by universities before the autumn.
Uniike Tier 2 the student route will have to cope with large volumes
of transactions in a very short period of timeJuly, August
and Septemberso it is essential that thorough testing by
universities and UKBA takes place both in the UK and overseas.
If the system failed during the peak period it would have potentially
disastrous consequences for students and institutions as students
have a very limited timeframe within which to apply for visas
and start their courses: so it is crucial that effective back-up
and business continuity arrangements are in place, if that timeframe
is missed the students may be unable to study in the UK that year
and may well look elsewhere, in this context it should be noted
that Australia's academic year begins in February.
COMMUNICATIONS
Universities UK is concerned about the lack
of communications that have accompanied the changes for students.
The system begins operation at the end of March but prospective
and current students have received no information about it and
its implications for them. A brief scan of overseas visa office
commercial partners (VFSGiobal and WoridBridge) conducted last
week revealed no information about the changes to student arrangements
on their websites. Overseas governments do not appear to have
received information about the new arrangements and its implications
for them, especially in relation to the scholarship programmes
they offer for students to come to the UK. Universities have also
received very limited information about the new system and its
implications for them in terms of changes needed to recruitment,
admissions and continuing administrative policies and processes
as well as preventing them from advising prospective and current
students about the new arrangements.
PRAGMATISM IN
OPERATION
Universities UK would urge UKBA to be pragmatic
in the administration of the new system. UKBA, universities and
indeed students will need time to adjust to the new system, particularly
as the finalisation of some of the detail has been very late.
We hope that minor errors in documentation or in the operation
of the system will be handled sensibly while this period of adjustment
takes place. It must also be highlighted that the student-institution
relationship is not like the employer-employee relationship and
there will be students who do not comply with the ruleshopefully
a very small number in higher educationbut this needs to
be recognised and understood by UKBA so that institutions are
not penalised for the vagaries of student behaviour.
Universities UK has encountered difficulties in dealing
with UKBA as different groups of staff within the organisation
do not appear to communicate very effectively. Different interpretations
of the new arrangements have been provided by policy staff compared
to operational staff based in the regions around the UK. We have
also encountered significant regional (within the UK) disparities
in the interpretation and understanding of the requirements of
the system as it will relate to students. The university sector
is very well-networked so these disparities are picked up very
quickly, but they cause serious concern for the sector as we are
a UK wide sector and cannot operate under different interpretations
of the rules according to geographical location. We would welcome
greater consistency throughout the UK in the training and development
of UKBA staff; and we will be proposing that a standing monitoring
group should be put in place, at least.for the first two or three
years of the new system, in order to pick up and resolve any problems
which arise.
CHANGES TO
TIER 2
We are concerned about the recent changes to
the arrangements for skilled employees announced by the Home Secretary
in February. Universities advertise all posts using appropriate
media such as the Times Higher and the jobs.ac.uk website. The
Home Office announced late last month that all jobs must be advertised
through Job Centre Plus. For academic jobs this is not an appropriate
medium and will waste university resources as well as adding inappropriate
jobs to the Job Centre Plus system.. The Home Office has also
asked the Migration Advisory Committee (the independent body established
by Government to advise on migration) to consider whether skilled
employment through Tier 2 should in future be limited to shortage
occupations. This would mean universities would not be able to
recruit international academic staff through Tier 2. As there
are significant numbers of international academic staff at UK
universities and particularly in key subject areas such as science
and engineering this would cause severe difficulties for UK universities.
POLICE REGISTRATION
As the new system will include closer monitoring
of international students and the introduction of ID cards Universities
UK would like to ask for a review of the police registration scheme.
It is not clear what the function of the police registration scheme
will be once the new arrangements are in place and should be reviewed.
OTHER VISA
SYSTEMS
A note is attached outlining some of the key
features of the visa systems for a selected group of other countries.
SPECIFIC INFORMATION
REQUESTED BY
THE SELECT
COMMITTEE
A note is attached on international students
working in the UK. A note is attached providing an overview of
the findings of a survey of academic visitors to the UK. An electronic
copy of the Universities UK economic impact report is attached
and a hard copy will be sent by post, it should be noted that
this report is being updated and a new version will be published
in April. If there is any further information required by the
Committee please contact Sarah Layfield at Universities UK.
July 2009
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