Written evidence submitted by University
for the Creative Arts (SV4)
EXECUTIVE SUMMARY
This submission responds to the main points in the
Home Affairs Committee Inquiry on the impact of the proposed restrictions
on Tier 4 (student route) migration. This submission, presented
by the University for the Creative Arts aims to outline briefly
the main disadvantages for the UK higher education sector should
the proposed restrictions be accepted. This submission argues
that reducing numbers of non-economic migrants is not the way
to respond to perceived abuse of this migration route. We believe
rather that efforts should be focused on ensuring that UK providers
of education (level 3 and above) to international students are
well regulated and compliant with Tier 4 requirements and, that
students who overstay their leave should be identified and pursued.
This approach we believe is preferable to closing routes to genuine
students and putting the future of bona fide UK organisations
at risk.
The following paragraphs address the particular points
the inquiry will focus on:
1. Whether the cuts should be limited
to certain types of courses (eg pre-degree level)
1.1 International students pursue level 3 programmes
in the UK by way of preparation for undergraduate study. Closing
this route to undergraduate study for international students has
the potential to depress numbers of international students able
and willing to participate in long-term UK higher education. This
will impact negatively on the UK economy, and will threaten the
sustainability of genuine level 3 providers, including many Universities
and other HEIs. It is a wholly inappropriate mechanism with which
to tackle abuse of the immigration system.
2. The impact different levels of cuts
might have on the various sectors
2.1 Denying the opportunity to offer particular
categories of courses to any provider other than one with HTS
status is problematic. There is a range of providers in the sector
offering courses to meet students' needs across a variety of levels
from pre-HE through to research degrees. Closing level 3 is likely
to have an impact on both private and public providers of foundation
and pathway programmes. Some organisations may have to close.
The proposal to raise the minimum level of English course that
an HEI may provide to C1 (equivalent to IELTS 7.0+), and to require
all students wishing to study an English course to have a minimum
level of B2 (equivalent to IELTS 5.0+), will also have a significant
impact on the sector. We believe that such a proposal is perverse,
and will cause immense damage to the English language training
industry, an industry of which state funded HEIs form a significant
part, and an industry which contributes significant sums to the
UK economy. To permit only those students who already have a high
level of English to come and study English clearly makes no sense
at all. To prohibit genuine students from studying English at
genuine institutions will do nothing to reduce abuse of the immigration
system. However it will put a huge dent in the UK's export figures
and will threaten the sustainability of a flourishing sector (one
of the few current economic success stories), including a number
of UK Universities.
2.2 In a context of unprecedented change, and
unknown consequences, in the UK higher education sector as a result
of the Browne Review, the sector has a serious need to protect
itself through the diversification of income. Buoyant overseas
recruitment will help to mitigate some of the effects of the changes
to funding arrangements for home/EU students. The proposed restrictions
put such recruitment at significant risk.
3. The impact, if any, that reductions
in student visas might have on the UK's standing in the world
3.1 The risk here is the likely damage to the
UK's reputation as the provider of a world-class education to
all those able to benefit from it. A cap on immigration numbers,
targeting some nationalities more than others, will demonstrate
the UK's apparent unwillingness to engage with large parts of
the global community. This is not an enviable subject position.
Managing student immigration through effective mechanisms for
checking qualifications, ability, financial means, potential and
return home after study, in dialogue with well-regulated, complaint
providers is a fairer and more defensible approach to immigration
control.
3.2 It is possible that the reductions in available
student visas will impact negatively on the UK's position as a
global leader in the creative economy (highest contribution per
capita to GDP, OECD figures). If UK higher education is unable
to attract, educate, retain and benefit from the world's best
creative talent, we will not maintain our position as the largest
in creative economy in Europe.
4. Whether cuts in student visas would
have any effect on the decisions of highly qualified graduates
to conduct research or take up teaching posts in the UK
4.1 It is conceivable that some international
graduates may choose not to pursue research or teaching positions
in the UK. However, as these activities are more than likely covered
by schemes other than Tier 4 (while PhD students may need a Tier
4 visa, those taking research or teaching posts will be covered
by Tier 2), the impact here is likely to be considerably less
significant than the impact that closing routes and capping numbers
will have on student recruitment.
5. Whether the post study route should
be continued
5.1 The current post-study work scheme does not
require an applicant to have a job offer in hand to qualify for
a two-year visa. This is inappropriate so the scheme as it currently
exists should be discontinued. Applicants for employment are able
to seek leave to remain through other means (Tier 2) which should
cover any shortfall caused by the withdrawal of the current post-study
route.
6. The educational routes through which
students come to the UK to study at degree level
6.1 The main disadvantage of the proposals is
the damage to the reputation of UK higher education as a world-class
destination for international students looking for a high standard
of education in a friendly and welcoming context. Using immigration
rules to limit numbers coming into the UK in the hope that problems
with the system will disappear as a result is unlikely to be successful.
It is possible that the reputational damage caused by separating
students and institutions into high-risk, low-risk, etc will do
little for the UK other than to lead students to elect to pursue
their education elsewhere.
6.2 Perhaps the most significant disadvantage
is the potential lack of level 3 opportunities in the UK. The
risk here is that such a policy is likely to propel students into
other education markets resulting in them remaining in alternative
locations other than the UK for the remainder of their educational
career. The UKBA's own consultation document draws attention to
the significant contribution that international students make
to the UK economy; a contribution that is at serious risk if students
are denied access to a major recruiting part of the sector.
6.3 The proposals do not take into account the
large numbers of international students who travel to the UK,
complete their course and return home without incident. They appear,
as presented here, to be a blunt instrument to deal with particular
and specific anxieties about high levels of immigration to the
UK. The issue is not one of denying students access to courses
or of forbidding particular elements of the sector the opportunity
to deliver high-quality programmes, but rather it is an issue
of the UK education industry being robust, well managed and compliant
with immigration regulations. Changing the Tier 4 route to simply
reduce overall numbers is not the way to proceed. We would urge
the committee to ask itself what is, or should be, the objective
of these proposals—is it simply to reduce student immigration
(in order to meet overall net migration targets), or is it to
reduce immigration by bogus students? If the former, then we believe
that this would be a misguided objective, as student migrants
are not economic migrants, and far from being a drain on the public
funds they, as customers of an export product, actually contribute
enormous sums to the UK economy. If the latter, then the objective
will not be achieved through the proposals as outlined—this
objective would best be met through greater focus on enforcement
and compliance, rooting out the least reputable institutions.
Whichever the intended objective, far greater transparency, honesty
and clarity of thought are needed.
We would agree with Keith Vaz's view that, "We
respect the fact that the Government wishes to tighten up the
immigration system but feel that … efforts would be far better
directed towards tackling bogus colleges and those who overstay
their visas in order to seek employment, than penalising legitimate
students."
January 2011
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