Written evidence submitted by the University
of Huddersfield (SV5)
EXECUTIVE SUMMARY
1. While it is recognised that robust control
of the UK immigration system is a key aim of the coalition Government,
there are concerns that the student route has been incorrectly
identified as a major channel of immigration abuse. The restrictions
that are being proposed could have a negative impact on the positioning
of UK higher education in the international market and create
significant damage for this important UK export sector.
2. Universities and other Higher Education Institutions
(HEIs) were invited to contribute to the last review of Tier 4,
which was initiated in 2009 under the previous Government and
was largely inconclusive. Many of the current proposals were posited
by and responded to in the earlier review, and we would question
why the new consultation is not taking these responses into account.
3. Revenue from international student recruitment
is needed to provide essential income diversification for public
sector universities following significant reductions in public
funding for teaching and research. It appears more than likely
that the proposed changes will restrict planned growth and the
essential development of alternative income streams, with a consequent
risk to the viability of some departments or institutions.
4. UK Universities are rigorously inspected and
have many years of experience in dealing with international students
in a trustworthy manner.
- (i) We operate our own sub-degree programmes,
in the form of English language programmes and foundation years,
for our own students progressing to our own degree courses. This
gives us a good chance of articulating with the many different
education systems across the world and gives us control over entry
standards to our degrees. Removal of the right would be catastrophic
for us.
- (ii) Working and dependents rights for international
students are essential to us if we are to maintain parity with
our major recruitment competitors in the United States and Australia.
There is little evidence that work rights are abused by University
students and students with dependents would have no problem funding
the costs of medical care and schooling for their dependents.
COMMENTS
The proposals which give greatest cause for concern
are listed below.
- Changes to work opportunities: Work rights and
the Post-Study Work Programme are important marketing tools for
HEIs and give us an even playing field with many of our closest
competitors. UK education is promoted for its quality, and is
appreciated as such worldwide, but it is also recognised
that it can be expensive in relation to the US and Australia.
It is particularly important in price-sensitive markets (the majority
of the countries from which we recruit) that we can offset or
challenge this view by conferring limited work rights. There is
no evidence that PSW participants displace UK nationals in graduate
employment.
- If the provision of sub-degree programmes is
restricted to HTS institutions this could undermine progression
arrangements developed between HEIs and other education providers
which are not HTS-rated. In most cases where these arrangements
exist they are subject to stringent quality assurance procedures
or the programmes involved are badged by professional education
providers eg ACCA, NCC, ABE etc. However, we would strongly support
an enhanced accreditation regime which integrates academic quality
assessment with immigration compliance needs, approving only the
largest and most professional providers.
- The proposal to require international students
to return home before progressing to a new course of study would
be disruptive and a strong deterrent to individuals planning to
continue their taught studies or undertaking postgraduate research
in the UK.
- The proposal to restrict permission to bring
dependants into the UK causes concern over the disadvantages this
would create for many students for both cultural and family reasons.
The majority of students with dependants at the University of
Huddersfield are from countries with which the UK is working to
achieve political détente or co-operation and a move to
restrict family transfers to the UK, in addition to affecting
individuals and families adversely, may jeopardise high-level
channels of co-operation.
- The proposed requirement for all non-EU students
coming to the UK to have undertaken an approved secure English
language test will jeopardise progression arrangements between
many UK HEIs and overseas partners, which normally incorporate
independent language testing activities. In addition, many countries
are English speaking and students are brought up speaking English
and taught in English. This proposal effectively removes the academic
freedom and autonomy of universities to determine and operate
independent entry requirements. Students coming to study English
language in a University, prior to an academic course, should
not need a secure test as we can assess them ourselves and subsequently
ensure that they reach the correct level to begin academic study.
CONCLUSION
1. Several proposals in the consultation are
welcome. These include the plan to reinforce accreditation procedures
for private providers. The proposal to offer a fast track service
to "low risk" applicants is cautiously welcomed; however,
we do have reservations about the application of differential
risk profiles and the possible introduction of subjectivity into
what was always intended to be an objective system.
2. The proposals as a whole fail to acknowledge
the economic importance of education exports from the UK as well
as ignoring the international dimension in which universities
and other educational organisations must work to maintain competitiveness
in both teaching and research. At present, the higher education
sector is facing an uncertain future and the expansion of international
activities constitutes one of the few areas available for further
development; if migration policy changes radically this will seriously
undermine this potential channel for growth.
3. We believe that within an international context,
the UK will lose the competitive advantage it has gained over
the last few years owing in part to a liberalised student immigration
regime and the overhaul of the visa application system. Of the
UK's major competitors in the international education market,
Australia felt the effects of a student immigration review that
led some of its universities to predict a fall of up to 25% in
its education export sector,[1]
and a 1.4% decline in enrolments in the current year has now prompted
another review of student visas.[2]
The USA has a similar system to that of the UK, although it could
be argued that the UK Tier 4 visa process is slightly more accessible
and straightforward.
RECOMMENDATIONS
1. Appropriate transitional arrangements must
be put in place for any changes made to the immigration system.
2. We would like to see HTS reserved for Universities
only, or a special HTS* category created, so that it becomes easier
to distinguish the rights that public funded and QAA inspected
institutions can hold.
3. Post-Study Work to remain but to be limited
to graduates of HTS institutions.
4. Dependants' rights to remain unchanged with
HTS, but charges made for medical care and schooling.
5. No requirement for University applicants to
English Language Programmes to undertake a Secure English Language
Test.
6. The higher education sector should be closely
consulted on issues such as differential risk assessment and to
advise on the academic aspects of accreditation of private providers.
7. It is suggested that a more rigorous sponsor
accreditation procedure is accompanied by greater benefits for
HTS institutions and their students.
January 2011
1 The Australian, 6 November 2010. Back
2
The Age, 17 December 2010. Back
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