Written evidence submitted The Northern
Consortium (SV12)
1. THE NORTHERN
CONSORTIUM (NCUK)
1.1 This paper is submitted by The Northern Consortium
(NCUK). NCUK was created in 1987 by 11 British universities to
facilitate their collaboration in establishing and running off-shore
foundation courses for international students. Building on its
achievements and experience over 23 years, NCUK is a highly successful
education organisation working in an expanding number of countries.
It provides a range of cost-effective pathway programmes that
prepare international students for part or all of their university
study in the UK. Essentially we do this by providing some of the
necessary education inputs needed to obtain a UK degree in the
students' home countries before they transfer to the UK. This
is known in the sector as Transnational Education (TNE) and it
is the fastest growing segment of the international education
market. As an education organisation owned by 11 UK universities
that operates in TNE we have a unique insight to bring to the
issues being considered by the committee. NCUK now has programmes
running in 10 countries (China, Kenya, South Korea, Ireland, Japan,
Nigeria, Sri Lanka, Morocco, Pakistan and the UK). To date more
than 15,000 students have progressed to degree studies from NCUK
programmes generating £335 million in fees for NCUK universities;
the additional income generated to local economies through accommodation
and day-to-day living is estimated at £225 million.
1.2 The 11 universities that came together to
set up NCUK and which still own the Northern Consortium today
are:
Bradford
Huddersfield
Leeds Metropolitan
Leeds
Liverpool John Moores
Liverpool Manchester
Manchester Metropolitan
Salford
Sheffield Hallam
Sheffield
2.3 Many other UK universities welcome NCUK qualifications,
not just its founding universities and currently some 20 English
universities receive our students on an annual basis. More than
20% of international students studying in England choose to study
at these 20 universities and this background of excellence in
international education underpins our policies and procedures.
In addition, NCUK qualifications are recognised in Australia and
the Republic of Ireland.
2. SUMMARY OF
KEY POINTS
2.1 The essential concern for NCUK and its UK
universities is that any move to limit student visas to public
universities and related institutions for degree-level study only,
will seriously damage the UK's standing in world education and
put at risk a vital income stream. International (non-EU) students
who legitimately enter the UK to study at university and/or to
undertake courses to prepare for degree studies do so because
of the quality of UK education, not because of the job opportunities
or welfare benefits the UK has to offer. The Points Based System
(PBS) was introduced to tie students into registered sponsoring
institutions (a move welcomed by universities) which now issue
Certificates of Acceptance to Study (CAS) and are required to
meet specific tracking requirements. We argue that the provisions
of the new PBS are more than adequate to sift out bogus students
and institutions. There is no evidence that PBS is not working
and needs further refinement.
2.2 Any move to require a Secure English Language
Test (SELT) for a study visa will also cause serious problems
for UK universities in general, and will undermine the work NCUK
has spent 23 years building up. If universities could register
their own programmes as SELTs and prove their security (as NCUK
would) this would not be an issue. However, recent guidelines
make it impossible for even relatively large testing units such
as ours to meet the requirements (eg evidence of secure testing
in over 40 countries).
2.3 NCUK contends that UKBA's focus should be
on bogus institutions and not on intervening on academic judgements
made by UK universities. The UKBA report Overseas Students
in the Immigration System: Types of Institution and Levels of
Study (Dec 2010) analyses types of course studied by non-EEA
students and the rate of compliance/non compliance by sector.
The 2% non-compliance rate for the university sector (table 4)
is strong evidence that students who have gone to public universities
have been highly compliant regardless of what qualifications and
routes were used for admission. This demonstrates there is nothing
essentially wrong with the current system for public universities.
3. COMMENTS ON
PROPOSALS
3.1 NCUK's owner universities and related organisations
are making comments and recommendations in their own submissions
that echo NCUK's thoughts on the general areas on which the committee
has invited comments. NCUK is therefore focusing our comments
on the areas most directly related to our business.
3.2 The impact different levels of cuts might
have on the various sectors
3.2.1 The rule changes are allegedly not intended
to "cut" recruitment of well-qualified students to UK
Universities yet they will have exactly that impact. The vast
majority of students who enter the UK for sub-degree (i.e. "FE")
courses at public and private institutions with HTS status at
16-plus do so to prepare for degree/HE study. Changes which directly
or indirectly (via e.g. SELT requirements and the proposal that
students will need to return to their home country to apply for
a new visa to progress to a higher level of study) will place
unnecessary barriers for well-qualified students from this sector
and will severely undermine recruitment to UK Universities. Any
restriction on student visas for genuine students aiming to study
at bona fide institutions at any level will have a very serious
detrimental impact on the UK economy. The international education
industry is second only to Financial Services in the level of
"export" earnings it produces for the UK's service sector.
3.2.2 Using our own operations as an example,
NCUK is currently preparing over 2,200 students to enter UK universities
in September 2011, (worth £45 million in tuition fees alone)
and proposals by UKBA to use a narrow range of SELTs to implement
cuts will put at risk at least part of that income - possibly
as much as 50%. Some of our students will fail to get a visa for
no other reason than they will be unable access a SELT in time.
Requiring a SELT will not only add an unnecessary layer of complexity
to visa applications for NCUK students, it will also seriously
undermine the quality of the student experience and the value
of the NCUK English for Academic Purposes (EAP) programme (see
3.3.7).
3.3 The educational routes through which students
come to the UK to study at degree level
3.3.1 NCUK has been involved in TNE pathway programmes
for international students for over 23 years; that is, we have
designed and managed programmes which help international students
to qualify for entry to UK Universities for over two decades.
Typically, these programmes are foundation programmes which prepare
students in terms of English language skills, study skills and
subject-specific knowledge that allow them to qualify for and
excel in their chosen degree. Currently we have a foundation programme
for undergraduate degrees (IFY), and Masters level (Grad Dip and
PMP).
3.3.2 NCUK also offer programmes which enable
students to study the first part of their undergraduate degree
in their own country., The NCUK International Diploma (Int Dip)
is the equivalent of the first year of a degree at one of our
owner universities and is often delivered as year-2 of a "2+2"
programme; that is one year for IFY, one year for Int Dip, with
the final two years at one of our UK owner universities.
3.3.3 NCUK programmes are administered and awards
made using stringent quality assurance procedures. Examinations
and assessments are externally set by NCUK, and our pool of external
examiners comprises academic staff from NCUK universities with
those universities being the ultimate guarantors of the quality
of our programmes. Certificates are printed and given to students
using stringent security checks; all NCUK owner and associate
universities receive student results directly from NCUK, and any
attempt by students to use a certificate fraudulently can immediately
be highlighted and rejected.
3.3.4 Our experience shows that students on NCUK's
and other TNE programmes present virtually a zero risk of non
visa compliance. This is because the students will be very committed
to genuine study in the UK having completed up to two years of
direct study in their home countries. Those seeking an easy route
into the UK will not choose TNE programmes; note that all NCUK
students are individually well known to the TNE providers and
their partners.
3.3.5 Because of NCUK's relationship with bona
fide organisations overseas, we are able to provide a flow of
well-qualified, "genuine" students. The partnership
we have with these organisations is entered into only after rigorous
due diligence checks, including liaison with local British Council
offices and intelligence from our owner universities. No partners
would risk sanction by NCUK or UKBA by knowingly providing access
to students who do not intend to follow their studies in the UK.
3.3.6 There are many valuable benefits of having
the first year (or more) of a degree studied overseas. The grades
awarded mean that only students who are committed to an international
education qualify to come to the UK; the process naturally filters
out (either at the entrance or exit stage) students who are not
capable of engaging in degree-level study in the UK.
3.3.7 These benefits extend to the UK as a study
destination and TNE is on the rise. A report produced by the UK
Council for International Student Affairs (UKISA) in 2009 ("Transnational
Education and the Student Experience: a PMI Student Experience
project report) estimates that "it is likely that, for the
UK at least, by 2010 the numbers of students registering on HE
TNE programmes will be greater than those coming to the UK programmes
from overseas by traditional recruitment". Many of these
programmes have integrated English programmes as a core activity
and do not rely on the current SELT exams as students transfer
to the UK, partly because the need to take a SELT would disrupt
their programming. NCUK programmes integrate tuition and testing
of English for Academic Purposes using the same rigorous philosophy.
3.3.8 In the UK, NCUK only works to deliver its
pathway programmes with a very limited number of organisations
who have proved themselves leaders in the field of quality international
education. The INTO Manchester and INTO Queens University Partnerships
(both of which have UKBA HTS status) started as a collaboration
with a local FE college, and our other partnership in Walsall
is with an established (HTS) FE provider. These organisations,
through their entrepreneurial attitude to education, have combined
a commitment to quality in international education with careful
market positioning.
3.3.9 All NCUK programmes rely heavily on English
language training, focusing on English for Academic Purposes (EAP).
Students who start NCUK programmes anywhere in the world need
to demonstrate that their general English language ability is
at an intermediate standard (effectively just below CEFR B2) on
entry. Although NCUK is not involved in courses below the intermediate
level, we are conscious of the fact that general English language
training in the UK, both private and public, provides an important
flow of students into our programmes. For this reason, any directive
to remove this flow of students will have serious ramifications
for NCUK programmes delivered in the UK with the concomitant serious
impact on our owner and partner universities.
3.3.10 Of serious concern for all NCUK stakeholders
is the proposal that a SELT with prescribed tests—such as
IELTS and TOEFL—will be the only tool in deciding on the
appropriateness of individual students' language proficiency for
UK HE study. For any student wanting to enrol on a pathway programme
(such as those offered by NCUK) this undermines the value of the
programme. Particularly for NCUK, where English for Academic Purposes
language training (EAP) is imbedded with subject study, our programmes
will be seriously damaged; the pedagogic arguments are difficult
to explain in a short paper such as this, but a focus on a SELT,
which is a snapshot proficiency exam, will be very much to the
detriment of a programme that covers a much broader (and necessary)
set of academic language skills and study skills. Added to this,
the practicalities of very large numbers of students typically
needing a local SELT at peak times coupled with the staff and
hardware requirements for SELTs will inevitably mean missed deadlines
for visas and a reduced student flow.
3.3.11 NCUK also believes that this is fundamentally
an issue of freedom of choice. The government is currently seeking
to extend greater choice and autonomy to institutions and learners
in many areas of the UK education system, yet they are seeking
to effectively limit the admissions procedures used by UK universities
for non-EEA students. Mindful of their HTS status and how non-compliance
can affect them, universities will want to be free to use all
tried and tested routes to admit students, not just those dictated
by a SELT list. International students seeking to invest thousands
in a UK education should be able to choose the routes that they
feel best prepare them for their experience. There is no evidence
to suggest that genuine students preparing for degree level study
(in the UK or off-shore) and their receiving universities have
misused or abused the choices now open to them, so we do not believe
it is desirable or appropriate to restrict those choices.
3.4 International comparisons
3.4.1 Few would doubt that recent changes in
immigration policy in Australia have had a disastrous impact on
genuine student recruitment from countries such as China and India
even though it was designed to deter only those looking to abuse
the system. The Australian government is reviewing those policies
as their sudden and far reaching implementation led many to believe
that the "Australian government was giving overseas students
the impression that it was not 'open for business', with the result
that students were heading for competitor countries such as the
US, Canada and the UK" (Times Higher 23 December 2010).
3.4.2 Conversely, UK policies on international
students and immigration have until now been seen as tough but
open and contributing to international student mobility. The UKBA
proposals would change this perception and reality irrevocably.
We believe it is no coincidence that the three licenses issued
by the Chinese government to date to establish full TNE campuses
(including full foreign degree delivery) have all been issued
to UK projects, including one in Shanghai in which NCUK plays
a pivotal role.
4. RECOMMENDATIONS
4.1 UK Universities are operating in a highly
competitive international education export industry. Current UK
university recruitment channels, which rely on visas being issued
to genuine students for study at pre-degree level at bona fide
UK institutions, are reliable and flexible, and give the UK a
unique standing over its rivals in this field. We recommend:
- 4.1.1 There should be no restriction on Tier
4 visas based on level/type of study alone. It is bogus institutions
who admit bogus students at all levels of study that pose a threat
to immigration security. Efforts should be focused on stopping
recruitment to bogus institutions.
- 4.1.2 English language levels should be assessed,
as they currently are, by the universities and other HTSs and
not by a SELT otherwise it would seriously undermine the market
position of the UK's HTSs. Imposing a SELT would not discriminate
between bogus and bona fide students since it would merely fuel
dubious test-preparation courses which encourage cramming to pass
the test rather than the development of language skills.
- 4.1.3 The proposal that would force students
to return to their home country to apply for a new visa to progress
to a higher level of study should be rejected.
January 2011
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