Student Visas - Home Affairs Committee Contents

Written evidence submitted The Northern Consortium (SV12)


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:



Leeds Metropolitan


Liverpool John Moores

Liverpool  Manchester

Manchester Metropolitan


Sheffield Hallam


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.


2.1  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.


3.1  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.


4.1  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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Prepared 25 March 2011