Written evidence submitted by The University
of Warwick (SV18)|
1.1 The University of Warwick is concerned that
the proposed measures to curb net migration by restricting the
student route, as set out in the UKBA's document The Student
Immigration System: A Consultation (December 2010), are disproportionate
to the risk posed by Tier 4 students on university courses, particularly
those provided by Highly Trusted Sponsors (HTS).
1.2 Proposals to raise accreditation and inspection
standards for private institutions are very welcome as this is
where most abuse of Tier 4 of the Points Based System occurs.
However, the majority of proposals in the UKBA document are wholly
unnecessary in relation to Highly Trusted Sponsors such as the
University of Warwick, who have a proven track record in responsible
international student recruitment and preparation of students
for graduate employment.
1.3 The University of Warwick would argue that
HTS institutions should be exempt from the majority of proposals
in this document given that they have already demonstrated their
trustworthiness to the UKBA through the HTS application process.
1.4 Were HTS institutions not to be made exempt
from these proposals, then there would be severe consequences
for the whole of the UK higher education sector. In 2010-11, the
University of Warwick welcomed an intake of 3,147 new international
students from outside the EU. This represents 33% of the total
undergraduate and postgraduate intake for 2010-11.
1.5 International students are vital to the UK's
prosperity, not just for the estimated £2.5 billion income
each year they bring in tuition and accommodation fees or the
£2.5 billion they spend off-campus in local communities,
but for the culturally diverse perspectives they bring to our
classrooms, enhancing both our UK students' learning experience
and employability as global graduates. Furthermore, the UK's soft
power is greatly enhanced by its growing base of international
alumni in positions of influence overseas furthering the diplomatic,
trade and cultural interests of the UK.
1.6 The proposals to ensure students return overseas
after their courses, in particular the proposal to curtail Post
Study Work is of particular concern, given that it is regarded
by international students as a key element of the UK higher education
offer in order for them to gain professional experience before
returning to their home country and not as a route to longer-term
settlement. Removing this opportunity, especially for those students
already recruited on the understanding that PSW would be available,
would cause long-term damage to the reputation of UK higher education
and provide a significant boost to our competitors.
1.7 Coupled to the proposals to limit students'
entitlements to work and sponsor dependants, the image portrayed
overseas would be one of a higher education system that does not
value international students except as a cash cow to replace lost
funding. This image will undoubtedly deter many of the brightest
and the best students from choosing the UK.
2. THE IMPACT
2.1 The proposal to restrict Tier 4 to degree-level
students only will have a significant impact on universities'
ability to recruit the brightest and best undergraduate students.
The pipeline from UK further education colleges, language schools
and foundation course providers is a vital part of universities'
international student recruitment as these students have had an
opportunity to adapt academically, socially and culturally to
2.2 In 2010, 42% of Warwick's new international
undergraduate intake had previously studied in the UK at sub-degree
level. 101 of these were students who had successfully completed
Warwick's own Higher Education Foundation Programme (NQF level
3). There was a 96% pass rate on this foundation programme and
all successful candidates were placed at Warwick or other top
2.3 Although recently extended to 11 months for
English language courses only, the student visitor route does
not offer a useful alternative for other sub-degree level programmes,
as it is limited to six months' study with no extensions or switching
allowed. Consequently, many credible nine-month foundation programmes,
which serve as strong feeder institutions, will have to shut down.
2.4 The University of Warwick would therefore
argue that only Highly Trusted Sponsors should be permitted to
offer study at below degree level as this should ensure only genuine
students are able to attend genuine institutions.
2.5 Language proficiency is an academic judgement
that should remain within the institution's control, especially
if that institution is "Highly Trusted". Therefore,
HTS institutions should be exempt from the requirement to take
a Secure English Language Test, particularly as non-acceptance
of certain qualifications, such as the International GCSE in English
Language is problematic and discriminates against international
2.6 The University of Warwick does not agree
with the proposals to restrict further the amount of work students
at HTS institutions should be allowed to undertake while studying.
HTS institutions should be exempt from this requirement given
their "Highly Trusted" status. Graduate employers the
world over want students to have gained some work experience in
addition to their studies. The proposed changes would make international
students less attractive to commercial employers due to the inflexibility
of not being able to work during the week.
2.7 The University of Warwick's campus employment
agency, Unitemps, has confirmed that for the key sectors they
recruit into (Events Work, Social Care, Education Research and
Languages Support), the new proposals would exclude international
students from this work. Unitemps supplies international students
as interpreters to the NHS for doctor's appointments. These take
place off-campus during the week, meaning the NHS would suffer
if this supply were to be cut. Weekend events work at the NEC
in Birmingham, such as Crufts, invariably begins on a Thursday
or Friday with the set up, making international students ineligible.
International students act as buddies to people with brain injuries
in the social care system. This would be curtailed as would Unitemps'
practice of recruiting Warwick students to work on other nearby
university campuses in the week.
2.8 Raising the minimum ratio of study to work
placement to 66:33 would have a negative impact on a number of
strategic partnerships. Hong Kong City University has confirmed
it would cancel the six-week voluntary placement programme it
runs with Warwick on a 50:50 study to work ratio. Medical Schools
in the UK would also suffer. In the latter years of a medical
degree, the vast majority (80-90%) of the course is undertaken
through clinical placements. Restricting this to 33% would make
it very difficult for students to learn about "being a doctor".
2.9 The UKBA's use of the term "work placement"
appears to mean experience in a work setting that might prevent
someone else from getting employment. In both examples above,
this is not the case. Clinical placements, for example, are very
different as the student is "observing practice" rather
than actually undertaking a job. Therefore, such placements should
3. THE IMPACT
3.1 The University of Warwick is concerned about
the UKBA's proposals to ensure students return overseas after
their courses. The requirements to show evidence of progression
and to return home to apply for a visa for a new course should
only apply to non-HTS institutions, as the problem appears to
lie with low-level programmes offered by private institutions.
3.2 Forcing all students to apply overseas for
a new visa would significantly increase the UK's carbon footprint,
largely for symbolic reasons. In his oral statement to Parliament
on 13 December 2010 on the outcomes of the Cancun Climate Conference,
the Secretary of State for Energy and Climate Change welcomed
the Spanish government's support for a 30% reduction in EU carbon
emissions by 2020. In the context of moving towards a low carbon
economy within Europe, requiring all international students to
incur two additional flights in order to apply for a new visa
overseas rather than extend in the UK cannot be justified. Furthermore,
the additional costs and practical difficulties with issues such
as housing contracts will lead to fewer of the brightest and the
best progressing from undergraduate to postgraduate courses at
the University of Warwick. This would mean our investment in these
students with a proven track record of achievement in UK higher
education could be jeopardized and their value to the UK as future
researchers, academics and loyal alumni could be lost to competitor
3.3 The University of Warwick is also concerned
about the proposals to restrict work opportunities after studies.
Tier 1 Post Study Work (PSW) is an extremely valuable route for
international graduates to build upon their academic experience
with a period of work and provides a competitive advantage for
UK universities competing for the top global talent. For university
graduates it is not seen as a route to gain longer-term settlement
in the UK. In the International Student Barometer Summer Wave
2010 survey, a survey of international student opinion run by
the independent research company i-graduate, only 1% of Warwick's
764 respondents said their plans after study were migration or
3.4 PSW applicants are looking to develop their
professional experience in order to return to their own countries
with a good professional standing to enter senior management positions.
This then means they are able to affect positive change in the
relationship between their countries and the UK. Any changes,
particularly those affecting current students recruited on the
understanding that PSW would be available on graduation, would
be received very negatively by current and prospective students
and would damage the UK's reputation for years to come. University
Careers Services are not currently set up to assist international
students seeking employment in their home countries meaning transitional
arrangements would be required.
3.5 PSW is currently used by international doctors
with a UK Primary Medical Qualification (PMQ) moving from the
Foundation Programme into specialty training. The proposal to
close PSW would mean that international doctors holding a UK PMQ
looking to pursue specialty training would need to apply through
Tier 2, making them subject to resident labour market tests. This
would make it very difficult for international doctors to pursue
specialty training in the UK.
3.6 The UKBA's consultation document claims that
(skilled) employment rates amongst international graduates using
the current Tier 1 route are disappointing. Global data from the
Higher Education Careers Services Unit (HECSU) for EEA nationals
follows a similar pattern to the data quoted for international
graduatesonly 59.2% were employed. This is a feature of
the current economic context rather than an argument that universities
are not admitting the "brightest and best".
3.7 The UKBA's consultation document also claims
that international graduates are still able to enter as Tier 2
sponsored migrants and indeed that the process for employers has
been made easier. This is misleading: the capping of Tier 2 visas
at 20,700 sends a clear signal that working in the UK post-completion
will not be an option for the vast majority of graduates. Inevitably
this will impact upon international student recruitment.
3.8 The University of Warwick recommends that
transitional arrangements are in place to allow undergraduates
and postgraduates who began their courses in or before the current
academic year to continue to benefit from the scheme in its current
iteration. This is based on the premise that they were sold a
UK higher education experience, of which for many a highly valued
feature was the opportunity to remain in the UK for work upon
3.9 Longer-term, PSW should be restricted to
HTS institutions only and to graduates from degree-level and above
programmes. Currently, students from 700 institutions with a range
of qualifications are eligible for PSW. Limiting this to university
graduates from HTS institutions would reduce numbers and increase
the quality of employment opportunities secured.
4. THE IMPACT
4.1 The closure of PSW would have a negative
impact on the quality of research carried out at UK universities.
Research-led universities need to recruit the brightest and the
best international talent to stay at the cutting edge of their
research discipline and a university's own PhD graduates are often
best placed to continue to support the work of leading academics
in Post Doctoral positions as they have been trained and supervised
by those particular academics in that particular specialised area
of research. If PSW is closed, universities would be forced to
appoint candidates from the UK/EU who they had not trained over
their own international PhD graduates. This undermines universities'
ability to be global leaders in research and development and could
lead to the best UK researchers moving their research groups overseas
where they would be free from immigration restrictions when recruiting
the best global talent.
4.2 Given the higher proportion of research students
wishing to bring their dependants with them to the UK, the University
of Warwick is concerned about the impact on research of the UKBA's
proposals to limit the entitlements of students to sponsor dependants.
4.3 The proposal to refuse dependant visas where
the main applicant is on a course of less than 12 months could
be problematic and subject to a challenge under Article 8 of the
Human Rights Act given there may be cultural and family reasons
why some are accompanied. This could discriminate against students
from certain countries and, in particular, against female students
and project an unnecessarily harsh and unwelcoming image of the
UK to prospective students.
4.4 The complete restriction on dependants working
in the UK is also likely to cause problems, particularly for postgraduate
research students, who may be more likely to have dependants and
who are here for a longer period. Given the current rules on employment
prohibition cover unpaid and voluntary work, it is not clear how
dependants would usefully spend their time in the UK. This could
act as a strong disincentive for the brightest and the best who
happen to have dependants to choose the UK.
4.5 This will particularly impact the recruitment
of PhD students, a key strategic priority for the University of
Warwick. Warwick has recently invested £1.5 million in PhD
scholarships for international students in order to attract the
brightest and the best who would otherwise choose the USA. This
proposal would appear at odds with our target to double PhD numbers.
4.6 Losing out on top PhD students would have
a direct impact on the reputation of the UK's research-led institutions.
For example, The Times Higher Education World University Rankings
uses the ratio of PhD to Bachelor's degrees awarded as a performance
indicator of teaching quality, so a drop in PhD student numbers
could have an impact on the global league table positions of the
UK's universities. The fact that there is a global shortage of
research talent, particularly in science and technology, needs
to be considered: the UK is already in competition for these students
and additional barriers such as work restrictions on dependants
will only serve to stymie efforts to recruit the top research
4.7 The University of Warwick would therefore
recommend that this restriction should not apply to the dependants
of students who are studying at HTS institutions.