Student Visas - Home Affairs Committee Contents

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.


2.1  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 the UK.

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 UK universities.

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 students.

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 be exempt.


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 countries.

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 permanent residence.

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 graduates—only 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 graduation.

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.


4.1  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 talent.

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.

January 2011

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Prepared 25 March 2011