Written evidence submitted by the London
School of Business and Finance (SV22)
EXECUTIVE SUMMARY
The London School of Business and Finance (LSBF)
is pleased to assist the Home Affairs Committee in its inquiry.
In this submission, we make the following points:
Now is the time to introduce a single regulatory
body governing both public and private educational institutions,
focusing on establishing and maintaining high academic, administrative
and regulatory standards. The new higher education funding environment
has significantly reduced real differences between public and
private organisations, and a new holistic, unifying regulatory
regime could bring consistent standards across the entire educational
system. In terms of student visa issues, the new system would
facilitate cooperative, effective, efficient relationships between
the sponsors and the authorities.
- The government's proposed changes to the student
visa system could have significant adverse implications for the
British higher education industry and UK plc more generally. We
believe that an economic impact assessment must be conducted before
proceeding.
- The government needs to stay focused on the fact
that the problem is the abuse of the existing visa system.
The system itself is not necessarily the problem; what we need
is smart enforcement of it across all routes, with the UKBA being
given proper resources.
- The Minister for Higher Education Rt Hon David
Willetts MP has called for an open market in higher education,
without prejudice to whether the institution is public or for-profit.
The proposals put forward by the UKBA, however, would make the
market less open. Indeed, while the Department for Business,
Innovation and Skills wishes to encourage a flourishing private
sector, these proposals serve as a massive disincentive for growth.
- Every effort should be made to ensure that the
UK higher education system attracts the world's 'brightest and
best'. The consultation paper published by the UKBA seems to assume
that those individuals coming to the UK for sub-degree courses
are not the "rightest and best" However, the "rightest
and best"must start somewhere. Albert Einstein was once a
patents office clerk. They should be positively incentivised to
come to the UK system early in their academic careers, before
they opt to pursue studies and then remain elsewhere.
- UK plc needs access to the best talent; but closing
down the Post Study Work route pushes that talent away. For the
brightest and best, the world is their classroom and their office.
If they do not see employment prospects in the UK, they may opt
to study in other, very grateful, countries.
INTRODUCTION
1. The London School of Business and Finance
(LSBF) is a privately financed, global leader in high performance
learning solutions. We are the fastest-growing business school
in Europe, with 16,000 students and over 20 offices worldwide.
Students come from over 150 countries to study in Manchester,
Birmingham, and London. About 80% of our students come from abroad,
mostly from non-EU countries.
LSBF programmes
2. LSBF is a market leader in developing learning
solutions that meet the needs of students and employers. LSBF
takes a problem-solving approach to education, identifying skills
shortages and gaps in the market and developing the most up-to-date
and relevant courses for students and trainees. We provide a unique
bridge between the formal education system and the ever-changing
financial industry, working with three of the 'Big Four' accountancy
firms and some of the world's top 10 banks to develop bespoke
training solutions. LSBF's educational programmes range from professional
qualifications to undergraduate and postgraduate degrees.[7]
3. In October 2010 we launched the groundbreaking
LSBF Global MBA™, which gives people anywhere in the world
access to high-quality academic material at no cost, via a Facebook
portal.
Highly Trusted Sponsor status
4. LSBF has been awarded Highly Trusted Sponsor
(HTS) status by the UKBA, and therefore we would be less affected
by the UKBA's proposed changes than would many other private providers.
Indeed, the increased importance that the proposals would place
on having HTS status would actually work to our competitive advantage.
Nonetheless, we feel it important to highlight the significant
negative impacts the proposals could have on the British educational
system and indeed all of UK plc.
The student visa system
5. We urge the government to stay focused on
the fact that the problem is the abuse of the existing visa system.
What we in the UK need is smart enforcement across all routes,
with the UKBA being given proper resources.
6. The government's proposed changes to the student
visa system could have significant adverse implications for the
British higher education industry and UK plc more generally. We
believe that an economic impact assessment must be conducted before
proceeding.
POTENTIAL IMPACT
OF THE
GOVERNMENT'S
PROPOSALS
Impact on the British educational brand
7. The UKBA's main focus is on reducing net migration.
However, to pursue that by reducing the numbers of student visas
may affect perceptions of the entire UK educational sector.
8. It is well known that the UK's educational
brand is among the most respected in the world. According to the
Times Higher Education World University Rankings, the UK is home
to five of the top ten universities in Europe, and three of the
top ten universities globally.[8]
9. However, the message being sent out by the
government's proposals is that it does not see the value that
many foreign students bring, and this message harms the reputation
of the British brand generally. The "brightest and best"
will increasingly choose to pursue their studies in more welcoming
countries, such as Canada or the US. Ireland, for example, has
set itself a goal of increasing the number of foreign students
by 50% in the short term, recognising that the country will see
a return on its investment in becoming an international centre
of educational excellence.
10. The UK should consider the experience of
Australia, whose $17 billion education sector is experiencing
a crisis resulting from a number of developments, including stricter
immigration controls (for financial and English-capability standards).
Enrolments of Chinese students, worth about $5 billion to the
Australian economy, are down 10-20%.[9]
11. Throughout the business world, the UK accountancy
and other professional qualifications are well respected. One
can commence the qualification in the UK and complete it anywhere
in the world. But if immigration rules make it more difficult
for individuals to conduct at least part of their coursework in
the UK, it may damage the excellent reputation that British accountancy
and other professional qualifications currently have.
Quality of the British education experience
12. Foreign students make a huge contribution
to the quality of higher education in the UK. They bring
different perspectives and innovative approaches. They bring energy
and passion for learning that is often lacking within the British
institutions, thereby introducing healthy academic competition.
They bring diversity, and help ensure that the British system
does not regress into a white, middle-class, Anglo-Saxon model.
Therefore, reducing the number of foreign students would make
the UK education sector less vibrant and competitive.
Impact on public services
13. One of the overarching rationales for the
government's commitment to reduce net migration to the tens of
thousands is based on the need to ensure that public services
are not over-stretched. Indeed, some pressure groups have been
vociferous in sounding alarms about the cost of migration to state-provided
services. However, the consultation paper does not present any
evidence that foreign students who enter and remain in the country
legally have a negative net impact on public services. The points-based
system's requirement for students to have adequate funds for maintenance
is designed to minimise any negative impact on public services,
and this requirement needs to be enforced. LSBF's students are
predominantly young and healthy, making significant investment
in the communities where they work through rent and living costs.
Impact on UK plc
14. Higher education is one of the UK's most
highly respected industries; any negative impact on it will have
drawbacks for all of UK plc. Business education institutions,
in particular, serve as seedbeds for entrepreneurship and innovation,
and by providing essential skills to the working population they
are engines for economic growth. Changes to the student visa system
must consider broader economic impact.
15. We are surprised that no economic impact
assessment has been conducted on the UKBA's current proposals.
16. Foreign students educated in the UK go back
to their country of origin familiar not only with our culture
and our system but also UK brands. These transnational relationships
not only boost trade and enterprise opportunities for British
companies, but also serve to solidify diplomatic relations.
KEY ISSUES
RAISED BY
THE GOVERNMENT'S
PROPOSALS
Differential treatment of private providers
17. Based on "indicative" figures,
the government has suggested that most abuses of the student visa
system take place with private sector institutions, and accordingly,
the proposed guidelines would impose greater restrictions on all
private providers. Notwithstanding the greater freedoms granted
for those private institutions with Highly Trusted Sponsor status,
there is still a differential treatment that effectively tars
all private providers with the same brush.
18. The government needs to stay focused on the
fact that the problem is the abuse of the existing visa system.
The system itself is not necessarily the problem; what we need
is smart enforcement of it across all routes, with the UKBA being
given proper resources.
19. LSBF does have Highly Trusted Sponsor status.
And as such, the proposed policy would allow it to continue to
offer most courses as it does currently. However, the principle
that private providers can be treated differently from publicly-funded
ones is troublesome. Essentially, the government's proposals would
require many private schools to gain Highly Trusted Sponsor
status—a very burdensome administrative process—or
go out of business.
20. As David Willetts MP said in his speech on
9 September 2010, "The acid test for HE providers is whether
they offer excellent teaching and a high-quality experience for
students. If they can do that, at a fair price, then it doesn't
matter whether they are old universities or new ones; for profit
or not for profit. They have something to contribute and should
have the chance to do so. That is the case for a more open market."
21. The proposals put forward by the UKBA, however,
would make the market less open. Indeed, while the Department
for Business, Innovation and Skills wishes to encourage a flourishing
private sector—expanding more into areas such as under-graduate
degrees—these proposals serve as a massive disincentive
for growth.
22. Accordingly, LSBF offers this solution:
- (a) Now is the time to introduce a single
regulatory body governing both public and private institutions,
focusing on establishing and maintaining high academic standards.
The new higher education funding environment has significantly
reduced real differences between public and private organisations,
so the previous rationale for maintaining two different regulatory
schemes is no longer valid.
- (b) But the current situation with regard
to student visas demonstrates that there is a need to hold all
academic institutions to the same high standards. A valuable paper
by Universities UK[10]
notes that there is already substantial agreement by publicly
funded universities as well as private institutions around convergence
of the existing regulatory schemes. This entails improving the
sharing of information across regulators, regular consultation
between government and the private sector, conducting a strategic
overview of developments, and monitoring of national and international
trends.
Impact on Innovation
23. Driven by the competitive need to meet the
needs of students and their future employers, indeed in order
to stay afloat, private institutions must innovate and respond
rapidly to changing economic circumstances.
24. There is a symbiosis and cross-fertilisation
between public and private education providers, with private schools
creating innovative learning solutions and complementary course
offerings. For example, private providers have worked with the
public institutions in developing sub-degree courses that help
prepare British students for University. These courses, generally
at the NQF 5 level, are offered mainly in essential fields such
as mathematics, business, engineering and nursing. They are an
essential bridge for many young people to reach university. And
yet if private providers are not able to offer them to the foreign
student market, the courses would not be financially viable for
British students.
Limits on courses for which Tier 4 visas are available
25. In its attempt to restrict Tier 4 visas to
the "brightest and best", the UKBA recommends raising
the level of courses Tier 4 students can study, placing restrictions
on sub-degree level study for those who do not have Highly Trusted
Sponsor status. There are numerous issues with this.
26. The professional qualifications offered by
LSBF and other private schools map to a wide range of NQF levels.
Many students come in at an NQF level below the threshold permitted
for non-HTS schools but subsequently advance. Would the proposals
mean that students could pursue the sub-degree courses if they
booked a course of study taking them through NQF 5 (eg, papers
1-8 of ACCA)?
27. The consultation paper published by the UKBA
seems to assume that those individuals coming to the UK for sub-degree
courses are not the "brightest and best". There is no
data (in fact, no logic) to support this. The brightest
and best must progress through the various levels of study, just
like anyone. They, too, take sub-degree courses. Should we not
make a special effort to attract the 'brightest and best' specifically
at the sub-degree level, and encourage them to remain through
the duration of their studies?
28. There is no mention of the need to positively
incentivise bringing the 'brightest and best' to the UK. The way
to do this is not to impose restrictions, but to continue to build
the attractiveness of the UK educational system so that it competes
effectively for those individuals it wishes to attract. Indeed,
Canada, New Zealand and the United States are already picking
off Australia's market share with their strong incentives.[11]
Post Study Work Route
29. There are numerous problems entailed in restricting
(not to mention eliminating) the Post Study Work Route
(PSWR). Eliminating the PSWR tells potential employers that they
will not have access to the best talent coming through our schools.
UK plc needs access to the best talent; but closing down the PSWR
pushes that talent away.
30. For the 'brightest and best', the world is
their classroom and their office. They choose where they pursue
their education based on a holistic assessment, taking into consideration
(a) the quality of the educational programme itself, (b) the benefits
of being in the particular location, and (c) prospects for employment.
By damaging this last criterion, the balance is significantly
tipped towards other, very grateful, countries.
31. The UKBA paper considers whether an exception
may be made for those obtaining PhDs in UK schools. If so, an
exception should be made for other terminal degrees, such as the
MBA.
32. More analysis of the potential effects of
eliminating the PSWR should be done to evaluate these potential
effects.
CONCLUSION
33. LSBF would be keen to discuss the points
we have made in our submission further with the committee.
34. Our recommendation for the creation of a
single regulatory regime across private and public sector educational
institutions goes beyond the topic of student visas (and therefore
the committee's scope of inquiry), but the challenges of immigration
policy are broad and cover the full gamut of government policy.
35. We recommend that the Home Affairs Committee
work alongside its other colleagues in Parliament—such as
the select committees on Education, Foreign Affairs, and Business—to
take a cross-departmental approach.
January 2011
7 More information about LSBF's programmes is available
at www.lsbf.org.uk/ Back
8
www.timeshighereducation.co.uk/world-university-rankings/2010-2011/europe.html
www.timeshighereducation.co.uk/world-university-rankings/2010-2011/top-200.html Back
9
Sainsbury, Michael, 'Decline in China numbers to Persist', The
Australian, 15.12.10. Back
10
www.universitiesuk.ac.uk/Publications/Pages/Privateandforprofitproviders.aspx Back
11
"Indian students ditching Australian education plans",
Hodge, Amanda, The Australian, 29.11.10. Back
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