Written evidence submitted by Navitas
(UK) (SV36)
1. Executive Summary
1.1 Navitas understands the Government's parallel
objectives of eradicating abuse of the migration system, including
any element of abuse via the student visa route, whilst ensuring
that the UK's education system continues to attract the brightest
and the best students from across the globe. It is very much in
the interests of the sustainability of not only the UK's education
exports services industry but also Navitas' UK College network
that the UK remains a top priority destination for legitimate
non-EU students; however it is imperative that policy be based
on empirically sound data derived from comprehensive consultation
and analysis as opposed to driving policy from less than robust
data sources.
1.2 The education export services industry in
the UK is complex and dynamic comprised of public and private
providers. Regulation is welcomed by all bona fide providers;
however any regulatory regime must be equitable across both the
public and private sectors in order that Government applies the
same standards of transparency and accountability across all providers
regardless of their funding base.
1.3 Ireland, New Zealand and the USA have recently
come out strongly in support of the economic and cultural importance
of the education exports services industry. The Australian Government
for example has recently recognised the negative impact on GDP
of recent visa tightening measures.[45]
1.4 International students contribute to their
local economies, providing a very significant income stream for
the UK economy. The 2009 Universities UK report on the impact
of universities on the UK economy indicated that in 2007-08 off-campus
expenditure by international students was c £2.3 billion.
1.5 The UK is sending mixed messages to the world.
Government words are signalling that the UK is keen to enhance
its global engagement and welcomes international students as part
of that engagement; however, Government action through the current
proposals is signalling to the world that the UK does not want
international students.
1.6 International student mobility is a very
successful activity for the UK and contributes to the success
of HE sector, the UK economy and international positioning. It
should be considered as an export success and not as an immigration
problem.
1.7 Government is focusing on net migration when
setting targets; it should be focusing on settlement and, making
it more difficult to transfer from temporary (ie students) to
permanent migrant routes.
1.8 International students are "educational
tourists" not immigrants; they may indeed be in the UK for
longer than 12 months but this is because of the nature of their
education programmes; they are not in the UK for economic reasons;
their time in the UK on a student visa does not earn points towards
applications for settlement and they have no recourse to public
funds. Further, if students wish to progress onto further study
or take up employment, they must apply to the Home Office for
another visa; this is an inbuilt and existing control mechanism.
1.9 The potential to inflict profound, long-term
damage on the HE and English language sectors for no discernible
gain looms large if the proposals currently on the table are taken
forward. The UK will not recover from this damage as trust and
market-share once lost are impossible to regain.
1.10 "Whole-of-course" visas will enhance
the UK's competitiveness as well as retention, progression and
completion rates. Forcing students to apply overseas for a new
visa between components of study pathway/programmes will have
a negative impact on retention rates and student progression as
well as create practical difficulties in terms of costs and accommodation.
1.11 International students/graduates play a
key role as diplomatic/trade/cultural assets for the UK—"soft
power" as it is known.
1.12 The Government endorsed and encouraged private/public
interface between education providers in the UK could be undermined
by these proposals thus in turn undermining the Government's need
for private enterprise to take a more dominant role in the provision
of employment opportunities and education costs as part of the
rebalancing of the UK economy.
1.13 The sector should work with the Government
to develop equitable and transparent accreditation and licensing
procedures for providers and this will enhance credibility and
establish acceptable standardised benchmarks for quality provision
within the HE sector.
2. NAVITAS LIMITED—AN
INTRODUCTION
2.1 Navitas Limited is a diversified global education
provider that offers an extensive range of educational services
for students and professionals including university programmes,
language training, work-force education and student recruitment.
Navitas Limited is a public listed company on the Australian Securities
Exchange (ASX) and is known as a world leader in the development
and provision of educational services and learning solutions.
Navitas Limited had a market capitalisation of approximately AUD$
1.4 billion as at June 2010. Navitas consists of four operating
divisions: University Programmes (the largest Division with operations
in Australia, the UK, the USA, Canada, Singapore, Sri Lanka, Kenya,
and Indonesia); English; Work-force; and Recruitment, all of which
report to the corporate headquarters located in Perth, Western
Australia.
2.2 Navitas University Programmes Division UK's
Colleges are located on university campuses in Aberdeen (Robert
Gordon University opening in October 2011), Cambridge (Anglia
Ruskin University), Edinburgh (Edinburgh Napier University opening
in June 2011), Hertfordshire (University of Hertfordshire), Plymouth
(University of Plymouth), Portsmouth (University of Portsmouth),
Swansea (Swansea University) and West London (Brunel University),
locations which enable students to experience the UK city, climate,
culture and lifestyle of their choice. Navitas' partner universities
are internationally renowned for their teaching and research.
2.3 Navitas understands that students coming
from all over the world have different English language, academic
and career levels and aspirations, so Navitas Colleges in collaboration
with their respective Host Universities provide a range of degree
pathways inclusive of flexible programme intake start dates to
suit students' pedagogical and personal needs. By studying with
Navitas, students join supportive, educationally focused communities
that help them to integrate into the UK culture, develop personally,
maintain balanced lifestyles and achieve their academic and career
potential before returning home armed with strong emotional, linguistic
and economic ties to the UK.
3. FACTUAL INFORMATION
3.1 The Navitas Colleges in the UK, under their
legally enforceable Recognition and Articulation Agreements, provide
significant third stream revenue to their respective Host Universities
via the direct royalty paid per head each semester (three semesters
in one calendar year) as well as "pipeline" income as
students move through the articulation process and pay the full
University fees directly to the Host University for the remainder
(usually a minimum of two academic years) of their degree programme.
In the period from September 2000 to December 2010 Navitas UK:
- has paid direct royalties to six Host Universities
totalling GBP £13,241,295.00;
- facilitated access to university education for
c 16,400 students who would otherwise have been denied access
to a UK University degree and a UK cultural experience; and
- facilitated Host Universities' access to c GBP
£220 million in pipeline income ie that income derived from
students progressing through the articulation agreement from a
Navitas College to their respective Host University in order to
complete their degree studies.
Indeed in the current financial year (2010-11) alone
our Host Universities will receive over GBP£6 million in
royalties and c GBP £27 million in pipeline revenue.
3.2 Any reduction in international students as
a result of visa constraints would have a severe financial impact
on a HE sector already under threat from funding cuts.[46]
3.3 Non-EU students from degree-preparation courses
are a significantly critical source of students for UK universities.
Universities UK (UUK) has estimated that 46% of all non-EU students
admitted to UK universities come via preparatory programmes inclusive
of those entering via formal, on-campus articulation and recognition
agreements. 37% of Navitas UK's annual revenue is derived from
its degree preparation route, a loss of this revenue would jeopardise
some 300 positions across the UK and would impact significantly
on both the direct royalty payments and pipeline income for our
Host Universities.
3.4 The regulatory regime should also be consistent
and equitable across both public and private providers; prohibiting
institutions from offering NQF Level 3 may well raise legal issues
such as restraint of trade.
3.5 Non-EU students make a significant contribution
to UK universities to the tune of between 10-30% of total income,[47]
the substantial contribution via full fees i.e. cost recovery,
ensures the enviable breadth of courses available in the UK is
protected.
3.6 Non-EU (International Students) have been
incorrectly categorised as an immigration risk, when in fact they
are "Education Tourists" who make an extremely important
economic contribution to the UK. These students main domicile
is outside of the UK and they return home on a regular basis for
holiday periods, so Government's intention to restrict an invaluable
export earning industry in this way does not match the need to
rebuild the economy and engage private industry to a greater extent.
The Government's own data illustrates that of the 186,500 students
granted visas in 2004, only 5,568 later gained settlement rights—ie
only 3%.[48]
Overall international students have a minimal effect on net migration
as there are approximately the same numbers of students leaving
the UK each year as there are entering it. It is also arguable
that the UK should be welcoming of UK-educated, highly skilled
workers who will make an above-average contribution to the UK's
economic future and also make excellent ambassadors for this country.
The Government should be targeting reductions in settlement rather
than using the student cum Education Tourist route to reduce net
migration, given that the Government's own data illustrates that
this is the group contributing the least to the net migration
problem.
3.7 A 2007 British Council Report stated that
in 2003-04, the Education and Training export sector was worth
£27.7 billion.[49]
In 2010, the sector estimates this to be closer to £40 billion
and thus the UK's second biggest contributor to our net balance
of payments, after financial services.
3.8 International students' contribution in tuition
fees and living costs to the UK economy each year qualifies them
as "wealth generators" for the UK economy. In addition
to the full cost recovery course fees paid to a Navitas College
for example, our students (all of whom are non-EU), and staff
(we focus on employing from the local community) bring significant
income to the local as well as the national economy through their
spend on accommodation, food, transport (rail, bus, taxis, air
and the purchase of motor vehicles), communication, clothing,
leisure and social activities. This translates to a conservative
estimate of economic impact for the 2009-10 student cohort's academic
year of c GBP £27 million from students in the Navitas UK
College network. Given the diversity of locations of our Colleges
this is an important regional economic impact. Students are also
visited regularly by family and friends further adding to the
economic value add element.
3.9 There will be major job losses in the public
and private sector as a result of a cap on international students.
These job losses may well be concentrated in areas where there
are large numbers of private and public educational establishments
which are the key employers in those regions.
3.10 The negative material impact on GDP of unnecessarily
tightened visa restrictions for non-EU students at a time when
the UK needs thriving export industries and harbours an expectation
that the private sector will pick up the shortfall in government
spending, will be considerable. The Australian government
for instance has just acknowledged the negative material impact
on GDP that its recent tightening of visa restrictions for international
students has had. Job losses in the sector are expected to be
in the thousands, including university staff.[50]
3.11 The global education sector is the largest
industry sector in the world after healthcare, and an industry
in which the UK has a pre-eminent advantage with "our"
language and the gold standard quality of our education system.
3.12 International students can legitimately
stay in the UK to study for up to eight years, as many enter the
UK to study GCSEs followed by A-levels, in order to win places
at UK universities and therefore it needs to be noted that students
who are still in the UK after five years are more likely to be
engaged in longer term study pathways than staying illegally.
3.13 The reason many international students have
to undertake preparation programmes prior to entry to a UK university
is because many countries have a 12-year secondary system (in
contrast to the UK's 13 years), and often both English language
and study skills need to be improved. Pedagogically this is sound
practice as our academic outcomes and success of our students
when they transfer to the host university attest.
3.14 Unlike EU students, who study at
UK universities under subsidy from the taxpayer, non-EU students
provide valuable full fee income, which subsidises domestic students'
places, builds numbers in declining programmes of study and helps
to sustain the quality of research and teaching in our world-class
university sector.
3.15 International students not only enrich
the learning environment for domestic students and provide substantial
economic support to universities, but also act as valuable ambassadors
for future commercial, diplomatic and cultural ties that benefit
the UK. We note here the Prime Minister's recent trips to India
and China in which he emphasised, "...how much we [the UK]
want to welcome international students to Britain". Proposed
changes to the student visa regime do not support this statement.
3.16 In addition to the in-country economic value
add of non-EU students to the UK, the UK also benefits from the
global networks and links the education services export industry
has established, particularly in key source countries such as
India and China, which are also foreign policy priorities. Given
the particularly high levels of satisfaction experienced in the
UK by non-EU students during their study programme, it is sensible
that the UK should capitalise on this potential for life-long
advocacy for the UK.
3.17 English language competency does not equate
to academic ability or capacity. The course accreditation process
should determine what English language level is required to ensure
success in an academic programme. Further, restricting the evidence
base to a limited number of tests of English language will have
significant implications for all institutions as this will dictate
what English language tests can be used by institutions to assess
students. It appears to entirely exclude the assessment and expertise
offered not only by universities but also by the many bona-fide
English language centres in the UK. Proposals related to English
language may be viewed as intruding into institutional autonomy
through setting particular requirements that have to be met before
students can be admitted and so interfering in admissions decisions
related to academic capability. It also appears at odds with the
approach taken in the United States, where institutions are able
to specify their own language requirements. The focus should be
on encouraging non-English language speakers to learn the language
in the UK in appropriately monitored and regulated English Language
Centres thus ensuring the integrity of the language as well as
earning important export income for the UK.
3.18 Recent increases (2008-09) in student visa
applications are not a reliable and objective indicator of a concomitant
increase in abuse. The declining value of the pound against many
other currencies alone has made the UK a much more affordable
study destination.
3.19 Non-EU students pay the full cost of their
education in the UK; have to prove that they can cover the cost
of their maintenance whilst in the UK; have very limited work
rights and cannot fill a permanent vacancy; have no recourse to
public funds and cannot claim any benefits related to housing
or living costs; have no right to stay beyond the period set in
their visa conditions. Given this, it is difficult to determine
what benefits a reduction in their numbers will have for the UK.
4.0 RECOMMENDATIONS
FOR ACTION
It is suggested that the following recommendations
be considered:
4.1 Require non-EU students to obtain private
health insurance or purchase National Health credits as part of
their visa acquisition process thus reducing the potential for
abuse of the student route to obtain medical services via the
NHS.[51]
4.2 Impose a reasonable and agreed (with the
export services industry) per-head (of non-EU students) levy on
each institution to provide the UKBA with additional funding to
resource comprehensive compliance measures.
4.3 Implement a risk-based approach on a country-by-country
basis to enable streamlined visa processing procedures for lower
risk countries.
4.4 Charge one higher education (possibly a new
one) accrediting body with the responsibility for:
- accrediting private sector providers under new
and enhanced accreditation requirements inclusive of a Quality
Assurance Agency (QAA) audit; and
- reducing the number of least compliant institutions
and removal of same from the Register of Sponsors.
4.5 Require students to pay all fees in advance
for courses of up to six months duration and at least two-thirds
of the first year fee for courses longer than six months duration.
4.6 Implement a tuition assurance scheme/insurance
scheme to protect pre-paid fees in the event of a closure (either
forced or voluntary).
4.7 Redefine students as "education tourists"
and therefore "temporary" visitors as opposed to "immigrants".
4.8 Move the focus of regulation and statistical
analysis related to students from net migration to settlement.
4.9 Implement a "whole-of-course" visa
approach for those institutions in legally enforceable, collaborative
partnerships designed around the provision of an education continuum.
It would effectively lock students into an agreed study pathway.
It is a system that would facilitate better tracking of students;
enhance progression and completion rates and prevent unnecessary
movement of students. In addition, such an approach would encapsulate
processes for inter-institutional transfer for those students
who need to/must transfer because of the nature of their programme
of study e.g. A Levels moving to HEI/FE; Foundation to HEI/FE;
or English language moving to academic/vocational studies. It
would also reduce the costs and inconvenience that students experience
when moving from one institution to another, thus keeping the
UK competitive and makes providers more accountable.
4.10 Make transfer from temporary e.g. the student
route, to permanent migration routes much more difficult.
4.11 Classify all post-study work as "not
leading to settlement" but maintain the current post-study
work entitlements in order to ensure international competitiveness.
4.12 Restrict work rights for shorter courses
ie those courses = 12 months in duration.
4.13 Remove the right to bring dependents if
enrolling on shorter courses ie those courses = 12 months in duration.
4.14 Remove work rights for dependents of students
on courses = 12 months in duration.
4.15 Continue to allow those visitors to the
UK on business or tourist visas to undertake a short course of
study/professional training at accredited and registered institutions.
4.16 Remain with the B1 level requirement for
English language courses and allow institutions to determine the
most appropriate method of determining English language levels
and entry points to English language programmes.
4.17 Allow private institutions offering bona
fide NQF Level 3 degree preparation programmes via legally enforceable
articulation and recognition agreements with a nominated Host
University to continue offering these validated programmes of
study.
4.18 Agree with the sector, discrete definitions
for sub-degree and pre-degree preparation programmes.
4.19 Adopt an agreed and generally accepted definition
of "pre-sessional courses".
4.20 Complete the current review and then leave
the visa system unchanged for at least one year after which changes
should only be introduced on one of two set dates each year eg
1 January and 1 July.
4.21 Establish appropriate consultancy mechanisms
whereby all registered and accredited providers can provide feedback
and input to future decision making processes related to this
vitally important education services export industry.
4.22 Undertake a comprehensive but separate review
of HTS in order to determine its real value-add particularly as
it was introduced in great haste and without consultation.
January 2011
45 See www.abc.net.au/lateline/content/2010/s3068304.htm;
New Zealand: New Zealand to make student immigration easier-Work
Permit.com; US: U.S. Voters Support International Education, Poll
Finds-The Chronicle. Back
46
www.compas.ox.ac.uk/fileadmin/files/pdfs/Non_WP_pdfs/Events_2010/COMPAS%20Breakfast%20Briefing%20Summary%20October%208%20Ursula%20Kelly.pdf Back
47
International Students in the UK: facts, figure- and
fiction: September 2010 UKCISA. Back
48
The Migrant Journey, Home Office, September 2010. Back
49
Global value: The value of UK education and training exports:
an update, British Council, Pamela Lenton, Dr of Economics,
University of Sheffield, September 2007. Back
50
www.abc.net.au/lateline/content/2010/s3068304.htm. Back
51
See the Australian Government's requirement of Overseas Student
Health Cover (OSHC) at
www.studyinaustralia.gov.au/sia/en/studycosts/oshc.htm) Back
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