Student Visas - Home Affairs Committee Contents

Written evidence submitted by Kaplan International Colleges (KIC) (SV38)

Kaplan International Colleges (KIC) supports the Government's goal of weeding out abuse of the student system. We also agree with the Home Office consultation document that any proposals should not deter genuine, high quality students from coming to the UK to study. We believe that a number of the proposals under consideration will not only deter these genuine students, but will put our higher education system at a competitive disadvantage and will seriously damage our universities and the UK's economy.

Further, while recognising the Government's commitment to reduce net migration, we would point out that students, as a group, make the least contribution to net migration. International students are, by definition, temporary students who fund their own expenses, have no recourse to public funds, and return home at the end of their studies. And, with the Government's top priority being to reduce the deficit, we question the wisdom of limiting growth opportunities in a sector that contributes between £5-£10 billion each year to our economy.

Compliance action should be targeted on areas of abuse, not colleges with good practice already established. KIC endorses the principles of the Highly Trusted Sponsor scheme but it is reviewed with a view to make it more practicable and less labour intensive for HTS sponsors. Accreditation arrangements should also be improved. This may result in a reduction in the number of international students, but that should not in itself be the primary policy objective.

We should not lose sight of the considerable progress over the last three years in tightening up the whole student visa system. There is, however, a need to let these measures take effect, and for there to be a period of stability before any further blanket measures or restrictions are introduced.


1.  The Coalition Agreement stated that the Government would set an "annual limit on the number of non-EU economic migrants admitted into the UK to live and work". It further stated that the Government "will introduce new measures to minimize abuse of the immigration system, for example via student routes". We note that the document does not propose a limit on the number of international students, nor does it suggest that the number of international students should be reduced (except implicitly as a consequence of minimizing abuse). We support the objectives set out in the Coalition Agreement.

2.  The current proposals, however, are set in the context of "reducing net migration". The policy objective of reducing net migration is in itself not particularly meaningful. It does not in fact matter if students enter the UK and remain here legitimately for more than a year on a course. What matters is whether they leave when they have completed the course, or whether they switch into a route leading to settlement. In other words, the ultimate and proper policy objectives are ensuring compliance with visa conditions, and reducing permanent migration, settlement and citizenship. The present proposals do not offer a particularly effective way of meeting these objectives and risk significant harm to one of our most valuable growth sectors.

3.  There does not appear to be any modelling of what impact the different proposals would have, either separately or cumulatively. Nor does there appear to be any set timescale. Reducing net migration is taken as a sufficient objective in itself, yet there is no indication of by how much it should or will be reduced by these proposals, nor by when. This does not give confidence that the impact of the proposals has been fully considered and that their possible outcomes are known with any certainty. Our view is that if there are measures which should be taken for immigration control reasons, such as ensuring compliance, then those measures should be taken, and any reduction in net migration as a consequence is incidental, but that it is a mistake to set a reduction in net migration as the primary objective.


The main impact would be caused by raising the level of English required for a Tier 4 visa from CEFR level B1 to B2. This would have a severe impact on the numbers of students coming into the UK since UK universities recruit around half their international students from English language and other university preparatory or "pathway" courses. Pathway courses are pre-degree not sub degree courses and can be defined as courses of pre-university study up to 18 months duration, including English and other academic study, either formally validated or otherwise officially recognised by a partner university.

They include a Foundation course which, on successful completion, allows the student to enter an undergraduate programme (this should not be confused with Foundation Degrees), and Pre-Masters or Graduate Diploma courses which allow students on successful completion to enter a post graduate masters programme. Pathway programmes have three main objectives: (1) to improve students' command of English to the level required for university entry (which is around level B2 or IELTS 6.0-6.5); (2) to teach the skills of independent study, necessary because many other parts of the world hold to a more didactic style of pedagogy; and (3) to top up students' subject knowledge (and in the case of the Foundation course, to top up their academic level to the equivalent of our Year 13, the second year of A level, which is not a required in many countries, ensuring all students start a degree course with more or less the same level of UK curriculum).

KIC estimates that around 70% of our current students who eventually progress on to pathway programmes initially arrive in the UK with an English level of A2-B1. These students would not be able to gain T4 visas for pathway courses if the level required was raised to B2. Across all pre-university courses (pre-sessional English and pathway programmes) there would be a loss of 35-40% of international students going into universities. At a time when many universities rely on the higher fee income from international students to maintain course options and departments, this would have a serious impact and it is no exaggeration to say that the financial stability of some universities would be threatened. The level of English required should either be set at A2, meaning that students would have a year to go up two levels to achieve university entrance standard, or as an alternative, the extended 11-month Student Visitor visa should be given one entitlement, which is to be able to switch in the UK to a T4 visa for the purposes of going on to a degree (or degree equivalent, NQF level 6) course. This we feel should at least be considered as a more flexible approach for HTS sponsors who have already demonstrated a high level of compliance.

KIC support the suggestion to reduce the level of abuse and to raise the standards of compliance to the highest level by working within the framework of HTS (all KIC Colleges are already HTS status). We also commit to work with the education sector to streamline accreditation and to achieve consistency of standards. If the consultation decided to move to a review of the existing accreditation systems, it would be vital for a continuous and close liaison between the relevant government departments, accrediting bodies and educational specialists within each sector to ensure the changes and reforms were appropriate to each sector, type of institution, and courses being delivered.

Generally the Home Office and the current consultation do not take into account the progress which has been made in tightening up the student visa system over the last three years when there were over 4,000 colleges on the DIUS Register of Education and Training Providers. There are now fewer than 2,000 on the Register of Sponsors. Colleges are limited in their annual allocation of Confirmation of Acceptance of Studies, and without a CAS, a student cannot get a visa. The electronic Sponsor Management System gives UKBA a wholly new dimension of control and security. The SMS and CAS together have removed one whole area of visa fraud through forged enrolment letters. Students now have to give biometrics as part of their visa application, which cuts down on impersonation and other forms of identity fraud. Other control measures in the last year have been the Highly Trusted Sponsor scheme, the limiting of lower level courses to HTS colleges, and the introduction of Secure English language tests for non-degree students. We can see no good reason to expand SELT or increase restrictions as has been proposed which would only result in more resource and cost in applying for and processing visas and further delays.

Accredited HTS institutions, including KIC, have robust quality assurance assessment and monitoring systems in place. Many of these have been developed with, and approved by, prestigious university partners to demonstrate each student's progress and progression. To place further demands and insist on more record keeping and reporting would be unnecessarily time consuming and would remove trust from the HTS institution.

Equally, requirements that students needing a visa for a new course should return home to apply are likely to be highly discouraging and will act as a considerable disincentive to come to study in the UK in the first place. In our response to the consultation we shall be arguing that UKBA needs to consider much more specific, targeted and graduated action.

To conclude, the UK student visa system has been changed radically and almost continuously over the past three years. While most of the changes have led to greater control, the pace and unpredictability of change and the prospect of more is not helping to make the UK an attractive study destination and this will result in key markets loosing confidence in UK study. KIC believes that the proposed changes discussed here do not have an adequate policy rationale and their impact could potentially be severe detrimental to the education sector. It would be preferable for UKBA to address any remaining areas of abuse in a more graduated and targeted way, which it has the powers to do.

January 2011

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