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.
THE POLICY
BACKGROUND
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.
IMPACT OF
THE CONSULTATION
PROPOSALS
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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