Written evidence submitted by the University
of Oxford (SV21)
EXECUTIVE SUMMARY
Our response to the UK Border Agency proposals is
outlined in the sections below. A summary of our main concerns
is as follows:
1. Closing the Post-study work route will deny
us the talents of young researchers whom we have trained as students.
It could seriously undermine our international competitiveness
as post-study work experience is often a determining factor for
applicants when choosing a country where they wish to study.
1.1 The proposal to only permit on-campus employment
during the week is impractical to administer and negatively affects
community integration.
1.2 Removing the right to work for all dependants
and not allowing them to accompany students if the course is less
than 12 months makes financial and pastoral support for couples
and families very problematic. These students may go instead to
our competitors abroad who offer more child/family-friendly visa
policies.
1.3 The introduction of the new points based
system has made the visa application process more complex and
confusing for students. In the summer of 2010 nearly 100 students
coming to Oxford were refused visas, mostly on minor technicalities,
and had to reapply. Further proposals that make the process even
more complex could deter applicants from applying to Oxford and
UK HEIs in general eg additional English language tests, tighter
requirements for academic progress, and not allowing students
to extend a visa within the UK.
1.4 Seeking assurance that students will still
be able to gain a visa for A-Level or Foundation courses is important
as they act as a crucial feeder route for our intake of undergraduate
students.
INTRODUCTION
2. The University of Oxford is a world-class
university with a strong international reputation. A key element
for our success lies in attracting the best students from schools
and universities worldwide. A third of our students and staff
come from outside the UK. The University has nearly 5,000 non-EU
students (ie those who may require a student visa) on course at
any one time, which represents 24% of our total student population,
and our students come from over 120 countries (including EU and
non-EU countries). When we focus on the graduate student population
within these figures, the non-EU percentage of the population
is much higher at 41%. Nearly 60% of our graduate applications
each year are from outside the EU.
2.1 Our international student and staff profile
generate an exceptional diversity in our academic and cultural
life. We are concerned that the proposals outlined may deter students
from choosing Oxford or the UK as a study destination. There is
a potential impact on our research activity if we are not able
to attract the best students to work and study in highly specialised
areas of research for which we cannot often recruit suitably qualified
UK/EU candidates. These students will go to the US instead. With
the introduction of higher fees for UK/EU undergraduate students
in the near future following Lord Browne's report, we may see
a shortfall in applications and it will therefore be increasingly
important that we can recruit competitively internationally, to
garner the most talented undergraduate students suited to our
highly academic courses.
2.2 The forecast income for Oxford University
for 2010-11 for non-EU students' fees is £72.5 million compared
to the income from Home and EU students' fees of £54 million
which is then supplemented with £68.8 million from HEFCE
income. Whilst we do not seek to recruit overseas students to
profit from the higher tuition fees it does demonstrate what a
large undertaking of teaching the University provides. The fee
income and corresponding daily expenditure by overseas students
represents a significant injection of capital into the local economy
from the overseas student body.
2.3 The University of Oxford is classed
as a Highly Trusted Sponsor of students by the UKBA. The University
should be classified as a very low risk institution because of
our stringent admission procedures, very high English language
requirements, a very low drop-out rate, and our systematic and
accurate student data management system which readily identifies
any absence or academic progress issues. However, when applying
for a visa our students face the same bureaucratic obstacles and
delays that students going to higher risk institutions also encounter.
2.4 The points-based system, while welcomed for
its greater transparency and less subjectivity, has introduced
more complexities into the visa application process for our students
and generated considerable confusion and frustration. The requirements
for documents have become much more specific and must be presented
in the exact correct format. Over the summer of 2010 we had a
large number of visa refusals, often on minor technicalities,
which caused some students to arrive late or to even consider
withdrawing from their course at Oxford.
UNIVERSITY OF
OXFORD RESPONSE
TO UK BORDER
AGENCY PROPOSALS
Our response to the proposals is divided into five
sections as outlined in the UK Border Agency consultation document.
Raising the level of courses students can study
3. Oxford only offers a few below-degree level
courses so the proposal to restrict courses to degree level, or
below degree level for Highly Trusted Sponsors would not be a
detrimental change for Oxford. We are concerned that many of our
international undergraduate students come to us via A-Level Colleges
or Foundation courses in the UK. However, most reputable A-Level
colleges and institutions offering foundation courses are already
Highly Trusted Sponsors so the direct impact may be small, providing
those institutions retain that status.
3.1 Data from our 2010 intake of non-EEA undergraduate
students shows that many of them apply from within the UK to commence
at Oxford. We received 2,905 applications of which 666 were already
studying in the UK, i.e. 23% compared to a sector wide average
of 33%. From these applications we made 388 offers and 102 of
these students were already studying in the UK, i.e. 26%. This
shows a high level of co-dependency with the FE sector. Any measures
or policy statements that send a negative signal to potential
applicants about the possibility to gain a visa for A-Level, Foundation
courses or other below degree level courses could lead these students
to avoid studying in the UK, and in turn, they may not apply to
UK HEIs.
Introducing tougher entry criteria for students
4. At the moment universities are free to make
their own assessment of a candidate's English language competency
and it is not part of the visa application process. Our English
language requirements are set very high at IELTS 7.0 for undergraduate
study and IELTS 7.0 or 7.5 for postgraduate study compared to
the proposed UKBA minimum B2 level which is equivalent to IELTS
5.5. Students are required to submit a test result by an approved
examining body which already meets the UKBA list of approved examiners.
The proposal to require English language test results as part
of the visa process would therefore put an additional burden on
our students and duplicate an academic condition which had already
been ascertained by the university. This takes away the trust
in universities to make their own capable academic decisions as
Highly Trusted Sponsors.
Ensuring students return overseas after their
course
5. The first proposal in this section states
that students wishing to remain in the UK after their first course
to start a new course would have to show evidence of academic
progression to a higher level. This does not allow flexibility
for students to take a second Master's if they had a change of
career direction, or if they were seeking to pursue a doctoral
degree at a later date and we were to recommend a second Master's
as a basis/revision for the later doctoral study.
5.1 The second proposal to require such students
to return to their home country and apply for a new visa would
not only be a major bureaucratic inconvenience to the majority
of students, but a considerable expense which they may not have
the funds to meet. A large proportion of our student intake
each year, an estimated 30%, are already in the UK taking another
course of study and apply for a visa extension within the UK to
start at Oxford. Returning home could be very problematic given
the long processing times for visa applications in some countries,
and the potential cost could be a factor in students deciding
not to study at Oxford. Many students would find the timescale
very difficult as with final papers and graduation ceremonies
due over the summer or even until September, they may not have
adequate time to return home and obtain a new visa.
5.2 Gaining Entry Clearance overseas offers no
right of appeal if the application is rejected; this is in contrast
to extending within the UK which does offer a right of appeal,
so students are further disadvantaged by being required to return
home. If the intention is to capture a small minority of students
who might be seeking permanent settlement through long-term residency
in the UK, or those not wishing to return home for other reasons,
it seems disproportionate to penalise genuine students progressing
through the UK education system. If this policy is implemented
an exemption should be given to Highly Trusted Sponsors to allow
students to extend within the UK.
5.3 The third proposal to close Post-study work
is of very serious concern to us as with the closure of Tier 1
and a cap on Tier 2 there would be very limited opportunities
for talented students to gain work experience in the UK. We are
particularly concerned about opportunities for exceptionally talented
students to stay on for highly specialised post-doctoral positions,
for which most job-seekers in the UK would not be qualified to
apply. If we cannot employ the graduate students we have so highly
trained, we will deprive ourselves of a real asset to the research
effort which sustains our leading international competitiveness.
5.4 Our internal findings through student surveys
such as the Student Barometer[67]
and research by our Careers Service show us that opportunities
for work experience during and after study are seen as essential
by prospective and current students. The UK currently performs
badly in this area compared to our competitors overseas. Further
restricting these possibilities to work will make it more difficult
to attract the best students from overseas to study here.
5.5 We would strongly suggest that instead the
Post-study work route should be refined. Possible options could
include allowing students from a Highly Trusted Sponsor University
to work for a Highly Trusted Sponsor Employer, a shorter length
ie one year only, restricting it to specified subject areas, restriction
by course level, or requiring a job offer at a certain salary
level before Post-Study work is granted. We would suggest that
such refinements should be the subject of future consultation
with the sector.
Limiting the entitlements of students to work
and sponsor dependants
6. The first proposal in this section to only
allow work on campus during the week and off campus at the weekend
or vacation periods would be very impractical to administer, or
to explain to students and employers. It also isolates students
from the local community and undermines integration efforts, especially
as many UK Universities are not campus based and are located within
cities or towns. As a collegiate university we would need an exact
definition of what constituted work on campus. This proposal could
exclude students from valuable opportunities to work part-time
in our large number of independent spin-off or partner companies
and institutions conducting ground breaking research in scientific
areas. We do not understand the exact rationale behind this proposal
and fear that it may also push home students out of on-campus
employment opportunities.
6.1 The second proposal to remove permission
for all dependants to work is again of serious concern for us,
as for longer courses this could be a very negative factor that
deters students from applying to Oxford. Undergraduate and graduate
research students would find it very hard to support dependants
if they were self-funded. Those coming from poorer countries would
face a particularly great burden. Scholarships are usually only
funded for the cost of one person so this could deter well qualified
applicants from taking up prestigious awards such as our Rhodes
and Clarendon scholarships. It also raises a pastoral care issue
for universities and the student visa holder in finding an activity
for the dependant to be engaged in for several years, if no work
is permitted.
6.2 The third proposal to restrict students on
courses of less than 12 months from bringing dependants would
be seen as a very negative factor in students deciding whether
or not to study in the UK. This would rule out our nine-month
Master's and 12 month Master's course students (short of 12 months
by a few weeks) from bringing their dependants. We also have a
large number of students who come from the US as visiting students
each year for a period of less than one year. We would strongly
suggest that the current position, which is that dependants may
only accompany students if the course is longer than six months,
be maintained. Again, the risk is that these students will choose
to study in the US instead.
Simpler procedures for checking low-risk applications
7. As a Highly Trusted Sponsor and an institution
with robust admission requirements and stringent attendance and
progress monitoring we would welcome this if it made the visa
process easier for our students. However, we understand this could
also be based on nationality which may make the visa process more
complicated and confusing for students. Determining how low risk
countries are to be identified and how it may vary over time seems
controversial and it also removes the subjectivity that was a
defining part of the new points based system. It could also be
seen to be penalising exceptionally talented students from high-risk
countries.
7.1 The second and third proposals in this section
about stricter accreditation procedures do not apply to us directly
as we already meet all the necessary requirements.
Recommendations for the Committee in its report
8 Recommend that alternative options be considered
to closing the Post-study work route (as outlined above) and that
exemptions should be offered for the current cohort of students
if any changes are to be implemented in the near future.
8.1 Propose that students should still be allowed
to bring dependants if the course is longer than six months, and
that alternative options are considered to the proposal of restricting
all dependants from working. Both of these proposals could seriously
affect our ability to recruit the best students and postgraduate
research students would be especially discouraged from coming
to the UK.
8.2 Advocate dropping the proposal that students
be restricted to campus employment during certain periods because
of the complexity of trying to introduce such a requirement and
the negative effect on community integration.
8.3 Recommend that (all) students, or at least
those moving to a Highly Trusted Sponsor, be allowed to extend
their visa within country when starting a new course.
8.4 Emphasise that the academic judgment of Highly
Trusted Sponsors should be relied upon to assess a candidate's
progress and English language ability. Further visa requirements
will only contribute to a more bureaucratic and complex procedure
and deter potential applicants.
January 2011
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