Written evidence submitted by Russell
International Excellence Group (SV51)|
The Russell Group represents 20 leading UK research-intensive
The international mobility of staff and students is essential
to the success of any world-class university. As such, the Russell
Group is very much affected by changes in immigration policy.
Moreover, at the current time, with direct public investment in
universities set to fall dramatically over the coming years, fee
income from international students has never been more important
to the sector.
The Russell Group shares the Government's commitment
to improving the public's confidence in the immigration system
and its concerns about abuse of the student visa route. Universities
have invested in professional staff and processes to ensure they
are able to meet fully their obligations as Highly Trusted Sponsors
(HTS) within the Points Based System (PBS), and are committed
to working closely with UK Borders Agency (UKBA) to improve further
the integrity and efficiency of the system in the future.
This document provides a summary of the importance
of immigration to Russell Group universities, and comments on
the Government's recent proposals for reform of the student immigration
routes. We have some key concerns about the Government's proposals
which can be summarised as follows:
- The opportunity for post-study work is important
in attracting the best international students who contribute the
most to the UK.
- High quality sub-degree provision, including
preparatory courses, English language courses, school and FE provision
are essential pathways from which many of the best international
students progress to undergraduate and postgraduate degrees at
- Raising English language requirements for all
international students is unnecessary and could be counter-productive.
- Removal of the right for dependents to work in
the UK could have a negative impact on recruitment of certain
students, particularly postgraduate researchers.
- Reputation and perceptions are important. Perceived
difficulties with visa applications and bureaucracy do influence
international students in choosing their country of study. The
UK should be projecting the message that it welcomes genuine international
1. International mobility of staff and students
is essential to the success of world-class universities
1.1 The ability to attract the most talented
students and staff from within the UK, the EU and internationally,
is essential to the success of the UK's leading universities.
There is a fierce global market for the best academic talent,
and our track record in attracting international staff and students
has made a very important contribution to the considerable success
of UK higher education to date.
1.2 The Russell Group accounts for nearly a third
of all international (ie Non-EU) higher education students in
These students, nearly 60% of whom are postgraduates, make a vital
contribution to the academic endeavour, and to the international
standing of our leading universities.
1.3 Through their tuition fees and living expenditure,
we estimate that non-UK students at higher education institutions
in the UK bring investment of at least £5.8 billion to our
Of all non-UK students, 68% are from outside the EU. Higher education
is an excellent export industry for the UK.
1.4 International staff are equally important.
Nearly a third of academic staff at Russell Group institutions
are non-UK nationals. Of these, more than half (over 9,000 staff
in total) are nationals of non-EU countries.
As world-class research universities, it is vital that we are
able to attract the most talented academics, from early career
researchers to eminent professors, able to contribute to maintaining
the UK's status as a leading nation for science, research and
innovation. As eight British-based Nobel prize-winners recently
warned, the UK cannot afford to isolate itself from the increasingly
globalised world of researchour success in science depends
It is not realistic to expect UK universities to meet all their
staff recruitment needs from within the EU. It takes a substantial
amount of time to 'train' someone for an academic job and this
relies on education throughout an individual's life.
1.5 Some subjects and disciplines are particularly
dependent on international staff and students, including Engineering,
Maths, Chemistry and Physics.
1.6 In addition, universities invite international
academics to come to the UK as sponsored researchers, visiting
academics, external examiners, conference speakers and other kinds
of visitors. These visits support important collaboration and
exchange between universities and academics in this country, and
those around the world.
2. Fee income from international students
has never been more important to universities
2.1 At a time when direct public investment in
universities is being cut by billions of pounds, international
student fees represent an absolutely critical income stream to
universities. In 2009 the Russell Group received £847 million
in international fee income, 39% of the sector total. Across the
Russell Group this represents 8.3% of total income but for some
individual institutions international fees make up as much as
30% of total income. If immigration policy were to reduce considerably
the ability of universities to recruit international students
and postgraduates, this would have a devastating impact on the
financial sustainability of Russell Group institutions.
3. Universities are highly trusted sponsors
of international staff and students
3.1 Universities have been very willing to accept
the responsibilities placed on them within the Points-Based System
to monitor international students and staff, and to work with
UKBA to minimise abuse of the PBS system. They have invested in
professional processes and staff to ensure that they are able
to meet fully their obligations as Highly Trusted Sponsors under
3.2 The vast majority of international students
are law abiding, and leave the UK after the completion of their
studies, or when their visa expires. Home Office research has
shown that only 20% of students remain in the UK for more than
UKBA research found that only 2% of students in universities were
non-compliant with the terms of their visa.
4. The opportunity for post-study work is
important in attracting the best international students who contribute
the most to the UK
4.1 The Government's consultation on the reform
of the student immigration system, published on 07 December 2010,
includes a proposal to close the Post Study Work (PSW) route.
We have some serious concerns about this proposal:
- (a) It is likely to have a very negative
impact on admissions, because many international students feel
it is important to consolidate their studies with some work experience
in the UK.
The UKBA is concerned that many PSW applicants do not enter skilled
work. However, we do not believe this is a widespread problem
for international graduates of Russell Group universities.
- (b) For some international students, a period
of post-study work in the UK is essential to the financing of
their studies here. For students from developing countries in
particular the higher earnings they can secure in the UK after
they graduate go some way towards making the higher university
fees in this country affordable.
- (c) There are some professions (eg engineering,
law) that require a period of work in the UK for qualification
or registration. Without the opportunity to work here, the attractiveness
of such courses for international students would be reduced.
- (d) Any introduction of this proposal must
be carefully phased in. There are thousands of international students
already at our universities who came here in the belief that PSW
would be available to them after they complete their course. It
would be very unfair to close the programme before current students
have had the opportunity to apply.
- (e) The closure of the PSW route risks damaging
businesses and the wider economy of the UK. Many of the innovative
spin-out companies which emerge from Russell Group universities
are established by entrepreneurial international graduates. Students
who remain in the UK for a period of post-study work bring unique
skills and experience to their employers here and many continue
to generate economic benefit to the UK by maintaining their professional
links with this country once they leave.
- (f) The PSW route is also important to universities
as employers, because it enables us to offer post-doc opportunities
to international students completing PhDs. Without the PSW route
we would only be able to use Tier 2 (skilled workers) for such
appointments. Given the other pressures on Tier 2, this would
lead to a reduction in the international post-docs we could appoint.
4.2 The consultation document says that the Government
recognises there are other options short of closing the PSW route
entirely. One option mentioned is limiting PSW to graduates with
higher level degrees. We would urge the Government to consider
retaining the PSW route, at least for graduates of higher level
degrees (such as Masters and PhD).
5. High quality sub-degree provision is an
essential pathway to undergraduate and postgraduate study
5.1 A key proposal within the UKBA's consultation
on the reform of the student immigration system is to raise the
level of courses international students can study, with only Highly
Trusted Sponsors (HTS) able to bring in international students
to enter courses below degree level.
5.2 If this proposal is implemented, it would
become absolutely essential for Russell Group universities to
be confident of being able to retain their HTS status, which is
still a relatively new category of sponsor. We hope UKBA will
work closely with universities in the development of the HTS category
in the future to ensure that universities are fully aware of any
changes to the requirements for HTS status, and that maintaining
HTS status does not place unreasonable costs or burdens on universities.
5.3 This proposal will directly affect the very
wide range of education providers who bring students to the UK
to study courses that are below degree level. It will also have
an indirect impact on universities. A significant proportion of
international students at Russell Group institutions are not recruited
directly from overseas, but are already in the UK when they apply
to the university. We understand that at some Russell Group institutions
up to half of their international students at undergraduate level
fall into this category. This includes students who study in the
UK at independent schools, FE colleges, language schools and other
private education providers.
5.4 For many international students, even very
talented ones, it is difficult to enter a Russell Group institution
directly from study in their home country. Some kind of additional
English language or education preparation is necessary to prepare
them for application and success at a leading UK university. Where
such courses are provided by institutions which do not have HTS
status, this proposal may mean that they can no longer recruit
non-EU students. If high quality preparatory courses available
in the UK are greatly reduced it will make it more difficult for
universities to recruit good international students, particularly
at undergraduate level.
5.5 Russell Group universities have developed
a wide range of pathway programmes specifically designed for international
students, which combine academic and English language preparation,
at a sub-degree level, with the aim of preparing students for
progression to degree and/or postgraduate study. In many cases
these are provided in-house by the university, and since universities
have HTS status, we do not anticipate that they will be affected
by the proposed restrictions on sub-degree courses. (We are, however,
concerned that these courses will be seriously threatened by the
proposed raising of the English language requirements. See section
5.6 In some cases, however, universities have
established partnerships with colleges or private organisations
to provide pathway programmes for international students below
degree level. If the partner institution is unable to obtain or
maintain HTS status, then such courses will be affected by this
proposal. For example, University of Manchester provides pathway
programmes in partnership with the private company INTO. If INTO
were to be lose its HTS status this would have a very negative
impact on University of Manchester.
5.7 We welcome the proposal not to make changes
to the visa system for child students, as this should mean that
the independent schools sector is able to continue to recruit
talented students who are able to go on to become international
students at Russell Group institutions.
6. Raising English language requirements across
the board is unnecessary and could be counter-productive
6.1 The consultation recommends a further increase
in the standard of English language required for all students
to obtain a visa. All students, including those on English language
courses, must be able to demonstrate that they have passed a secure
English Language test showing proficiency at level B2 across all
four components of Language testing.
6.2 This proposal will have a potentially very
serious impact on Russell Group universities. Universities currently
sponsor many students who do not have this level of English. Such
students are very unlikely to be on degree programmes, but on
English language programmes, or on pathway programmes, which include
both language training and other academic preparation for degree
programmes. Whilst there is an exemption for pre-sessional courses
of up to three months, many students study on preparatory programmes
for up to a year before embarking on an undergraduate or postgraduate
degree programme. Such programmes, whether provided directly by
a university, or by a partnership organisation risk being affected
by the proposed changes to English language requirements. For
- (a) University of Glasgow runs a 12 month
pre-sessional English course. This programme enables students
to progress onto degree programmes with high standards of English.
- (b) University of Manchester has a range
of preparatory courses for international students. Some of these
programmes are sponsored by key partner organisations (e.g. the
Saudi Government) and include programmes for students aiming to
progress onto postgraduate research degrees, as well as postgraduate
taught and undergraduate programmes.
- (c) University of Leeds offers a total of
nine pathway programmes for international students, across a range
of subjects including Arts, Dentistry, Engineering and Science.
Many international sponsoring organisations and companies choose
to place their sponsored students on the foundation year programme.
- (d) University of Warwick has a international
foundation programme that was established in 1983, which is provided
in partnership with two FE colleges, and recruits over 300 students
- (e) Newcastle University has over 500 students
enrolled on a range of pathway programmes provided in partnership
with INTO Universities.
6.3 The introduction of the proposed English
language requirements could have direct and significant financial
consequences for Russell Group universities. Preparatory English
courses and pathway programmes generate important income to universities.
If they are forced to close or restrict such programmes, they
will suffer considerable financial loss, in some cases several
million pounds per year. Moreover, if preparatory courses provided
by universities or their partners are not available this will
remove an important pathway through which some of the best international
students enter Russell Group universities.
6.4 There is a lack of detail in the consultation
document about the rationale for the proposals in relation to
English language proficiency, and the problems they are intended
to address. We remain unconvinced that there is a need for a higher
English language requirement across the board. Moreover, we have
concerns that by setting such a requirement the UKBA is indirectly
determining the entry requirements for degree programmes in the
UK, which should more properly be an academic decision, to be
taken by individual universities, particularly those with HTS
6.5 The consultation document says there will
be a requirement for a 'secure' language test, and level B2 in
4 elements. It is unclear whether this requirement can be met
by students taking any test other than IELTS. Universities currently
accept a number of different language tests (eg TOEFL, IELTS,
PTE), and it is important that the requirement of UKBA does not
pose unnecessary restrictions on the choice of language tests
available to students or to universities.
7. Removal of the right for dependents to
work in the UK could have a negative impact on recruitment of
7.1 The proposal that dependents will lose the
right to work in the UK is particularly worrying to the Russell
Group. It is likely to have the biggest impact on postgraduate
research students, who tend to be older and more likely to have
a partner and/or a family. It is not realistic to expect a research
student to support a family financially in the UK. Without the
right for the spouse or partner to work, the UK may become significantly
less attractive to postgraduate research students. The ability
to attract the most talented postgraduate research students is
essential to the research endeavour and the international competitiveness
of Russell Group institutions.
7.2 If the proposals are implemented, students
studying for less than 12 months will not be permitted to bring
dependents with them to the UK. This may adversely impact on students
from certain countries (eg Muslim women who may not be willing
to travel to the UK without a male relative).
8. Other comments on the Government's proposals
for student immigration
8.1 We welcome the proposal to reduce the requirements
on documentary evidence from students who are judged to be "lower
risk". However, further clarification is needed about the
different requirements for different students, as there would
appear to be some scope for confusion.
8.2 The proposal to raise accreditation and inspection
standards within private providers is very welcome. Institutions
offering poor quality courses, deceiving students or abusing the
student immigration system damage the reputation of the UK as
a world-leader in education. Recent UKBA research has demonstrated
that significant levels of non-compliance occur in the private
further and higher education sector.
8.3 We have some concerns about the proposed
requirement that a student returns home and applies for a new
visa between courses. This will create additional expense and
difficulties for legitimate students and disrupt their studies.
For students progressing from Masters to PhD programmes, there
is almost no time between the two courses. It is not clear whether
this proposal would extend to students who complete a pre-sessional
English course, and then progress to a degree. Again, such students
have only a very short amount of time between the two courses,
and could not possibly return home and apply for another visa
in the time available.
8.4 It is proposed that during their studies
students should not be allowed to work during the week unless
they do so "on campus". We have some concerns about
how the university might be required to monitor their students
in this respect.
9. Reputation and perceptions are important
9.1 It is crucial that the immigration system
continues to support the efforts of our leading universities to
attract talented people who have a legitimate interest in studying,
working or carrying out research here.
9.2 Even before the introduction of PBS there
was already evidence that visa and immigration issues were an
area of concern for international students both before coming
to the UK, and whilst here.
The difficulty (whether actual or perceived) of obtaining a visa
is one of the most important factors in determining applications
from international students.
9.3 The UK should be doing everything it can
to project a message that it welcomes genuine international students
and academics who choose to come here. There is a real risk that
the UK begins to be seen as unwelcoming at a time when our key
competitors such as the US are succeeding in projecting a much
more positive image to international students and researchers.
70 Members of the Russell Group are: University of
Birmingham, University of Bristol, University of Cambridge, Cardiff
University, University of Edinburgh, University of Glasgow, Imperial
College London, King's College London, University of Leeds, University
of Liverpool, London School of Economics & Political Science,
University of Manchester, Newcastle University, University of
Nottingham, University of Oxford, Queen's University Belfast,
University of Sheffield, University of Southampton, University
College London, University of Warwick. Back
For a discussion of the global nature of the market in recruitment
of academic staff, see Terri Kim and William Locke (2010) "Transnational
academic mobility and the academic profession" in Higher
Education and Society: A research report, pp.27-34. CHERI,
The Russell Group accounted for 30 percent of the 251,330 international
students in UK universities in 2008-09. Back
The report Global Value by British Council estimated that
in 2002-03 higher education attracted £2.1 billion of investment
into the UK in the form of tuition fees paid by non-UK students
and that students also accounted for £2.6 billion in other
spending whilst in this country. Given that the total population
of non-UK students in the UK increased by 23% between 2002-03
and 2008-09 (from 300,055 to 368,970), it is likely that tuition
fees and living expenditure of all non-UK HE students now account
for a minimum of £5.8 billion investment in the UK. Back
Data is for 2008-09, HESA. Back
UK must not isolate itself from research world, The Times,
7 October 2010
The Home Office, The Migrant Journey, September 2010. Back
The Student Immigration System A Consultation, UKBA, December
International students were first given the opportunity for post-study
work in 2004, through the Science and Engineering Graduates Scheme,
which was later replaced by the International Graduates Scheme,
and most recently by the Tier 1 (Post Study Work) route. It is
worth noting that numbers of international students at Russell
Group institutions increased by over 25% since 2004, when the
SEGS was first introduced. Back
Broadening our Horizons: international students in UK universities
and colleges, UKCOSA, 2004. Back
What does the future hold? China country report: the outlook
for international student mobility A report by the Economist
Intelligence Unit for the British Council, 2008, pp11. Back