Written evidence submitted by Cambridge
Education Group (SV 52)
1. EXECUTIVE
SUMMARY
1.1 Cambridge Education Group employs more than
500 people, specialising in pre-university programmes and preparation
for undergraduate and postgraduate entry, plus short and long-term
English provision. Teaching more than 2000 full-time equivalent
students per year, of whom 90% are successful in progressing to
a UK university, we estimate this supplies universities with approximate
revenue of circa £54 million (once a student completes a
three-year degree).
1.2 Statistics on immigration misrepresent the
intention and actual migration status of international students
who have no recourse to public funds, the vast majority of whom
return home after studying.
1.3 The impact of proposed changes will decimate
a large and vibrant sector of private academic and English language
providers, with a subsequent impact on the UK Higher Education
sector, which is currently worth up to £40 billion to the
UK economy.
1.4 Education providers are the experts in assessing
the suitability of students for particular study plans, of varying
lengths and composition, not the UK Border Agency (UKBA). Forcing
students to return home or frequently renew visas within the UK
means students will find the UK an unattractive, expensive and
uncompetitive study destination and look to the USA, Australia,
Canada and New Zealand as alternatives.
1.5 A sliding scale of ratings (A, B, Highly
Trusted Sponsor) should be rewarded according to the level of
compliance reached, and an enhanced model of accreditation, by
a new, independent and centrally appointed body would be
welcomed, if criteria and compliance are transparently and fair
across the public and private sectors. These ratings should allow
Highly Trusted Sponsor (HTS) institutions unfettered decision-making
authority to accept students onto suitable programmes.
2. STATUS OF
TIER 4 STUDENTS
2.1 The UK's International Education sector unfairly
suffers from an overriding lack of public understanding concerning
the status of Tier 4 students, made more opaque by conflicting
official statistics on net migration. The statistical methodology
used by the government misrepresents the number of students in
the UK at any one time and is impossible to calculate accurately
in the absence of exit statistics. International students have
a minor effect on net migration since there are approximately
the same numbers of students leaving the UK each year as entering
it.
2.2 Rather than focusing on net migration
figures UK government would benefit instead by focusing on the
more "reassuring" settlement statistics and the rigour
of limited transfer from temporary to permanent migrant routes.
According to the Home Office of the 186,500 students granted visas
in 2004, only 5,568 (3%) obtained settlement rights.[81]
If the only reason students are counted as migrants is because
the definition applies to all in the UK for more than 12 months,
why are Student Visitors who, by definition, stay for less than
12 months, also included in the net migration figures?
2.3 Tier 4 students are not immigrants—they
are domiciled abroad and often return home for summer or Christmas
holidays; they do not come to the UK for economic reasons but
rather to study; their time in the UK on a student visa does not
contribute points towards any future application for settlement
and, furthermore, they have no recourse to public funds.
Like tourists, on completion of their visit, they exit the
UK having contributed to the UK economy. If students wish to progress
onto further study or take up employment, they must apply to the
Home Office for a new visa—an inbuilt and existing control.
That some students may legitimately undertake a programme for
up to eight years, from GCSE through University, controlled by
visa application and reapplication, simply serves to underline
the potential contribution made by students towards the UK education
sector and wider economy.
3. IMPACT OF
CHANGES ON
EDUCATION SECTOR
3.1 A 2007 British Council Report stated that
in 2003-04, the Education and Training export sector was worth
£27.7 billion.[82]
In 2010, the sector estimates this to be closer to £40 billion
and thus the UK's second biggest contributor to net balance of
payments, after financial services.
3.2 Universities UK (UUK) estimate that upwards
of 40% of all international students in higher education have
come through a pathway programme such as those offered by our
own centres. Other estimates put this figure as high as 70%. Cambridge
Education Group's Foundation Campus business pays a per capita
"student service" fee each term to each of its partner
Universities pre-degree in addition to the direct full-fee income
as students progress to the university for three undergraduate
years, or one postgraduate year.
3.3 The University of Strathclyde's study estimates
that for every £1 million in HE revenue a further £1.38
million is generated for the wider economy through fees spent
on accommodation, food, local travel, family visits, etc. Each
job created in the sector as a result of international student
income creates and supports a further 1.27 jobs.
3.4 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.[83]
3.5 There will be major job losses in the public
and private sector as a result of a cap on international students.
These are likely to be concentrated in areas where there are large
numbers of private and public educational establishments which
are the key employers in those regions—Cambridge, Brighton
and London being the obvious areas. In particular:
- loss of 500 jobs at Cambridge Education Group;
- loss to UK universities of c 1,800 full-fee-paying
international students per year (directly from Cambridge Education
Group courses); and
- loss to UK universities of £54 million revenue
per year after three years (typically international students spend
>three years with universities with a three year bachelor programme
and then many continue to Master's programmes).
3.6 For an overview of the potential negative
impact on the UK's GDP, refer to what is happening in Australia
as the direct result of international student visa restrictions.[84]
4. RAISING THE
LEVEL OF
COURSES STUDENTS
CAN STUDY
4.1 As pathway providers largely of pre-degree
programmes at NQF levels 3-5, the potential threat to our sector
is of grave concern. We are confident of our ability to comply
with UKBA requirements and have achieved and maintained Highly
Trusted Sponsor status for our standalone centres and those under
the licences of our partner universities—investing heavily
in systems, training and processes to maintain exemplary levels
of compliance, far in excess of that employed by universities.
4.2 The same levels of scrutiny are not applied
in practice to our public-sector colleagues. We insist that the
same criteria to gain and maintain HTS status are applied consistently
across public and private-sector providers if the UK education
sector is to remain credible globally.
4.3 Academic justification for "pathway"
programmes offered by Cambridge Education Group and our competitors
is straightforward but often misunderstood when presented in the
context of "risky" categories of students. Many international
students have to undertake preparation programmes prior to entry
to a UK university because their home countries have a 12-year
secondary system (as opposed to the 13-year UK system). Often
both English language and study skills need to be improved. Private
"pathway" providers offer courses of pre-university
study, usually between three and six academic terms, (but only
11 months if on a Student Visitor Visa), including English and
other academic study, formally validated or officially recognised
by a partner university, which on successful completion and attainment
of required grades, provides a student assured progression to
a specific university course at the partner institution.
4.4 Approximately 50% of pathway provision is
operated by five organisations in partnership with universities:
INTO, Study Group International, Kaplan International Colleges,
Navitas and Cambridge Education Group.
4.5 We are reassured that the Tier 4 Child Student
category is not set to change, and welcome the extension of the
Temporary Visitor Visa from six months to 11 months of the Extended
Student Visitor Visas (ESVV)—see also para 6.3.
5. INTRODUCING
TOUGHER ENTRY
CRITERIA FOR
STUDENTS
5.1 The debate over whether to raise the level
of English required from Common European Framework of Reference
(CEFR) B1 to CEFR B2 is arguably the greatest risk to the UK English
language teaching sector, pathway providers, universities and
UK education as a whole.
5.2 A student's ability to follow a course at
the right level is vital from a pedagogical and moral standpoint.
But that is our area of expertise. Our reputation (and
that of colleagues in our sector) rests on the final academic
outcome and progression to the satisfaction of the student themselves
and their parents or fee payers. It is our responsibility
to assess the student's English level and academic capability
and provide for them the most appropriate course for their
needs. This is a fundamental premise and we could not operate
for more than a few months if we systematically failed to get
this right. We have maintained a strong reputation for successful
placements at leading universities, demonstrating that we are
the academic experts.
5.3 While the assessment and verification of
a student's English language needs cannot demonstrate a student's
academic potential, intention to study or complete a programme,
nor should English level be regarded as a robust measure for the
assessment of relative "risk" between one group of students
and another. But this is what it has been put in place to do.
5.4 If students do not attain the required level
to progress, the control is in place, through UKBA, to ensure
that students leaving early are reported, or students needing
more time request visa extensions. But it is our belief, that
students assessed properly by trained staff, offered the most
suitable study plan, and supported academically and pastorally
can and do achieve their academic aims. More than 90% of our students
progress to university successfully every year.
5.5 We would be prepared to agree that only HTS
institutions should be allowed to judge the academic and English
language levels of students joining programmes below degree level
and to maintain the B1 level as the preferred entry point. The
availability of Secure English Language Test (SELT) tests is limited
in some key markets, and we would prefer the autonomy (within
HTS) to utilise a wider range of English language tests appropriate
to the academic course that a student has applied for.
5.6 The suggestion that only SELT tests may be
used, and that only B2 entry will be allowed also puts at risk
our School of English business. We should encourage non-English
language speakers to learn the language in the UK in well monitored
and regulated English Language Centres to ensure the integrity
of the language as well as earning important income for the UK.
5.7 We request clarification and consistent advice
on what is a pre-sessional course, and whether or not it requires
a SELT. We received conflicting UKBA advice on what constitutes
an English language or academic pre-sessional programme, when
SELT is required whether it matters that the follow-on offer is
conditional or unconditional, and whether the student needs to
return home for visa extension.
5.8 We propose students are offered whole-course
visas, eg making what is currently a pre-sessional programme level
zero of the degree, and enabling a four-year visa to be issued
(common practice in Australia). Despite not effecting a temporary
drop in net migration rates, this would ensure clearer articulation
between programmes, better progression and completion, curtail
unnecessary movement, and reduce bureaucracy and cost for students,
pathway providers, universities and UKBA processing outposts.
6. ENSURING STUDENTS
RETURN OVERSEAS
AFTER THEIR
COURSE
6.1 If students are required to return home whenever
they need to renew, extend or change their visa, this will make
the UK a singularly unattractive destination for those legitimately
progressing from one level to another. Home Office statistics
(The Migrant Journey) prove that students do return home
after their studies so the minimal risk of overstay cannot justify
the associated burden of practical issues, high costs and bureaucracy.
6.2 Students should be allowed to progress from
one HTS sponsor to another HTS sponsor in the UK to facilitate
progression of academic students to university study from an independent
school with A-levels, from pre-sessional courses, and from Undergraduate
to Master's degrees.
6.3 We would further recommend that students
on 11 months Extended Student Visitor Visas should be allowed
to transfer to Tier 4 within the UK—as long as they remain
under the sponsorship of an HTS, and that the 11 months Student
Visitor Visa be extended to academic programmes as well as English
language programmes, without the need for SELT.
7. LIMITING THE
ENTITLEMENTS OF
STUDENTS TO
WORK AND
TO SPONSOR
DEPENDANTS
7.1 Although we support some of the restriction
already in place on students' right to work during their study,
work experience can play a valuable part in a person's education,
and can help students support themselves during their studies.
If students are allowed to work on campus, this ambassadorial
role can help newly arrived international students settle in to
their studies.
7.2 The Tier 1 Post Study Work (PSW) visa is
an attractive feature of UK study and its restrictive parameters
ensure that students may only transfer for a limited time and
Tier 2 is not a viable alternative since this already restricts
the competitiveness of UK business. It may be possible to restrict
the Tier 1 PSW route to a specific group of graduates, such as
those exiting at Master's level.
8. SIMPLER PROCEDURES
FOR CHECKING
LOW-RISK
APPLICATIONS
8.1 This implies that stricter procedures will
be applied to higher risk categories, and this is welcomed. Since
the introduction of PBS (Points Based System) Tier 4, we have
invested significant resource in training, compliance, accreditation
and administration—a burden imposed by the UKBA on all educational
institutions but formerly the responsibility of the government.
This not insignificant cost to our business cannot be sustained
as long as the government chooses to reduce the responsibilities
of the UKBA and continues to cut public sector jobs.
8.2 This imposition means our overseas and UK-based
recruitment staff are trained in assessing any risk from individual
applicants and from specific regions. If there is to be any reward
for this investment in compliance, we as holders of HTS are best
placed to continue to assess relative "threat", at the
risk of losing our HTS status, especially since the promised appointment
of UKBA account managers has not materialised, and notwithstanding
the difficulty of obtaining any useful statistics or feedback
from UKBA on our students via the SMS.
8.3 Currently any new private provider has to
operate for six months prior to applying for HTS status and to
be allowed to recruit for pre-degrees. A probation system would
iron out compliance queries collaboratively, under close scrutiny.
In applying a sliding scale of responsibility by sponsor rating
(A, B, HTS), the scheme's credibility can only be maintained through
transparent and fair rules applied across the private and
public sector.
8.4 Additional mechanisms, eg full-fee advance
payment, pre-visa deposits or bonds, might also help assess students'
intention to study, perhaps according to the length of their course,
again if applied consistently.
9. STRICTER ACCREDITATION
PROCEDURES FOR
EDUCATION PROVIDERS
IN THE
PRIVATE SECTOR
9.1 To impose stricter accreditation on the private
sector will only further compound the unfair and anti-competitive
treatment of the private education sector.
9.2 We would support the establishment of a centralised
independent inspectorate to standardise accountability, and support
the view of the Independent Chief Inspector of the UKBA in his
2010 annual report.[85]
9.3 Should the private sector fail, the public
sector will, in turn, suffer through the loss of a vital revenue
stream.
January 2011
81 Home Office, The Migrant Journey (September
2010). Back
82
globalhighered.files.wordpress.com/2007/09/britishcouncil.pdf Back
83 www.compas.ox.ac.uk/fileadmin/files/pdfs/Non_WP_pdfs/Events_2010/COMPAS%20Breakfast%20Briefing%20Summary%20October%208%20Ursula%20Kelly.pdf Back
84 www.abc.net.au/lateline/content/2010/s3068304.htm Back
85
icinspector.independent.gov.uk/wpcontent/uploads/2010/03/Independent-Chief-Inspector_Annual-Report-2009_20102.pdf Back
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