Student Visas - Home Affairs Committee Contents

Written evidence submitted by Cambridge Education Group (SV 52)


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.


2.1  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.


3.1  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]


4.1  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.


5.1  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.


6.1  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.


7.1  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.


8.1  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.


9.1  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

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Prepared 25 March 2011