Student Visas - Home Affairs Committee Contents

Written evidence submitted by Pearson's Language Testing Division (SV55)

As some of the major representative bodies of both the public and private sector involved in pre-degree programmes, we welcome the continued review of the Tier 4 criteria. We support the focus on eliminating "bogus colleges" which facilitate inappropriate immigration into the UK. We acknowledge their existence and the damage they cause to the reputation of the sector. As outlined in previous correspondence, we want to work with you to crack down on them. We have submitted to this review earlier in the process and appreciate the reflection of some of our views in the most recent proposals issued.

As you enter the final phase of consultation on Tier 4, we want once again to remind you of the risks to restricting study below degree level and urge caution in using the blunt instrument of qualification level or public versus private provision as a means of containing immigration. Creating an arbitrary cut off at degree level risks harming legitimate and high quality provision, undermining an important source of income for colleges—which may increase costs for UK students. It will also damage the reputation of UK education overseas, where many of our colleges are looking to address current funding challenges by building business opportunities. Pre-degree level qualifications—particularly vocational Higher Nationals—have a strong reputation with employers internationally, but they need championing at home if they are to retain this value.

We have made more specific comments on current plans in the attached and request to meet with you urgently to discuss in particular the route to Highly Trusted Status for private colleges and the impact of proposed changes to working entitlements on students studying in Further Education (FE).

The focus must be on checking the quality of institutions and of the candidates studying in them rather than on restricting the level of the qualifications. We want to work with UK Border Agency (UKBA) to address quality and legitimacy issues in a proactive and transparent way across the public and private sector. This includes developing a quality marks for colleges, raising the bar on testing quality of English and strengthening measures to ensure students return home after study. By working together we believe we can effect quick and effective change to the sector without harming legitimate provision and the status of UK education overseas.

Pearson's Language Testing Division has specific concerns, detailed below, relating to:

  • The misalignment of English language test scores to the Common European Framework of Reference (CEFR).
  • Proposal to increase the minimum English language proficiency from CEFR B1 level to B2 level for all students.

Edexcel, Pearson's awarding body, has also submitted its broader views, including concerns over college accreditation, in a separate submission to this consultation.


Government proposal: "We therefore propose that all students using the Tier 4 (General) must be able to demonstrate that they have passed a secure English language test showing proficiency at level CEFR B2 across all four components of language testing"

As a provider of English language tests, including Pearson Test of English (PTE) Academic—one of the current approved UKBA tests, we have a specific interest in the proposal to use the CEFR to set minimum English language standards for all students.

Pearson supports the Government in its efforts to eradicate any abuse of the student visa route, with security being one of our key priorities to ensure reliable and robust English language test results. However we have two key concerns around the use of the CEFR which we are highlighting in this contribution to the consultation.

1.  The misalignment of English language test scores to the Common European Framework of Reference

Firstly, we have concerns around some of the misunderstandings of how test scores relate to the CEFR-for example, in the Student Immigration System Consultation Document, in paragraph 5.5 it states: "While education providers specify their own minimum language requirements for nationalities deemed to be lower risk, many universities require language proficiency at International English Language Tests System (IELTS) 6.5, which is approximately equivalent to C1 level." Cambridge ESOL (one of the IELTS partners) has recently adjusted this and, according to information on their website, an IELTS 6.5 is a B2 level.

As outlined in previous correspondence to the Home Office over the course of the year, we have highlighted our concerns around the Common European Framework being open to misinterpretation by some English language test providers. Test providers are currently not required to produce empirical evidence, verifiable by independent peer review, of the relation between the results on their tests and the levels of the CEFR. If test providers are allowed to make unsubstantiated claims about the alignment of their test scores to the CEFR, then students will be tested to significantly different English language standards whilst being erroneously awarded the same required CEFR level.

Pearson urges that independent advice be given to the Government and UKBA on the Common European Framework by experts in the field of language testing, who can advise on setting the appropriate language levels and review language tests, with a particular focus on evidence for their claims regarding CEFR alignment.

We believe that this approach is the only way to ensure a fair and transparent system for students, sponsors and test providers.

2.  Proposal to increase the minimum English language proficiency from CEFR B1 level to B2 level for all students

We believe that the proposed CEFR B2 level is too high for students applying for foundation and other non-degree level courses, which often includes English language improvement and support as part of the curriculum. Based on Pearson's rigorous CEFR alignment data, and score requirement data we have from universities, the minimum entry requirement for many university degree-level programmes is CEFR mid-B1. We are therefore concerned that thousands of genuine students will have their visas rejected as a result of not being able to meet the proposed new level.

January 2011

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Prepared 25 March 2011