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 collegeswhich
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 qualificationsparticularly vocational
Higher Nationalshave 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
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) Academicone 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
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
We believe that this approach is the only way to
ensure a fair and transparent system for students, sponsors and
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.