Written evidence submitted by Edexcel
(SV55a)
Edexcel, Pearson's awarding body, has previously
put forward to the UK Border Agency (UKBA) and Home Office its
view that any changes to the student immigration system through
the Review of Tier 4 must take into account the following factors:
- The contribution of the legitimate
private college sector to the UK education and economy.
- The importance of maintaining
the credibility of British qualifications abroad, particularly
as many of the larger UK colleges from both the private and public
sector seek to develop their distance learning or franchised offer
for students studying overseas, partly as a means of generating
additional revenue to enhance their offer to UK students.
- The importance of qualifications
at skill levels at above and below degree level in respect to
the above.
We proposed that changes should not make a broad
distinction between qualifications at degree level and above and
those below it, but rather that greater rigour be exercised in:
- Checking the quality of the institutions
offering places to overseas students.
- Assuring the quality of the qualifications
being studied—their level, content and assessment methodology.
The letter attached, signed by Edexcel and leading
private and public college representatives, underlines that the
interests of colleges, awarding bodies and the Government are
aligned on this matter. The reputation of UK education and qualifications
internationally—in the education sector and in industry
and business—depends on only the highest quality students
gaining our awards, and that these students go onto champion those
qualifications by working across the globe, not just in the UK.
We offered to work with Government, through our awarding
body Edexcel, to ensure that centres offering Edexcel qualifications
not only offered the highest standard of teaching and assessment
to their students, but have the right provisions in place to ensure
that students return home on completion of study.
We have also spoken in some detail to officials about
the current imbalance in the treatment of Higher National Diplomas
offered by the Scottish Qualifications Authority (SQA) versus
those offered by Edexcel under Tier 4. This undermines the efficacy
of current rules, as well as creating an anti-competitive distortion.
We have been pleased to receive assurances that this will be resolved
when new rules are finally announced.
THE GOVERNMENT'S
PROPOSALS
We welcome the direction of travel, which favours
a nuanced approach to the issue of pre-degree level study and
recognises the need to protect legitimate international students
at all skill levels, studying in a range of institutions.
However, we see two critical issues as being unresolved
and potentially harmful to the interests of the reputation of
the UK education sector as a whole, and the UK economy:
- (1) We must ensure that the legitimate private
college sector, is given fair chance to access Highly Trusted
Status (HTS) before the new rules come in.
- (2) Any changes to work placement and working
arrangements must adequately recognise the needs of students studying
vocational courses in non-traditional settings, and the possible
impact on the offer to UK students.
RAISING THE
LEVEL OF
COURSES STUDENTS
CAN STUDY
Of the alternatives offered, facilitating entry to
study at below degree level through the use of the Highly Trusted
Status badge is the most favourable in that it seeks to make the
condition for entry the quality of provision and the student involved,
rather than the level.
However:
- There needs in addition to be
clarity on the process for new sponsors-specifically
the private college sector-to attain HTS.
- Changes should be phased with
those sponsors registering an interest to gaining HTS being allowed
to continue to offer courses whilst applications are processed.
- There should be clear criteria through which
private colleges can achieve HTS automatically.
International colleges already have more inspections than the
public sector. We believe that the suggested mechanisms below
are more than enough to warrant HTS.
Private colleges could be eligible through either:
- Successful achievement of Integrated
Quality and Enhancement Review (IQER)—the review method
specially devised for higher education in further education colleges
in England.
- University validation.
- Or, subject to development work with the UKBA:
- Approval from awarding bodies,
approved by the Office of Qualifications and Examinations Regulation
(Ofqual)—we would work with the UKBA to develop an Edxecel
kite mark, and could include:
- Specific evaluation of a college's
tracking of student whereabouts as part of the original centre
approval process.
- Conversion rate on qualifications
(from registration to final certification), where if a centre
falls below a certain percentage their endorsement from Edexcel
would go on hold.
INTRODUCING TOUGHER
ENTRY CRITERIA
Enhancing the requirement for English testing to
level B2 is a valid means of checking the quality of candidates
but not necessarily the best or only measure of determining fitness
for a course. For many courses, especially more vocationally oriented
study, the possession of other specialist skills is more important,
and many institutions are able to support candidates to increase
their level of skill in English through pre-course classes and
support. Many candidates come into the UK with a standard of English
below level B2 and still go on to achieve well.
There is an issue with the parity of approved English
tests whatever level is determined as the entry requirement. On
this issue, we refer officials to the evidence submitted by our
English testing business, Pearson Test of English, which queries
the current levelling of approved tests. This needs to be further
explored and tightened in the context of this Review if new rules
are to be effective.
ENSURING STUDENTS
RETURN OVERSEAS
AFTER THEIR
COURSE
There should be some flexibility on the principle
that student should be required to show progression when requesting
additional leave to remain is sound, as some students may wish
to study for a course in a new sector to enable a career change
or to pursue a new interest.
We do not believe that students wishing to study
at a higher level should be required to return home, provided
that the sponsor can vouch for the increase in level, since there
is a natural cap on the number of times that a student can do
this.
To prevent abuse, students wishing to study for a
new course at the same level could however be required to return
home to seek a new visa, replicating the proposed arrangements
for transitioning to a working visa after study.
As mentioned above, we recommend that the criteria
for Highly Trusted Status in the private college sector include
specific evaluation of a college's tracking of student whereabouts.
LIMITING THE
ENTITLEMENT OF
STUDENTS TO
WORK AND
TO SPONSOR
DEPENDENTS
Of critical importance here is the level playing
field: qualifications of the same level and type must be subject
to the same restrictions. The current rules, which give favourable
conditions to the SQA Higher National (which can be studied across
the UK, not just in Scotland) and foundation degrees over the
Edexcel Higher National, create an anti-competitive market distortion
and does not offer the best service or choice to students.
We call for the Edexcel Higher National to be recognised
on the same terms as the SQA Higher National and the Foundation
Degree.
In particular:
- We welcome the flexibility around weekend and
vacation work—this will help students to support themselves
without distracting from their course.
- The "on-campus" work rule is however
focused on a view of study in a traditional university environment,
which does not apply to many students studying at a college and
so may disadvantage this group of learners. For this reason, we
propose that institutions with Highly Trusted Status should have
the option to make links to local employers who may employ students
for a limited number of hours during the week.
- Changes to the ratio of work placement to study
would risk damaging the value of certain vocationally focused
qualifications for employers. For example, the Higher National
Diploma is valued for the hands on experience it gives in often
highly specialised skills. Since any moves in this direction would
require revisions to curricula and syllabuses and would likely
alter the nature of provision offered to UK as well as to international
students, changes should be conducted very cautiously and in consultation
with the end-users of qualifications, like employers, on their
needs and expectations.
- Given that many work placements are unpaid, the
logic that a work placement element disproportionately attracts
economic migrants is unpersuasive, and even more so in the light
of planned changes to the Post Work Study Visa.
STRICTER ACCREDITATION
PROCEDURES FOR
THE PRIVATE
SECTOR
Legitimate private providers must have access to
Highly Trusted Status. It is clear, however, that the reputation
of legitimate private sector is undermined by a minority who do
not adequately select or track their students.
Awarding bodies have a key role to play in building
confidence in private provision at all levels. We want to work
with you to develop an established route to HTS for private colleges.
In addition to this, we will enforce greater conditionality
on the offer of our qualifications and introduce more inspection.
We would establish an Edexcel kite mark to support this, as described
above. We would also publish each year a review of the private
sector colleges who offer our qualifications each year, including
measures of:
- Date of approval.
- Number of registrations.
- Blocks on certification or approval.
- External verification grades by
programme.
- Conversion rate (as above).
January 2011
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