Student Visas - Home Affairs Committee Contents

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.


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.


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.


  • 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.
    • Or
  • 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.


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.


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.


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.


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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Prepared 25 March 2011