Written evidence submitted by English
UK (SV17)
English UK is an association of nearly 450 English
language centres in universities, further education colleges,
and independent schools and private colleges, some of which are
educational trusts.
Over 400,000 students a year learn English at English
UK member centres. The UK is the global leader in the learning
of English by study abroad. The sector is worth approximately
£1.5 billion a year in foreign earnings to the UK economy.
All member centres are accredited under the Accreditation
UK scheme, which is managed by the British Council in partnership
with English UK. Accreditation UK is approved by the UK Border
Agency for the purposes of the Register of Sponsors for Tier 4.
English UK is a UK registered charity with the object
of advancing the education of international students in the English
language. It is also a company limited by guarantee and its Board
of 12 trustees is elected from and by the member centres.
English UK has been a member of the UKBA Joint Education
Taskforce since its inception in 2005, and has supported efforts
to reform the visa system for international students and to root
out bogus colleges, both on educational and immigration control
grounds.
SUMMARY OF
KEY POINTS
Reducing net migration by students is not a Coalition
Agreement objective. It is not a meaningful policy objective in
any case.
The impact of the proposals could be severe, especially
on those courses preparing students for university entry.
Compliance action should be targeted on areas of
abuse. Accreditation arrangements should be improved. This may
result in a reduction in the number of international students,
but that should not in itself be the primary policy objective.
There has been considerable progress over the last
three years in tightening up the whole student visa system. There
is a need to let these measures take effect, and for a period
of stability, before any further blanket measures or restrictions
are introduced.
THE POLICY
BACKGROUND
1. The Coalition Agreement stated that the Government
would set an "annual limit on the number of non-EU economic
migrants admitted into the UK to live and work". It further
stated that the Government "will introduce new measures
to minimize abuse of the immigration system, for example via student
routes". We note that the document does not propose a limit
on the number of international students, nor does it suggest that
the number of international students should be reduced (except
implicitly as a consequence of minimizing abuse). We support the
objectives set out in the Coalition Agreement.
2. The current proposals, however, are set in
the context of "reducing net migration". The policy
objective of reducing net migration is in itself not particularly
meaningful. It does not in fact matter if students enter the UK
and remain here legitimately for more than a year on a course.
What matters is whether they leave when they have completed the
course, or whether they switch into a route leading to settlement.
In other words the ultimate and proper policy objectives are ensuring
compliance with visa conditions, and reducing permanent migration,
settlement and citizenship. The present proposals do not offer
a particularly effective way of meeting these objectives.
3. There does not appear to be any modeling of
what impact the different proposals would have, either separately
or cumulatively. Nor does there appear to be any set timescale.
Reducing net migration is taken as a sufficient objective in itself,
yet there is no indication of by how much it should or will be
reduced by these proposals, nor by when. This does not give confidence
that the impact of the proposals has been fully considered and
that their possible outcomes are known with any certainty. Our
view is that if there are measures which should be taken for immigration
control reasons, such as ensuring compliance, then those measures
should be taken, and any reduction in net migration as a consequence
is incidental, but that it is a mistake to set a reduction in
net migration as the primary objective.
IMPACT OF
THE CURRENT
PROPOSALS
4. We first wish to address Question 5,
which suggests raising the level of English required for a Tier
4 visa to CEFR level B2. This is equivalent to an A level in a
foreign language. This would have a severe impact since UK universities
recruit around half their international students from preparatory
courses in the UK, generically termed international foundation
year (IFY) programmes (not to be confused with Foundation Degrees).
These IFY programmes usually do three things. First, they improve
students' command of English, to the level required for university
entry (which is around level B2 or IELTS 6.0-6.5). Second, they
top up subject knowledge (many other countries do not have the
equivalent of our Year 13, the second year of A level) so that
all students start a degree course with more or less the same
level of UK curriculum knowledge. Third, they teach the skills
of independent study, which is needed since many other parts of
the world hold to a more didactic style of pedagogy. One English
UK member, a group of centres which is a leading provider of IFY
programmes, with links to around 20 universities, has given us
the estimate that around 75-80% of their current IFY intake have
an English level of A2-B1, meaning that these students would not
be able to gain T4 visas for IFY courses if the level required
was raised to B2. If that was the case across the whole of pre-university
courses (pre-sessional English for academic purposes and IFY programmes)
then there would be a loss of 35-40% of international students
going into universities. At a time when many universities rely
on the higher fee income from international students to maintain
course options and whole departments, this would have a serious
impact and it is no exaggeration to say that the financial stability
of some universities might be threatened. The level of English
required should either be set at A2, meaning that students would
have a year to go up two levels to achieve university entrance
standard, or as an alternative the extended 11-month Student Visitor
visa should be given one entitlement, which is to be able to switch
in the UK to a T4 visa for the purposes of going on to a degree
(or degree equivalent, NQF level 6) course.
5. In contrast, we support the thrust of Question
18, which suggests raising the standards of accreditation
and inspection. We do not think that the present accreditation
arrangements are fit for purpose. For example, a significant number
of colleges which have had accreditation withdrawn, or have failed
a first inspection, with one of the approved accrediting bodies,
have subsequently gained or have retained accreditation by another
approved accrediting body. There is clearly no consistency of
standards, which is hardly surprising since the different accrediting
bodies have adopted different criteria and have different teams
of inspectors. This is an unsatisfactory situation which needs
to be addressed. We can see no good reason for there to be more
than one approved accrediting body for independent tertiary colleges
and one for English language centres, and indeed there may be
a case for these to be unified or at least to carry out combined
inspections where independent colleges also deliver English language
courses. A consequence of improving the accreditation arrangements
and raising standards might well be that those colleges which
have had accreditation withdrawn, but have had the fallback of
getting accreditation from a different body, finally lose accreditation
and their T4 sponsor licence. That in turn would have the effect
of improving the UK's reputation for quality, which is our main
selling point in the competitive world of international education.
If that also led to some reduction incidentally in the numbers
of international students coming to the UK, that would be an acceptable
consequence as indicated in our argument in paragraph 3 above.
6. We now wish to comment more generically. First,
the current consultation does not take adequately into account
the progress which has been made in tightening up the student
visa system over the last three years in particular. There were
over 4,000 colleges on the DIUS Register of Education and Training
Providers. There are now fewer than 2,000 on the Register of Sponsors.
Colleges are limited as to their Confirmation of Acceptance of
Studies annual allocation, and without a CAS a student cannot
get a visa. The electronic Sponsor Management System gives UKBA
a wholly new dimension of control and security. The SMS and CAS
together have removed one whole area of visa fraud through forged
enrolment letters. Students now have to give biometrics as part
of their visa application, which cuts down on impersonation and
other forms of identity fraud. Other control measures in the last
year have been the Highly Trusted Sponsor scheme, and the limiting
of lower level courses to HTS colleges, and the introduction of
secure English language tests for non-degree students. In essence
we can see no good reason for most of the other restrictions now
proposed, and no reason why such blanket restrictions should be
imposed. If there are still areas of abuse, then it is surely
possible to target those specifically: for example, if a college
is not fulfilling adequately its duties as a sponsor, or its recruitment
practices are leading to high rates of student drop-out and absconding,
then UKBA should use the powers it has to degrade that institution
to a B rating and/or remove it from the Register of Sponsors.
This would be a far better approach than in effect penalizing
all satisfactory Sponsors for the poor performance of a relative
few. Equally, blanket requirements on students (such as the proposal
in Question 8 that students wanting a visa for a
new course should return home to apply) are likely to be highly
discouraging and act as a considerable disincentive to come to
study in the UK in the first place. In our response to the consultation
we shall be arguing that UKBA needs to consider much more specific,
targeted and graduated action.
CONCLUSION
The UK student visa system has been changed radically
and almost continuously over the past three years. While most
of the changes have led to greater control, the pace and unpredictability
of change and the prospect of more is not helping make the UK
look an attractive and welcoming study abroad destination. We
believe that the proposed changes do not have an adequate policy
rationale and their impact could potentially be severe. It would
be preferable for UKBA to address any remaining areas of abuse
in a more graduated and targeted way, which it has the powers
to do.
January 2011
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