The Student Immigration System in Scotland

Written evidence submitted by Heriot-Watt University

Executive Summary

1. Heriot-Watt University (HWU) is one of the most culturally diverse centres of study in the UK. We have a long tradition of welcoming students from all over the world, and 35% of our students studying in Scotland come from outside the UK. We also have an unsurpassed international in-country presence, delivering degree programmes to 11,800 students in 150 countries around the world. HWU is therefore particularly concerned regarding the proposed changes to the UK’s visa regulations as outlined in the recent UKBA consultation document.

2. HWU welcomes the UKBA’s consulation on reforming the provision of private sector sub-degree provision and understands that the current abuses of the PBIS system require further revision of existing regulations.

3. We are deeply concerned, however, that the proposed changes will impact severely on the University's ability to recruit suitably qualified international students. Fee income from international students studying in our Scottish campuses accounted for approximately £19 million to Heriot-Watt in 2010/11. With an overall institutional turnover of £147.6m in 2010/11, this income stream therefore plays a central role in institutional strategy for growth in the face of reductions in public-sector spending and cuts to funding. Furthermore, a significant proportion of the University's international students are recruited from within the UK. UK-based Further Education and private-sector institutions offer valuable and legitimate sub-degree level provision to students who intend to come to the UK in order to progress into Higher Education.

4. As requested by the Scottish Affairs Committee, the key issues relating to impact on the University and more broadly Scottish economy and society are discussed below.

1. How the proposal to reduce the number of international students might impact upon Universities in Scotland

1.1 The announcement of proposed tighter regulation is already being perceived negatively overseas in key markets such as China and India. The University is very concerned about the adverse impact of proposed immigration policy changes on the reputation and image of Scotland & the UK as a preferred destination for high quality education provision, particularly in an increasingly competitive global market. The consultation's proposals appear to be focused on correcting problems centred on provision in the private, sub-degree sector. However, it is of great concern that remedial measures may have a significant and adverse impact on the whole of the UK's Further and Higher Education capacity to recruit international students and operate successfully internationally. HWU has a wide range of international teaching and research initiatives and has developed a global presence as a transnational provider of UK HE through collaborative activities, research and teaching partnerships and its branch campus in Dubai. Such activities are of economic and political value, supporting government policy for international development with key global markets.

1.2 HWU supports the assertion made by Universities Scotland that ‘the successful recruitment of international students is integral to Scottish Universities’ contribution to Scotland’s international profile and to the Scottish economy.’ (U.S. Circular 02/11, p.2). It is worth noting that Universities Scotland also quoted a 2009 University of Strathclyde report on the economic impact of Scottish Universities which estimated that overseas students generated £516m of export earnings, including off-campus expenditure of £231m.

1.3 Whilst HWU supports changes to UKBA policy designed to deter the operation of ‘bogus colleges’ offering programmes at sub-degree level, we are concerned about the way in which such provision is defined. In particular, our concern is that the proposed changes may severely impact on legitimate private and public providers which offer sub-degree level programmes to students who intend to progress to degree level programmes. These providers offer important progression routes into Scottish Higher Education.

1.4 As an example, HWU admitted 39% of its non-EU undergraduate intake in 2010 from other UK institutions and the impact of limiting legitimate UK providers in this sector could have severe financial consequences for HWU, particularly given the comparatively longer time that undergraduate students spend at the University compared to those registering at posgraduate level.

1.5 For reference, during the academic cycle 2009/10 HWU attracted 871 applications from non-EU students at undergraduate level with 194 new entrants. At postgraduate level, HWU received 8133 applications and admitted 781 new non-EU students.

2. Broader impact on Scotland’s economy and society

2.1 The benefits of allowing suitably qualified international graduates 'leave to remain' for work purposes should also be considered. Heriot-Watt's portfolio is specifically focused on business and industry-relevant qualifications and centres on STEM disciplines (identified as a priority by the UK and Scottish Governments), Business, Textiles and Languages.

2.2 Our international graduates are actively sought after, notably in specialist and economically vital disciplines such as Petroleum Engineering, Actuarial Science and Logistics & Supply Chain Management.

2.3 In the instance of the University's highly-rated Institute for Petroleum Engineering, 109 of the 181 students registered in 2010/11 are classified with non-EU status. These graduates are in high demand in both the Scottis, British and International Oil & Gas sector and preventing such well trained graduates from accessing the Scottish & UK workforce will mean the loss of highly valuable graduate-level knowledge and expertise. This could result, for example, in non-EU graduates being employed by multinational companies overseas rather than in North Sea Oil & Gas to the detriment of the Scottish economy.

2.4 Indvidual examples of graduates of a non-EU background include the following who have succesfully used the Post-Study Work route:

- A Chinese PhD graduate in Computer Science who worked successfully for a research spin-out company before returning to China as Heriot-Watt University's in-country representative

- A Syrian PhD Graduate in Built Environment who lectured in the University's School of Built Environment before returning to Syria to participate in the Syrian Higher Education Capacity Building Project .

- A Chinese PhD graduate in Translation & Interpreting who works for the Scottish Government as a translator, recently supporting the Scottish First Minister during the visit of a delegation led by the Chinese Vice-Premier.

2.5 As a Scottish institution, Heriot-Watt has been an enthusiastic supporter of initiatives to address the demographic problems of the reducing Scottish population (e.g. the Fresh Talent initiative). The UK government’s stated intention to reduce immigration levels threatens to impact particularly on Scottish society given the declining population (the number of births is projected to fall from 60,000 in 2008 to 53,600 in 2033).

3. Specific concerns on proposed changes

3.1 HWU would oppose any proposed change to require international students on student visitor visas to return home to apply for a Tier 4 visa. International students at HTS institutions should be permitted to apply from within the UK, thus removing an impractical and expensive barrier to appropriate progression of bona fide students.

3.2 Expecting students to return to their home country to apply for their new visa is impractical for many students as additional costs, disruption to both them and their dependants and lead time for new visa to be processed will all impact on study. There would also be adverse implications in terms of cost and accommodation for the students concerned. Also, the gap between students finishing summer pre-sessional or foundation study and commencing degree programme can be less than 3 weeks, significantly less than the targets currently being met by many Entry Clearance managers. Disruption to continuing students (e.g. PhD students) who need additional visa time to complete their studies would be significant if they can not apply for this extension from within the UK.

3.3 Our HESA data shows that around 150 international students progress each year between HWU's own programmes, which includes progression from pre-sessional English courses and from Undergraduate to Postgraduate level.

3.4 At undergraduate level HWU is particularly concerned that sub-degree providers such as Scottish Further Education Colleges and private sector partners such as Study Group are able to maintain and develop their portfolio as they offer valuable opportunities to international students and act as important feeder institutions to HWU.

3.5 At postgraduate level, a key concern is the impact that the proposed changes may have on the Post Study Work route, as discussed below.

4. Protecting the Post Study Work Route

4.1 The post study work route is a valuable route for international graduates who wish to build on their academic experience through a period of work and it is a significant asset in attracting international students to the UK for Higher Education. Particularly in Scotland, we welcome high quality graduates contributing to economic development and playing a valuable role in our universities.

4.2 The University wishes to highlight that doubts about the future of PSW are already having a negative impact on recruitment, based on feedback from our international representatives in core markets such as India and China - both established as significant markets for UK-international relations and business development. The University is very concerned about the impact of proposed immigration changes on its ability to achieve its goals for international development. These include transnational provision which may also be adversely affected in key markets as a result of the negative perceptions being associated with the UK through changes proposed to immigration policy.

4.3 The total closure of the PSW route would impact negatively on international recruitment and send the wrong message overseas (we believe that this would lead to the UK being seen as unwelcoming). This is of particular concern to Heriot-Watt as 48% of our postgraduate students come from outside the EU.

4.4 Therefore, restrictions to HTS graduates or only postgraduate students would be preferable to a total closure of this option. Also, a transitional arrangement should be in place, at least for students who will be completing their studies this academic year, otherwise this could cause severe damage to the UK HE sector and our ability to operate successfully in international markets.

5. Alternative approaches

5.1 As an institution with Highly Trusted Sponsor status, HWU is of the view that changes to the system should further develop the responsibilities given to 'bona fide' HTS institutions. Such development would allow Universities to continue to make informed, professional decisions on both English and Academic entry requirements, allow international students to progress to new courses with minimum interference (with their dependents) and allow well-qualified international graduates to pursue Post-Study Work opportunities.

March 2011