The Student Immigration System in Scotland

Written evidence submitted by university pathway providers: Cambridge Education Group, INTO, Kaplan International Colleges, Navitas and Study Group UK

Executive summary

a. The following responses are being submitted by the five leading providers of pathway programmes that prepare international (non-EU) students for entry to undergraduate and postgraduate studies at 40 of Britain’s leading universities including Glasgow, Glasgow Caledonian, Herriot-Watt and Stirling Universities with programmes opening this year at Edinburgh Napier and Robert Gordon Universities.

The five pathway providers are:

Cambridge Education Group, Fergus Brownlee, Chief Executive

INTO, Andrew Colin, Chairman

Kaplan International Colleges, Linda Cowan, Managing Director

Navitas , Kerry P. Hutchinson, General Manager, Navitas UK

Study Group UK, James Pitman, Managing Director, HE - UK and Europe

b. While our businesses may compete and our business models may differ, we share a total commitment to preparing students from around the world for the opportunity to study at our world-leading universities.  Their success translates into economic benefits for these universities and their local economies, as well as turning these students into lifelong advocates for the British education system and Britain as a whole. With declining population in Scotland and with significant cuts in university funding, international students are arguably even more important to the Scottish economy and univer sit i es.

c. International students make a substantial and crucial contribution to our higher education institutions – up to 30 percent of a university’s income [1] in many cases – and international students contribute £10 billion a year to the UK economy in fees a nd living costs.

d. Colleges like ours exist not only to improve English language proficiency, but also to facilitate entry to undergraduate study through the provision of the final Year-13 tuition (or equivalent), which many countries lack, and to provide the research methodology skills vital to succeed at master’s level. The entire pathway concept is predicated on the preparation of students for success in the different learning culture that exists in British universities. Students leave our colleges to enter our universities fully prepared for the rigours of study in Britain.  In fact, international students who enter university from these pathway programmes are often more likely to meet the entry requirements and to be successful at university than international students going straight into university.

e. Following the completion of their degrees, students that have begun their programme of study at our colleges will, in almost all cases, leave: 97% of our international students leave the UK following study, returning to their home country with a much greater understanding of Britain, its culture and its business community. The reality is that international students should not be caught up in a debate about immigration – they are not economic migrants but paying customers to one of Britain’s most successful export earning industries. Many of the key competitors to the UK in the Education Services Export Industry do not classify students as migrants at all.

Home office proposals

f. Independent research by Centre Forum indicates that, on current operations, our five pathway organisations make an annual contribution approaching £300 million in tuition fees to UK partner universities and a further UK£672 million in student spend directly feeding into local economies. [2] This makes a total annual contribution approaching £1 billion to the UK economy.

g. Reducing net migration to tens of thousands within the course of the current Parliament by limiting the number of non-EU economic migrants, including those who enter the UK as students, will , it is widely agreed, have the effect of deterring some genuine, high quality students from applying to study in Scotland.

h.   We support measures designed to root out abuse of the Tier 4 system. Bogus colleges provide a damaging immigration ‘back-door’ and damage the reputation of international students, and the universities, colleges and educational institutions at which they study.

i. However, we have concerns about some of the proposals as originally put forward by the Home Office. We believe that policy implemented to curb abuse of the system should not become confused with another stated aim of the Home Office consultation which has been to reduce the number of international students who come to our universities to study. Many of them are genuine, high-quality students who bring talent, cultural diversity and importantly – money -- into the universities, their communities and the Scottish and UK economies.

j. We welcome the Home Offices’ decision to leave the English language requirement at B1 for pathway courses in recognition that these courses play a crucial role in preparing genuine, high-achieving international students to enter UK universities.

k. We believe that there are a number of alternative proposals, not included in the Student Immigration System consultation that might control the number of international students entering Scotland more effectively and without risk of c ausing the high level of collateral damage that would have been caused by some of the proposals in the consultation. We do not want more regulation, additional cost for the taxpayer or additional headcount for government. We want clearer and simpler regulation. We see a need for action on THREE fronts:

i. Stamp o ut the bogus colleges . We want to see them shut down so that they stop dominating perceptions of our industry.

a) We want to see stricter and more rigorous accreditation for all colleges.

b) We believe that there should be one accreditation agency -- not five. This would stop the practice of accreditation shopping where colleges who have failed with one agency simply try another. This single agency should work closely with the QAA.

c) Only colleges with HTS status should be allowed accept Tier 4 students. This single measure would cut as many as 30,000 students every year from the current numbers, and at the same time ensure that the government had much better monitoring on the students that do come. HTS criteria should also be made consistent across the whole sector.

d) In addition to the compliance costs that the colleges already contribute, a modest levy per international head in each institution could raise the money necessary to fund the increased costs of compliance.

ii. Stop the bogus students applying . We want to continue to attract highly motivated, bright and capable students. The current level of controversy stops some good students from applying to the UK. We want students who are motivated and committed to their chosen course of study. From our experience a student’s English Language ability when they first arrive in the UK is not a strong indicator of their academic ability and/or likelihood to complete the course or even likelihood to abscond. However, their finances - and the financial commitment they are willing to make usually are.

e) Students could be asked to pay a full year’s tuition fees upfront. We would have to be sure that legitimate and talented students were not put off. These funds would have to be held in an escrow account to safeguard the students’ money and then drawn down by the education provider under agreed terms and conditions. A similar proposal was included in the Conservative Election manifesto.

f) We would support a proposal that "foreign students at new or unregistered institutions pay a bond in order to study in this country, to be repaid after the student has left the country at the end of their studies" which was included in the Conservative Election manifesto.

g) Students should be required to take out health, travel and personal insurance. A student visa cannot entitle individuals to UK state benefits, the NHS etc.

iii. More transparency and better record keeping . Immigration figures and international student numbers have been a source of dispute for some years. The imminent introduction of new borders IT systems will make it much easier to track individuals and analyse particular categories and trends.

h) We believe that colleges should commit to a greater level of data transparency. We want all college admissions and graduation data to be opened up to the government.

i) We support the suggestion proffered by Professor Acton of the University of East Anglia at the recent Home Affairs Select Committee hearing to fund and conduct a detailed cross-referencing analysis of HESA records against student visa data. This will help to create a more accurate picture of student inflow and outflows.

A s Highly Trusted Sponsors – each with significant experience in the UK and elsewhere throughout the world – we look forward to working with colleagues in government and with our university partners to help achieve the Government’s objectives while protecting the value that our pathway programmes contribute to our university sector and the broader economy.

March 2011

[1] “International Students in the UK: facts, figures – and fiction”: September, 2010 UKCISA


[2] This data was derived from the 2009-2010 academic year which was based on a total of 12,586 students enrolled at our five programmes, 10,199 of whom have so far progressed on to UK universities. Others will still be in the pathway programme, still others will have returned home or gone on to another country to study. Actual completion rates were high and to HTS current requirements. Student spend was based on published recommendations by the British Council of minimal annual living costs (not inclusive of tuition fees) for students wishing to study in the UK, see