Written evidence from the Study Group
EXECUTIVE SUMMARY
Study Group believes that the government's proposals
to restrict immigration of international students will do enormous
harm to the UK's second biggest export sector- Education and Training
and as a result unbalance the economy. In the second largest global
industry - education, second only to Healthcare and almost certainly
faster growing, the UK has a pre-eminent position with numerous
historical, quality, HE sector and language advantages which give
it a competitive advantage that many competing countries will
have difficulty to replicate quickly. Government policy should
be to encourage export industries that sustain hundreds of thousands
of high quality jobs and offer great opportunity for growth in
the next decades. Study Group believes that the government should
promote the knowledge export sector and treat international students
as education tourists, as they have no recourse to public funds,
make a substantial contribution to the UK economy and more specifically
the funding of the HE sector, culturally enrich our HE learning
environment and project "soft power" on their return
to their home countries.
The export Education and Training sector is worth
£40 Billion per annum to the UK and this makes it the second
biggest contributor to the UK's net balance of payments, after
Financial Services (and far less controversial). This value is
based on British Council research published in 2007 and extrapolated
to 2010.
Were the immigration proposals to be implemented
unchanged, Study Group predicts significant damage to the UK's
economy and the annualised loss of £300 Million and up to
30,000 jobs from our segment of the sector alone, within three
years. A real life example of the impact of ill-conceived restrictions
on international students in an increasingly competitive global
education market can be seen in Australia.
As the single largest educator of international students
in the UK, Study Group is well placed to advise the committee
on the impact of the proposed restrictions and we would caution
a careful impact assessment of the implication of these restrictions
before irreparable damage is done to the UK's second largest export
sector and thus to the trade profile of the UK economy.
1. BACKGROUND
Study Group is an acknowledged leader in international
education specialising in the provision of world-class university
access and English language programmes. Each year over 55,000
students from more than 140 countries enter these programmes
in 38 locations drawn by certainty of outcome and the sector-leading
quality of our educational provision.
Our global network of education centres and nearly
200 university partnerships across the United States, Canada,
the United Kingdom, Australia and New Zealand is on a scale unrivalled
in modern international education. Further information: www.studygroup.com.
In the UK Study Group recruit and teach 22,000 international
students every year. Our annual turnover approaches £100
million and we employ just over 1,000 FTE staff which increases
to 1,700 during the summer period. We have exclusive contractual
partnerships with 12 UK universities- Lancaster, Leicester, Sussex,
Surrey, Keele, Lincoln, Kingston, Wales, Stirling, Heriot-Watt,
Huddersfield and LJMU. We recruit and teach preparation programmes
to international students on the campuses of our partner universities,
the students then progress to degree studies at those universities.
Our Bellerbys colleges teach GCSE, A level and Foundation programmes
exclusively to international students and to give you a measure
of the quality of those students 45% of all Bellerbys A levels
students were accepted by top ten UK Universities, our A level
maths results in 2010 at our Brighton Bellerbys College were the
best in the country for girls and for boys the best of any independent
school in the UK. 98% of our students progress to UK Universities
for degree study, but self evidently almost all our courses are
at sub-degree level (NQF 3,4,5). Our Bellerbys Colleges are inspected
by OFSTED and we are on the register of Independent Schools. All
operations are accredited by BAC and several in addition by the
British Council. We are members of Study UK, English UK and AIHEP.
In terms of Tier 4 licenses we hold 15 Tier 4 HTS licenses and
a further 4, Tier 4 sponsor licenses. Our business is exclusively
dependent on international students being able to enter the UK
to study with us. Further information: www.bellerbys.com.
As the largest single educator of international students
in the UK and as a business that also operates in US, Australia
and New Zealand, we are uniquely placed to appreciate the damage
that the Tier 4 proposals would do to our business and the perception
of the UK in the global education sector.
2. FACTUAL
BACKGROUND
A fact sheet that Study Group prepared and distributed
to media, stakeholders and some MPs and which is in the public
domain, is attached.
3. VALUE OF
THE UK EXPORT
EDUCATION AND
TRAINING SECTOR
The value of the UK export Education and Training
sector being annually worth £40 Billion is derived from a
government publication of the British Council of 2007 see: http://www.britishcouncil.org/global_value_-_the_value_of_uk_education_and_training_exports_-_an_update.pdf,
which is attached. This assessed the value of the sector to be
£28.8 billion, a figure that was quoted by both the Prime
Minister and Minister for Education in the last government during
2010. However, the data set that was used related to the year
2003-04 and Study Group's estimate based on our knowledge of sector
inflation and growth from 2003-04 to now, is that the true figure
for 2010 is circa. £40 billion pounds.
4. VALUE OF
INTERNATIONAL STUDENTS
TO THE
UK ECONOMY
The assessment of the direct value to the UK economy
of international students, of £10 Billion per annum, is based
on tuition fees and living costs (using the UKBA's own minimum
financial resources figures eg £600 per month and £800
per month for London). The segments that are included within this
are:
300,000 non-EU students in HE @ £25,000 a year
fees plus living costs = £7.5 billion
25,000 non-EU students in FE @ £15,000 a year
fees plus living costs = £0.375 billion
600,000 EFL students (EU and non EU) @£2.5,000
per course + living costs = £1.5 billion
25,000 non-EU students in independent (boarding)
schools @£25,000 a year = £0.625 billion
100,000 non-EU students in private sector tertiary
colleges @ £15,000 a year fees and living costs = £1.5
billion.
5. ARE INTERNATIONAL
STUDENTS IMMIGRANTS
OR EDUCATIONAL
TOURISTS?
The crux of the issue is whether international students
are immigrants and therefore a contributory component to perceived
public concern over immigration or whether they are actually valuable
education tourists, who should not be counted in the immigration
figures and have no recourse to public funds of any kind. The
Home Office's own figures (from the Home Offices publication-The
Migrant Journey) show that only 3% of students actually achieve
settlement rights and the public perception of tourists is that
they visit and contribute to the economy of the UK and sustain
jobs and then leave. This is what the vast majority of students
do and when they are contributing on average £20,000 per
year, then we should be happy that they stay as long as they do-
in our students' cases up to seven or eight years. If the definition
of a migrant has to be anyone in the country for 12 months, then
why do we count international students who are clearly domiciled
abroad and who return to their home country for summer holidays
for c. eight weeks every year and also include student visitors
who by definition stay for less than 12 months? In addition, the
industry does not understand why net migration of students' ie
total number of new student visas issued, less all those leaving
the country is not the metric that should be of interest. That
the net figure increasing is good news, because the UK is successfully
attracting international students and we are competing effectively
in the second largest and fastest growing industry sector in the
world.
6. IMPACT
OF UKBA PROPOSALS
TO RESTRICT
INTERNATIONAL STUDENTS
FROM COMING
TO STUDY
IN UK
The following points and impact assessment relate
to the UKBA Consultation on The Student immigration System (December
2010)
Study Group's assessment is that £300 million
and 30,000 jobs are at direct risk from the implementation of
the proposed restrictions on international students, by our government.
(a) Raising the level
of courses students can study
Study Group supports the concept that only Highly
Trusted Status sponsors can sponsor students for NQF 3, 4, 5 level
study. However the private sector will insist that the same criteria
to gain and retain HTS sponsorship status are applied by the UKBA
in the same way for both public and private sectors. It should
also be noted that there are some 700 institutions that offer
degree level study in the UK (vs some 130 Universities), many
accredited to do so in a variety of ways by other degree awarding
bodies. Study Group would propose that only institutions with
their own degree awarding powers or HTS level licenses should
be able to sponsor students for degree level study or above.
(b) Introducing tougher
entry criteria for students
As a global organisation recruiting and teaching
55,000 international students every year, we can say with absolute
certainty that English level on its own is no indicator
of ability or intention to study or indeed risk of absconding.
Tightening English level may be a surrogate control mechanism
if focussed on high risk groups, but broadly applied, the proposal
to lift the minimum English level to B2 will be disastrous to
Study Group and the whole HE sector in the UK. The US, Australia,
Canada and others accept students for sub degree study on much
lower levels of English precisely because the preparatory courses
that we and others offer cover study skills, academic subjects
and English- specific for study at University. We estimate that
80% of our academic students who come to Study Group and study
in the UK in order to prepare themselves for degree level programmes
at UK universities currently arrive with English below B2- and
yet 97% gain successful entry to UK universities, and among the
best (11 of our students gained entry to Oxbridge last year).
Self-evidently English level on its own is not an indicator of
academic potential.
(c) Ensuring students
return overseas after their course
The Home Office statistics (The Migrant Journey)
prove that students do return home after their studies but of
course they may have several visas issued by several sponsors
during the course of those studies, over potentially a maximum
of eight or nine years (eg GCSE, A level, Bachelors, Masters and
possibly PhD). This proposal would make the UK significantly less
competitive internationally, if students were forced to leave
the UK each time they needed a new visa or extension - expensive
and logistically inconvenient
Closing the Tier 1 Post Study Work Route is unwelcome
as many international students see the opportunity to get a quality
education and also gain valuable work experience in the UK (maximum
two years) which is often not available in their own country,
as very attractive. Our competitors are strongly promoting differentiation
in this area. UUK believe that there is no evidence to suggest
that these international students are taking jobs from UK graduates
and Study Group would support the tightening of the Tier 1 Post
Study Work Route so that it is restricted to skilled and highly
skilled occupations. We do not consider that the alternative of
Tier 2 migrants, as a practical alternative as this route is already
ridiculously restricted, to a level that negatively impacts our
own competitiveness. Why restrict the global competitiveness of
the UK's businesses further?
(d) Limiting the entitlements
of students to work and sponsor dependents
Study Group would generally support these proposals
except that there have already been substantive curtailments of
the right to work while studying and for some students this work
experience is a key part of the educational experience. The opportunity
to work to sustain an educational course is important for some
international students from less advantaged backgrounds.
(e) Simpler procedures
for checking low-risk applications
Study Group would welcome this implied focus of resources
and attention on higher risk categories. Study Group has incurred
substantial incremental cost to the business of complying with
the Tier 4 system (£100,000 per year in new compliance roles
and costs of accreditation, inspection and UKBA licenses). Whilst
we have taken on more of the burden that hitherto was the responsibility
of government via the UKBA, there is a limit to what we can sustain
as a business whilst the government reduces the resources of the
UKBA and cuts public sector jobs in this area. For more costs
and responsibility there should be benefit to those complying
and investing in that compliance with the increasingly onerous
burdens placed on the sector by the UKBA.
Study Group though its long experience, 30 regional
offices and 200 staff in markets from which we recruit students,
is well aware of the differential risks from students from different
countries and even regions (in the case of China). We support
the focus of attention of limited resources on higher risk areas
and this is the principle that is applied by Australia. We are
best placed to assess that risk and in order to retain our HTS
licenses we proactively manage those risks.
Differential treatment according to a sponsor's rating
is sensible in principle but as long as the criteria for gaining
and retaining those licenses are transparent and fairly applied
across both the public and private sectors.
(f) Stricter accreditation procedures for
education providers in the private sector
The implication of this proposal is that there is,
or should be, a different standard of quality and accreditation
applied to the private and public sectors. In the long term interests
of the competitiveness of the UK's education sector and our quality
image, we cannot support this. Study Group would support a tightening
of the accreditation regime for Tier 4 across the board and believe
that there are too many accrediting bodies with inevitably different
standards. The quality, knowledge and experience of the inspectors
that we have dealt with, particularly from the UKBA have been
poor and we have little confidence that the UKBA has the resources
to effectively manage the Tier 4 license sponsor system. There
have been numerous examples of slow process (four to five months),
subjective and opaque decision making - leading the sector to
see the HTS mechanism as slow and risky and therefore a threat
to commercial business, continuity and planning. See the Annual
Report 2009-10 of the Independent Chief Inspector of the UKBA
for further evidence of this (see http://icinspector.independent.gov.uk/wp-content/uploads/2010/03/Independent-Chief-Inspector_Annual-Report-2009_20102.pdf).
Despite the removal of some 2,000 educational institutions
from the Tier 4 sponsor register (in comparison to pre- PBS),
there seem to be on-going concerns as to whether so-called "bogus
colleges" are still operating. It is not in the interests
of quality education providers such as Study Group for this to
continue and in order to sustain the globally recognised quality
image of education in the UK, effective action must be taken,
without causing collateral damage to quality providers in both
the public and private sectors.
7. The Economic Impact
of Increasing the Minimum English Level to B2 would be:
- Loss of 600 jobs at Study Group UK in Brighton,
Oxford, Cambridge, London and all University campuses where we
teach (see university list above).
- Loss to UK universities of 4,000 full fee paying
international students per year (directly from Study Group courses).
- Loss to UK universities of £180 Million
revenue per year after three years (typically international students
spend three years with universities with a three year bachelor
programme and then many continue to Masters programmes).
- Total loss to the UK economy of £300 million
per annum by year three.
- Loss of 2,300 jobs in UK universities and 2,300
jobs in local regions.
(see research by UCU on the calculation of job losses
per £1 million loss of revenue: Summary issues and regional
revenue-employment/output multipliers
http://www.ucu.org.uk/media/pdf/t/a/ucu_universitiesatrisk_dec10.pdf)
attached—see pp27-32).
If we assume that Study Group represents 10% of the
sub degree university preparation market in the UK, we believe
that we can estimate the economic impact of this proposal to be
the loss cumulatively of c. 30,000 jobs (this includes regionally
dependent jobs).
If the committee wishes to see a real life example
of the impact of ill-considered visa restrictions, we would point
them to Australia where the student visa restrictions (among other
factors) is now recognised to be having a material negative impact
on Australia's GDP and has already led to the loss to 300 university
sector jobs with many more to come and Study Group has also been
forced to retrench over 100 positions so far.
The proposals to restrict international students
is ill-considered, not based on any rational fact or evidence
and has the potential to be extremely damaging to the whole HE
sector and UK economy if implemented.
January 2011
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