Supplementary written evidence submitted
by the British Accreditation Council for Independent Further and
Higher Education
The impact of recent changes to the student visa
system on the Government's plans for private higher education
as set out in the White Paper, Higher Education: Students at
the Heart of the System, June 2011.
In reply to Katy Clark, MP on 24 May 2011, I supported
the notion of a "level playing field" for higher education
quality assurance regardless of the ownership status of particular
institutions. I said, on behalf of BAC, that:
"we hope that whatever the common level playing
field for quality assurance is, it should be inclusive. It should
not damage the access that students have, through private colleges,
to higher education of all sorts, in a range of fields."
(Question 609)
I should like to amplify this comment in the light
of more recent developments.
In their Foreword to the Higher Education White Paper
Students at the Heart of the System, the Secretary of State
for Business, Innovation and Skills and the Minister for Universities
and Science argued that:
"Responding to student demand also means enabling
a greater diversity of provision. We expect this to mean more
higher education in further education colleges, more variety in
modes of learning and wholly new providers delivering innovative
forms of higher education". (Cm 8122 p. 3)
The White Paper recognises and celebrates diversity
of provision:
"Over 1,600 bodies, public and private, at home
and overseas, offer some form of UK higher education provision,
around 250 of which are further education colleges." (Cm
8122 p. 46)
Apart from this reference, the Paper is curiously
silent on the issue of UK-domiciled private higher education institutions.
Yet BAC estimates that these teach at least 36,000 students on
degree courses and a further 11,000 on UK University-validated
non-degree courses.[34]
70 of the 86 Listed Bodies are BAC-accredited private institutions
whilst a further 52 offer substantial elements of UK university-validated
provision.
The Paper then goes on to argue that:
"Many private providers run successful higher
education courses in England without wanting to enter the English
higher education sector and will probably go on doing so. As with
other providers, the regulatory regime will depend on what alternative
providers wish to access. If they wish to hold degree-awarding
powers they will have to sign up to a quality assurance regime."
(Cm 8122 p. 73)
Whilst this may continue to be true for those recruiting
UK and EU-domiciled students, it fails to recognise the mandatory
nature of the new arrangements for "Educational Oversight"
which the Home Office has imposed on Tier 4 Student Visa Sponsors
with effect from 4 July 2011.
Private institutions have undergone a long period
of uncertainty regarding their ability to recruit international
students. In particular the following three points are of concern
following the most recent raft of changes:
— Students
at private institutions will have no work rights, compared to
their peers at public institutions (including those on the same
course, such as university-registered degree students) who can
work part time. This is seen as particularly inequitable and potentially
open to legal challenge.
— Private
institutions now have to apply for a new system of Educational
Oversight, incurring significant additional costs, despite having
already undergone demanding accreditation processes; this system
is not yet fully in place and institutions are not yet able to
apply to the relevant bodies.
— In
the interim, private institutions have had the number of offers
they can make to international students frozen, leading for most
to a significant real-terms cut in number of enrolments. For many
institutions, some of which were experiencing rapid growth, this
represents a significant shortfall in revenue which may threaten
the viability of their business.
Taken together, these changes are likely to cause
a significant number of reputable, high-quality educational institutions
to close because of the negative effect on international student
recruitment. The UK education sector is highly interlinked and
interdependent; any negative publicity arising from the closure
of private institutions will damage the UK brand and is likely
to impact significantly on other institutions by steering international
students towards other countries which are perceived as a safer
bet. The rules surrounding the student immigration route have
become extremely complex over the last few years and there is
already considerable confusion and some wariness amongst international
students.
In light of these difficulties, BAC has proposed
the following measures to alleviate some of the potential damage
to the education sector:
— The
expansion of the 11-month extended student visitor visa to include
academic and vocational courses. This would mitigate some of the
damage to the private sector and save some institutions from closure,
without adding to net migration figures; this concession has already
been provided for the English language sector.
— Equality
in work entitlements for students registered with a UK university,
but studying at a partner college; the disparity between working
rights for international students is unfair and unnecessary in
all cases, but this would go some way to rectifying the problem
for a proportion of these students.
— That
the newly designated Educational Oversight Bodies make full use
of existing and proven inspection procedures and monitoring strategies
in developing the new quality assurance system for the private
sector, so that it is fair and fit for purpose.
The Select Committee is asked to consider the consequences
of these differences in treatment between public and private sector
institutions (which appear to have had the tacit support of the
Education Ministries) for the principle of greater diversity of
provision envisioned by the Higher Education White Paper and the
access that students have, through private colleges, to higher
education of all sorts, in a range of fields.
Professor Steve Bristow
Senior Advisor (Quality Assurance and
Governance)
July 2011
34 Briefing note for Select Committee prior to Oral
Evidence, May 2011 Back
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