The most comprehensive study yet of the UK higher education sector’s international student visa costs has revealed a complex system characterised by confusion and inconsistencies. The estimated cost to universities in 2012-13 was a whopping £66.8 million (US$87 million) – £26 million higher than the most recent estimates.
The research was conducted by the Higher Education Better Regulation Group, or HEBRG, which was established in 2010 to tackle changing attitudes towards accountability and a transforming regulatory landscape, and is supported by the representative bodies Universities UK and GuildHE, the higher education funding councils for England and Scotland and the Department for Employment and Learning in Northern Ireland.
In a press release, Andrew Boggs, policy advisor with HEBRG, said: “Higher education institutions are prepared to meet Home Office expectations on student visa compliance, but confusion over requirements and constant rule changes have led to waste and overspending in an effort to comply.”
He said the study took a representative sample of higher education providers with international (non-European Union) students and found that, on average, they were investing £312,000 to £358,000 per year to meet visa oversight requirements.
The study also noted massive variability between institutions, with one spending 50 times more per student than another to meet regulations, yet both meeting Tier 4 visa requirements.
Tier 4 of the Points Based System for student immigration was introduced by the Home Office in March 2009 to control the entry of students from outside the European Economic Area who come to the UK to study.
“This variability cannot be explained by economies of scale or intensity of international student enrolment,” according to Boggs, but instead indicated irregular and varied interpretations of Tier 4 visa compliance requirements across institutions.
The study found that the already well-documented issues around the initial implementation of the Tier 4 system, and subsequent frequent changes to the system, had led to unnecessarily high set-up costs for higher education providers.
The perception was that costs had been higher than necessary due to past issues with efficiency and effectiveness at the former UK Border Agency, and the turbulence created by repeated guidance changes with little lead time for change.
A number of providers had been forced to implement policies and procedures reactively to the frequent changes, in a haphazard, incremental way, rather than being able to proactively plan more efficient procedures.
The study also found that the requirement to ensure students were attending properly, and to report 10 expected contacts via text message, was one of the single biggest costs in the system because it involved so many staff across institutions. In some areas the guidance was highly specific, but in others it was much more general and therefore open to interpretation.
Included in the research was the question of benefits, if any, of Tier 4 regulation. It was found there had been several, including improved recruitment and application systems; time- and paper-saving thanks to increased digitisation; improved monitoring of international students; and more standardised admission procedures.
HEBRG recommended various changes to the system to improve visa compliance and reduce the cost burden to institutions.
One suggestion was that the Visa and Immigration Directorate should work with the sector when changing regulations, to reduce administrative burdens while dealing with and tackling risks. For example, providers can now define their own induction period, giving some flexibility to when they report students who enter the country but do not enrol.
Second, a longitudinal study could be undertaken of the correlation between the introduction of Tier 4 regulations and successful retention, progression and completion rates by international students.
It was also suggested that while the removal of the sponsor licence was appropriate in some circumstances, across the higher education sector there was a much smaller risk of misuse of Tier 4 visas than in other areas.
Penalties for non-compliance could be tiered, with more consideration given to actual breaches than to administrative errors, and more intermediate steps before suspension or revocation of the licence.
Boggs added: “Applying a sliding penalty structure, rather than ‘all or nothing’ punishments for institutions, regular training events for higher education providers, and providing feedback on visa refusals, in addition to the Home Office’s introduction of an immigration Higher Education Assurance Team, could help institutions to do their job more effectively while reducing the cost to institutions and, by extension, students and the public.”
A spokesperson for the Home Office was quoted in a BBC report: "The student visa route we inherited was open to widespread abuse and neither controlled immigration nor protected legitimate students from poor quality sponsors.
“We have overhauled this to tackle abuse and figures show our changes are having the right effect. Most recent statistics show a 5% increase in the number of sponsored student visa applications for our world-class universities while net migration is at its lowest level in a decade.”
A new co-regulation group has been set up with membership from the Home Office, the department for Business, Innovation and Skills, Universities UK and GuildHE, and the Visa and Immigration Directorate – the operational arm of the group.
The group’s focus is on simplifying Tier 4 policy, making it less difficult to follow, and reducing the administrative burden on universities.
In June, Universities UK and the Home Office issued a joint communiqué on co-regulation to higher education providers. And new Tier 4 guidance was published by the Home Office on 1 July.
The government has indicated that no future major policy changes are envisaged, there is to be a period of stability, and the focus of Tier 4 regulation will be on the private college part of the sector, rather than on universities.
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