education update - issue nine


Tier 4 management system: are partnership agreements the answer?


In March 2009, the government over-hauled the way students from outside the EEA and Switzerland gain entry to study in the UK.  The Home Office’s four-stage licensing scheme, the new Points Based System (PBS), was rolled out to all educational establishments to ensure more forensic accreditation processes are followed.  The PBS scheme obliges educational institutions to be accredited, to register their sponsors, to identify key personnel to manage the systems, to have a certificate of sponsorship and requires prospective students to gain a minimum level of entry (assessed by points).

The rationale behind this change is to stop the abuse of the system by both fraudulent students and institutions.  Tuition fees from international students generate £2.5 billion a year in the UK and the scope for exploiting this market has, until recently, been vast.  The Home Office scheme seeks to encourage only genuine applicants to apply and study in the UK. 

How is the new licence affecting education providers?


The reasons for the change are apparent and necessary.  However, what has not been so widely acknowledged is the extra administrative time and costs this measure will create for education providers now that they must be licensed as a sponsor.

There are at least four separate roles involved in managing the scheme as a sponsor.  Costs may be kept down if these responsibilities can be merged with existing roles.  If not, the cost of employing new staff will, no doubt, create problems for the providers in question.  Furthermore, the cost for a school or college to apply for a licence and becoming an accredited sponsor is currently £400, with each confirmation of acceptance for study costing £10 per student. 

More onerous than the financial burden are the duties these roles impose.  Record keeping and compliance with the law is one thing, but the reporting duties also place considerable responsibilities on the sponsors.  If they are found to be falling short of any of their obligations, criminal proceedings can be instigated against individuals and there could be civil penalties against the provider.  Most likely the sponsorship licence will also be withdrawn, creating financial concerns, but more importantly, there will then be the problem of numerous non-EEA/Swiss pupils living in the UK without a valid sponsor.

Where are we now?

Phase three of Tier 4 went live on the 5 October 2009.  Phase three is the voluntary trialing period of the sponsorship management system for Tier 4 sponsors.  This trial period allows sponsors to continue using visa letters, whilst gradually adopting the use of the sponsorship management system to issue confirmations of acceptance for studies prior to them becoming mandatory in February 2010.

Could partner institutions be the solution?


A high level of confusion has surrounded pupils who attend pre-sessional courses in the UK before they move onto their main educational provider (as is often the case with international students).  Do they need two different visas? Do both the pre-sessional provider and school have to offer visa letters?  The answer could be no if education providers can benefit from forming ‘partnerships’ with each other.  This would ensure less administrative costs for the providers, and a hassle-free transfer for the pupil from one provider to the other. 

Are there any catches?


As with all new things, there are some pros and cons as things develop.  On the positive side, the collaborative effect of ‘partner institutions’ means the pupil will only need to apply for one child student visa.  The administration involved in this would be minimal for the institution offering the pre-sessional course as well as less cost and paperwork for the parents.  Furthermore, a student would not need to leave the UK after completing the pre-sessional course in order to make a fresh application in respect of their substantive education provider.

On the other hand, the single grant of entry clearance to cover both the pre-sessional course and the substantive course will only be granted where the two providers are named as ‘partner institutions’ on the sponsor licence.  This could lead to problems if one institution omits to fulfil their obligations or fails in their duties. In this case both institutions would be held accountable given the singular nature of the application.  

How can you avoid these pitfalls?


A legal agreement between the partners would allow for transparency as well as security.  It would mean both providers are clear about their obligations to one another as well as where liability for the students begins and ends.  It does not have to be a lengthy document, but it needs to outline all the key areas of responsibility and when and how they manifest themselves.  Given the very recent closures of bogus institutions and fraudulent applications, prudent sponsors should ensure they have one in place should they elect to respond to the new requirements in this way.  

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picture of Helen Rideout
Helen Rideout
0115 976 6291
Associate

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