Recruiting Overseas Students - what to expect for 2017?
Brexit, a new Prime Minister, a new Home Secretary, concerns around high level of immigration, a consultation on reducing student immigration numbers anticipated
Brexit, a new Prime Minister, a new Home Secretary, concerns around high level of immigration, a consultation on reducing student immigration numbers anticipated - the watchword for independent schools recruiting pupils overseas has to be 'uncertainty' as we move into 2017 and, for admissions teams, the recruitment round for 2017/2018 entry.
Fewer Overseas Pupils?
According to government figures, in the year ending September 2016, there were 207,522 study-related visas granted, 3% lower than the previous year. Comprising a small fraction of these visas, but suffering the same fate, the number of independent school-sponsored study visa applications also fell by 3% to 13,340.
We won't know until the 2017 ISC Census is published whether this fall is reflected in fewer overseas pupils at ISC schools for this current academic year. The current census, which contains figures for the 2015/16 academic year, in fact shows a worse position, with ISC schools reporting 10% fewer new pupils from non-EEA countries, down to 8,752.
School Sponsors on the Decline
Government figures show a total of 1,362 licensed sponsors under Tier 4, of which 774 are registered for Tier 4 Child. These are all independent schools as, under current guidance, only independent schools are eligible to sponsor pupils for Tier 4 Child visas.
Numbers of licensed sponsors have been falling for years, and government data reveals one reason for this. In the year to September 2016, UKVI threatened 102 Tier 4 sponsors with the loss of their licence, and actually revoked 43 Tier 4 licences. These revocations will include other education institutions besides independent schools, of course, but we have seen an increase in the number of independent schools against which UKVI has taken or threatened regulatory action this year. This includes a number of schools whose ability to recruit international pupils has been temporarily curtailed following adverse inspection judgements of ISI or Ofsted, with a zeroing of the school's CAS allotment.
The Importance of Compliant Tier 4 Processes
Compliant Tier 4 policies and processes, properly embedded across the school, cannot be overemphasised. Last year, UKVI carried out 113 compliance visits to Tier 4 sponsors, the majority of which were unannounced. Even for the best prepared teams, these can be daunting visits.
We are carrying out an unprecedented number of pre-compliance visits to schools and a number of themes always emerge:
- The importance of embedding processes, both within the school's Tier 4 'key personnel' (authorising officer, Level 1 user, etc.) and more widely across academic and pastoral staff, who need to be reminded when information must be shared with the key personnel. Compliance with Tier 4 responsibilities, which is a sponsor-wide commitment, must not depend on the working knowledge and availability of one individual.
- Asking the right questions early in the pupil application/registration process. This includes identifying pupils who might need immigration permission to study at the school but who do not ask for sponsorship. Some of these questions, particularly regarding immigration history, can seem intrusive but if visa applications are destined to fail, better that the school learn about this prior to issuing a precious CAS (and definitely prior to a visa refusal).
- Thorough enrolment processes, so that the school gathers all the required documentation prior to a pupil's commencement of studies. This includes checking BRPs for errors (we are aware of numerous errors regarding a pupil's work rights), collecting documents required for under 18s which are, inconveniently, not listed in Appendix D, assessing a day pupil's residential arrangements (see below) and arranging for police registration where required.
- Day pupils are particularly tricky, especially those living with parents or close relatives where there are often awkward questions about the immigration status of the carers.
- For schools issuing Tier 4 General CAS, the need to be aware of specific additional complexities that don't apply to Child CAS, such as time limits studying above the age of 18, assessing English language proficiency and academic progression rules.
We have developed a tailored suite of compliance checklists and guidance packs specifically for independent school Tier 4 sponsors, and can visit your school to assess compliance and recommend improvements.