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Save my job!

As most of you probably know the UKBA are holding a consultation exercise in advance of further changes to PBS.  They have produced some extremely damaging recommendations – which would have a potentially devastating effect on UK ELT – and put thousands of jobs at risk.  To date, the consultation review has received an estimated 20,000 responses, many of which are emanating from the anti-immigration lobby.  It is vital that our voice is heard.   

Summary of the UKBA recommendations:
Restrict NQF 3, 4 and 5 programmes to Highly Trusted Sponsors only
Introduce Secure English Language Testing for all Tier 4 levels and increase the minimum entry point to B2 of the CEFR (which, depending on interpretation could mean IELTS 6 – or A-level foreign language standards)
Students would be forced to return home to extend/renew their visas
Restriction on working privileges including the removal of the post-study working rights to international students
Introduction of differential procedures based on level of perceived risk
Tighter accreditation controls.

A suggestested response:
International students are not economic migrants.  They have no recourse to public funds and generate £10 billion of revenue for the UK economy.  They should not be included in migration figures at all. They are wealth and employment creators and not major consumers of public services.
The statistical data which is used by the UKBA within their consultation lacks rigour and integrity. They calculate students impact on net migration as those who enter the UK for the purpose study minus those who leave the UK for the purpose of study.  A more accurate methodology  – and one endorsed by the Migration Advisory Committee would be to calculate those entering the UK to study and subtract those leaving from study and to study.  
There is no evidence of public or pressure group support for measures which target international students.
We estimate that up to 150000 jobs are dependent one way and another on the money which international students bring to the UK
We broadly support the additional focus on HTS – but are campaigning for a separate sub-category of Pre-Degree (as opposed to the current sub-degree) – this would cover students on pathway programmes with assured progression to recognised UK university or consortium of universities.
Students ought to be able to renew their visas in the UK. Student Visitor Visas ought to be able to transfer to Tier 4 in the UK if they hold an unconditional offer from an HTS – for a Tier 4 programme.
We oppose the broadening of the use of SELT – it is not a reliable discriminator for identification of likelihood of visa abuse.
If SELT is introduced, any move to introduce English competence at B2 would be completely disastrous – especially if this is interpreted at IELTS 6.0.  Approximately 60% of students where I work would not be able to come to the UK – if B2 is introduced.   
We support differential measures to guard against abuse – and in particular favour the introduction of mandatory deposits for programmes.
We also support the develop of tighter and more consistent accreditation controls.

How to respond to the Consultation
The consultation review and response can be found here – http://www.ukba.homeoffice.gov.uk/sitecontent/documents/policyandlaw/consultations/students/
The closing date for submission is 31 January.
UKCISA have produced some guidelines for students who wish to respond – and they are encouraging as many as possible to get a submission in – http://www.ukcisa.org.uk/student/index.php#student_consultation

Can I just reiterate, it is imperative that we generate as many responses as possible to the consultation.

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