The Home Office response to the ICIBI's report on an inspection into the immigration system as it relates to the higher education sector (October 2021 to March 2022)
Published 30 June 2022
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The Home Office response to the Independent Chief Inspector of Borders and Immigration’s report: an inspection of the immigration system as it relates to the Higher Education Sector.
The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for his report. The Home Office is grateful to the ICIBI for the effort that he and his team have devoted to this inspection, and the attention which has been given to examining the relationship between the Study and Work services within Visas, Status & Information (VSI) and the higher education sector.
Work is already underway to take forward the recommendations in this report to ensure that VSI continues to meet not only its own objectives but also to support the delivery of the Home Office’s broader aims in responding to the findings.
The Department has accepted all three of the ICIBI’s recommendations.
The Home Office response to the recommendations
The Home Office should:
1. By August 2022, conduct a review of the Graduate Route:
a. To monitor and report on the success of the route after the first 12 months of operation, tracking the number of applications received, broken down by nationality and most recent qualification in the UK.
b. Developing this analysis, work with representative bodies to evaluate the impact of the Graduate route on international student recruitment, considering to what extent the route has helped universities diversity in international markets.
1.1 Accepted
1.2 The Graduate Route operational team regularly use existing data to monitor and analyse operational trends and will work with Home Office Science colleagues on expanding and developing this into an initial report by August 2022. The report will be shared with analysts from the Department for Education and wider professional membership bodies to secure feedback, insight, and areas to develop. A fully- consolidated report incorporating numerical analysis and insight from representative bodies will be available in October 2022.
1.3 Policy requirements for students and their sponsors relating to Graduate route eligibility are kept under regular review. There has been extensive engagement on elements of Graduate route policy since the launch of the route in July 2021, including further sessions of the working group set up to implement the ‘successful completion’ reporting duty for sponsors. The department continues to engage with key stakeholders to discuss take-up of the route and policy issues raised. Home Office Science have carried out early insights research on the Graduate route and provide advice on publication of that research.
2. By October 2022, undertake a comprehensive review of the Premium Customer Service Teams for Work and Study, taking into account feedback from the sector and findings from this inspection to:
a. Review roles, responsibilities, and grade structures for those working in the team.
b. Provide refresher training to the team and reinstate quality assurance mechanisms to improve consistency and accuracy of the advice they provide.
c. Identify what the sector wants from the service, working with sector representatives to develop agreed service standards.
2.1 Accepted
2.2 The Department has commenced a full and comprehensive review of Premium Service offerings, including direct engagement with existing Premium subscribers and umbrella education sector bodies to ensure their needs and suggestions are taken into account in designing the new service. This will go further than simply looking to improve delivery of the existing service by developing new, more diverse, service options in recognition of the changing education landscape and varying needs of premium customers.
2.3 The review considers existing resources, roles and capabilities, and internal information channels for ensuring consistent and accurate advice. While the review identified resource gaps as the result of long-standing recruitment challenges, existing gaps will be filled by October 2022 along with several additional roles to continue to invest in developing our sector engagement and premium growth. Quality assurance processes have been reinstated after a short pause and will continue to be a core part of operational activity.
2.4 Completion timescales consider the annual peak of student visa applications and associated operational demands, though with a dedicated project manager in place since April 2022, we would expect to have a report reflecting the needs of the sector and identifying a range of potential options for the new service by October 2022.
3. Develop and apply mechanisms to measure the compliance of the higher education sector (as opposed to the Basic Compliance Assessment process, which applies to individual institutions) in Study routes by March 2023.
a. Accurately measure, supported by quantitative and qualitative evidence, the level of abuse of the Study visa route by non-genuine students.
b. On an annual basis, using evidence acquired by 3a) assess whether the higher education sector’s sponsorship compliance duties are proportionate to the risk of abuse.
3.1 Accepted
3.2 As part of our ongoing engagement work with the education sector around areas of emerging risk, we already use a range of qualitative and quantitative data to inform the overall picture and areas of focus. We will continue to develop our work in this regard with the aim of creating a consistent framework and dataset without requiring significant manual intervention.
3.3 On the sector’s sponsorship compliance duties being proportionate to the risk of abuse, we will continue to engage with the sector to agree how we can best make further changes to the sponsorship of students and will further improve compliance through better data-sharing with sponsors, combined with easier-to-view information to measure compliance and act where required. Working in conjunction with education providers, we will explore how we can deliver reforms to the strategic design of student sponsorship to deliver benefits for users.
3.4 We are transitioning to a service delivery model which will include provision of service managers by September 2022. Part of their role will be to look at compliance data from the sector as whole. By March 2023 we will be using sector compliance data as part of our service management data packs at Executive Boards.