One of the benefits of conferences is that some issues bubble up that may not have been addressed elsewhere. Whilst that isn’t entirely true of the list of questions I was given regarding the new points based immigration system, I’ve published the answers (as I see them) to the questions raised below:
1. How to make payments. Currently the only mechanisms on offer are payment by credit or debit card or by cheque. Payment is for the batch of CAS (confirmation of acceptance for studies) numbers generated so whether it is for one number or a thousand (the maximum allowed for a batch) the process will be the same. And that process is that payments will only be accepted by credit/debit card or cheque. If the option selected is to pay by cheque then there will be a delay in issuing CAS numbers as the cheque needs to clear before the numbers are issued. The feasibility of a pre-payment mechanism has been raised with the Home Office. However, the official line is that customers should not pay for a service before it is delivered. In this case the service is the generation of the CAS number. There are discrepancies with other Home Office services, notably criminal records bureau checks where prepayment is allowed. Universities UK are continuing to press UKBA on this issue to try to ensure that pre-payment can be delivered.
2. Partner companies. The whole premise of the new system is that the sponsoring institution (ie the institution that the student/applicant is applying to) takes responsibility for students they expect to enter the country. So in the case of organisations such as INTO, the applicant is not applying to study at INTO but is applying to an institution that subscribes to INTO. Consequently it is the institution where the student has applied forthat should take responsibility (as the sponsor for that student) for the student entering the country. I am not aware that there is any change in this position but hopefully Friday’s presentation will address this.
3. Restricting the numbers of CASs issued. Institutions are asked to estimate the number of CAS numbers (ie the number of non-EU students they expect to offer places to) when they apply to be sponsors of students entering the country. I understand that this is not a hard and fast limit and may be expanded on application to the Home Office. I believe that the Home Office/UKBA recognise that this year will be something of a transitional phase and will not impede institutions that may have underestimated the number of CAS numbers they require.
4. Extra resource required. There will be extra resource required to enter data required for UKBA that is not required for normal registry operations. To some extent this is a consequence of new legislation; for example there was no additional resource generated for the introduction of the data protection act. The response below answers the point made on extra resource for monitoring.
5. UKBA have been at pains to stress that they do not require any new monitoring to be introduced to meet the reporting requirements of the new system. Rather, they need to see evidence of the processes in place to identify students that have failed/or are in danger of failing to meet the requirements of meeting ten expected contacts. What an ‘expected contact’ is is being left to the institution; it is not intended that the institution will need to introduce new procedures to meet UKBA’s requirements. Rather that they will have processes in place currently that demonstrate that students’ progress is being monitored. So put simply, normal academic monitoring which should identify when a student has missed a number of expected contacts and so is at risk of failing their course/module, should be sufficient to meet UKBA’s needs and (given that such measures should be applied to all students) should address any equal opportunities issues that may arise.
The caveat is that the responses outlined above are my own and may not be reflective of UKBA policy. The points raised above will be forwarded to David Ramsbotham who is speaking on the implementation of the PBS at the CISG conference on Friday to give him an opportunity to comment or correct the responses I have given here.