TIER 4 STUDENT ATTENDANCE AND ENGAGEMENT POLICY

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1 TIER 4 STUDENT ATTENDANCE AND ENGAGEMENT POLICY Contact Officer Euan Fergusson, International Office [email protected] Purpose As a sponsor of international students within the UK immigration system the University is required to evidence Tier 4 student attendance and engagement. This policy will ensure that the University has relevant guidance for staff and mitigates risk related to the University s sponsor licence by ensuring that we have robust student attendance and engagement procedures in place. This policy is an essential component of the University s sponsoring of international students. If the Home Office were to identify that attendance and engagement monitoring was not being implemented as required in regulation, the University may face either a suspension or revocation of our Home Office Tier 4 Sponsor licence and Highly Trusted Sponsor Status. Aside from the significant financial and reputational damage this could cause, it would place the immigration status of all Tier 4 students at the University of Edinburgh at risk and would also likely impact upon all sponsored skilled workers working at the University. This policy supports the improvement of the overall student experience. The policy will further assist with identifying where students may be experiencing difficulties and ensure that timely and appropriate intervention can be delivered to ensure that support can be provided. Overview As a sponsor of Tier 4 international students within the UK immigration system it is a requirement that the University is able to evidence a robust process and internal system that relates to oversight of student attendance and engagement with their programme of study. As a sponsor within the UK immigration system the University is subject to audit visits by UK Visas and Immigration (formerly the UK Border Agency) within the Home Office. One of the key areas used to assess sponsor performance is management of student attendance and engagement. UK Visa and Immigration Sponsor duties relating to this area are detailed in the Tier 4 Sponsor Guidance in the following documents: 1. Applying for or renewing a Tier 4 sponsor licence and highly Page 1 of 14

2 trusted status. 2. Assigning Confirmation of Acceptance for Studies and sponsoring students. 3. Sponsors duties and compliance. Scope This policy applies to all Tier 4 international students attending the University of Edinburgh. The policy applies to on-campus students, those who are registered as writing up their thesis, and those students who are on study away from the University or are on Leave of Absence. The policy will be implemented by School Administrators/Directors of Professional Services across the University and supported by Student Administration, Colleges and the International Office. SECTION ONE PRINCIPLES OF STUDENT ATTENDANCE AND ENGAGEMENT The following Six Key Principles of Student Attendance and Engagement represent the University s policy on attendance and engagement for Tier 4 international students, and what the University requires to do in order to meet Home Office monitoring requirements, as detailed in the Tier 4 Sponsor obligations. Six Key Principles of Student Attendance and Engagement 1. Tier 4 regulations require institutions to demonstrate that sponsored students are attending and engaging in studies and that there are active procedures in place to identify and address attendance/engagement patterns of concern. 2. Students are defined as those students who are owned by their lead School. Schools expressly have oversight and responsibility for the students who are primarily linked to them. 3. The University must identify 10 points of contact throughout each academic year from which they can provide evidence from records as to whether students are attending and engaging with their programme. The points should be spread evenly throughout the year, for each year of a programme. Schools are required to identify up to six points of contact from these identified 10 points of contact. The University is required to: 4. Retain evidence of attendance/engagement records (spreadsheets/databases/online software etc.) to demonstrate that attendance/engagement is recorded and that nonattendance/engagement is noted and acted upon, where required. These records must be kept up-to-date, accessible and available. 5. Report to the Home Office within 10 working days of decision, any Tier 4 student whose lack of attendance or engagement or lack of progress has resulted in their Page 2 of 14

3 exclusion, thereby cancelling the University s education sponsorship of the student to be in the UK. 6. Ensure that attendance and engagement records are securely retained in line with relevant data protection legislation, for a period of one year after the end of the programme. This is for Home Office audit purposes. SECTION TWO - DEFINING POINTS OF CONTACT Meeting the basic licensing requirements means ensuring that students are physically present (attending), but also that they are engaging with their programme of studies. The following examples are interactions from which attendance and engagement can be monitored and recorded: Attendance (Student Administration) Student Administration will use the following to record attendance: Confirmation of Attendance element of matriculation Census points Examination attendance (where applicable) Engagement (All Schools/Colleges) Schools must determine a selection of the following for all students owned by their School to record engagement: Submission of assessed work (assignments) Programme induction sessions Submission of coursework either in-person or electronically Attendance at feedback or feed-forward events Achieving research or writing-up milestones as per agreed schedule/timeline or research plan Accessing and engaging with online/virtual learning content Meetings with PTs/supervisors Laboratory practical sessions Specific seminars/tutorials (for example, during a defined period in the academic year) [Schools and OLL are responsible for monitoring the students they own, registered on degree programmes or courses that they deliver. The responsibility does not extend to monitoring engagement on any other courses taken by the student in other Schools. In all the text below, the usage of School should be taken to include OLL students.] Page 3 of 14

4 The identified points of contact must involve a mixture of both attendance and engagement attributes. A schedule might be formed as follows: Point Attribute Description Timeline 1 Attendance Confirmation of Attendance monitored by Student Administration 2 Attendance Attendance at Semester 1 census point - conducted by Student Administration 3 Engagement Attendance at one of the various engagement points detailed earlier Sept/Oct Oct/Nov Oct/Nov 4 Engagement Engagement with online virtual learning content on or by a given date (Learn) Throughout year 5 Engagement Submission of scheduled assessed work Nov/Dec 6 Attendance Attendance of the examination diet monitored by Student Administration Dec 7 Engagement Mid-year meeting with Personal Tutor/Supervisor Jan/Feb 8 Engagement Submission of scheduled assessed work Feb/Mar 9 Attendance Attendance at a census point (x 2) monitored by Student Administration 10 Attendance Attendance of the examination diet monitored by Student Administration Jan/Mar/July for PGs May/June Students on semester or year-long exchange Tier 4 students on semester-long or academic year exchanges are, by definition, outside the UK. The University s sponsoring duties nevertheless continue for such students and for the student record to reflect that students are on an anticipated period of study away from the University. As part of exchange agreements, partner institutions are notified that the University of Edinburgh wishes to know that their students have arrived and are regularly attending classes and other engagements, and to have its Exchanges Team in the International Office notified where these are not being satisfactorily met. Students on work placements or field work Tier 4 students are permitted to carry out field work, work placements or work based learning during the academic year, where this is a required and an integral part of the course, as confirmed in the Degree Regulation and Programmes of Studies (DRPS) and as indicated in the Confirmation of Acceptance of Studies (CAS) where relevant. The host organisation Page 4 of 14

5 should report the student s arrival and raise any issues on attendance with their contact at the University. Contact should continue during a period of work placement or field work. Examples of these could be regular and scheduled contact for an update or phone contact. Postgraduate research students For postgraduate research students, the contact points should similarly contain a mixture of attendance and engagement attributes and should include supervisory meetings and meeting milestones towards thesis completion. Where students are off-campus (field work, research in another country/location), there can also be virtual contact points: s, skype interactions, etc. For students on permitted field-work, or off-campus for research or other similar activities, scheduled updates between supervisors and supervisees can constitute contact points, especially those which contain a requirement for the student to forward work completed to date, or linked to research milestones or other course/programme outcomes. Examples might include agreed deadlines for completion of a particular thesis chapter, deadlines for conducting a particular piece of research or similar. In such cases, milestones should be auditable meaning they are recorded, checked against and retained. SECTION THREE: REVIEWING ATTENDANCE AND ENGAGEMENT Effective monitoring is not a passive data collection exercise. In addition to monitoring attendance and engagement, best practice indicates the need to identify a point at which attendance or engagement issues can be escalated, as required, from informal warning through to exclusion. For auditing purposes, it is important to record and retain any information which indicates when such additional measures have been enacted. A student does not need to miss all contact points for it to constitute an attendance/engagement pattern of concern. Similarly, the missed contact points need not be consecutive before it is appropriate to draw the student s attention to attendance requirements. Circumstances in which a student may be excluded are detailed in 3.2 and of the Procedure for Withdrawal and Exclusion from Studies : udy.pdf It is essential that students are encouraged to fulfil their obligations as set out in section 3.2. A suggested escalation schedule may be as follows: First stage One scheduled contact point missed without explanation or following significant delay. An informal message from the School to advise the student that active participation is expected on the programme and to highlight how to contact relevant members of support Page 5 of 14

6 Second stage Third stage Final stage Note: a student may be excluded due to failure to attend a census or fail to confirm attendance at matriculation. Two expected or scheduled contact points missed without explanation, or which are attended following significant delay/chasing. A student misses three consecutive contacts or reaches a third missed contact within the ten; attendance/ engagement could be reasonably deemed to be inconsistent and of concern. Where a student has consistently missed contact points or his/her attendance/ engagement or progress more widely is at a level staff to discuss any issues A formal message from an appropriate School contact to advise the student of his/her responsibilities to attend the chosen programme; reiterate the warning at the first stage, and to invite him/her to discuss any issues affecting attendance/engagement with a relevant member of staff. A best practice example within the University s Vet School shows that a second consecutive missed contact is an opportunity to speak to the student directly either through the Student Support Officer, a Personal Tutor or similarly appointed person, to affirm the need to attend. Any problems which may account for a recurring absence can be investigated and support measures suggested. A brief minute of this meeting should be retained on file. At this point, further investigation may be necessary to determine whether the student is otherwise progressing with his/her programme and in the light of any relevant information, whether a more formal discussion with a Personal Tutor or Supervisor is merited. It would be at this stage that a reiteration of the Tier 4 sponsor/student relationship is appropriate and that a discussion of the requirement to report exclusion through non-attendance would be proportionate. In such cases, an appropriate Head of College or delegated officer (e.g. a Dean) should consider the student s overall progression in relation to academic policies, including the Page 6 of 14

7 deemed unacceptable. Procedure for Withdrawal and Exclusion from Studies. Where excluded, the student s record must be updated to reflect the new status and the resulting report by Student Administration to the Home Office to withdraw sponsorship must be actioned within 10 working days of the date of decision to exclude. NOTE THAT THESE POINTS OF CONTACTS ARE ASSIGNED THROUGHOUT THE YEAR AND THEREFORE MISSING MORE THAN TWO POINTS CAN REASONABLY BE CONSIDERED BEYOND COINCIDENCE. A. ABSENCE AND INTERRUPTIONS OF STUDIES Authority to be absent: Under the University s academic regulations, students are not permitted to be absent (unengaged) temporarily from their studies without prior consent. The absence must be authorised by the School or College involved, as required. Requests for temporary absences must be dealt with promptly via the appropriate route (e.g. invoking Special Circumstances or Interruption of Studies procedures). Evidence of requests: s, letters, meeting notes, decision notifications should be retained. Leave to study away ( Leave of Absence ). Note that study away is not an absence from study, and leave to study away is called Leave of Absence. Students may require time to work off-campus for temporary periods. Authorisation may be given by Colleges or Schools, provided that such a temporary move does not conflict with any other requirement of the student s programme of study, including any obligations to be physically available for on-campus activity. Such periods may occur, for example, when students have been given leave to prepare their Master s dissertations or PhD theses or to carry out field work or research in a particular offcampus location. Leave of Absence should not be confused with an Interruption of Studies, during which no study work should be required. Interruptions of studies must be reported to the Home Office in all cases where the interruption is longer than 60 days. Note that interruptions of studies must not be granted retrospectively. Immigration impact of Interruptions of Studies: an interruption of studies reported to the Home Office that is longer than 60 days will normally result in a cancellation of Tier 4 sponsorship and the student will be required to leave the UK. If/when the student re-joins the programme at a later date, he/she will need to be issued with a new Confirmation of Acceptance for Studies (CAS). Sponsorship under Tier 4 resumes on the date of a new Confirmation of Acceptance for Studies (CAS) being issued. Page 7 of 14

8 Please ensure students in this situation are directed at the earliest opportunity to the International Office to seek appropriate visa guidance: SECTION FOUR: RESPONSIBILITIES STUDENTS A Tier 4 visa permits an individual to be a matriculated student in the United Kingdom, in order to pursue studies at his/her sponsoring institution only. Students must ensure they have obtained the appropriate visa for studying in the UK ahead of enrolling at the University of Edinburgh. Attending/engaging: Tier 4 visa holders are expected to be in attendance on their chosen programme and engaging with it, as required within relevant academic regulations. If the students or staff discover potential attendance problems which will affect engagement with the degree s requirements, students should be encouraged to discuss these early on with their supervisor or personal tutors as appropriate and to obtain visa guidance where required from the International Office. Contact details: it is the students responsibility to ensure that University holds their most up to date contact details. Students can update their details on a self-service basis through their MyEd channel. Communication: Students MUST use their student address and must respond timeously to official contact from the University. SCHOOLS Confirming attendance of students at matriculation: Schools must confirm the attendance of students annually as part of matriculation. This should be done as a result of face-to-face, in-person interaction with the Personal Tutor/Supervisor. Attendance confirmation is required at first matriculation and thereafter at the start of each successive year of study, following the standard University process, with Student Administration monitoring. Awareness: Schools should ensure that students are made aware of their attendance, engagement and on-campus obligations. Programme handbooks should include this information, together with guidance on how students should submit requests for absences (special circumstances, interruptions of study, etc.). Monitoring of students engagement: Schools are responsible for identifying the following number of contact points of on-programme participation per level of study and the responsibility for recording this: Level of Study Undergraduate Attendance (Student Administration) Engagement (Schools) With Exams 6 4 Page 8 of 14

9 Without Exams 4 6 Postgraduate - Taught With Exams Without Exams Postgraduate - Research 6 4 Records must demonstrate the contact point and highlight the identity of those who have not engaged. Documenting monitoring method: Schools must maintain records of student engagement monitoring and ensure that these records can be made available for inspection and audit requirements when requested. These records must be made available as required by the Home Office as part of their annual compliance visit. While notice is normally given, visits can be conducted with minimal or no prior notice. Records can include: i. Notes in the EUCLID notes field for Personal Tutors/Supervisors ii. iii. iv. spread sheets/databases outlining identified contact points per programme word documents s v. letters vi. minutes of meetings Reviewing student engagement data: It is the responsibility of every School to review on a regular basis the student engagement data that they collect and record, and any attendance data sent to them by Student Administration which highlights absences. The review should determine whether and what appropriate action needs to be initiated including follow-up directly with any student whose attendance/ engagement is deemed inadequate as set out in (Section 3). Reporting on student non-engagement: If a student continues not to engage or attend and is excluded as a result, the exclusion must be processed and completed as required for all students. Once the decision to exclude has been made, the student s details must be changed on the on-programme change of details request form in Page 9 of 14

10 EUCLID. This will alert the Operations Manager (Immigration Compliance) that the student has been excluded and a report will be issued to Home Office as required. It is vital that any exclusion decision is full and final, as immigration curtailment action will not be reversed once enacted. The University is required to report any exclusion to the Home Office within 10 days of decision of exclusion. Colleges Changing student status: where a student is excluded due to nonattendance/engagement or where s/he withdraws by personal preference, the College Office should request that the student s status is changed through the Online Programme Details Change Request Form. Maintain school contacts: Colleges and Student Administration are required to maintain a network of School contacts, which coordinate student engagement and attendance as communicated via Student Administration monitoring and ensure that there is a consistent approach in place. Review school monitoring plans: Colleges should review annually the monitoring plans for each School, with assistance from the International Office and Student Administration and their advice on best practice. Student Administration Monitoring of students engagement: Student Administration is responsible for identifying the following number of contact points per level of study: Level of Study Undergraduate With Exams Without Exams Postgraduate - Taught With Exams Without Exams Attendance (Student Administration) Engagement (Schools) Postgraduate - Research 6 4 Reporting: The Student Administration team will respond to the change of status affected by the College updating the student s record Page 10 of 14

11 in exclusion cases. Tier 4 Students who have been withdrawn due to nonattendance/engagement or other academic reasons will then be reported by the Operations Manager (Immigration Compliance) at Student Administration to the Home Office. Note: only Student Administration staff are designated to issue reports to the Home Office. Arrange census and census review: Student Administration will arrange census points throughout the year. It will review the census data and will undertake follow up action as required with any Schools where non-attendance has been reported or identified for their students. Census review: Student Administration will also monitor full completion of the enrolment process, attendance at exams and send timeous lists of all non-attenders to the relevant School contact for appropriate follow-up action where applicable. Immigration advice The International Student Advice Service at the International Office can provide further immigration advice to students who have been withdrawn and reported to the Home Office. Requests for appointments should be sent to [email protected] SECTION 5: CONSEQUENCES OF REPORTING TO THE HOME OFFICE If students on a Tier 4 visa are reported to the Home Office as excluded, this will lead to cancellation of their sponsorship by the University and with that, their visa will be curtailed. The students will normally be expected to leave the UK within 60 days as required by Home Office. In order to safeguard a non-eea nationals potential to return to the UK at any point in the future (for whatever purpose) and to minimise the possibility of students inadvertently overstaying a curtailed visa, students are advised to consider the start of their 60 days as the date they were notified in writing by the University that a report withdrawing sponsorship has been issued to Home Office. Given the requirements of law, the timescales set out and the action of curtailment that will result in a report to the Home Office, it is essential that any exclusion action taken is a definitive and final decision, as once a report has been made, there is minimal opportunity to rescind it. SECTION 6: CONSEQUENCES OF LACK OF ENGAGEMENT MONITORING PROCESS The requirements to monitor attendance and engagement are part of the Tier 4 licensing and Highly Trusted Status requirements and relevant immigration law. If an audit or intelligence or spot checks by the Home Office revealed that attendance and engagement monitoring is not being delivered as required in regulation, the Page 11 of 14

12 institution may face a suspension or revocation of both the licence and Highly Trusted Status. Aside from the financial and reputational damage this could cause, it would place the immigration status of all Tier 4 students at the University of Edinburgh at risk and would also likely impact upon all sponsored skilled workers working for the institution. SECTION 7: OPERATIONAL CONTACTS Kate Monroe Operations Manager (Immigration Compliance) Student Administration [email protected] Euan Fergusson International Student Support Manager International Office [email protected] Page 12 of 14

13 APPENDIX 1 ATTENDANCE/ENGAGEMENT MONITORING TO COMPLY WITH THE HOME OFFICE TIER 4 REQUIREMENTS In 2008, the UK Government introduced the points based system and five categories or tiers for sponsoring Non-EU/EEA/Swiss nationals to undertake a variety of activities in the UK. Tier 4 is the category for sponsoring education activity. Under Tier 4, all educational institutions must have a Home Office approved sponsor licence to recruit and retain students. Additionally, all institutions must meet the detailed requirements for being Highly Trusted Sponsors. Tier 4 students are sponsored by the institution to study in the UK. The University of Edinburgh currently sponsors over 5,000 students for their UK education. The Tier 4 requirements set out a sponsor/student relationship and include a number of basic student management requirements to ensure the license can be maintained. In doing so, the sponsor assumes responsibility to ensure the institution is complying with the legislation. If the Home Office determines that these duties are not being carried out they can suspend or withdraw the license; an act which would affect all Tier 4 students at the institution and would have repercussions on Tier 2 staff members. One of the primary on-course duties is the requirement to monitor the attendance and engagement of all Tier 4 students, and to report any sponsored student who - as a result of non-attendance/engagement - the University has excluded and no longer agrees to continue sponsoring. Meeting these requirements requires engagement by both academic and support staff across the University. Home Office sponsorship duties on monitoring are detailed in the Tier 4 Points Based Migrant System Guidance for Sponsors. The procedure for withdrawing students due to lack of attendance is detailed in Section 3 of the Procedure for Withdrawal and Exclusion from Studies with reference to Tier 4 students in DOCUMENT CONTROL Date approved 5 June 2014 Approving authority Curriculum and Student Progression Committee (CSPC) Consultation undertaken Schools, Colleges and EUSA consulted through Managed Migration Group. Equality Impact Assessment TBC Date of commencement 01 Aug 2014 Amendment dates Routine annual amendments in relation to UK government policy changes Date for next review 01 Aug 2015 Section responsible for policy maintenance & review International Office and Student Administration for ongoing administrative review. Substantive changes to be submitted for noting and approval by CSPC. Page 13 of 14

14 Related Policies, Procedures Guidelines & Regulations United Kingdom Immigration Rules and related statutory instruments and secondary legislation Tier 4 Sponsor Guidance Procedure for Withdrawal and Exclusion from Studies Code of Practice for Research Supervisors Policies superseded by this Policy Alternative Format New policy If you require this document in an alternative format please [email protected] or telephone Keywords Tier 4, migrant sponsorship, compliance, Home Office, attendance, monitoring, international students. Version 1.1 Page 14 of 14