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Student visa Engagement and Monitoring Policy 20/21

Last updated: Oct 2021

0. Temporary concession Distance Learning (August 2020, may be removed by UKVI April 2022).

1. Student visa Engagement and Monitoring Policy

2. Enrolment and re-enrolment

  • Failure to enrol or re-enrol

3. UKVI Engagement and Monitoring requirements SMULIC and St Mary's

4. Management of non-engagement

5. SMULIC pathway courses and Pre-sessional programmes

6. Email reminders

7. 60 days of non attendance

8. Change of course (all programmes)

9. Authorised Absence letters

10. Leave of absence (LOA)

11. Early completion

12. Repeating a year

13. Withdrawals

14. Programme termination

15. Other engagement and monitoring considerations:

  • Work Placements
  • Study Abroad
  • Distance Learning
  • Short Courses
  • Student Ambassadors
  • Student Union sabbatical officers
  • Offsite Teaching
  • Students with ‘other’ immigration status
  • Debtors
  • Reporting students and visa curtailments
  • All other programmes with Work Placement opportunities
  • EU Nationals

Temporary concession Distance Learning August 2020 (may be removed by UKVI April 2022)

UKVI guidance for sponsors now permits Distance Learning under the Points Based System. It is possible for learning to be completed inside or out outside the UK for semester one but only if the programme permits.

Where it is found that students have not engaged with Distance Learning via ‘Moodle’ (where applicable) for 30 days, the UKVI Compliance and Immigration Team (UCIT) may withdraw sponsorship unless the reasons for absence have been recorded. Circumstances will be investigated on a case by case basis, if there are no levels of engagement, or communications explaining absence, students are at risk of being withdrawn.

UCIT receive weekly Moodle reports from the Technology Enhanced Learning Team (TEL). Moodle reports will be used as an engagement measure and will be collated for UKVI audit purposes.

1. Student visa Engagement and Monitoring Policy

 

An appropriate level of engagement from all students with their programme of study is important and has a direct impact on their success. Sufficient attendance at relevant classes is a strong indicator of engagement and is essential for international students who have a Student visa, to ensure visa compliance.

It is therefore important for the University to undertake effective and efficient monitoring of student engagement and be able to produce and analyse attendance data.

The monitoring of student engagement is a mandatory requirement of the Home Office (UKVI) for the University to maintain its Sponsor Licence as a sponsor of ‘international students’. Loss of this status and hence the ability to admit international students, would be extremely detrimental to the University and would constitute a significant financial and reputational risk.

During a UKVI audit, St Mary’s staff will need to provide evidence of a robust engagement and monitoring system. The minimum expectation from UKVI is that student engagement is recorded throughout the full academic journey. As a duty of care to our students we must maintain regular contact and keep records of any interventions where any authorised and unexplained absences have occurred. We need concise, user friendly processes that evidence how we monitor engagement, progress, wellbeing, authorised absence, unexplained absence and any non-academic progression of our students.

The Student visa Engagement and Monitoring Policy is to be used in conjunction with: How to use the Attendance and Engagement Tracker, St Mary’s Attendance Monitoring Policy, The Personal Tutoring Policy, Fitness to Study Policy, Leave of Absence Policy, Extenuating Circumstances Policy, Withdrawal Policy and the Fee Regulations.

2. Enrolment and re-enrolment

 

To improve student satisfaction, St Mary’s University has opted in to be an: Alternative Collection Location (ACL). This means we will receive delivery of all Biometric Residence Permits (BRP’s) on behalf of our students. All BRP’s will need to be checked for errors and stored in a safe located in Registry to meet the expectations of Appendix D of the immigration rules. The UCIT team will meet and greet all international students during the enrolment period and distribute the BRP’s.

During enrolment and throughout the duration of studies for all international students with a visa status, we must ensure we have up to date copies of passport biographical pages, visa entry stamps, Entry Clearance Vignettes, Visitor visas and any paperwork clarifying up to date immigration status copied and saved against relevant student admissions/enrolment records (SITS). This is to ensure that all students have the right to study whilst enrolled.

Enrolment and re-enrolment will be recorded as the first key event for the academic year, providing the opportunity to explain to each student the student visa engagement requirements, employment regulations (during studies) and police registration (if applicable).

Failure to enrol or re-enrol

A student with a USED CAS number who does not enrol within 10 working days of the latest enrolment period, (this is usually 2 weeks after teaching has begun), will be reported to the Home Office for failing to register at St Mary’s if there are no communications received and there has been no engagement.

A continuing student will need to re-enrol to continue with their studies at St Mary’s. SITS reports will be generated throughout the enrolment period to ensure that all re-enrollers are identified.

A student who does not re-enrol within 10 working days of the latest enrolment period, (this is usually 2 weeks after teaching has begun), will be reported to the Home Office for failing to re-enrol at St Mary’s if there are no communications received and there has been no engagement.

3. UKVI Engagement and Monitoring requirements SMULIC and St Mary's

 

(UKVI Band 1)

Below Undergraduate degree level

(Including Pre-Sessional, Foundation level and first year of Undergraduate degree level studied at SMULIC).

Where a student has not reached 85% attendance of the minimum of 15 hours of classroom-based study in any given month, the reasons for absence must be reviewed and documented. A student’s attendance record must be annotated with the reason for non-attendance and what steps are being taken to improve this. (Please review SMULIC SINOS attendance report information below).

Where attendance falls below 70% for 3 consecutive months, a sponsor must withdraw sponsorship unless there are exceptional reasons for the non-attendance (e.g. Illness) according to UKVI Sponsor Guidance.

The SMULIC Engagement and Attendance tracker will be used for recording all attendance and absences. The SMULIC-PD3 Attendance and Monitoring Policy includes the details of the UKVI attendance thresholds

(UKVI Band 2)

Foundation degree, UG, PG, MPhil, MRes, PhD level programmes studied at St Mary’s University.

The UKVI Sponsor Guidance. provides academic engagement examples to be used for the purposes of monitoring. The examples below will be used throughout the full academic year to ensure we have clear visibility of progression until the end of a programme. During a UKVI audit, we must produce the Student visa Engagement and Monitoring policy on request.

The engagement tracking examples will be recorded on the Attendance and Engagement Tracker for UKVI audit purposes.

UCIT engagement tracking examples:

  1. Course registration/enrolment.
  2. Lecture/Seminar attendance.
  3. Weekly Moodle reports (SMU and SMULIC).
  4. Marks Entry deadlines.
  5. Exam Board progression.
  6. Outstanding fee payment status checks.
  7. Continuing student re-enrolment.

4. Management of non-engagement

 

A student who knows they will be absent for any period of time must make this known to their Programme Director or Personal Tutor. All lecturers are responsible for populating the CELCAT attendance registers accordingly, for example, if a student has forgotten to ‘tap in’ but was present, the CELCAT attendance registers must be amended by their lecturer to show that the student was present.

During teaching weeks, UCIT must populate the Attendance and Engagement Tracker with attendance percentages on a weekly (Moodle) and fortnightly (ID card tap in) basis. Academic Administration staff must supplement this tracker weekly with any other notes pertaining to known information regarding their students (e.g. meetings, extensions, emails, etc). Please refer to: ‘How to use the Attendance and Engagement Tracker’ access granted via UCIT stored on SharePoint. UCIT will follow up with: Academic Administration staff, Programme Directors and lecturers where necessary. Academic Administration staff will continue contact with students where this contact has already been initiated to ensure a clear line of communication.

If ID card tap ins are below 50% and Moodle logins are below 2 per week, UCIT will make contact with the individual students to ‘check in’ and signpost St Mary’s support services where applicable. Students will be asked to complete a survey which will ask a series of questions including: ‘Please tell us why your attendance is showing as below 50%/your Moodle logins are below an average of 2 per week’, ‘Would you like us to send you links to any study support’. If engagement does not improve UCIT will request a meeting. If students do not attend their meetings or respond to surveys sent via email, further investigations will take place and they may be placed in a ‘High Risk’ category and will become more ‘at risk’ of withdrawal for non-engagement. Please refer to 60 days of inactivity below for more information.

5. SMULIC pathway courses and Pre-sessional programmes

 

St Mary's University London International College (SMULIC)

Teaching takes place from the Naylor Library and attendance registers are recorded for each class. The SMULIC cohort are expected to maintain a minimum of an 85% attendance record in each enrolled module. Any enrolled student whose attendance does not meet the expected 85% requirement or presents an inconsistent pattern across a set of modules, will be placed on the Students In Need Of Support (SINOS) programme for close monitoring. This will enable closer scrutiny of attendance and performance where the student will meet with their tutor and the Academic and Student Services Manager to discuss progress and improve attendance.

St Mary’s PRE-SESSIONAL 10 and 6 week

Teaching takes place from the Naylor Library and attendance registers are recorded for each class.

Students are expected to maintain a minimum of an 85% attendance record in each enrolled module.

Any enrolled student whose attendance does not meet the expected 85% requirement or presents an inconsistent pattern across a set of modules, will be placed on St Mary’s Attendance Report. This will enable closer scrutiny of attendance and performance where the student will meet with their tutor and the International Student Experience Manager or with UCIT to discuss progress and improve attendance.

The SMULIC Engagement and Attendance tracker

Is used to track attendance, engagement, absences and progress. The Tracker must be updated on a weekly basis by relevant SMULIC colleagues and UCIT and will reflect the student journey from enrolment – successful progression.

Class registers

Are recorded by SMULIC lecturers during class and must be saved to The SMULIC Engagement and Attendance tracker by relevant SMULIC colleagues.

Moodle logins

UCIT will update Moodle reports on a weekly basis and must save to The SMULIC Engagement and Attendance tracker

SINOS

Students In Need Of Support (SINOS) must be saved to The SMULIC Engagement and Attendance tracker by relevant SMULIC colleagues.

Weekly attendance meetings

Are held between UCIT and relevant SMULIC colleagues to review the previous weeks attendance and identify any issues with attendance or engagement.

Lists of students for UKVI reporting

Where students fall below the required attendance thresholds or are identified for UKVI reporting, lists will be emailed to the Registry withdrawals team and UCIT with notification of the reasons for reporting.  

Before any student details are communicated, the SMULIC Student Services manager will have made continuous efforts with the students to improve student retention. Withdrawals will have a negative impact on St Mary’s BCA course completion rates so it is critical that students fully engage with their studies.

Resits and Repeating (Re-Study) students

Where students have not successfully completed their programme during the initial study period, they must successfully complete resits or repeat (re-study) modules before they can progress. Under normal circumstances students will be advised to complete their studies during recognised vacation periods, e.g. During the summer vacation period before progressing in September. To ensure there are no long periods of non-engagement, e.g. 60 days of inactivity, student cases must be considered on an individual basis to ensure students do not remain inside the UK if there are no studies to engage with. All resit and repeat activity must be saved to The SMULIC Engagement and Attendance tracker.

SMULIC withdrawals process

The SMULIC cohort should follow the SMU withdrawal process to withdraw from the university via the student portal and indicate their reasons for withdrawing from the university.

6. Email reminders

 

UCIT will send regular email reminders throughout the academic year to all students as a reminder to ‘Tap in’ to every lecture and taught sessions as this is a key indicator to record engagement.

7. 60 days of inactivity

 

The Sponsor Guidance It is our understanding that UKVI guidance implies that where there is 60 days of inactivity a Sponsor should withdraw sponsorship. Where a student is inactive for 60 days without authorisation, they should be withdrawn.

UCIT must submit a report to the Home Office within 10 working days of the considered date. Before such reports are submitted to the Home Office any cases of non-engagement will be investigated.

We must keep records to demonstrate our intervention with any students who have not engaged with their studies. Where an absence has been explained and recorded on the Attendance and Engagement Tracker, this should not count against any of our students.

Any students who have failed to engage for 60 days will be invited to attend an appointment with UCIT to explain their withdrawal in person. Students will be emailed by the Registry Team to inform them they have been de-registered and also by UCIT when reported to UKVI.

8. Change of course (all programmes)

 

There are restrictions in the Immigration Rules that do not permit course changes. A course transfer will only occur once any visa implications have been considered by UCIT.

A student must submit their request via the Student Portal. When submitting a request students are advised to contact UCIT before attempting to submit a course change to learn the visa implications. UCIT will receive email notification via studentvisas@stmarys.ac.uk. If there are any visa implications to consider UCIT will contact the student directly to discuss the visa implications.

If a course change is possible UCIT must submit a report to UKVI within 10 working days from the date of change. 

9. Authorised Absence letter

 

A student may need to travel to their home country urgently during term-time. Any absences during term time must be authorised by a Course Lead. An Authorised Absence letter request form can be found through Registry services and will need to be approved by your Course Lead and the Head of Registry Services. A student can be granted a maximum of 60 consecutive days Authorised Absence. Any absence accrued must not lead to the requirement to make a visa extension in the future. UCIT will issue an Authorised Absence letter and make a note on the Attendance and Engagement Tracker. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

10. Leave of absence (LOA)

 

If there is an ongoing issue that can be evidenced, which prevents a student fully engaging with their studies, it may be appropriate for them to take a leave of absence (LOA) until they are able to return. In some cases if a student becomes pregnant, LOA may also be the most appropriate route to use if the pregnancy will affect attendance and engagement with studies. If a student decides after their arrival to the UK they want to defer until the following academic year, LOA is also appropriate.

A student must submit their request via the Student Portal. When submitting a request students are advised to contact UCIT before deciding to take LOA to learn the visa implications. UCIT will receive email notification via: studentvisas@stmarys.ac.uk. If there are any visa implications to consider UCIT will contact the student directly. If LOA is the best option, UCIT must submit a report to UKVI within 10 working days from the date of change and will make a note on the Attendance and Engagement Tracker. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

11. Early completion

 

In some cases students will finish their course earlier than anticipated.  There can be different reasons for early completion, for example, if the original course end date on the CAS was inaccurate. Students studying at RQF level 7/8 may submit their dissertation/viva early and will complete their course earlier than expected. In all cases there are visa implications.

UCIT will save a note on the Attendance and Engagement Tracker. A report must be submitted to the Home Office within 10 working days of the new early completion date. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

12. Repeating a year

 

A student may need to repeat a year, for example, if extenuating circumstances have been accepted leading to a failed year or where failed modules require completing to successfully progress. Where an additional year of study is required a new visa application for a visa extension will need to be submitted to the Home Office. The exams team will notify UCIT with a list of all students who are required to repeat modules in order to progress. UCIT will contact the students to explain the visa implications.

Any requests for visa extensions must be submitted via the Student Portal. (Immigration rules are subject to change). Students are requested to complete a CAS request form. Each request will be considered on a case by case basis. To request a repeat year students must complete application to repeat a year request form. In the event a student is required to extend their visa, UCIT will save a note on the Attendance and Engagement Tracker

13. Withdrawals

 

A student must submit their request via the Student Portal. When submitting a request students are advised to contact UCIT before deciding to withdraw to learn the visa implications. UCIT will receive email notification via: studentvisas@stmarys.ac.uk. If there are any visa implications to consider UCIT will contact the student directly.

If a withdrawal is agreed, UCIT must submit a report to UKVI within 10 working days from the date of the withdrawal, a note will be made on the Attendance and Engagement Tracker. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

14. Programme termination

 

If a student is found to have no visa status or is unable to produce documentation to prove their visa status they will have no permission to study and will be withdrawn.

Programme termination can also occur where students are found to have academic misconduct, fail to pay course fees or are withdrawn due to disciplinary regulations.

In the event a student is programme terminated, UCIT will save a note on the Attendance and Engagement Tracker. A report to the Home Office must be submitted within 10 working days of the considered date and sponsorship will be withdrawn by the Home Office. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

15. Other attendance monitoring considerations

 

Work Placements - Programmes with ‘WPL’ modules arranged by CWL, including internships.

Students must have their attendance and progression monitored via their employer, a Work Placement Supervisor and Placement Officer. Work Placement checklist, assessment form and timesheets are completed as part of the assessment procedure and saved by The Centre for Workplace Learning (CWL) for UKVI audit purposes.

Information to be collated for UKVI reporting:

  • Employer, contact name and address
  • Start and end dates
  • Days per week worked and hours per week

The placement details must be collated and where possible reported to UKVI before the placements are started. Students will be asked to complete a survey via CWL that will be sent back to UCIT to store and report.

UCIT must submit an SMS report to the Home Office confirming the above details for each student on a placement.

 

All other programmes with Work Placement opportunities - (Not arranged by CWL)

Students must have their attendance and progression monitored.

Information to be collated for UKVI reporting:

  • Employer, contact name and address
  • Start and end dates
  • Days per week worked and hours per week

The placement details must be collated and where possible reported to UKVI before the placements are started. Students will be asked to complete a survey that will be sent back to UCIT to store and report.

UCIT must submit an SMS report to the Home Office confirming the above details for each student on a placement.

Appendix A

 

QTS/Teaching

Progression whilst on placement will be closely monitored by the Institute of Education in line with teaching standards and the Department of Education regulations. Where placement modules are failed there is no progression.

The placement details must be collated and where possible reported to UKVI before the placements are started. Students will be asked to complete a survey that will be sent back to UCIT to store and report.

UCIT must submit an SMS report to the Home Office confirming the above details for each student on a placement.

 

Study Abroad (incoming) - Student visitors

For September and January intakes there will be Study Abroad students completing a semester at St Mary’s. All students should be contacted before they visit regarding UK border control policies.

A Visitor stamp must be provided at the UK port to enable students with the right to study.

Copies of all visa stamps should be recorded against each student admission/enrolment record to ensure that all students have the correct immigration permission during enrolment periods.

 

Study Abroad (incoming) - Internships (Vignettes)

Study Abroad students will require a Student visa if they are coming to the UK to complete an internship as part of the course.

Students must have their attendance and progression monitored.

Information to be collated for UKVI reporting:

  • Employer, contact name and address
  • Start and end dates
  • Days per week worked and hours per week

The placement details must be collated and where possible reported to UKVI before the placements are started. Students will be asked to complete a survey via CWL that will be sent back to UCIT to store and report.

UCIT must submit an SMS report to the Home Office confirming the above details for each student on a placement.

 

Study Abroad (outgoing)

Where students are completing a semester of an outgoing Study Abroad programme the International Mobility Manager and the affiliated faculty will maintain contact with the student and the partner institution during the Study Abroad period.

Outgoing students must find out what the immigration controls are for the country they are visiting to ensure they have the correct permission to study.

Students should contact the Embassy in London of the country they are visiting for more information.

 

Distance Learners - Student visitors

The MSc Strength and Conditioning Distance Learning programme has two mandatory sessions (per academic year) held on the St Mary’s main site. (June and August).

All visiting international students will require Visitor visas when they enter the UK at the port.

A Visitor stamp must be provided at the UK port to enable students with the right to study.

Copies of all visa stamps should be recorded against each student admission/enrolment record to ensure that all students have the correct immigration permission during enrolment periods.

 

Short Courses - Student visitors

All visiting international students will require Visitor visas when they enter the UK at the port.

A Visitor stamp must be provided at the UK port to enable students with the right to study unless exempt. More details can be found on the SMU website.

Copies of all visa stamps should be recorded against each student admission/enrolment record to ensure that all students have the correct immigration permission during enrolment periods.

 

Student Ambassadors - 20 hours per week (max) employment

Student visa conditions restrict students to work no more than 20 hours per week during term time depending on their level of study. Working hours must be monitored to ensure that permitted working hours are not exceeded.

Student Union Sabbatical Officers

Students' union sabbatical officers are paid, elected executive union positions. The term "sabbatical officer" also includes those elected to posts with the National Union of Students (NUS). These posts are usually full time. Students can continue studying the course for which their student visa was granted while working full time as a Sabbatical Officer. The Immigration Rules permit full-time work as a sabbatical officer for students who are "part-way through their studies" (Appendix A paragraph 116(g)) Employment as a Student Union Sabbatical Officer can be for up to 2 years and students can work for up to 20 hours per week during term time in a different job.

 

'Off site’ teaching locations

All sites/locations where students are taught from must first be approved locations by UKVI before they are added to the Sponsor licence.

In the absence of CELCAT attendance registers, attendance must be recorded for any offsite locations with evidence of our interventions where any unexplained absence has occurred. Programme Directors must be able to demonstrate how attendance has been monitored for the full duration of studies.

St Mary’s teaching locations:

  • Teddington Lock campus, Teddington
  • Naylor Library, Teddington
  • 60 Waldegrave Road, Teddington
  • The Exchange, Teddington

 

St Mary’s offsite teaching locations:

  • News Associates (TBC), Twickenham 

 

Partnerships - (collaborative provisions)

Any UK based collaborative provisions where students complete part of their studies with a different institution must first be approved by UKVI before any students can be taught by the partners. If students remain sponsored, attendance must be registered and recorded for the full duration of studies with evidence of our interventions where any unexplained absence has occurred.

 

Updated address and contact details

Appendix D of the immigration rules indicate that Sponsors must keep up to date contact details for all sponsored students.   

Students must keep all contact details up to date via the Student Portal. UCIT will run regular audits to ensure contact details are maintained and students will be communicated with to remind them of the importance update their details.

 

Students with ‘other’ immigration status

The immigration permission of all other students with a visa must be regularly monitored to ensure that all students enrolled at St Mary’s have the correct immigration permission to study throughout the duration of their studies. Audits will be held every 2 weeks to ensure that no student can study without the correct immigration permission at St Mary’s.

 

Debtors (X3)

Students who are debtors and owe money for modules should not attend any timetabled sessions when course fees are owed.

UCIT will run SITS reports that show students with an X code status. The UKVI Compliance and Immigration Team will contact any students to explain the attendance requirements.

Failure to pay tuition fees within 42 days of the due date will result in the immediate termination of registration or withdrawal from University facilities.

When a student is deregistered from their programme, they must be reported to the Home Office within 10 working days from the date of withdrawal.

 

Reporting students and visa curtailments

UKVI guidance states that reporting duties should be completed within 10 working days from the date the change was actioned.  

When a student is reported to UKVI their visa is curtailed to 60 days. UKVI send notification to the last known address via the post and via email.

UCIT will email any students who are reported to advise them of the visa implications including visa curtailment information.

A student will lose all working rights if they are no longer studying and should be advised to leave the UK at the earliest opportunity.

Please contact UCIT with any questions: studentvisas@stmarys.ac.uk

 

EU Nationals

According to Appendix D of the immigration rules, EU nationals who are required to apply for Pre-Settled or Settled Status must have their ‘Share Code’ checked and uploaded to their enrolment record (in SITS) to ensure they have the correct immigration status to study. Unless an applicable EU national has legal status and has their status checked, they are unable to enrol from September 2021.

Any EU national with ‘digital status’ inside their passport who has applied under the ‘Student Route’ with a CAS will also require their ‘Share Code’ checking and their status uploaded and updated within SITS to be permitted to enrol.

It has also been determined by the Home Office that all students must have their entry to the UK checked and logged (in SITS) to ensure students have not entered the UK too early as a visitor. In this instance where student leave has not been registered correctly at the border, students must re-enter the UK via Europe when their entry to the UK as ‘a student’ is valid. (France is the closest country, NOT Ireland). 

Appendix A

 

All other programmes with Work placement opportunities: (Not arranged by CWL)

Teaching (EHSS)

  • PGCE Primary with QTS
  • MA Teaching and Learning with QTS (discontinued 19/20)
  • PGCE Secondary with QTS
  • MA Human Traffikcing, Migration and Organised Crime
  • MA Playwriting

Sports (SHAS)

  • FdA Football Coaching (Chelsea Foundation)(September 2019 FdSc Football Education, Coaching and Development
  • BSc Strength and Conditioning
  • MSc Applied Sport and Exercise Physiology
  • BSc SPort Rehabilitation
  • MSc Sport Rehabilitation
  • MSc Physiotherapy
  • BA PSE
  • MSc Football Coaching