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Student visa Engagement and Monitoring Policy 22/23

Last updated: November 2022

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:

  • St Mary’s Attendance Monitoring Policy
  • Personal Tutoring Policy
  • Fitness to Study Policy
  • Leave of Absence Policy
  • Extenuating Circumstances Policy
  • Withdrawal Policy
  • Tuition Fee Regulations

2. Enrolment and re-enrolment

To improve student satisfaction and retention, 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 after studies) and other visa conditions.

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

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 Personal Tutor Dashboard for UKVI audit purposes.

UCIT engagement tracking examples:

  • Course registration/enrolment.
  • Lecture/Seminar attendance.
  • Weekly Moodle reports
  • Marks Entry deadlines.
  • Exam Board progression.
  • Outstanding fee payment status checks.
  • Continuing student re-enrolment.

4. Management of non-engagement

There must be a robust monitoring and engagement system in place:

  • To identify non-attendance and engagement.
  • To record interventions and aid retention.
  • To identify any students to report to UKVI where applicable.

During teaching weeks, the Personal Tutor Dashboard will be used to identity cohorts of students for visa monitoring and to establish students with low or no attendance. Examples of engagement data retained in the Personal Tutor Dashboard are:

  • Card ‘Tap Ins’ for face-face classes.
  • Moodle logins.
  • Submission of work.
  • Meetings with Personal Tutors.

Where low or no attendance is found, the UKVI Compliance and Immigration Team will investigate. Course Leads and faculty staff members will be contacted to establish the facts. Students will be contacted and engagement meetings arranged for students to attend. Any visa sponsored student who does not attend St Mary’s University without good reason is at risk of withdrawal and UKVI reporting. Information regarding attendance and engagement expectations is clearly explained in all literature and in-person during welcome and enrolment events.

A student who knows they will be absent for any period of time must make this known to their Course Lead, Personal tutor and/or their programme administration team.  A note must be made on the Personal Tutor Dashboard in the student record for visibility of any communications to establish the reasons for any non-engagement.

Please refer to 60 days of inactivity (Section 6) below for more information.

5. 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.

6. 60 days of non attendance

The Sponsor Guidance It is our understanding that UKVI guidance implies that where there is 60 days of no engagement a Sponsor must withdraw sponsorship. Where a student is inactive for 60 days without authorisation, they must 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 Personal Tutor Dashboard, 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.

7. 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.

8. Authorised Absence letters

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 on the Visa section through Registry Services and will need to be approved by a 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 Personal Tutor Dashboard. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

9. 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 Personal Tutor Dashboard. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

10. 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 Personal Tutor Dashboard. 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.

11. 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. Students must have classroom attendance to be classified a repeater. Where work can be submitted remotely because there are no modules to repeat that include classroom attendance it is not suitable for students to remain inside the UK ‘not studying’. In these instances students should return to their home countries and submit any work remotely. A new visa is required to re-enter the UK.

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 found on Registry pages 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 update the Personal Tutor Dashboard.

12. 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 Personal Tutor Dashboard. Please contact UCIT with any questions: studentvisas@stmarys.ac.uk.

13. 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 update the Personal Tutor Dashboard. 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

14. Other engagement and 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, 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