If you are a higher education provider with a Tier 4 Sponsorship License for international students, you know how important it is to comply with the UK Visas and Immigration (UKVI) regulations. Failing your UKVI compliance can result in serious consequences, such as losing your sponsor license, paying for an action plan, and damaging your reputation.
To help you avoid these risks, we’ve put together a list of our ten top tips to achieving audit-proof UKVI compliance! Check them out below.
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10 Tips to Help your University Achieve Audit-Proof UKVI Compliance
10 Tips to Help your University Achieve Audit-Proof UKVI Compliance
Tier 4 UKVI compliance presents an ongoing risk for universities sponsoring international students. The best way to reduce any stress and risks associated with a UKVI audit is to be prepared. To ensure your institution is compliant with your sponsor duties and ready for an audit, follow these tips that cover the key areas of sponsor management, student monitoring, record keeping, and reporting:
1. Know Your Responsibilities
The first step of audit-proof UKVI compliance is knowing all the duties and responsibilities of a Tier 4 sponsor. These can be easily checked on the UK Government website. The UKVI regulations should align closely with your academic regulations and it should be clear where they sit within your own institutional policies. This is important so that your staff and students know what is expected of them and the processes they should follow.
2. Keep Your Records Up to Date
The next crucial step of audit-proof UKVI compliance is maintaining an accurate and complete records of your sponsored students. Sponsors are required to keep copies of their passports, immigration status, visa, academic qualifications, English language certificates, financial documents, contact details, and any other relevant information. These records should be securely stored and easily retrievable in one central system within your institution, as a UKVI audit may request access to any of this information at any time.
3. Appoint a Dedicated Compliance Manager or Team
Having a dedicated team or manager within your institution who will own your UKVI compliance is a key element of staying on top of your responsibilities. They will usually be responsible for the main aspects of your Tier 4 sponsor duties including monitoring of student attendance, visa expiry dates, reporting changes to UKVI as well as keeping track of changes to the Tier 4 requirements and performing internal audits.
If you don’t already have a dedicated UKVI team, get one!
4. Implement an Attendance and Engagement System
One of the biggest aspects of your Tier 4 Sponsor UKVI duties is ensuring that sponsored students are academically engaged throughout their sponsorship.
A student is academically engaging if they are actively and consistently following their course of study.
Sponsors must be able to produce their academic engagement policy on request and demonstrate:
- how it is being applied
- that systems are in place to monitor academic engagement
- what information is being recorded to confirm that students are academically engaging
- what actions are expected when a lack of academic engagement is identified
- that they have a robust system in place to identify any student who has ceased to engage with their studies and the action they will then take to support the student to re-engage
To most efficient and recommended way of remaining compliant is to implement a system that monitors student attendance and engagement in real-time. This will give staff and compliance teams instant access to the data they need for a UKVI audit and ensure they can quickly follow up with any students who are in breach of their Tier 4 visa requirements.
5. Remove Data Silos
One challenge many institutions have in relation to the UKVI compliance is accessing information in relation to Tier 4 students that is held in different systems. During a UKVI audit, the auditor will need access to admissions records, student attendance and progression reports, mitigating circumstances applications, email communications to students and other necessary information. If you store all this information across multiple different systems, this can be difficult to accurately and quickly retrieve for an audit.
“Good internal communications are important for institutions to function efficiently and adhere to Tier 4 requirements … [and] can help to ensure that institutions can confidently meet their monitoring and reporting requirements”
Using one central system for all your UKVI needs, including tracking and reporting on student attendance, storing student information and communication and managing mitigating circumstances applications, means that all of this crucial information is at your fingertips when it is time for an audit.
6. Look for Attendance Trends and Patterns
According to UKCISA’s Tier 4 Compliance Guide, it is clear that the UKVI also expects institutions to look for any patterns in attendance and absences of sponsored students.
If Tier 4 sponsored students are consistently missing certain teaching events or ‘contact point’ sponsors are now expected to spot such patterns and investigate further. An attendance and engagement monitoring system can help you identify these trends among Tier 4 students.
The SEAtS UKVI attendance and alert system enables important, actionable insights through features such as:
- Multi-metric chart: Compare trends across all performance and engagement metrics.
- Module Comparison Chart: Compare attendance, submissions, and grades more easily across modules.
- Annual Attendance Chart: View a full year of attendance patterns at a glance, and drill-down for additional actionable insights.
7. Use an Early Alert Workflow
Implementing an attendance system with an early alert workflow is another crucial step to ensuring audit-proof UKVI compliance. An early alert workflow allows staff to help “at-risk” students re-engage with their studies before they drop-out or risk losing their Tier 4 visa. By identifying these students, staff can provide additional support and ensure their academic progression and success. With an early alert workflow, the system will automatically warn staff and the student that they are at-risk of breaching their sponsorship. The workflow can engage predetermined intervention strategies for Tier 4 students, monitor their progression and escalate the situation if they fail to re-engage.
“Effective attendance monitoring processes which are seen as examples of good practice generally include early warning indicators to identify students who have a poor attendance level. ”
8. Report Any Important Changes
It is crucial as a UKVI Tier 4 sponsor that you report any changes or events affecting your Tier 4 students or your sponsor license to the UKVI within the specified timeframes. You should use the sponsor management system (SMS) to report any changes in your students’ circumstances, such as changes in course details, study location, contact details, immigration status, or withdrawal from studies. You should also use the SMS to report any changes in your organisation’s details, such as changes in address, ownership, structure, or key personnel.
9. Conduct Internal Audits
One way of ensuring you’re always ready for a UKVI audit is to have your compliance team conduct regular internal Tier 4 audits. It’s important to regularly assess how your institution would perform in a UKVI audit. Monitoring your compliance performance and identifying any areas of improvement or concern is great way of staying on top of your UKVI compliance.
10. Ask Questions or Seek Guidance
Our final top tip for ensuring UKVI compliance? Seek advice and guidance from the UKVI if you have any doubts or questions about your Tier 4 sponsorship obligations. It is far better to seek clarifcation around certain rules or responsibilities than to risk breaching them.
For institutions that wish to retain their Tier 4 sponsorship license for international students, it is essential that UKVI compliance is a top priority. In this guide, we’ve shared our top tips for ensuring audit-proof UKVI compliance. These are based on our experience and knowledge of UKVI compliance as the leading provider of UKVI compliance solutions since 2015. By following these tips, institutions can demonstrate their commitment to UKVI compliance and avoid the risk of losing their Tier 4 sponsorship license.
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