PAPER 2008/1/8


       MANAGED MIGRATION: Draft Monitoring of Attendance Plans

Committee members will be aware that the UK Border Agency is in the process of
introducing new regulations governing the immigration of staff and students to the
UK, an initiative instigated by the previous Prime Minister in 2004, which are closely
modelled on those devised by Australia some years ago.
Under the new regulations the University will have to keep records on all overseas
students. Students will have to submit certain material when they apply for a course.
The University may have to verify students’ identity when they arrive, and will have
to keep track of the students as they progress through the University and report them
to the relevant authorities if they fail to attend.
This paper reports progress to CUGSC and CPGSC on the last 3 meetings of the
Managed Migration Planning Group; on the implications of the new Statement of
Intent issued by UKBA in July 2008, and on the results of various meetings of Old
College staff with Universities UK, Scottish Universities, the Russell Group
Universities and with UKBA representatives.
This paper focuses purely on one small aspect of the work associated with these
new regulations: how we might monitor the attendance of UG and PG students.
The principle behind the draft proposals below are that we will change our
current business processes as little as possible in order to comply with the
Statement of Intent. The paper is a draft working document, for information
and for debate: ideas are sought on the proposals below.
It is proposed that staff will keep track of students as they progress through the
University, and report them to the College if they fail to submit essays, sit exams, turn
up for lab sessions or attend PhD (for which read also MPhil, MSc by research etc)
supervisory sessions. This is explained in more detail below.

Attendance management
1. The principle behind our attendance management response is to change our
   current business processes as little as possible while complying with the Statement
   of Intent (SoI). This increases our likelihood of compliance and reduces our risk
   of non-compliance. Any additional audit requirements are also likely to affect the
   performance of the EUCLID system and so should be minimised.
2. In the event of non-attendance, the SoI guidance suggests that non-attendance
   crystallises ten working days after a contact point is missed i.e. the student has not
   been in touch, physically or otherwise, to explain the situation within ten days.
   The organisation then has a further ten working days to attempt to trace the
   student. Essentially therefore, we have a month to establish non-attendance
   without good reason and to report this to UKBA.
3. We are assuming that contact points mean physical, rather than virtual, contacts,
   since emails and phone calls can be made from any location.
4. Standard contact points will be registration (including the confirmation of
   attendance); assignments; exams; lab work records and PhD supervisor meetings.
   There may be other contacts that apply to segments of the student population such
   as police registration, resits and appeals but because these only apply to that
   individual, (and for reasons of confidentiality) they will not form part of our
   overarching contact recording framework.
5. For a UG student taking courses in more than one School, the “owning” School
   will take responsibility and the lead in tracing a student when s/he is reported
6. If a student fails to hand in an assignment, the tutor responsible must advise the
   School office as soon as s/he knows for certain that this is the case. The School
   will then attempt to contact the student and has a further ten days to do so before
   the University must legally declare to the UKBA that the student is not in
   attendance. The College will then update the UKBA system to withdraw the
   Confirmation of Acceptance of Studies (the certificate enabling the applicant to
   get a visa, known as a CAS) from the student. UKBA will then withdraw the
   student’s visa.
7. At the moment we record course marks centrally, but not assignment marks,
   which are maintained at School level. Post-EUCLID (2011-12), we will have
   access to assignment marks centrally, although we will not have information about
   when the date the assignment was or should have been handed in. The Euclid
   team is still considering how it can assist with this monitoring.
Exams (including resits)
8. Non-attendance at an exam crystallises at the point that the marking has been done
   and it is noted that no paper was available and that no special circumstances case
   has been lodged. School offices will have to follow-up any absences with their
   Subject Areas as soon as the marks list is available after the Exam Board meeting.
Research Student Supervisor meetings
9. EUCLID will be designed to require research supervisors (PhD, MPhil and MSc
   by Research) to record all meetings between supervisor and student. It is felt by
   the EUCLID team that recording attendance is easier for supervisors than only
   recording non-attendance, as it will more easily become second nature (and will
   be useful for other purposes). School offices will have to run a report on this data
   at least twice a month (probably weekly has been suggested) to look for any non-
   attendance. They will then have to initiate enquiries with the Supervisor and
   others (see section 11 below) as to the whereabouts of the student and any reasons
   for non-attendance.
Delegation of system update
10. An academic may choose to delegate the clerical elements of updating the system
    to a support member of staff but s/he remains responsible for ensuring that the
    system is updated with the required non-attendance information within the legal
Enquiries to be made: role of School support staff
11. School support and administrative staff will be key to successful attendance
    management. They will have to ensure they are ready to take these necessary
    follow-up actions in a timely manner:
    i) Attempting to contact the student including, potentially, via their classmates
       and emergency contact numbers; (this suggestion is still being debated, JPR)
   ii) Asking the PhD supervisor if there was a good reason why the contact point
       was missed;
  iii) Checking no special circumstances case has been lodged;
  iv) If applicable, contacting any other School, even in another College, being
      attended by the student to establish if the student is missing from there too.
      Note: responsibility for doing this lies with the lead School;
   v) Checking that the student’s fees are up-to-date;
  vi) Ultimately, obtaining the approval of the Head of College (or delegate,
      possibly Dean of UG or PG Studies) to report the student to UKBA, and then
      withdrawing the CAS which will lead to the withdrawal of the visa.
  vii) Appendix 1 contains a draft pro forma for documenting the decision to deem
       a student not in attendance: comments on whether this would be helpful to
       Schools/how it might be amended would be very welcome.
Summary of reporting procedures
12. At exam/assignment time, Schools will summarise any cases where work or marks
    have not been submitted and no special circumstances case has been lodged;
    follow up with the tutor, any other Schools involved if relevant and finally, with
    the agreement of the Head of College (or delegate), report the absence to UKBA.
13. Lab reports will be reviewed by tutors once a week and any absences notified to
    the School Office for follow-up with the student, with any other Schools involved
    if relevant, and finally, with the agreement of the Head of College (or delegate)
    report the absence to UKBA.
14. Schools will run reports (weekly?) re whether expected research supervisor
    meetings have taken place or whether non-attendance has been reported; follow
    up the results and with the agreement of the Head of College (or delegate) report
    the absence to UKBA.
15. Exception reports and University-level reports: Registry and/or SRA will run
    single reports to collate results on different issues for the whole University, to
    allow them to analyse trends and issues arising and to provide any feedback and
    data requested by UKBA.
16. Reporting suspicious behaviour (a requirement under the Sponsor Statement of
    Intent): individuals can send information anonymously to (contact address at
    Registry/ SRA??)
17. Reporting a student in breach of the terms of his/her stay (a requirement under the
    Sponsor Statement of Intent): e.g. working longer hours than s/he should in term-
    time: as 16 above.
18. Notifying UKBA of agents used in recruitment (a requirement under the Sponsor
    Statement of Intent): this will be done by International Office on an annual basis.
Communications Strategy
19. It will be evident from the above that Schools will be closely involved in this new
    work. School Administrators will need to either be responsible for compliance
    themselves, or appoint someone in the School to be responsible for compliance –
    so that if any students or members of staff have questions about the legislation or
    procedures, this person would be their first port of call.
20. The Managed Migration Planning Group is working with C&M to provide 4
    strands of communication and training: for applicants, for on-course students, for
    academic staff and for support staff. Further details will be available later this

Janet P Rennie
22 September 2008.
        Proforma: Decision to report non-attendance

1    Date of report
2    Name of person             DoS?
     completing report from
3    Role
4    Non-attendance trigger     Essay/ Dissertation/ Thesis
     event                      Exam
                                PhD supervisory session
5    Date of event              Essay / Dissertation/ Thesis – date when marks posted and no
                                Special Circs case lodged
                                Exam – date marks posted and no Special Circs case lodged
                                Lab – date of lab
                                PhD supervisory session – date session due
6    If the student attends
     classes elsewhere in the
     University, date
     confirmation received
     that student is in non-
     attendance there also.
7    Emergency contacts
8    Finance check – are fees
     up-to- date?
9    Name of person             Head of School?
     approving report to
10   Date of approval, and      Head of College (or delegate)
     name of person
     approving report to
11   Name of person             School administrator? SRA?
     inputting decision to
     UKBA sponsor
     management system
12   Date of input

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