Washington Post 2015 Annual Report Download - page 28

With respect to KIC’s businesses in the U.K., the pathways group of colleges continues to retain Tier 4 sponsor
status and Educational Oversight accreditation, and all gained the status of “commendable progress” in the
Quality Assurance Agency Educational Oversight Annual Monitoring. One of the most recent embedded
pathways colleges within the University of the West of England, which obtained Educational Oversight in 2014,
was granted a full Tier 4 sponsor license in 2015. The pathway colleges at the University of Brighton and
Bournemouth University have also gained their own Tier 4 sponsor licenses.
In April 2015, the UKVI replaced the previous requirement that each Tier 4 license holder have Highly Trusted
Sponsor (HTS) status with one overall Tier 4 status requirement. Ten of the Kaplan colleges subsequently
completed their Tier 4 renewal in 2015. With the restructuring of the Tier 4 licenses, the next Tier 4 renewal
submissions will be due in July/August 2016, with one exception, the Pathway College in Brighton, whose
renewal will be due in March 2016.
All of the English-language schools presently have Tier 4 sponsor status and have completed annual monitoring
achieving “extended expectations” from the Independent Schools Inspectorate. The Kaplan International English-
language business is considering a consolidation of its Tier 4 licenses from June 2016 so that only four UK
English-language schools will remain on the Kaplan Tier 4 master license. As noted above, students studying the
English language can choose to enter the U.K. on a student visitor visa as opposed to a Tier 4 visa.
Changes continue to be made to U.K. immigration rules. The UKVI continues to tighten the regulations around
sponsoring students from outside the EEA and Switzerland. Changes over the past three years have included the
introduction of a rule that restricts to five years the time a sponsored student can spend studying at or above
degree level in the U.K. The post-study work visa, which permitted postgraduate students to work in the U.K.
without being sponsored, was closed to new applicants. In addition, sponsored students who do not attend an
institution that qualifies as a Higher Educational Institution (HEI), which includes students attending Kaplan
UK’s colleges, are no longer permitted to work part time while studying. In 2013, the biggest change was the
introduction of a new screening process called a “Credibility Check” for potential students. This interview
process can affect the number of visa refusals Kaplan International’s businesses receive, which is a risk factor for
loss of the relevant license. However, Kaplan International has not experienced a significant increase in visa
refusals. Since the introduction of the Points-Based System in 2009, all Tier 4 students are subject to strict checks
pre and post arrival, including verification that their qualifications are genuine, confirmation that the students
maintain a good attendance record and that they can be contacted at all times, and verification that they have
academic progression and that their visa is valid at all times while they are present in the U.K. Failure to meet
these requirements obliges Kaplan International to withdraw sponsorship and report these students to the UKVI.
In 2014, there were additional changes to the UKVI rules, including a significant tightening of the core
measurable with respect to visa refusals. Effective November 1, 2014, no more than 10% of the students to whom
a CAS is issued by a Tier 4 license sponsor can have their visa refused. Formerly, the limit was set at 20%. In
2015, the Tier 4 licenses for Kaplan Financial, KIC’s London College and all of KI’s English-language colleges
were consolidated into one single “master” license. If this license were lost, all of these colleges would lose the
ability to sponsor international students. Furthermore, students applying to another education provider after
completing their studies at these colleges are now required to return home to apply for a second visa. All of KI’s
colleges dedicated to working with one university partner that held their own individual sponsor license before
the introduction of the master license have retained their individual licenses. Academic service providers are
required to have rigorous processes to verify all English-language test certificates. The introduction of revised
immigration rules has negatively impacted Kaplan UK’s enrollment rate in relation to students from outside the
EEA and Switzerland.
No assurance can be given that each Kaplan International business in the U.K. will be able to maintain its Tier 4
BCA status and Educational Oversight accreditation. Maintenance of each of these approvals requires
compliance with several core metrics that may be difficult to attain. Loss of either Tier 4 BCA status or
Educational Oversight accreditation would have a material adverse effect on Kaplan Europe’s operating results.
13 GRAHAM HOLDINGS COMPANY