Monthly Archives: February 2011

JCWI Response to Student Visa Consultation – part 1


About JCWI

Joint Council for the Welfare of Immigrants (“JCWI”) is an independent, voluntary organisation working in the field of immigration, asylum and nationality law and policy. Established in 1967, JCWI provides legally aided immigration advice to migrants and actively lobbies and campaigns for changes to immigration and asylum law and practice. Its mission is to promote the welfare of migrants within a human rights framework.


Non-EEA students bring a range of cultural and economic benefits to the UK.   In relation to the latter it should be noted that:

i.                     Education and training exports represent the second biggest contributor to the UK’s net balance of payments. They are, according to the Financial Times worth £40 billion.

ii.                   According to the independent Migration Advisory Committee, for every one pound students generate for universities, a further fifty pence is generated for other industries.

iii.                  The independent Migration Advisory Committee found that non-EEA national students subsidise the educational system in the UK.  In fact they account for 37% of total university fee income.

iv.                 Research shows that students bring knowledge of different countries, languages and cultures which are beneficial to UK businesses that wish to develop markets new markets.

v.                   Non-EEA national student graduates who remain in the UK contribute £1 billion per year to GDP.

vi.                 Non-EEA national students who remain in the UK after graduation contribute at least £100 million per year in fiscal benefits.

vii.                The independent Migration Advisory Committee concluded following its recent examination of the Post Study Work route that there was no evidence that non-EEA nationals using the Post Study Work route displaced nationals in the labour market.

viii.              Research from the US has shown that for every 1% increase in the share of immigrant university graduates in the US population, patents per capita are increased by 6%. We expect similar trends to be prevalent in the UK.

By way of general observation, given the above, and given that statistics show that the British economy shrank by 0.5% in the last quarter, and that educational establishments including world class universities like Cambridge are already starting to shed jobs (due to cuts of 25% and 40% to the further and higher education budgets) it is disingenuous to make the reduction of foreign students/graduates a general policy objective in itself. We go on to deal with the specific consultation questions below.

Question 1

Do you think that raising the minimum level of study sponsors with a standard sponsor licence can offer under Tier 4 (General) to degree-level and above is an effective way of reducing abuse of Tier 4 (General) route, increasing selectivity and simplifying the current rules?


There seems to be no adequate policy justification for this.  From the point of view of economic value, this will result in loss of fee revenue both for further, but also higher education institutions given that approximately half of all students recruited by universities start out on sub-degree courses.

So far as the underlying rationale goes –  there is a higher rate of non-compliance amongst this group, the research on which this conclusion is based is unreliable given that the study is based on: a.  potential non-compliance, b. focuses only on an unrepresentative sample of organisations UKBA already had concerns about and c. offers a ‘maximum potential estimate’ only.

Question 2

Do you think that only Highly Trusted Sponsors should be permitted to offer study below degree level to NQF levels 3,4, and 5/SCQF levels 6, 7, and 8 in the Tier 4 (General) category?


See above comments. The current system which was only put in place in 2010 is adequate to deal with this.

Question 3

Do you think that the changes discussed in this section should be phased in?


If they must be introduced they should be brought in over a 37 months plus time-frame as they will be disruptive for educational establishments and students.

Question 4

Do you think that, in the light of the low risk of abuse amongst users of the Tier 4 (Child) route, there should be no changes to the route?


We have had also had sight of the response by the Immigration Law Practitioners’ Association13 and agree with their further observation about the need for amendments to rule 56(a)(iii) of the Immigration Rules.

Question 5

Do you think that all students using Tier 4 (General) category should have passed a secure English language test to demonstrate proficiency in English language to level B2 of the CEFR, in order to improve selectivity and to simplify the current system?


As the UK Council for International Student Affairs suggests, this is most likely to affect students from Korea, Japan, Taiwan and Saudi Arabia – all low risk countries, and could lead to the loss of somewhere in the region of £120 million for the UK.

More generally, however, there is simply no sound policy justification for this. It is more appropriate for educational providers to make assessments about suitability for courses.

Question 6

Do you think that students from majority English-speaking countries, those who have been awarded a qualification equivalent to UK degree-level or above that was taught in English in a majority English-speaking country, and those who have recently studied in the UK as children should be exempt from any new language testing requirement?


Additionally notwithstanding the above comments this should extend to:

i.                     Any degree taught in English – otherwise there is a risk that such provisions would be inconsistent with statutory race equality duties.

ii.                   Students who have obtained a qualification equivalent to A-Level or ILB through the medium of English.

Question 7

Do you think that students wishing to study a new course of study should be required to show evidence of progression to study at a higher level?


Academic progression is not a mere evolution from undergraduate to Masters to Phd. A well rounded education may for example require studying two separate Masters degree courses. Indeed there are number of perfectly valid reasons that students may wish to study at different levels.

It should also be noted that Article 2 of Protocol 1 of the European Convention on Human Rights provides that no one should be denied the right to education.  The former includes a right of access to existing educational institutions. When read with Article 14 ECHR and in the light of the justification advanced in the paper- the need to prevent students from staying in the UK indefinitely without making academic progress,15 there is a question about the extent this would be consistent with this. Furthermore given that Article 10 ECHR also encompasses the right to receive and impact information and ideas16, there is also a question mark as to the extent to which such as measure may potentially unlawfully interfere with ECHR rights.

Question 8

Do you think students wanting to study new courses should return home to apply from overseas?

No. There is nothing in the evidence that would suggest that this would be desirable either from the perspective of educational establishments, students or immigration control. See also above point about Article 10 ECHR which may potentially also come into play.

Question 9

What changes do you think we should make to the Tier 1 Post Study Work Route?

The independent Migration Advisory Committee examined this issue carefully recently in 2009 and concluded that the route should remain open because of the implications for fees for universities – PSWR has an influence in the decision to chose the UK as a place of study. It also concluded that there should be broad continuation of the current policy.

If the route is ultimately to be closed down, appropriate transitional arrangements will need to be put in place as those already in PSWR were given a legitimate expectation that they would be able to switch to Tiers one and two after a two year period.

We agree with ILPA that transitional arrangements should also extend to students who are already in the system given that their choice for their university of study may well have been based on the existence of the PSWR.

JCWI Response to Student Visa Consultation – part 2

JCWI Response to Student Visa Consultation – part 2

Question 10

Do you think that we should restrict further the amount of work students should be allowed to undertake when studying?

No.  There are a range of perfectly valid reasons that students may need to work.

Importantly, Article 6(1) of the International Covenant on Economic, Social and Cultural Rights recognises the right to work which includes the right of everyone in the jurisdiction to the opportunity to gain work. The UK is bound by this obligation. Its reservation extends only to the purpose of protecting the employment opportunities in the UK/regions within it. This however is not the stated rationale of the proposal, nor is it supported by any evidence.

Question 11

Do you think we should make it simpler for employers to understand the rules around student work by limiting it to set times except

We agree with ILPA’s comments in their response to this Consultation.

Question 12

Do you think that the minimum ratio of study to work placement permitted should be increased from the current 50:50 to 66:33, except where there is a statutory requirement that the placement should exceed one- third of the total course length?


If courses are set up in this way it is because the course providers are of the view that this is the most effective way to acquire the relevant knowledge/expertise in question.  There is no evidence put forward to justify putting foreign students a disadvantage in comparison to domestic students. Further it is unclear as to how this would practically operate.

Question 13

Do you think that only those studying for longer than 12 months should be permitted to bring their family members to the UK?


This will of course deter people from studying in the UK. Furthermore, it is not consistent with internationally accepted human rights principles of family unity, and non-discrimination. These principles should be reflected in these proposals which are likely to have discriminatory effects for women. Women overwhelmingly assume child-care responsibilities and are subject to cultural norms which might make it unacceptable to travel alone.

Question 8

Do you think students wanting to study new courses should return home to apply from overseas?

No. There is nothing in the evidence that would suggest that this would be desirable either from the perspective of educational establishments, students or immigration control. See also above point about Article 10 ECHR which may potentially also come into play.

Question 14

Do you think that family members permitted to accompany the student should be prohibited from working?


Article 6 (1) of the 1966 International Covenant on Economic, Social and Cultural Rights recognises the right to work which includes the right of everyone to the opportunity to gain work.  The rationale for the proposal is to limit access to public services and to limit unlawful work is not consistent with the terms of the UK’s reservation. This permits interference only for the purpose of protecting employment opportunities in the UK/parts of the UK.

Question 15

Do you agree that differential requirements for high and low risk students should be adopted?


We have several concerns about this. They are as follows:

Race equality exemptions have historically been problematic. A constant theme of the former Race Monitor’s reports was that basing selections on previous adverse decisions meant that passengers were less likely to be given the benefit of the doubt. They were therefore more likely to be refused.

This will discriminate against people from countries or regions where corruption, state failure or inefficiency plagues administrations and is likely to have greater impacts on developing countries.

It is inherently unfair given that prospective applicants will be subject to more stringent testing simply on account of simply having ‘a risk profile’ as opposed to anything they have said or done.

Question 16

Do you believe that we should focus on the abuse of documentary evidence for maintenance and/or qualifications as the basis of differential treatment?


See above.  We also agree with the comments made by the Immigration Law Practitioner’s Association in their response – the figures are difficult to rely upon given that they could simply be representative of higher numbers of applicants applying from those countries, or representative of the fact that more rigorous checking procedures are in place in certain countries.

Question 17

Do you believe that we should also, or alternatively look at the sponsors rating as a basis for differential treatment?


We agree with the comments by ILPA in their response to this consultation.

Question 18

Do you think that more should be done to raise accreditation and inspection standards to ensure the quality of education provision within private institutions of further and higher education for Tier 4 purposes?

No (not through the use of immigration law).

We do not believe that the question of regulation of educational standards is one for immigration law. This is better dealt with the context of education, and should be left to regulators in that friend to determine.

Question 19

In the light of the proposals described in this document, what do you think will be the main advantages/disadvantages, including any financial impacts, to you, your business or your sector?

We will not directly be affected however see the introduction to this paper for the potential economic impacts for the UK of reducing student numbers.

JCWI Response to Student Visa Consultation – part 1

Student Visa Cuts – 8 facts you should know

The UK education industry has taken quite a beating lately. Set against a backdrop of a shrinking economy and budget cuts of up to 40%, it is no wonder there will be job losses in the education sector and the wider public sector. We already know that 73 jobs are to go at East Durham College and even Cambridge University is not immune, with staff asked to consider voluntary redundancy. Clearly, education providers are feeling squeezed already and with the UK Coalition considering restricting the numbers of international students, here are eight key facts that should also be remembered. I invite anyone in support of the drastic reduction in student migrants to also consider the following facts in relation to their argument.

1.      Vital part of Economy: Worth some £40 billion, the export of education and training is the second largest contributor to the UK economy.

2.      Benefit the Wider Economy: For every £1 in income generated by education providers, 50p is generated in other industries.

3.      Subsidise Home Students: International student migrants from non-EEA countries provide 37% of total fee revenue for universities alone.

4.      Cultural Value: Bringing knowledge of different cultures to the UK benefits businesses wishing to expand overseas, as well as wider society.

5.      GDP Benefits: Those non-EEA international student migrants who graduate and remain in the UK contribute £1 billion every year to UK GDP.

6.      Fiscal Benefits: Those non-EEA international student migrants who graduate and remain in the UK contribute more than £100 million a year in fiscal benefits.

7.      Foreign Graduates not a Threat: The most recent independent research into the Tier 1 Post-Study Work category of the Points Based System clearly shows that non-EEA students who graduate and remain in the UK do not displace British citizens from jobs.

8.      Increase Competitiveness: In the US it has been found that a 6% rise in patents per capita can be attributed to a rise of 1% in the proportion of student migrant graduates. It is likely a similar relationship exists in the UK.

Brightest Young Engineers Receive Funding for MBAs

Eight young engineers with both exceptional talent and managerial dreams have been awarded £240,000 by the Sainsbury Management Fellowship (SMF). Founded in 1987 by Lord Sainsbury, SMF’s mission is to ensure young engineers are equipped with the skills to take them into the boardrooms of the largest UK blue chip companies. SMF also aims to nurture any entrepreneurial shown by the engineers of tomorrow, giving them the skills to start successful business and grow the UK economy. It is this mix of business and engineering skills that is key to the SMF’s work.

Competition is fierce, with only 10 scholarships awarded each year for a Masters in Business Administration (MBA) course. It goes without saying that only those with exceptional academic qualifications and serious leadership potential make the cut.

SMF has provided funding for 270 engineers since 1987, providing over £7 million in bursaries to talented individuals. Many are part of the selection process each year for new candidates, which is run by the Royal Academy of Engineering. The latest to win the award are:

Stephane Lee-Favier, a Chartered Engineer with the Institute of Engineering and Technology from Blackpool, previously worked for Rolls-Royce in Derbyshire and the USA, after completing a Masters Degree in Engineering Science at the University of Oxford.  Stephane will commence his MBA study at INSEAD Business School in France this year.

After completing a degree in Mechanical Engineering at Imperial College, Nimesh Thakrar from Peterborough worked as an automotive engineer at MIRA Ltd and then for the Super Aguri F1 team.  Nimesh has commenced his MBA study at London Business School and will graduate in July 2011.

Simon Fowles, an engineer from Crewe in Cheshire, previously worked at Network Rail in London, after completing a Masters in Civil Engineering at UMIST (now the University of Manchester).  Simon has commenced his MBA course at Tuck Business School in Dartmouth USA.

Hind Zaki, an engineer from Boston in Lincolnshire, worked at Unilever for six years after completing a Masters Degree in Mechanical Engineering at Imperial College. Hind is studying for her MBA at Harvard University.

Wasim Lala from Dublin has been working in the oil and gas industry in Aberdeen, Chester and The Hague since completing an Masters of Engineering degree at Cambridge University.  Wasim is studying for his MBA at Harvard University.

James Stewart from Torquay in Devonshire, is both a UK Chartered Engineer and a European Engineer (EurIng) with a designation from FEANI, has worked internationally for GNK Plc since completing a Masters Degree in Manufacturing Engineering at the University of Cambridge. James received an MBA degree award at INSEAD Business School in France.

Faisal Bachlani, an engineer from Kew in Surrey, worked at the Department for Business, Innovation & Skills in London since completing a Masters Degree in a Chemical Engineering. Faisal has been awarded a bursary to study for his MBA at London Business School.

Kimbal Virdi from Pembrokeshire worked for Ove Arup & Partners Consulting Engineers, after completing a degree in Mechanical Engineering at Imperial College.  Kimbal is studying for his MBA at INSEAD Business School in Singapore.

Commenting on the awards, SMF’s president, David Falzani said: “An MBA offers individuals with high potential the opportunity to complement their engineering qualifications with business skills that will open up exciting new opportunities in the business world. It can cost between £50,000 and £100,000 to study at one of the leading business schools, which can often deter ambitious young engineers, SMF was set-up to respond to this need. It’s our pleasure to assist talented experts with this cost.”

Video Response to Threat of Student Visa Cuts

Tony Millns, chief executive of English UK, took part in a press conference with other sector bodies such as Universities UK, UKCISA, Study UK and the National Union of Students, regarding the government’s plans to review Tier 4 of the Points Based System and raise English language requirements. The press conference took place at the Queen Elizabeth II Conference Centre on Wednesday 26 January.

In a BBC News article published on 27 January 2011, Tony Millns was quoted as saying that the planned raising of the required language level would rule out 70-80% of students who currently study foundation courses.

He also said: “International student fees subsidise home student places, they keep courses and sometimes whole departments open. In some universities, where more than 60% of students are not home students, they are vital to the survival of institutions.”

Register of Tier 4 Sponsors – 01 February 2011

Differences against the Tier 4 Register 17 January 2011

From now on, Highly Trusted Sponsors will be dealt with on the Highly Trusted Sponsors List, whilst Tier 4 Sponsors Register posts will cover A-rated, B-rated and Trusted Sponsors.

The following schools and colleges were removed from the Register:

  • Grampian Languages
  • Stevens College of Technology and Management

The following schools and colleges were added to the Register:

  • BD Dreams Limited T/A Queensway College
  • Buckingham College of London
  • Camphill Rudolf Steiner Schools Limited
  • European College London LTD
  • Helios International College Limited
  • International College of London
  • John Wheatley College
  • Middlesex Academy of Business and Management Ltd
  • Modern Manchester Academy Ltd
  • Royal Grammar School
  • St Peter’s School of English Limited
  • UK Business Academy
  • Download the Register of Sponsors Tier4: 01 Feb 2011

    Tier 1 to Close in Three Months, Act Fast

    The Tier 1 Post Study Work category will close in April 2011 and the replacement category – the exceptional talent visa – will be very hard indeed to get. For students who are already in the UK and qualify under the Tier 1 (General) route, you are advised to get your applications in as soon as possible. As a sign of the times to come, Tier 1 (General) applications have not been available outside the UK since 23 December 2010.

    The following categories will still be open to migrants wishing to stay in the UK:

    • Any other Tier 1 category
    • Any Tier 2 category
    • Any Tier 4 category
    • Work permit holder
    • Dependent partner of a Tier 4 migrant

    There have been many reports published recently showing that many people are coming to the UK through the intra-company transfer route available in Tier 2 of the Points Based System and then switching to the Tier 1 (General) category in order to remain in the UK.

    April 2011 will see the introduction of the Coalition Government’s permanent immigration cap. It is becoming increasingly likely that all movement of skilled labour in the UK will only be secured with a job offer from a UK entity. This position has arisen from concerns that many migrants have been granted visas as skilled workers, but have been working in low-skilled jobs.

    The immigration cap to come in to force will operate as follows:

    • The quota for Tier 2 visas will be significantly increased from the current quota of 20,700
    • Replacing Tier 1 (General) the Exceptional Talent Visa will be capped at 1,000 per year only

    The increased Tier 2 quota will however, not apply to various groups of people:

    • Those already in the UK and making a Tier 2 in-country application
    • Tier 2 migrants dependants
    • Employees moving through the Intra-Company Transfer scheme

    It will also become more difficult to come under the Tier 2 (General) visa as this will be limited to graduate level job vacancies from April 2011.

    Cross-sector Initiatives Begin in Opposition to Student Visa Cuts

    English UK and Study UK this week joined other leading international education groups opposed to the Government’s proposals on student visas in a national press conference.

    This is likely to be the first in a series of cross-sector initiatives to raise awareness of the dramatic consequences for Britain’s international and higher education sector, worth £10bn a year, if proposals including raising the language requirement to B2 for visa students become law.

    The press conference was a joint initiative by Universities UK, the University of East Anglia, the National Union of Students, the UK Council for International Student Affairs, English UK and Study UK.

    Each organisation expressed its alarm at the proposals in the Government’s consultation, intended to cut student numbers, warned that the proposals risked seriously damaging both the fragile British economy and the university sector, and questioned whether students, 97 per cent of whom leave within two years of their courses ending, should be included in migration curbs at all.

    Tony Millns, chief executive of English UK, said international education was a growth sector for the UK at a time when the economy as a whole had contracted. Demand at all levels was growing and the UK had a high reputation for quality education.

    However, the actions of the Government and the constant visa changes of the past three years were leading to a perception that the UK was not welcoming to students. “There is market scepticism about whether the UK is open for business,” he said.

    He said the requirement that visa students must have reached level B2 in English -equivalent to a high A Level -would particularly hit international foundation year courses, which typically run for 44 weeks and prepare students for the demands of a UK degree course. At present, most of these students arrived at roughly A2/B1.

    If the foundation course route was closed to large numbers of students, that would affect not only English UK members but have a “highly damaging” effect on universities, almost half of whose international students come from foundation courses. That in turn would damage university finances, as many are kept afloat by international student fees.

    Susan J Hindley of Study UK said the sector would support proposals intended to eradicate abuse of the system, but the suggested changes went well beyond that.

    Dominic Scott of UKCISA said the proposals on student visas were probably “the most radical for a generation” and had attracted 25,000 responses including many comments from students who had come to the UK expecting to be able to progress in their studies. “Students don’t want to settle in the UK. They want to get work experience and then go back to Shanghai or Taiwan and say, ‘I’ve got real credibility.'”

    He added: “On a number of proposals I think the Government is beginning to realise it’s gone too far. I hope they will moderate that. if they don’t it will undermine a successful industry. Without doubt we will lose students, lose trust, lose income, lose reputation and lose business links around the world.”

    Nicola Dandridge of Universities UK (UUK) was equally forthright. There were three areas of particular concern: damage to the UK economy, universities’ economies and a consultation document which was “inappropriate”.

    UUK research had shown international students brought around £5bn into the UK economy each year, of which £2.3bn was “off-campus” expenditure in the local economy. “This is a hugely significant export industry,” she said.

    She said international student numbers for the UK were second only to the US “which given the size of the US is quite an extraordinary demonstration of the quality of the UK higher education industry. This is a very successful industry which the Government is actively seeking to constrain. Given the economic circumstances this is quite extraordinary that the government is putting these proposals forward,” she said.

    Ms Dandridge added that not only did nine per cent of the sector’s income come from international students, but that universities were now hugely dependent on international researchers to teach some key STEM courses.

    Professor Edward Acton of the University of East Anglia warned of a “catastrophic” effect on university finances and their role in driving their local economies.

    The sector representatives also agreed that students should not be regarded as migrants. “97 per cent of them are transient. If you wanted, you could tackle that other three per cent,” said Aaron Porter, president of the National Union of Students.

    Do I have right to get the refund from LITE?

    I enrolled post graduate diploma course from ICM at LITE and paid 3900 pounds for the course then the college told me to started studying that course but a few weeks later the college told me that ICM did not accept me to the course as I have no related education background.Now I cannot study that course as the college said and I want to get the money back to pay for another course I can study.So my question is “Do I right to get the refund?”
    I really need help urgently ,please please.

    This post was submitted by Arthit.

    Directors of Top UK Universities Condemn Planned Student Visa Cuts

    Directors of Top UK Universities Condemn Planned Student Visa Cuts

    Universities UK who represent UK tertiary education institutions, says Britain’s place as 2nd in the global education market is at serious risk should the Coalition government make good its threat to slash student migrant numbers.

    Britain takes 11.8% of the international student market, behind the USA. The UK is in fact, a significant destination for those international postgraduates studying engineering (62%), maths and computer science (63%) and physical sciences (27%).

    The concern is great enough for Directors of Imperial College London and the London School of Economics to tell MPs today that their world-leading research was at jeopardy as a result of the planned cuts. They also argued that it should be academics and universities that set the required English level students require, arguing that English needed for engineering is completely different from that needed for classics.

    Describing the planned student visa action as “hostile” towards UK universities, MPs were warned today that the proposed changes would “savagely cut” recruitment, costing universities at least £1bn in fees as well as jeopardising future research capability in the key areas of science, technology, engineering and maths.

    Today’s arguments given to MPs follow a speech given yesterday by UK Immigration Minister, Damian Green. He used the speech to highlight cases of “unpleasant abuse” and to lay out plans to drastically reduce the number of student migrants in the UK.

    Insisting that the cuts would only target students studying courses below degree level, Damian Green has been trying to allay the fears of academics, all but promising to “do nothing” to prevent the brightest and the best international students coming to study at “our world-class academic institutions above and below degree level.”

    According to Professor Edward Acton, vice chancellor at the University of East Anglia, as much as 30-50% of international students at British universities would be affected by the proposed changes, in contradiction to Mr Green’s position of not hurting university recruitment. Professor Acton told MPs today that this huge number of students makes use of pathway or foundation courses, especially where English language support is required, to prepare for their main degree course.

    Professor Acton went on to argue that the Coalition’s focus on the abuse of the student visa system in fact hides the fact that the proposed changes would hit higher education recruitment drastically. Targeting pre-university coursers alone would cost more than £1bn in lost fee income alone and Professor Acton called the Coalition’s actions a “hostile act.”

    Tougher English language recruitments are also on the cards for overseas students, as well as severely limiting their rights to work and their ability to bring their families with them during their studies or indeed after graduating. It is thought that courses offered by non-highly trusted sponsors will simply no longer be an option for non-EU student migrants i.e. those visa nationals requiring a UK student visa for their studies.

    Estimates put the drop on non-EU student numbers at somewhere around 120,000 if the proposals are all enacted. This is a reduction of almost 50% of the 300,000 non-EU migrants that study in the UK annually.

    Damian Green did say that he does not want to jeopardise the £5bn per year international student migrants contribute to the British economy, but as the majority of non-EU migrants are students, he has little choice if the Coalition government is to meet its pledge of reducing net migration to the tens of thousands. “I am seeking to eliminate abuses within the system,” he said defiantly.

    Firmly in his sites are the private courses which have yet to take up the UK Border Agency’s highly trusted sponsor status. 91,000 international students applied to private colleges in 2010. Mr Green cited cases where a college had only two lecturers for more than 940 students and another where the work placement element of the course was with a pizza company.

    The official consultation period on the student visa route closed this week. Green confirmed that he intended to press ahead with his proposals and may go further in limiting post-study work “at a time when graduate unemployment is at its highest level for 17 years.”