Monitoring Student Attendance

CPGSC (Paper 2009/1/3)

MONITORING STUDENT ATTENDANCE

DRAFT IMPLEMENTATION PROPOSALS: GUIDANCE PAPER FOR SCHOOL ADMINISTRATORS, COURSE AND PROGRAMME DIRECTORS AND POSTGRADUATE SUPERVISORS

Implementation date: 22 September 2009

This paper outlines draft plans for monitoring student attendance in the University of Edinburgh. In particular, this gives details of a pilot on attendance monitoring to be run in CHSS from 22 September 2009, with CSE and CMVM following in semester 2.

1. What is Attendance Management?
College and School staff will be aware that the UK Border Agency (UKBA) has introduced 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, students will have to submit certain material when they apply for a course. The University will have to keep records on all overseas students. It will have to verify students’ identity when they arrive, and will have to keep track of the students as they progress through the degree programme and report them to the relevant authorities if they fail to attend. This paper focuses purely on this latter requirement: how we propose to manage the work associated with monitoring the attendance of UG and PG students.

The principle behind the draft proposals below is that we will change our current business processes as little as possible in order to comply with the requirements of the UKBA. Although these requirements only come into force on 1 February 2010, CHSS proposes to introduce them at the start of the new session from 22nd September 2009 in a pilot, in order to save upheaval and potential confusion mid-session.

It has now become clear that a light touch approach is acceptable: it is for each Higher Education Institute (HEI) to decide how to monitor non-attendance, in the light of its structure, type of courses, etc. In particular UKBA do not require a minimum percentage attendance; nor do they require HEIs to put in place new attendance recording mechanisms such as registers, swipe cards, etc.

It has been agreed at Edinburgh that the attendance of all students should be monitored, and not only of those who are international – that, it was felt, would not only have been seen as discriminatory by all students, but it would not have allowed us to use this new monitoring as an opportunity to improve the support offered to all students by identifying early those in need of assistance and advice.

It is proposed therefore that staff will keep track of all students regardless of their immigration status as they progress through the University, and report them to the School for investigation 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. Only if they are international students and cannot be traced by the School, would they be reported further to the appropriate dean in the College Office – so that the University meets its legal duties to monitor the students it sponsors to study here (to use the language of UKBA). This is explained in more detail below.

The UKBA are very clear that a report to them of non-attendance by an international student will trigger the removal of the student from the UK. The judgement on non-attendance is for us as the sponsor, and not for UKBA. (Staff should note, however, that not all international students fall to be reported, eg one-semester Visiting students can enter either under a student visitor visa which does not require the same level of monitoring and has to be for 6 months or less, or under a general student visa, which does carry these statutory duties. Interruptions of study, placements etc are not counted as non-attendance. However, interruptions of study should ideally not be approved retrospectively, especially for PG students.)

The UKBA has suggested ten contact points should be monitored for a degree programme – note that ten is for the total for the length of the visa (which might be four years plus extensions), and not the total requirement per annum. For shorter courses which have fewer than ten contact points, a pro rata number is acceptable. We are assuming that contact points mean physical rather than virtual contacts, since emails and phone calls can be made from any location.

Standard contact points will be registration (including the confirmation of attendance), assignments, exams, lab work records and supervisor meetings. There may be other contact points that apply to certain Schools only, which relate to the discipline – Schools therefore have the discretion to define their own contact points. For UG/PGT students, Schools will identify UG/PGT students failing to engage with academic activities, but in a way appropriate for the individual subject. (This will involve judgement rather than automatic classification as non-attendance in every case of failure to engage.) For PGR students, non-attendance will be a judgement call for the principal supervisor, in the light of knowledge of the student's project/research, patterns of working, and progress.

Students on joint programmes are the responsibility of the lead University or the University that admitted them. Where the student belongs to the University of Edinburgh, this University’s relevant School will be responsible for leading the investigation into a missing student. For teaching/other academic activity delivered by the partner institution we would expect the partner to monitor attendance (as they would for their own students) and report any problems to us. It is important therefore that partner institutions understand our requirements, and similarly that we understand other HEIs' requirements in cases where they sponsor (or “own”) students for joint degrees involving Edinburgh. In general, it would be safe to assume that our partner HEIs applying their attendance monitoring arrangements designed to meet the UKBA’s requirements and reporting any problems to us for our own sponsored students would be satisfactory - but it would be wise for these expectations to be written into memoranda of understanding.

Another factor that will trigger investigation and which can lead to a student’s removal, is non-payment of fees, so Finance and Accommodation Services will be introducing measures to monitor this (which reflect the existing student debt policies).
The University only has a short fixed amount of time from when it confirms that a student is not in attendance before it must legally report the student to UKBA, at which point the student’s Confirmation of Acceptance of Study (used to gain an entry visa to the UK) and the visa are both withdrawn. In the event of non-attendance, the sponsor guidance states 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 University then has a further ten working days to attempt to trace the student. (see the flow chart below for guidance on this). Essentially, therefore, we have a month to establish non-attendance without good reason and to report this to UKBA. (Public holidays are not included in this period of twenty days, but other University holidays are).

2. Summary of non-attendance reporting procedures

1. At exam/assignment time, course secretaries, teaching organisations or graduate school offices or equivalents will summarise any cases where marks are unavailable and no special circumstances case has been lodged. 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. Schools will have to follow up any absences as soon as the marks list is available after the Exam Board meeting – that is “day 1” for these purposes. For an assignment, the tutor and/or course secretary responsible must advise as soon as s/he/they know for certain that the piece of work is unavailable, and the School’s designated staff will then attempt to contact the student within the 10 day period.

2. Lab attendance reports will be reviewed by tutors once a week and any absences notified to the school office for follow-up with the student. Missing lab assignments will be reported as soon as they are noticed, and followed up like any other missing work.

3. For Postgraduate Research students, the contact point is the regular research supervisor meetings. PG supervisors will record that a meeting has taken place, and at the meeting will agree the date of the next. The frequency will vary significantly according to the stage of the research reached by the student. Only if a planned meeting is missed with no good reason will the supervisor report it to the Graduate School Office for further investigation.

4. Exception reports and University-level reports: Registry will need to be able to run single reports to collate results on different issues for the whole University, to allow it to analyse trends and issues arising and to provide any feedback and data requested by UKBA.

5. Schools will be closely involved in this work, and the School Administrators will either be responsible for compliance in their School or for appointing someone in the School to be responsible. If any staff or students have any queries about the legislation or procedures, this person would be their first port of call.

3. Investigating and reporting non-attendance

School administrative and support officers will be key to successful attendance management. When they identify, or have reported by academic colleagues to them, that a student is absent through non-attendance or non-submission of required assessments etc, they will have to ensure they are ready to take these necessary follow-up actions in a timely manner: 1. Chasing non-attenders: All registrations and confirmation of attendance has to be completed by 31 October. It is at this point that Registry will report all "no shows" to the UKBA (obviously not this year 2009 - it starts for entry in 2010 - this year is a pilot year). This fits in with the normal timeline for chasing those not matriculated either because they haven't registered, or not had attendance confirmed, or both. As part of this Registry normally sends out lists to Schools to check. They will probably bring this slightly forward to ensure we're in a position to meet the 31 October deadline. So, the Schools probably need to start chasing those without attendance confirmed as soon as is practical (probably after the end of week 1) and Registry can provide ists whenever a School would like them.

2. Attempting to contact the student including, potentially, via their classmates and, if necessary, their emergency contact numbers. (Data Protection advice has been taken on this point and confirms that this is an appropriate use of emergency information. Students will be pre-notified through registration and other information that their emergency contacts may be used in this way).

3. If applicable, checking with the Director of Studies and/or Course Organiser/Tutor/PG supervisor if they have knowledge about why the trigger event has been missed: e.g. why an essay has not been handed in or a meeting was missed.

4. Checking no special circumstances case has been lodged for an Exam Board.

5. If the School finds, after it has investigated any non-trivial non-explained absences that the outcome is not a satisfactory explanation or that the academic colleague(s) are not satisfied that the student will re-engage with the academic activity, then a further report is required. If the School that has noticed the non-attendance does not “own” the student, then they should simply report their findings to the School or institution that does “own” the student, who will be responsible for investigating further. If, however, they “own” the student, then they should take the lead in contacting any other School or College (or institution) being attended by the student to establish if the student is missing from there too.

6. Checking that the student’s fees are up-to-date and if appropriate that his/her Accommodation Services rent is up to date.

7. Ultimately, submitting a recommendation to the Head of College (or his/her nominee – i.e. the Dean of Undergraduate or Postgraduate Studies) to suggest that the student should be reported to Registry. If this is supported, the College will report this to Registry, who will report onwards to the UKBA. Registry will also withdraw the CAS, which will lead to the withdrawal of the visa.

This process is summarised in the diagram below:
Non-attendance process

This pro forma is for documenting the decision to deem a student not in attendance.
Proforma: Decision by School to report non-attendance
1
Date of report

2
Name of person completing report

3
Role
School Office administrator
4
Non-attendance trigger event
Essay/ Dissertation/ Thesis
Exam
Lab
PhD supervisory session
5
Date of event
Essay / Dissertation/ Thesis – (date the results are posted and no Special Circumstances case lodged) -
Exam – (date results are posted and no Special Circs case lodged) -
Lab – (date of lab) -
PhD supervisory session – (date session due) -
6
If the student attends courses elsewhere in the University or in a partner HEI, date confirmation received that student is in non-attendance there also and name of person reporting.

7
Emergency contacts contacted?

8
Finance check – are fees up-to- date?

9
Accommodation Services, if applicable – is rent up to date?

10
Name of person approving report to Registry, to be conveyed to UKBA
Dean of Undergraduate or Postgraduate Studies on behalf of Head of College -
11
Date of approval by College

12
Name of person inputting decision to UKBA sponsor management system
Registry. Level 1 user.
13
Date of input

APPENDIX
Attendance management scenarios
a) A student fails to hand in an essay, but comes in person to his/her Director of Studies to request an extension within two weeks of the deadline for the essay.
We would not count this as non-attendance.
b) A student fails to hand in an essay and telephones or emails his/her Director of Studies to request an extension.
This might count as non-attendance. The student should ideally be physically seen (by DoS/ by administrative staff/ a Level 2 user/ any member of academic or administrative staff). That means either we require students to request extensions in person (which may or may not be the case already), or we make the extension conditional on their physically presenting themselves at the School office. This latter approach would require superior communications and record-keeping between the School office and the academics and would not be possible if the student were not present for legitimate reasons of significant illness. This therefore has to be a case where Schools exercise their judgment.
c) A student fails to hand in an essay/ does not turn up for an exam, and is not heard from within a fortnight.
We would count this as non-attendance.
d) A member of staff does not advise the School or College that the student has failed to hand in an essay until well over two weeks have passed.
This would count as non-attendance from the date the essay was due. School offices and Registry are required to report this as non-attendance as soon as they become aware of it.
e) A supervisor cancels or postpones a session with a student.
We would not count this as non-attendance by the student.
f) A student requests a postponement of a supervisory session in person. We would not count this as non-attendance by the student
g) A student requests a postponement of a supervisory session by telephone or email to a date which is within two weeks after the original one was due to take place.
We would not count this as non-attendance by the student, but if it happens twice, we would count it as non-attendance from the date the original session was due to take place.
h) A student requests a postponement of a supervisory session by telephone or email to a date which is more than two weeks after the original one was due to take place.
(This, and the item above, will require all academic staff to be made aware of the implications of accepting a request to postpone a session. In addition, PG research students will need to be advised by their Graduate School and supervisors and in student handbooks that this applies, or they might innocently be caught out.)
We would count this as non-attendance and the student would have to either make the request in person or be seen by someone as in scenario b).
i) PGR students want to renew a Visa, who are not resident in Edinburgh.

i - a) If the students wished to apply through the University's visa application service run by the International office or by EUSA, then they would need to be physically present in Edinburgh. This is for a variety of reasons, but the main one which prevents these offices from handling the application remotely is that their OISC exemption requires them to be satisfied that they (as immigration advisers) are applying for who they say they are applying for. Hence, they do not have a drop-box system and insist on seeing students to sign some forms if they wish UoE representation to apply for them by post. i- b) There is nothing to prevent students who are elsewhere in UK from making their own application either by post or in person if they are away from the University. The visa extension letter as issued essentially approves the student to join our licence. Provided they had the correct documents and make a good application which fell within the rules, they should be able to extend their own visas without our assistance. The down side of this is that it takes significantly longer to apply by post in these circumstances and if it went wrong, there would be nothing we could do as we were not the student's representatives at the time of application. Students off-campus can obtain suitable advice before making the application through the [e-mail] email address and detailed online web information. There is also a network called the Immigration Advisory Service UK which can be found in most major towns and cities across the country where students and others can obtain free immigration advice. i- c) For out of country extenders, this would be something that they could handle on their own in that country, in the same way that new entrants arrange their visa before they arrive. Such students can contact the International office for advice, and they (Euan Fergusson, Ann Mackay and colleagues) would ensure that they do as much as they can to give the student information sufficient for them to make a reasonable go of an application.

j) A student fails to attend a placement.
We would count this as non-attendance under the same sorts of rules as above.
k) A student is discovered to have used fraudulent evidence of qualifications, whether or not they appear to be coping with the course requirements.
We would withdraw our certificate of sponsorship and report the student as no longer a student from the date we became aware of the fraud.
l) A student registers for a resit but fails to turn up.
We would count this as non-attendance from the date of the resit result being posted, not the date of the registration.

Nicola Rankin / Janet Rennie.
(edited July 2009 and 17 August 2009.)