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Dear Home Secretary, 

I am writing in regards to Government’s decision to increase visa fees. Announced in July by the Prime Minister, these changes are scheduled to come into effect later this week on Wednesday 4 October 2023. 

As you will know, the UK is increasingly reliant on the internationally educated nursing workforce, with over half (53%) of nurses joining the Nursing and Midwifery Council register having been trained internationally.¹ The RCN is clear that governments across the UK must invest in expanding the UK-educated workforce. In the context of a global nursing shortage, current international recruitment levels are unsustainable and unethical.  

However, we are concerned that these fee increases will make the UK a less attractive place to live and work for the nurses and other health professionals who make vital contributions to our health and care sector every day. Government has suggested that fee rises are in part to fund pay rises in the public sector, the RCN is clear that it is wholly unacceptable to pass on the cost of much-needed public sector pay rises to these staff.

Application fees for the health and care visa route are due to increase by 15%. Staff applying for the health and care visa where a certificate of sponsorship will be issued for up to three years will now pay £284, and £551 for more than three years.² This is despite an estimated cost to the Home Office for processing health and care visa applications of only £129 for overseas applicants and £151 for in-country applicants.³ 

In addition to this, overseas nursing students in the UK will now see their fees increase by £127, from £363 to £490.⁴ Together with recent changes that prevent overseas students from bringing their dependents to the UK, visa fee increases will further disincentivise overseas applicants from studying in the UK.⁵ Since 2019, the number of international students accepted onto nursing courses across the UK has been steadily rising. In just the last three years, the number of nursing students coming to the UK from outside the European Economic Area has risen by 69%.⁶ Raising the costs for students to undertake nursing degree programmes in the UK risks stalling this growth. 

With regards to permanent settlement in the UK, the Migration Advisory Committee (MAC) has highlighted the generally high cost of indefinite leave to remain (ILR) fees in comparison to other countries. The Committee has made a strong recommendation for Government to review ILR fees with a view to reducing them.⁷ Despite these recommendations, the cost to apply for settlement is set to increase by 20% to £2,885. By comparison, the latest visa and transparency fees data suggests that the estimated cost to the Home Office of processing an ILR application is just £646.⁸ In the context of a decade of pay erosion,⁹ ILR fees may be unaffordable for many health workers and act as a significant barrier to settlement.

The RCN believes that by improving pathways to ILR, the Home Office could help to tackle abusive labour practices and reduce the ability of employers to use immigration status to tie staff to exploitative situations.¹⁰ It is my view that enabling greater numbers of health workers to attain settlement is also beneficial to the UK’s health system, with positive impacts on workforce recruitment and retention. 

In addition to the visa fee hikes, Government is set to increase the Immigration Health Surcharge (IHS) by 66%, from £624 to £1,035. We recognise that health workers under the health and care visa remain exempt from the charge. However, health and care workers under different visa categories must still find the funds to pay this cost up front before applying for a reimbursement. 

I am also concerned about the possible impact that this increase may have on patients, as access to NHS services for most visa holders is dependent on payment of the IHS.  Increases to the IHS and visa fees more generally may act as a barrier for migrant workers and their families to maintain regular status. There is, therefore, a risk that the introduction of higher fees may increase the number of people that will be subject to the NHS charging system, and deterred from accessing the health care that they need.  

Nurses and care workers, regardless of their country of origin, make a vital contribution to this country in both the care they provide and the taxes and National Insurance contributions they already pay. They deserve to be valued and recognised. Subjecting our much-needed internationally educated staff in the health and care sector to additional levies is not only unjust but divisive and short-sighted. 

I would welcome the opportunity to meet with you to discuss these matters further, and urge you to revoke these changes.

Yours sincerely, 

Pat Cullen

General Secretary & Chief Executive

CC Rt Hon Steve Barclay MP
Secretary of State Department for Health and Social Care

¹  Nursing & Midwifery Council – Registration data reports (2023)
²  UK Visas and Immigration – Home Office immigration and nationality fees: 4 October 2023 (2023)
³  UK Visas and Immigration – Visa fees transparency data (2023)
⁴  UK Visas and Immigration – Home Office immigration and nationality fees: 4 October 2023 (2023)
⁵  Home Office – Changes to student visa route will reduce net migration (2023)
⁶  UCAS - Statistical releases – day 28 daily Clearing analysis (2023)
⁷  Migration Advisory Committee – Annual Report (2022)
⁸  UK Visas and Immigration – Visa fees transparency data (2023)
⁹  London Economics – A decade of pay erosion: The destructive effect on UK nursing staff earnings and retention (2022)
¹⁰  Migration Advisory Committee – Annual Report (2022)