Response internetconsultation Law Internationalization in Balance (WIB)

The Hague University of Applied Sciences is a knowledge institution with a clear international profile, which wants to contribute to a sustainable and just world. This is only possible by having an eye for that world in our education and research. Sometimes this is local, with a project on resident participation in our multicultural The Hague neighborhood of Laak. Sometimes it is global, in a European research project on healthy ageing. In our experience, an international dimension enriches education and research and is sometimes even crucial. After all, global issues require global solutions.

From this conviction, The Hague University of Applied Sciences brings together students from more than 100 countries and from numerous cultures in The Hague. To learn together and to learn from each other. In our international classroom we prepare students for a society and a field of work that are unmistakably international.

The Hague University of Applied Sciences has therefore taken notice of the bill Internationalization in Balance (WIB) with concern. Not only because of the content of the bill, but especially because the underlying analysis does not do justice to the situation at universities of applied sciences. 

As the minister notes, there are significant differences between universities of applied sciences and research universities, and bottlenecks occur primarily in a few specific research university programs. There is no uncontrolled growth of international students at the universities of applied sciences. The Haagse Hogeschool currently has 13% international students and no structural capacity problems. Nevertheless, the bill hardly distinguishes between hbo and wo. In fact, universities of applied sciences are more heavily burdened with new measures than research universities. For example, the most international studies are the university masters and the least international studies are the associate degrees. Yet in this bill, the minister proposes to exempt wo-masters from the "test of foreign-language education" and to subject hbo integrally to this regulatory burden. 

In response to the bill, The Hague University of Applied Sciences is pleased to offer the following four considerations:

• Opt for customization: the bottlenecks caused by English as the language of instruction occur in specific university bachelors. If the minister deems an additional test necessary, limit it to only those university bachelors and avoid unnecessary regulatory pressure in higher education. This will increase the practicability of this law for all parties involved and do justice to the differences between hbo and wo. Also: the bill mentions 5 aspects that may be taken into account when choosing to offer an English-taught program. We would like to see the following added: 'the international profile of the institution'. This addition does justice to many years of government policy to stimulate profiling and differentiation of institutions. 
• Language is crucial, leave it up to schools how they interpret this. The Hague University of Applied Sciences invests firmly in the Dutch and English language skills of its students. The inclusion of mandatory language instruction in the curriculum is unnecessary and encroaches far into the autonomy of education. Moreover, this provision is insufficiently elaborated and poorly enforceable (for further explanation, see the response of the Association of Universities of Applied Sciences).
• Central Control: The bill assumes self-direction by the sector, but also introduces an "emergency brake" and an advisory committee at the CDHO. The consequences of this are poorly understood on the basis of this bill. Details are lacking about the criteria for selfgovernment, the composition and mandate of the advisory committee, and the minister's scope for revoking accreditation. Moreover, this introduces a possible conflict between the binding right of consent of the internal participation council and the emergency brake of the minister. Agreements with the sector are a more appropriate solution than this law.
• Work on Implementation: The Hague University of Applied Sciences is familiar with the government-wide Work on Implementation program. In the opinion of The Hague University of Applied Sciences, this bill is at odds with the government's intentions under this program. We request that you also look at the feasibility of the bill through this lense: unnecessary administrative burdens, a zig-zag course and a stacking of tests and instruments, which do not benefit the feasibility. 

The Hague University of Applied Sciences sees in this bill mainly measures to limit internationalization. This is a missed opportunity, because internationalization also offers many opportunities. Instruments other than legislation may be more effective and faster for this. Think of an ambitious program to attract significantly more technical students to the Netherlands or a new action plan to increase retention of international alumni in the Netherlands. Consider substantial investments to expand the supply of student rooms, because the National Action Plan for Student Housing is not yet producing sufficient results. In this regard, The Hague University lacks the instruments that would provide balance. The name of the bill does not cover the content. 

Finally, The Hague University of Applied Sciences calls on the Minister to address a more important bottleneck as a matter of priority: the accessibility of higher education for refugee students who do not yet have a residence status of 'asylum'. Because this group of students is now ineligible for funding, institutions are forced to charge institutional tuition fees. Some institutions, such as De Haagse Hogeschool, choose to reduce tuition fees for specific groups out of their own resources, thereby ensuring the accessibility of education. Nationwide, however, this situation creates ambiguity, financial risks and, at many educational institutions, tuition fees that are unaffordable for refugee students. Moreover, in the case of refugee students from Ukraine (falling under the European Directive on Temporary Protection), the numbers are limited, for which national funding would amount to only 10-15mln euro. The Hague University of Applied Sciences therefore appeals to the Minister to make funding available for refugee students per academic year 2024-2025. 

Kind regards, 

The Executive Board of The Hague University of Applied Sciences