Freedom of Information Request – Ref: GHC-21042026-790819
Thank you for your recent Freedom of Information request. Please find our response below.
You asked:
The impact of the April 2025 visa salary threshold changes on lower-paid NHS staff, particularly Band 3 and below roles. Please provide information covering the period: 9 April 2025 to 31 March 2026.
1) Employees requiring visas in Band 3 and below Please provide the number of employees at Band 3 and below who, during the period above, required a visa in order to work for the Trust.
Please break this down by:
- pay band
- job title / role
- visa type, where recorded (for example: Skilled Worker visa, Graduate visa, Dependant visa, Health and Care Worker visa, or other)
- If visa type is not centrally recorded, please state this.
Our response:
| VISA Type | Number of Colleagues | Job titles | Pay band |
| Skilled Worker | 50 | HCA, Decontamination Assistant, Senior Rehab Assistant | 3 |
| Graduate | 6 | HCA, Admin Assistant, Service Admin | 3 |
| Dependant | 34 | Housekeeper, HCA, Rehab Assistant, Ward Secretary, Call Handler, Team Admin | 2 and 3 |
You asked:
2) Staff whose employment ended or changed where visa status was a contributing factor – Please provide the number of employees whose employment ended or whose role changed during the period above where visa status, visa expiry, or visa-renewal ineligibility was a contributing factor.
Please include the following categories, if held:
- formal dismissals
- non-renewal of fixed-term contracts
- resignations linked to visa-related issues staff who left employment before visa expiry due to anticipated ineligibility redeployments or transfers to different roles due to visa/salary issues cases where sponsorship was not offered or not renewed
Please break this down by: pay band job title / role reason category
Our response:
We fortunately haven’t had any situations arising as above in relation to VISA changes although we can foresee some issues with some colleagues at VISA renewal.
You asked:
3) Staff in roles below the relevant visa salary threshold – Please provide the number of employees who, at any point during the period above:
- required visa sponsorship (or would require sponsorship upon expiry of their current visa in order to remain employed)
and
- were employed in roles whose salary was below the relevant visa salary threshold applicable to them at that time.
Please break this down by:
- pay band
- job title / role
If the Trust does not hold this as a single dataset, please provide any equivalent recorded information, internal reports, or assessments used to identify staff potentially affected.
Our response:
| VISA Type | Number of Colleagues | Job titles | Pay band |
| Graduate (if we needed to sponsor) | 9 | Assistant OD Project Manager
Senor Rehab Assistant 2 Administration Assistant 3 Healthcare Assistants Business Support Supervisor |
5
2 3 3 4 |
| Dependents (if we needed to sponsor) | 16 | 3Administrators
Ward Secretary House keeper Facilities Supervisor 3 Hotel Services Assistant 2 Rehabilitation Assistant Financial Accounts Assistant Call Handler Registered Nurse 2 HealthCare Assistants |
2 and 3
3 2 3 2 2 3 3 5 3 |
| Skilled Worker (If we need to renew) | Senior Psychological Wellbeing Practitioner
2 Community Nurse Facilities Supervisor |
6
5 2 |
You asked:
4) Sponsorship decisions and Certificates of Sponsorship Please provide the following information for the period above:
a) The number of Certificates of Sponsorship (CoS) issued by the Trust, broken down by: pay band job title / role
b) The number of cases where sponsorship was: not offered not renewed withdrawn determined not to be viable where the salary for the role did not meet the applicable visa salary threshold.
Please break this down by:
- pay band
- job title / role
Our response:
| VISA Type | Number of Colleagues | Job titles | Pay band |
| Skilled Worker | 56 | 32 Nurses
20 Health care Support Workers 1 Speciality Doctor Building Improvement Manager Dental Therapist Senior OH Nurse |
5
3
6 7 7 |
You asked:
5) Policies, guidance, and mitigation measures – Please provide copies of any policies, guidance, internal instructions, or briefing documents issued during the period above relating to: employees unable to meet visa salary thresholds handling visa expiry where sponsorship or renewal may not be possible any mitigation measures intended to retain affected staff.
This may include, but is not limited to:
- HR guidance
- manager guidance
- workforce planning instructions
- redeployment guidance
- salary/uplift
- role-change mitigation discussions
Our response:
Below are links to:
- Colleague briefing document
- Presentation to International nurse Council
- Starting Salary Policy for salary uplift based on experience
Fact Sheet UK Immigration Changes February 2026
NHSE Settlement Presentation 280126
You asked:
6) Internal assessments, risk reviews, or communications – Please provide copies of any recorded information created or held during the period above relating to the impact of the April 2025 visa salary threshold changes on staffing.
This may include:
- internal impact assessments
- workforce risk reviews
- HR reports board, committee, or senior management papers
- internal emails or briefing notes
- communications with NHS England, DHSC, UKVI, or the Home Office
Our response:
Freedom of Information Act 2000 – Exemption Applied – Section 36(2)(b)(i) and (ii) – Prejudice to the Effective Conduct of Public Affairs
The Trust has applied Section 36(2)(b)(i) and (ii) of the Freedom of Information Act 2000.
In the reasonable opinion of the Qualified Person, disclosure of the requested information would be likely to inhibit the free and frank provision of advice and the free and frank exchange of views for the purposes of deliberation.
The requested information relates to internal assessments, workforce risk reviews, communications, and senior-level discussions regarding the impact of changes to visa salary thresholds. This includes material considered at Board, committee, and senior management level, as well as internal briefings and correspondence.
This information involves detailed discussion of workforce planning, staffing risks, and individual circumstances, including matters relating to immigration status and employment. These are inherently sensitive areas, as they may directly affect individuals’ ability to remain in their roles and the Trust’s ability to manage staffing safely and effectively.
Disclosure would be likely to inhibit open and candid discussions between staff and senior leaders, as individuals must be able to provide honest advice and fully explore risks without concern that such discussions will enter the public domain. This would be likely to prejudice the Trust’s ability to make informed decisions and effectively manage its workforce and services.
You asked:
7) Recording systems – Please state whether the Trust has a specific policy, procedure, or system for recording and monitoring employee visa status, visa expiry dates, and sponsorship status.
If so, please provide:
- the name of the policy/procedure/system
- a copy of the relevant policy,
- or a summary of the process if a full document cannot be provided
- Clarification / format
Our response:
Colleague details are recorded via ESR system.
Recruitment use a tracking spreadsheet to monitor sponsorship requests for direct applicants.
Workforce Team monitor VISA status and expiry dates and work alongside recruitment to monitor renewal processes.
Next steps:
Should you have any queries in relation to our response, please do not hesitate to contact us. If you are unhappy with the response you have received in relation to your request and wish to ask us to review our response, you should write to:
Louise Moss
Head of Legal Services / Associate Director of Corporate Governance
c/o Gloucestershire Health and Care NHS Foundation Trust
Edward Jenner Court
1010 Pioneer Avenue
Gloucester Business Park
Brockworth, GL3 4AW
E-mail: louise.moss@ghc.nhs.uk
If you are not content with the outcome of any review, you may apply directly to the Information Commissioner’s Office (ICO) for further advice/guidance. Generally, the ICO will not consider your case unless you have exhausted your enquiries with the Trust which should include considering the use of the Trust’s formal complaints procedure. The ICO can be contacted at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9