Sponsorship licences: the punitive approach

The approach of the UKVI in sponsorship has moved from collaborative to punitive and minor infractions are now being used to downgrade and worse suspend licences. Gone are the days when not finding an illegal worker was good enough to prevent any serious consequences. The problem is that there is no appeal before an independent body.  This is of course a problem in all other areas of immigration but felt acutely in the area of sponsorship. The only recourse is to apply to the High Court but this is an expensive process.  Furthermore its jurisdiction is different as does not consider the merits but looks at whether the process has been a reasonable one.
Of course the downgrading and suspensions means that new staff cannot be brought in and this works effectively in cutting numbers of migrant staff and helps the government by reducing numbers.
At present care homes are being targeted and this is causing great concern. These homes cater for vulnerable patients with dementia. Taking away their ability to retain or bring trained staff will only put pressure on a system that is already reeling with constant regulation.  In the end the people who will suffer most will be the residents themselves. Local residents do not want to work the antisocial hours that are required and they will take these jobs as stop gaps moving on as soon as something better comes along. The situation is becoming desperate. So what is to be done?
First make sure you have your systems in order.  This means checking documents, ensuring your paperwork is uptodate and that you regularly check that you remain compliant. It is important to allocate this task to someone reliable. Secondly if you believe that you have acted reasonably be prepared to fight. Don't give in.