Memorandum submitted by Universities UK
INTRODUCTION
1. Universities UK is pleased to respond
to the first phase of the consultation process on the reform of
the 14-19 curriculum and qualifications. The intention, from the
outset, to involve the higher education sector in the design and
delivery of future 14-19 reform, in terms of the Working Group,
the HE sub-group and the Associate Network, is particularly welcome.
2. We recognise that this part of the consultation
process focuses on establishing the key principles for reform
and agreement to the overall architecture of a national qualifications
framework. In view of this it is not appropriate to offer detailed
comments at this stage, particularly in terms of how a whole programme
with a single qualification will work for the purposes of application
to HE, however, we look forward to working with the Group to establish
the details and commenting on a fully worked up model of the diploma
framework in January 2004.
3. We have encouraged individual universities
to make a contribution to the consultation. In addition, the proposals
by the Working Group have been considered at a meeting of the
Universities UK Board on 24 October. We have also invited Mike
Tomlinson, Chair, Working Group to address vice-chancellors on
5 December 2003.
4. We would like to make the following points.
OBJECTIVES FOR
REFORM
5. Universities UK supports the concept
that 14-19 education should be viewed as a coherent single phase
of learning with clear paths of progression. We strongly support
the need to improve retention rates, particularly post 16, encourage
progression and increase attainment levels amongst young people,
acknowledging that this is crucial in terms of increasing/broadening
widening participation and of fundamental importance to the success
of the overall education sector.
6. We support the objective to improve the
transparency and simplicity of the structure for 14-19 courses
and qualifications. It is vital that the final proposals are transparent
and coherent, clearly understood, can be valued for both the users
and the owners and have national and international credibility.
The measured and long-term approach undertaken by the Working
Group should help avoid loss of confidence in education at these
levels.
7. In addition, we welcome the assurance
given by Mike Tomlinson that the proposals to reform the overall
structure of 14-19 programmes and qualifications should impact
on the quality of achievement and the coherence of a young person's
learning programme and should not result in establishing a different/new
bureaucratic approach.
THE 14-19 QUALIFICATIONS
FRAMEWORK
8. Universities UK notes the proposal to
develop a national framework of diplomas covering whole programmes
of study, rather than existing individual qualifications such
as GCSEs, GNVQs, A-levels and NVQs. In view of this, it will be
important for the overall Diploma to have currency and status
and to be able to offer some clear added value to students and
end users including higher education and employers. This will
be particularly relevant to university admissions, whereby institutions
will need to be clear as to the benefits to be gained from making
offers on the basis of the overall diploma rather than focusing
on achievement within individual components. Further clarification
of the role of existing qualifications within the diploma is required
and of the different levels and types of diploma within the overarching
framework. Mapping of the skills base of the diploma on to the
range of products within HE will also be necessary.
9. The recommendation that the diploma might
recognise students' wider activities and interests is in line
with the current momentum to widen access and increase participation.
There is a general recognition that HEIs are making decisions
on applicants from a diverse range of educational experience.
It is also acknowledged by some HEIs that formal qualifications
may need to be supplemented with other forms of assessment in
order to determine effectively the potential of an applicant.
(This issue is currently being consulted on by the independent
review on admissions, led by Professor Schwartz.) The move to
recognise a wider range of learning, skills and personal development
should provide valuable information. This does, however, need
to be underpinned by genuine equality of opportunity. The impact
of this on the admissions system will also require further analysis,
as will the assessment and certification of the wider activities.
10. The emphasis placed on the need to address
the needs of all learners is critical. The aim to use the diplomas
to challenge the most able learners whilst embracing the full
range of programmes of study and ensuring some form of recognition
of achievement for all students will require careful consideration.
We are aware that this will not be an easy balance to achieve,
and must be determined in a way that can be clearly understood
ie not resulting in an over complex system of qualifications within
a diploma.
11. In response to the 14-19 Education Green
Paper, Universities UK acknowledged support for the existing view
that vocational pathways needed strengthening in order to encourage
more young people to stay in learning. We therefore welcome the
recognition given now to the role of advanced vocational and occupational
learning as a viable route into HE and the objective to ensure
genuine parity of esteem for academic and vocational routes.
12. Building on this, however, is the need
to clarify how vocational programmes of study and those with "academic"
subjects will be able sit side by side in a diploma given that
these are currently very different programmes.
BALANCE OF
PROGRAMMES
13. Universities UK recognises the benefits
to be gained from a balanced curriculum consisting of coherent
programmes of learning and incorporating general skills and knowledge
as well as academic or vocational specialisms and supplementary
learning. This complements developments in teaching and learning
within the HE sector, where prior experience of independent learning
would be beneficial to students and where there is a growing emphasis
on generic skills and personal development planning. Supplementary
learning which could support students' HE studies such as analytical
and research skills, development of self-management and reflection
skills, and problem solving could also be valuable. Likewise,
short work placements could form a useful part of the curriculum.
14. It is equally important, however, that
programmes of learning allow sufficient depth of study, particularly
in disciplines where it is necessary to have prior knowledge at
a certain level before beginning a university programme of study.
This is particularly significant in England, Wales and Northern
Ireland whereby the traditional three-year programme of study
frequently demands and builds upon a high level and depth of knowledge.
In view of this, Universities UK welcomes the objective to develop
a qualification system which delivers a wider range of skills
and knowledge as an integral element of the qualifications package,
provided this is not at the expense of breadth required for some
programmes of study at HE and that HEIs can be reassured that
schools/FE colleges will be able to deliver a broad and deep diploma.
15. Further information on the proposed
balance of programmes is required, alongside the clarification
of the definitions of general/core, specialist and supplementary
learning. The balance between specialist, general and supplementary
learning will be crucial to determining whether or not the diploma
will be a suitable vehicle for preparation to higher education.
16. Given the national difficulties in encouraging
students to study science, engineering and languages we would
welcome consideration to be given to improving the attractiveness
of these disciplines to the 14-19 group within the context of
curriculum development.
ASSESSMENT ARRANGEMENTS
17. Universities UK acknowledges the need
for fitness for purpose of assessment and welcomes the proposal
that all young people should experience a variety of assessment
methods. This diversity in assessment methods will better reflect
those used in higher education and in employment.
18. From an HE perspective it will be important
that the diploma framework provides a full picture of what an
individual can do and has achieved, as well as demonstrate progression
and potential for the future. The transcripts behind the diplomas
will provide further information although the nature and content
of these, including the description/measurement of performance
and potential, and validation, within the context of HE requirements,
will require careful consideration. Reference should also be made
to Progress Files and the Record of Achievement.
19. The issue of differentiation is critical
to HEIs. The qualification framework must facilitate distinction
between high calibre applicants and provide sufficient evidence
to institutions to allow selection decisions to be made. This
will be particularly important for selecting institutions and
those with selecting courses.
20. The new framework will require a consistent
approach to certification. If it is proposed that all learners
should gain formal recognition at different points within the
14-19 phase this may necessitate a single awarding body on the
basis that the diploma will have to recognise awards, qualifications
and experience gained via a variety of authorities.
21. In recognising students' wider activities
and interests, careful consideration must be given to the value
of the contribution these activities may make to the overall diploma
"score". HEIs may find it difficult to discern high
academic achievement (eg when considering high demand programmes)
if an overall diploma score contains a large proportion of extra-curricular
"credits".
PACE AND
PROGRESSION
22. If the emphasis on the qualifications
framework is to be "stage not age" related this may
result in larger numbers of young people applying to HE. This
will have implications for institutions in terms of adequate "duty
of care" and the provision of support mechanisms which may
have significant resource implications.
COLLABORATION
23. The success of the qualifications framework
will depend on collaboration between different types of institutions.
This will be difficult unless there are changes to the current
funding methodologies and a commitment to provide funds for a
coherent and consistent pattern of provision.
ADVICE, GUIDANCE
AND FLEXIBILITY
24. A strong system of effective and impartial
information and high quality guidance for all 14-19 year olds
will be essential in a context of substantial choice. In addition,
a high level of transparency regarding the potential of particular
combinations of courses and pathways to facilitate progression
will be required in order to support students in making well-informed
choices. Likewise, if young people are to have flexibility in
terms of programmes of study, pathways must be clear and transparent,
and avoid a requirement for students to specialise at too early
a stage.
STAFF DEVELOPMENT
AND TRAINING
25. Effective staff development for existing
teachers, lecturers and other professionals will be necessary
for successful implementation of the proposed changes. The possible
future impact on initial teacher training standards and requirements
will also require further analysis.
IMPACT ON
OTHER SECTORS
AND STAKEHOLDERS
26. It is important that the diploma framework
is viewed holistically across the relevant sectors and stakeholders
and considered within the context of developments in the 14-19
education phase in other parts of the UK. This is important in
terms of the impact the changes may have on student flows within
the UK. The Welsh Baccalaureate pilot scheme is currently undergoing
a six-year pilot with the first student cohort in 2003. The National
Assembly will then decide whether the new framework should be
made available to all students in Wales from 2006. In Scotland,
in 1999, the Scottish Qualifications Authority introduced the
National Qualifications system. This brought academic, general
and vocational subjects into a single curriculum, assessment and
certification system. Reference should also be made to take account
of differences across European nations in the length of undergraduate
degree programmes.
POST QUALIFICATION
APPLICATION SYSTEM
(PQA)
27. In the light of the proposals it is
important to consider the possible establishment of a Post Qualification
Application (PQA) system into entry for higher education. This
issue is not raised specifically in the consultation document,
although it may be relevant given the proposals to introduce flexible
patterns of learning, a new approach to the curriculum and a preference
for a system which is "stage not age" related (thereby
allowing different progression rates). In addition, changes in
the structure and the volume of assessment could make PQA easier
to accommodate. In view of this, it would be helpful, within the
context of the 14-19 reform, to consider the feasibility and practicality
of a PQA system.
28. Universities UK is aware of the increasing
interest in the establishment of PQA and has acknowledged the
benefits, in principle, which could arise from the introduction
of such a system. It is generally accepted, however, that a PQA
system would only be feasible from an HE perspective if (a) universities
have a sufficient admissions period ie between the announcement
of the Alevel results and the beginning of the academic year and
(b) this would not require a change in the date of entry to higher
education.
29. A sufficient admissions period is particularly
significant in terms of the widening participation agenda and
fair admissions requirements. From an HEI perspective, sufficient
time must be made available to ensure that universities can make
decisions which take account of a wide range of factors such as
potential, interest and commitment, as well as achievement. This
is important in terms of mature students and other students following
non-traditional routes to HE who may have uncodifiable skills/experience
which may require more time for consideration in the admissions
process. Furthermore, there must be sufficient time built in for
interviews. Although most courses do not require interviews, some
institutions use them systematically (eg Oxford, Cambridge) and
they are statutory or standard practice for a range of subjects
(teacher training; social work; medicine and health care courses;
performing arts and art and design). In these cases, universities
use interviews to help determine suitability for a profession
or aptitude for a course. Interviews can also be used to help
distinguish between high-achieving candidates particularly for
selecting courses. If a PQA process did not provide enough time
there would be a risk of a "shadow" conditional offer
system emerging.
30. It is also crucial that universities
have sufficient time to implement fair, efficient and transparent
admissions procedures/polices and enough time to deal with any
appeals that may arise. From an applicant's perspective, a PQA
process would need to provide sufficient time to enable prospective
students to visit universities so that they can make an informed
and reflective choice and prepare portfolios for arts courses
and attend auditions for drama courses etc.
31. Accommodating PQA via a change to the
date of entry to higher education, such as January, would not
be acceptable for most HEIs. This could be detrimental in terms
of widening participation. A January start could affect those
students who have no financial support covering the period from
the summer when examinations end until January and have negative
consequences for attracting students from lower socio-economic
groups. Furthermore, a longer gap before term started could result
in more prospective students dropping out before entering higher
education. This could again be significant in terms of non-traditional
students who may not wish to wait so long. A later start date
could also affect applications from international students who
may prefer to go to other countries whose academic year starts
in the autumn.
32. A Universities UK-led Working Group
has undertaken some detailed work in terms of the implications
of a PQA system, not only for universities in general, but also
in relation to specific issues such as medicine and health related
disciplines, art and design and drama. In view of this, Universities
UK would welcome the opportunity to become involved in any detailed
discussions on this issue. For PQA to be accepted by all education
stakeholders it must be compatible with both the university and
school year, and the timing of national examinations. Consideration
must also be given to the UK-wide dimension, particularly in terms
of the variety of developments in 14-19 education in each nation
(see paragraph 26). It is also important that PQA be considered
in the light of other current developments, particularly the Review
of Higher Education Admissions led by Professor Schwartz and the
use of new technology to speed up the processing of exam results.
IMPLEMENTATION ISSUES
33. We endorse the clear remit of the Group
to consider the practical steps which should be taken to implement
the 14-19 reform and the recognition that the reforms should be
carefully phased in over 5-10 years. It is important that synergy
is created between the new proposals and existing systems and
to ensure that students, parents, teachers and end users such
as HEIs are fully informed of changes and it is vital that confidence
is maintained in terms of current learning and attainment. We
also support the decision to pilot the proposals and would encourage
reference to be made to other systems to build on good practice
such as successes from within the Scottish experience.
34. Universities UK supports the Working
Group's focus on ensuring that the needs of end users including
higher education will be met and look forward to working with
the Higher Education Sub-Group to consider further how this may
be achieved.
27 October 2003
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