Memorandum submitted by the National Union
of Students (NUS)
INTRODUCTION
1. The National Union of Students (NUS)
1.1 NUS is a voluntary membership organisation
comprising of a confederation of local student representative
organisations in colleges and universities throughout the United
Kingdom which have chosen to affiliate. The organisation has nearly
750 constituent members (CMs)—virtually every college and
university in the country.
1.2 NUS is one of the largest student organisations
in the world and provides research, representation, training and
expert advice for individual students and students' unions.
2. NUS' support for the Bologna Process
2.1 NUS welcomes the Education and Skills
Select Committee's inquiry into the Bologna Process and are pleased
to present this submission to a timely and much needed review
of the UK's current engagement with Bologna and the future direction
of the Process.
2.2 NUS is a strong supporter of the Bologna
Process and this submission focuses on some of our key concerns
and interests around qualifications, credit and student mobility.
2.3 NUS is currently refocusing the scope
and scale of our engagement with the European policy making process.
The organisation engages with European policy through the following
channels:
— ESIB—The National Unions
of Students in Europe: NUS is an affiliate to ESIB, a democratic
umbrella organisation representing 50 national unions of students
from 36 countries across Europe. ESIB is heavily focused on policy
development and represents the educational, social and cultural
interests of its members to relevant European bodies, most notably
the European Union, Council of Europe and UNESCO. Further information
can be found at www.esib.org. NUS will be hosting the 52nd Board
Meeting of ESIB in London later in 2007 to coincide with the Bologna
Ministerial Summit.
— Europe Unit's High Level Policy
Forum (HLPF): NUS feeds directly into the UK HE sector's position
on European policy debates through the HLPF, coordinated by the
Europe Unit at UUK.
— UK Socrates-Erasmus Council:
NUS is a member.
— Ministerial Delegation to the
Bologna Process: NUS has sent a student representative (typically
the Vice-President for Education) as part of the UK's delegation
to the Bologna Process.
3. NUS' support for the Bologna Process
3.1 NUS has been a long-term supporter of
the Bologna Process and has engaged in debates—both nationally
and internally through ESIB—with the important developments
that stem from the Process.
3.2 The Process is in its final years; so
it is timely to reflect on achievements (learning opportunities)
so far; and project onto next steps.
3.3 The principal reasons for NUS' support
of the Process are two-fold:
— The Bologna Process aims to create
a European Area of Higher Education (EAHE) as a way of promoting
citizens' mobility; so it assigns central importance to the social
dimension.
— The Bologna Process sees higher education
as a public good and a public responsibility; so it re-affirms
the importance of international co-operation rather than competition
in higher education (which NUS understands is philosophy behind
the Lisbon Convention, for instance).
4. Lessons learnt: Bologna 1999-2006
4.1 It is NUS' view that the UK has not
engaged as effectively, or proactively, with the Bologna Process
as it might have done. This is a challenge as much for students'
unions as it is to Higher Education Institutions (HEI's). We believe
that both the UK Government and the UK HE sector could have been
more pro-active with engagement in the Bologna Process. We also
believe that where sector bodies have shown leadership and engagement,
this approach has not been followed consistently by HEI's, who
have been too precious about institutional autonomy at the expense
of clarity, consistency and transparency for students.
4.2 NUS believes that it is crucial that
students' union students and staff are well informed of these
developments and we have welcomed the willingness of Universities
UK to run training sessions for student union officers at NUS
training events. As mentioned previously, NUS will be holding
ESIB's 52nd Board Meeting in London in May 2007 (to tie in with
the ministerial meeting). The theme of BM52 will be equality in
education, which we hope will provide a useful platform to engage
our membership with the Bologna Process.
4.3 NUS believes that more could be done
at the national/governmental level to raise the profile and the
level of awareness of the Bologna Process to key stakeholder groups:
students, institutions, staff and employers. The Europe Unit,
hosted by Universities UK and funded by GuildHE, the Quality Assurance
Agency and the HE Sector funding councils, is an increasingly
important partner for NUS and has been instrumental in providing
leadership and direction from the HE sector bodies. But we believe
more needs to be done to ensure that this leadership is disseminated
throughout HEI's.
4.4 NUS bats out the challenge to the Government
that it demonstrate its support and willingness by detailing the
level of support so far provided (strategically, procedurally
and financially) to disseminate the Bologna Process to the stakeholder
groups detailed above. If there were evaluative work to measure
outcomes and outputs all much the better as this information would
add to something that is sorely needed around the Bologna Process
at the national level: an objective national evidence base.
4.5 NUS accepts that the level of institutional
engagement, for example, varies markedly. Some might argue that
this is to be expected in a diverse sector. NUS would argue, however,
that the Government might like to consider doing a simple piece
of research: the credit test? How many institutions look at student
workload as a means of developing a credit notion? Consistency
and clarity are incredibly important from the student perspective
and we have significant concerns about how consistently HEI's
are complying with Bologna developments.
4.6 NUS predicts—rather than wagers—that
the outcome would be a diverse response—from the engaged
to the benignly non-committed. NUS also believes that perhaps
some levers might be applied to enhance the relative importance
of this area. One way might be to embed expected outcomes and
outputs in institutional strategic plans around the 10 Bologna
action lines. A brave move, perhaps, and NUS fully recognises
institutional resistance to such a notion (the need for extra
resources—administration time, more paperwork etc) but surely
the argument must be that any future system of higher education—that
wants to see itself aligned with its European partners and looking
out to the global market—is equipped to provide students
with the means to fulfil their potential wherever that might be
in the EHEA; and that students' expectations are met.
A EUROPEAN QUALIFICATION
FRAMEWORK (EQF)
5. Foundation degrees and two-year "fast
track" degrees
5.1 NUS is of the understanding that a Foundation
Degree is still not recognised as the first step in the three-cycle
model (ie as a bachelors degree). NUS would argue that this places
a prejudice on those students who have adopted this "degree"
in the understanding/ hope of future advancement/mobility within
Europe.
5.2 It is NUS' understanding that their
expectations—as things stand—would be a unceremonious
awakening at the application phase, with a prompt dismissal, as
his/her qualification is not recognized as a degree. As mentioned,
this has serious implications for progression/social mobility
within the European Higher Education Area (EHEA).
5.3 The thorny issue of foundation degrees
has been re-invigorated with recent proposals contained in the
Further Education and Training Bill (2006) to enable the
Privy Council to grant powers to further education colleges to
award foundation degrees. NUS believes that foundation degrees
are an important part of the Government's strategy to widen access
and promote progression; and that they are respected by both students
and employers alike.
5.4 NUS believes that the development of
foundation degrees has been a success—in a very short amount
of time—but more thought and debate needs to go into how
these degrees should be recognised at the EHEA level; so that
some consensus can be reached; and students are "in the know".
NUS makes this point with no intention whatsoever of under-mining
the qualification or jeopardizing its future success. Foundation
degrees suit the needs of some students, in their bid to fulfil
their potential; but these same students, surely, have a right
to the right information and an understanding as to where their
qualifications sit within the Bologna framework. Ensuring Bologna
recognition for Foundation Degrees should be a priority at the
London summit. Discussions at a European level must not jeopardize
the development and success of Foundation Degree programmes.
5.5 NUS has similar concerns about the "Fast
Track" two-year honours degrees programme. The Bologna Process
states that the first cycle (Bachelor level) should last a minimum
of three years. We share the concerns of other HE sector bodies
that it is not clear that European partners will be prepared to
recognize two-year bachelors within the Bologna framework. This
may well hinder graduate mobility within Europe and hamper employment
in the European labour market. It is deeply unacceptable that
this has not been communicated to students currently pursuing
those courses.
5.6 NUS firmly believes that these issues
should not be raised at a European level (and certainly not at
the London Ministerial Summit) until sufficient evidence is gathered
on national acceptance and recognition of these programmes, student
uptake, employability and progression to postgraduate study. While
NUS believes there is potential merit in two-year honours degree
programmes, we are concerned that the pilot has been developed
without due reference to the Bologna Process and seek clarification
from the Department for Education and Skills about the review
process.
5.7 NUS believes that Bologna compliance
must, in future, be a litmus test in the development of new Higher
Education qualifications.
6. Masters
6.1 NUS recognises the value of the range
and diversity of masters qualifications (eg some are one year,
others are two; and some are attached to four year programmes).
These meet the needs of a diverse student population. However,
NUS believes that a serious debate is needed on how some of these
could—legitimately—be incorporated into a European
qualification framework; and recognised by all.
7. Degree classification and transcripts
7.1 NUS continues to be strongly engaged
in the Measuring and Recording Student Achievement Steering Group
(Burgess) discussions around degree classification and transcripts;
and await the group's formal response to their second consultation
due in early 2007. NUS is a member of the Burgess Scoping
Group; and is fully engaged with that debate.
7.2 NUS strongly believes that the current
classification system is unfit for purpose; and that a new system
is needed. NUS recognises that this is a major challenge to higher
education institutions (HEIs) and that consensus within the sector
is crucial in achieving successful change.
7.3 NUS also recognises that a gradual approach
to reform may be necessary to engage HEIs in this change; and
that it will be the brave institutions that accept the need for
change and implement change.
7.4 Students' unions and students have expressed
some concerns at the proposals put in the group's second consultation,
namely:
— That they fail to capture the students'
"real" development and achievements in the three years
(or more) of study; and
— that institutions—and employers—will
gain a skewed understanding of what the student has actually achieved
(in terms of experience, skills and knowledge) with the emphasis
on the formally assessed academic work. This is compounded by
the lack of meaningful employer engagement with the Burgess Review.
7.5 NUS' four core principles around degree
qualifications and transcripts are:
— Holistic information: NUS
has consistently maintained that to represent the interests of
students, their achievements and personal development—in
terms of skills, knowledge and experience, both formal and informal)—should
be captured, evidenced and formally recognised.
— Student development: NUS believes
that it is vital that the students' development, in terms of distance
traveled, is embedded in any national formal recognition template.
NUS remains convinced that one of the most important questions
to ask is: how far has the student traveled in terms of their
academic and personal development given their own particular circumstances?
— A national approach to recording
achievement: NUS remains opposed to any "piece-meal"
approach to recording achievement. A level of national direction
and control needs to be co-ordinated and monitored, if students'
interests are to be safeguarded.
— Employer engagement: NUS also
recognises that fundamental prejudices exist in recruitment processes,
especially amongst graduate recruiters. NUS believes this must
be acknowledged and tackled at the national level.
8. Diploma Supplement
8.1 NUS supports the Diploma Supplement.
By making it easier to compare qualifications gained in higher
education systems across Europe, the Diploma Supplement offers
enormous potential for facilitating recognition of UK qualifications
and, it is hoped, lead to greater transparency and mobility.
8.2 NUS is concerned that any recommendations
from the Burgess Steering Group must incorporate the Diploma Supplement
as an essential component of measuring and recording student achievement,
rather than an added extra. Institutions must also be consistent
in their use of the Diploma Supplement.
A CREDIT FRAMEWORK
9. A credit framework
9.1 NUS supports a national credit framework
that aligns with others in the European Higher Education Area
(EHEA). NUS believes that it is crucial that a coherent approach
to credit is adopted across the EHEA, to ensure success in the
mobility of students. It needs to be meaningful to European students,
transparent and easy-to-use. There must be a shared meaning of
credit at institutional, national and the EHEA level.
9.2 NUS is, however, aware of the current
tension in the European Credit Transfer System (ECTS) debate as
detailed on page 22 of the Final Report of the Burgess Group Proposals
for national arrangements for the use of academic credit in higher
education in England (December 2006): "Many believe that
the ECTS approach—which is designed with student mobility
in mind—has disadvantages compared to the UK approach."
9.3 NUS understands ECTS's intention as
a student-centred system based on a student's workload to achieve
the objectives of a programme of study. NUS also understands that
this includes work that is required to be completed—that
is, all planned learning activities—not just lectures and
seminars (ie direct contact)—but excursions, preparation
for exams, self-study as well.
9.4 NUS would also argue that the annual
workload may be significantly lower in England with the rejection
of the workload concept; and understand that highlighting the
"truth" may well not allow students to work as much
as they currently do to finance their high study costs.
10. Lifelong learning
10.1 NUS believes that it is crucial that
any new Bologna developments in this phase or beyond recognise
and build on the range of life long learning programmes and modes
of study which have been built, and respects the value of mobility
and international recognition.
MOBILITY
11. Opportunities to enhance the mobility
of students from the UK
11.1 UK student mobility in the EU is affected
by many factors, not least the lack of language skills amongst
UK students (only about a third of British citizens speak a second
language) but the rules governing student finance do not make
this any easier. NUS would like to concentrate on the opportunities
to adjust student finance rules to encourage students from the
UK to study elsewhere in the EU.
12. Funding for undergraduates
12.1 Horizontal mobility, where the student
spends part of their studies in another country but the main programme
is provided in their home country, is relatively well catered
for at undergraduate level, and several EU funded schemes such
as Erasmus exist to enable students to spend a term, semester
or full year abroad, and the student support scheme offers slightly
higher loans to those studying overseas for at least eight weeks
as part of their course.
12.2 Nevertheless, NUS believes awareness
of the schemes is limited, and more could be done to raise their
profile with both current and prospective students.
12.3 However, whilst most grant and loan
funding can follow the student to the host country, for some students
there are several elements of funding which will not, most notably
childcare grants. Whilst most full-time students cannot claim
means-tested social security benefits, disabled students and those
with children can—but these too cannot be paid during abroad,
and so these students' mobility is doubly restricted.
12.4 Vertical mobility, where a student
completes an entire course in another European country is not
supported directly through the student finance system, as living
costs support cannot be paid unless the course is based at a UK
institution. This goes against the intention of the Bologna Process
and NUS Believes that this situation must be reviewed and meaningful
change introduced at the earliest possibly opportunity.
12.5 Some EU nations such as Ireland do
offer maintenance funding for study elsewhere in the EU and it
would not be administratively burdensome for the UK to do the
same. see for example www.education.ie/servlet/blobservlet/student_financial_support.pdf?language=EN
12.6 An alternative solution advocated by
ESIB, the National Unions of Students in Europe, is that the host
country should provide finance for fees and living costs to students
and this may be a potential avenue for The UK Government to consider
with other European partners in the Bologna Process.
12.7 NUS would be content for either policy
to be enacted, although we expect that it would be easier for
the UK Government to fund UK students in the EU in the short term.
In any case, we would also urge the government to look at making
up the social security funding that students entitled to it would
lose by studying elsewhere in the EU.
13. Funding for postgraduates
13.1 Funding for postgraduates is poor for
UK students in the UK, but for postgraduate students wishing to
study in the EU, funding is even more difficult to secure. NUS
urges the Government to work with the research councils to help
provide for EU study.
QUALITY
14. Quality
14.1 It is NUS' understanding that a pragmatic
approach to quality assurance is being followed by ENQA, which
registers national agencies, so that the Quality Assurance Agency
(QAA) maintains its vital role in assuring and enhancing quality.
15. Student engagement in institutional audit
15.1 In July 2005, HEFCE published a Review
of the Quality Assurance Framework: phase one outcomes (HEFCE
2005/35), which set out the Quality Assurance Framework Review
Group's (QAFRG's) conclusions and recommendations about institutional
audit. HEFCE, Universities UK and GuildHE endorsed those recommendations,
and in the light of them the QAA has revised its methodology for
institutional audit.
15.2 However, NUS believes recommendation
8 of the "Burslem Report" (2005) still remains inadequately
addressed to date: "Student participation in institutional
audit has been successful and valuable, and should continue to
be promoted and supported by all."
15.3 NUS continues to work closely with
the QAA in developing and providing training events and information
that enhance the skills, knowledge and experience of student union
officers and staff to engage around the quality agenda.
15.4 For more information on the "Quality
Takes Time" (QTT) branded work that NUS has developed and
promoted, please go to www.officeronline.co.uk/quality. This database
includes details of past NUS QTT events (including presentations
and handouts), as well as some examples of student written submissions,
access to QAA materials and much more.
15.5 It might be timely to repeat a few
other concerns currently in the system as it stands now, in terms
of institutional audit:
— Student selection for auditor
student discussions: QAA will be familiar with this issue
as NUS has continually maintained that the students' union should
have a role in ensuring that students are appropriately elected
to this important position. As QAA is aware, NUS has serious concerns
at the potential threat of institutions "cherry picking"
and "training up in message management" those students
selected. NUS believes, therefore, that students elected should
be selected by election by their peers to sit on auditor student
discussions. NUS also believes that course reps should be involved
in student discussions.
— Student confidentiality: NUS
believes that the students' voice in focus groups with auditors
should be signposted as strictly confidential. Institutional staff,
for example, should be absent from the student discussions. NUS
also believes that QAA pointers should be developed to aid auditors
in the appropriate form of feedback to ensure student confidentiality
eg the exclusion of institutional staff from the distribution
list, or minutes in the form of bullet pointed anonymous comments.
— Team composition: As an adjunct
to this NUS believes that there is great value—as evidenced
in Scotland via the SPARQS programme—for student representatives
to be part of audit teams (refer to www.sparqs.org.uk). NUS also
believes that institutions should recognise and reward the skills
developed by students in their involvement/engagement in internal
and external quality assurance processes (eg PdP development,
certificates and accreditation).
— International provision: Looking
to the future, NUS would value clearer information to students
on who "quality checks" higher education institutional
provision internationally, now and in the near future. NUS is
a member of QAFRG and welcomes the research and debate around
this issue in "Burslem phase two b".
15.6 NUS has committed itself firmly to
the quality agenda, but wishes to point out that this heightened
expectation on students/student union officers and staff has a
resource implication; and expectations should be realistic.
CONCLUSION
16. Conclusion
16.1 NUS supports and commends the level
of progress made around the Bologna Process at the EHEA level;
although we have misgivings at the level of governmental engagement
with stakeholders at the national level in terms of promoting
debate and awareness around key issues and concerns.
16.2 As mentioned in the introduction, the
London inter-ministerial conference in May 2007, which is the
fifth in the sequence which started with Bologna, will begin the
drive to conclude phase one of the Process.
16.3 NUS believes that early/timely development
of its successor needs to be addressed in London. What are the
next steps going to be? What are the priorities going to be? How
will the strategy ensure and evaluate effective stakeholder engagement
in the Process across nations? What evaluation tools can be used?
Are benchmarks valuable?
16.4 As we move forward, the UK HE Sector
will need to confront the challenges and opportunities presented
by our engagement with the Bologna Process more consistently and
proactively than has previously been the case.
16.5 NUS would be delighted to present oral
evidence to the Select Committee's inquiry alongside our partners
from ESIB's Bologna Process Committee and hope the Select Committee
will give positive consideration to this offer.
December 2006
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