Memorandum submitted by The UK Inter-Professional
Group (UKIPG)
EXECUTIVE SUMMARY
The UKIPG is a group of 30 professional and
representative bodies and statutory regulatory bodies from a wide
range of professions. The UK professions work in partnership with
the HE community. Whilst generally interested in HE, their key
role is to ensure that practitioners have the necessary knowledge,
competence and values to practice safely in the UK.
All HE students must be properly educated, not
just narrowly in the science of their discipline. HE is expected
to provide intellectual challenge, capacity for reflective learning,
and a scholarly and ethical foundation for future work. In addition,
professionally-related courses must be properly resourced, with
up-to-date equipment and professional role-model staff, to achieve
"day one competences" in new graduates. Some of this
work will be post-graduate and not all will be for school leavers.
Workforce development is equally important.
The sub-heading "University Funding"
is seen as a symptom of a subconscious problem; HE is much wider
than universities. Much is provided in the FE and work-based context
at sub graduate, undergraduate and post graduate levels. There
must be some rational comparability in approach (if the various
sets of funding are to remain separate) between that taken in
England by HEFCE and LSC, and that taken by those two English
bodies and the approaches taken by their counterparts in other
parts of the UK. More care is needed to balance the effect of
research and teaching funding to ensure that the teaching of undergraduates
does not become a "distraction" for academics from the
financially and personally more rewarding RAE work.
Current HE funding models are excessively focussed
on full-time undergraduate programmes for young people. Without
further absolute increases in funding, some reallocation is required
to promote entry to vocational higher education later in life,
perhaps through phased progression via "technician"
and "associate professional" work, and without discrimination
against part-time and distance students. Finally on funding, UK
HE must look to its attractiveness to potential UK "home
grown" academics of the future.
The "HE structure" needs to reflect
issues raised under "funding" relating to staged progression
through HE, rather than excessive focus on young first-time entrants.
Also the HE structure must be reviewed in the context of the overall
and complex education and training structure. A key role for the
Inquiry is to question the overlaps and tensions between the tradition
HE structures and those implicit in the roles of National Skills
Academies, Sector Skills Councils, those responsible for National
Occupational Standards, those applicable to different professional
areas (eg from the CMO/Foster reports on medical and healthcare
professions), Directive 2005/36EC, and now Leitch.
"Bologna" offers opportunities for
UKHE to show the comparative value of UK HE qualifications. It
needs to be progressed with more enthusiasm.
INTRODUCTION TO
THE UKIPG
1. The United Kingdom Inter-Professional
Group (UKIPG) has been in existence since 1977 and currently has
a membership of about 30 professional organisations, representative
and regulatory bodies from a wide range of professions. Its objectives
are:
— To promote recognition of the importance
and raise the profile of the liberal professions in society to
government, the media and consumer organisations;
— To consider proposals for legislation
or administrative action likely to affect the professions, to
identify matters of common concern and, where appropriate, make
joint representations and take actions;
— To act as a forum for exchange of
information on any topic likely to be of interest to a substantial
proportion of members; and
— To provide opportunities for members
of the Group to present the views of the professions at meetings
with individuals with influence and standing in a particular area
of activity of interest to the professions.
2. About 6 years ago, UKIPG published a
position statement on the educational role of professional bodies,
which set out some of the key principles behind professional regulators'
involvement in education and training. In all cases, the UKIPG
members, whether statutory regulators, professional bodies operating
under Royal Charters, or simply incorporated professional associations,
work within common codes of ethics and values, and generally with
"objects" which require them primarily to work for the
public benefit. They are concerned with the objective benefit
of individual citizens and the "UK PLC", and not primarily
with the benefit of their professional members or registrants,
although that may well also be a consequential outcome.
3. In this context, the UKIPG member bodies
have a role in:
— Providing careers information and
guidance for those considering professional careers.
— Formal accreditation of undergraduate
(and some post-graduate) programmes which are either the prescribed
qualifications for a statutory qualification to practice or the
recognised educational base for progression to a full professional
qualification.
— Specifying, accrediting, and sometimes
delivering, post-graduate level programmes for continuing professional
development or for specialist or advanced practice.
— Working with QAA and the HE community
on the academic infrastructure, such as programme specifications
and subject benchmark statements.
4. The Group comprises representatives from
each of the Professional and Statutory Bodies in membership, drawn
from both the elected / appointed members of governing bodies,
and from employed specialist staffs. The wider group is advised
by a standing committee of education specialists.
5. The Professional, representational and
regulatory bodies in UKIPG membership work in partnership with
the education sector. Because of this relationship, there is a
wide range of data, mostly held by individual member bodies and
relevant to their related academic disciplines and modes of professional
education and qualification. Many of the data are sourced from
UCAS and HESA, but much evidence is collected directly by formal
visits to HEIs and other providers. As the range is both wide
and discipline specific, it is best taken from evidence provided
by individual professional and statutory bodies. This response
from UKIPG will address wider policy issues affecting most UK
professions.
THE INQUIRIES'
AGENDA AND
QUESTIONS
6. The Inquiries address the future sustainability
of the higher education sector: purpose, funding and structures,
and the Bologna Process in the context of the European
Higher Education Area. In the primary area of interest of the
professional bodies, the European dimension needs also to be seen
in the context of Directive 2005/36EC on the Recognition of Professional
Qualifications, particularly as the final (and inevitably compromise)
version contained some nuances of "level" which do not
sit comfortably with UK HE generally.
7. The Professional, representational and
regulatory bodies in UKIPG membership work in partnership with
the education sector. Higher education provides essential educational
routes towards professional qualifications, while the professional
bodies represent their professional areas and set the standards
on which the educational programmes are based. FE provides valuable
opportunities which enable more diverse range of candidates to
progress towards professional qualifications. It is therefore
essential that an Inquiry of this nature should take a holistic
view of post-compulsory education sector in the UK.
8. Within the UK context, HE cannot be considered
in isolation from the FE and work-based learning sector, and HE
cannot be considered only from the perspective of the HEFCE-funded
"English" perspective. The environment is becoming increasing
convoluted, on the one hand with the "chinese wall"
between HE and LSC funded provision in England (eg in the context
of apprentice frameworks requiring significant elements of HE
as their "Technical Certificates"), and the almost parallel
infrastructure of the Sector Skills Development Agency, Sector
Skills Councils and now National Skills Academies, which themselves
sometimes cause overlap and tensions with the education, training
and competence activity required to be undertaken by professional
and statutory bodies. There is an equal need for clarity between
the emerging work by QCA on the Qualifications and Credit Framework
and the proposed European Qualifications Framework on the one
hand, and the Framework for Higher Education Qualifications and
European Credit Transfer System in HE.
9. The educational map of the UK has become
increasingly complex since devolution, with varied awards, qualifications
and credit frameworks, and funding policies. It is not clear from
the terms of reference whether this Inquiry is addressing higher
education only in England or more widely. The review would be
of greatest value if it adopted the broadest possible perspective
throughout the UK.
10. The UKIPG believes that it is important
that both Inquiries take cognisance of these issues, which do
not appear explicitly in the current terms of reference.
THE SPECIFIC
TERMS OF
REFERENCE
A. The Role of Universities over the next
5-10 years
11. This section asks what students want
from universities, what employers want from graduates, and what
should the Government, and society more generally want from HE.
There is no single comprehensive answer from the professions,
because the entry modes are so different. All categories expect
the "HE experience" to be truly educational; to lead
people out from where there are and open up new horizons though
acquired knowledge, understanding, skill and attitudes. Thus,
whether a HE course is strictly vocational from the beginning
(eg medicine), one that has strong vocational roots but is taken
by many as a general education (eg many of the science, engineering,
technology and language courses), or one which is essentially
study in depth of a subject of interest at the time, it must:
a. Engage students in independent thought,
research and argument;
b. Develop a sound understanding of the essential
knowledge base of the relevant disciplines;
c. Motivate students to challenge, learn,
and learn how to learn; and
d. Develop a maturity of purpose, a scholarly
approach, and an ethical foundation for future life and work.
12. It is UKIPG's view that this is what
students, employers and the wider community really require of
higher education. When all of the currently fashionable role or
job-related abilities have become obsolescent, it is the graduates'
true education that will enable them to adapt to new circumstances,
environments and technologies. This must be the essential outcome
of undergraduate HE.
13. In the context of sustainability of
HE, the views of "students" must be further divided:
— Prospective students, whether still
at school, in FE, at work, or later in life, want realistic and
informed guidance on what to expect and what are the likely consequences
of their choices. Some courses, which sound interesting and relevant
and seem to keep options open, may be too general as a foundation
for any one discipline. Some location choices may be financially
preferable, but will limit the opportunities for professional
developmental experience. Much better guidance needs to be available,
especially that which is not founded on the experiences of a previous
generation or influenced by the potential benefit to the guidance
provider. The wrong choice of HE can be financially and motivationally
devastating.
— Current students, whether on a vocationally-specific
or more general course, do want value for money, not in a narrow
consumerist sense but in true opportunities for learning in ways
which match their learning styles and circumstances. Whilst a
minority of very able and emotionally tough students could always
cope with a "take it or leave it" approach, the wider
cross-section attracted into HE by the current targets may need
more help and differentiated provision. The worst case is to attract
more students into less well provided programmes, and for them
to achieve mediocre or poor outcomes. Wider access does not simply
mean economies of scale; quite the opposite.
— Immediate past students need access
to structured graduate training and development programmes, which
assume that new graduates will be inexperienced. The current recruitment
attitude, and not just financial imperatives, tends to drive students
to gain experience of any kind of work for a CV, sometimes to
the detriment of real and relevant study and placement. Even HE
programmes allegedly designed specifically to meet employment
needs, such as Foundation Degrees, are often found to be weak
at providing realistic work-based learning for lack of sufficient
employer engagement.
14. Some specific programmes must seek to
achieve a range of competence wider than the general outcomes
expected of all HE, particularly those programmes which lead to
a qualification to practice. This will be over and above, and
not instead of, the general educational outcomes set out in paragraph
11. Such programmes must be additionally resourced in terms of
teaching and learning contact time (usually a longer course eg
a 4 or 5-year rather than 3-year degree), using industrial or
professional standard equipment, and with staff who are themselves
also competent practitioners and so able to be professional role
models in terms of competence and ethical conduct.
15. The added cost, complexity and specificity
of outcomes of professional courses may, in many cases, make it
appropriate for them to be delivered as post-graduate enhancements
to relevant first degrees. Access to this post-graduate education
must be considered as important as initial access, and funded
and supported appropriately.
16. As with everything else in the modern
world, higher education is subject to global competition. Higher
education is meant to be elite and challenging; otherwise it will
not survive in a globally competitive environment. On the other
hand it has to be flexible and adaptable, not assuming that one
model will suit all purposes. Access, participation and engagement
with society will be enhanced through innovative provision, which
enables people to progress in stages through the various levels
on the FHEQ at different stages of life, and not simply by opening
the gates to more full-time 19-year-olds, irrespective of preparedness
or motivation.
17. The true current HE target, across the
range of HE levels from Higher National to Doctorates by the age
of 30, is quite different from forcing ever more young students
into pseudo-academic courses immediately on leaving school, thereby
delaying the experience of life and work sought after by employers.
18. The time has now come for the HE target
to be reviewed in the light of experience and taking into account
the opportunities provided by further education. Updated targets
could then be established, with appropriate funding, which provided
more realistic learning opportunities for the young people of
the UK after they have completed compulsory secondary education.
B. University Funding
19. The Inquiry is into "higher education"
but this sub-heading is focussed, perhaps subconsciously, on universities;
there are other "players" in HE, particularly among
the FE Colleges, professional bodies, and some private providers.
In his report about a decade ago, Dearing was conscious of a different
way of funding HE from FE and other work-based routes. In terms
of what government funds to what level, there needs to be some
logical connection in the approach to LSC and HEFCE funding of
teaching and learning, and of student support, (in England, and
the equivalents elsewhere). There needs to be some consistency
of approach to the appropriate shares of funding between the state
(for the common good), the individuals (for their own lifelong
personal and financial benefit), and employers for the direct
subsidy provided by educated and skilled people entering their
businesses. The Inquiry should challenge HE funding from this
overall perspective.
20. The second area for comparative inquiry
should be the balance between funding for teaching and for research.
The current process causes tensions in both directions. On the
one hand, the "gearing" to departmental and institution
funding provided by top RAE rankings can make the quality of the
undergraduate learning experience be a much lower priority for
academics than the research activity needed to achieve high RAE
ratings. Ordinary students almost become a "drain on the
system". Top rated research universities, by virtue of their
good name and excellent "market value", may well be
best placed to gain non-public funding support for their work
(whether from alumni or industry or others). It may be tempting
to use public funding to "back the winners", but—if
others will do this—it may be more useful in the long term
for public funding to "back the outsiders", enabling
the research base to increase and flourish in non-traditional
areas, particularly those relating to applications and practice
compared with pure science. Perhaps it is in this area of practice-related
research that the professions could contribute most effectively
to assessment for funding of research activity.
21. Currently central funding for teaching
and student support is excessively focussed on the first undergraduate
experience, whether or not this happens to be the most useful.
As argued earlier, those seeking to enter specific professionally-relevant
HE, either at post-graduate level or again at undergraduate level,
now to take a professionally qualifying course, find it difficult
to do so. There must be a balance to be achieved by an "equity"
argument, which simply provides three years HE for all who wish
to enter, and a more focussed approach which transfers some of
that resource to fund those who, later in life, wish to qualify
for a socially and economically useful profession.
22. Funding for part-time students should
be part of the equation, enabling a more diverse population to
progress towards degree level study, and subsequent professional
development, without incurring the debts that appear to continue
to discourage wider participation. Perhaps it would be worth considering
whether repayments of student loans, of deferred payment of fees,
could be offset by payments in kind, such as through employment
in socially valuable but less economically rewarding work.
23. Finally in this section, the funding
regime must, without being xenophobic or racist, enable and encourage
"home grown" talent to progress through the highest
levels of HE and post-doctoral work, to produce the next generation
of world-class researchers and academics. A system which is so
heavily reliant on non-UK residents, as is the case currently
in many academic disciplines, is unbalanced.
C. The Structure of the HE Sector
24. Some of the questions raised under this
heading have already been addressed in the previous section on
"funding". It is probably doubtful that all aspects
of the current HE sector will be sustainable in the future. The
introduction of higher and repayable fees is a market force which
will increasingly come into play, alongside the other "market
force" of an increasing proportion of "graduate entrants"
seeking work. There is already the paradox that employers frequently
bemoan the dearth of quality UK graduates (and increasingly rely
upon international recruitment) whilst new graduates bemoan the
dearth of jobs, the limited range of graduate training schemes,
and the difficulty of getting past the "cannot do anything
for the first time" attitude of many recruiters seeking a
wealth of experience from the inevitably inexperienced. It is
probably too soon for statistically significant data to emerge
from UCAS and HESA, but anecdotal evidence is beginning to emerge,
both in UK and elsewhere, to show that "long and hard"
courses are attracting fewer applicants.
25. With demographic trends of fewer 18-year-olds
and towards the later assumption of family responsibilities, there
could well be a trend towards a more stepped approach to higher
level education and work. This approach could also more appropriately
assist the "opportunity and diversity agenda", as proportionally
more people might go into "technician" or "associate
professional" level work initially, and wish to progress
to full professional level through "bite-sized" steps.
This could increase the importance of "HE in FE" and
of flexible, part-time and distance learning, as well as of work-based
and professional providers. All of higher education need not be
structured within universities.
26. It seems strange that the Committee's
Terms of Reference make no mention of the impact of other education
and training strategies and structures, such as the role of Sector
Skills Councils and their work on Sector Qualifications Strategies,
National Skills Academies (whose recently launched prospectuses
equally target HE), "Train to Gain", and the role of
lower levels of HE (eg Higher Nationals and Foundation Degrees)
as Technical Certificates in Apprenticeship Frameworks.
27. There is an urgent need for clarity
in the respective roles of professional regulators (particularly
those of statutory origin), of those working on National Occupations
Standards under the auspices of SSDA, of National Skills Academies,
and of those engaged in the Academic Infrastructure work of QAA
(eg on Subject Benchmark Statements and Programme Specifications).
In many professional areas, confusion reigns—this Inquiry
offers the opportunity to challenge government about some real
"joined-up thinking". In medicine and healthcare, the
educational recommendations of the Chief Medical Officers' Report
and the Department of Health's "Foster Report" need
to be included in the "HE structure" debate.
28. Any review of the structure of HE must
take into account the tension between the freedom of the universities
to do what they do best, and the longer term needs of the UK.
Market forces alone must not be the sole arbiter of the "safety"
within the structure of what HEFCE has identified as Strategically
Important and Vulnerable Subjects. Moreover, the inquiry must
not limit itself to "within HE". There must be at least
a review of whether the National Curriculum (as currently applied
and sometimes "disapplied") is starving HE of potential
students in the basic sciences and foreign languages.
29. Finally, the structure must be influenced
by the outcome of the parallel inquiry into the implications of
the Bologna Process for UK HE. However, that inquiry must also
see UK and European Higher Educational Area education both in
the broader context of the global HE market, and in the "regulated
by Directive" environment of professional qualifications
within the EU.
INQUIRY INTO
THE IMPLICATION
FOR UK HE OF
THE BOLOGNA
PROCESS
30. The UKIPG-represented professions are
aware of the Bologna Process and are generally supportive of the
ten "action lines". Historically, there has been difficulty
in resolving practical and cultural differences arising from different
traditions both of HE and of professional regulation across Europe.
However, in professionally-related HE, many of these issues have
been overcome, either through the voluntary work of pan-European
professional associations, or by the detailed work leading to
the adoption of Directive 2005/36EC and its predecessors.
31. The Bologna arrangement of originally
two cycles (now three to include doctorate level) has generally
served UK HE (and its users) well. However, all accept that there
are exceptions. There are occasional misconceptions that it would
be beneficial for "Bologna purposes" to divide artificially
the long vocational HE for medicine, dentistry and veterinary
medicine into two parts; they are more "fit for purpose"
in their currently integrated mode. Some rationalisation of titles
may aid comparability for those few wishing to use these very
special courses other than for their vocational intention, but
that is a trivial issue. Recognition for professional purposes
is covered by the Directive.
32. There have been some other anomalies,
with reference to the first cycle and second cycle "Bologna"
model, of a number of UK professional HE courses. These include:
— The 4-year "undergraduate masters"
courses, which are the extended and enhanced undergraduate course
intended for professional practitioners in the disciplines (eg
MChem, MEng, MPharm etc);
— The "one calendar year masters"
(longer than one academic year but less than two), which are the
means of converting from a generally relevant degree to a professional
one in some disciplines;
— The five-year two-phase degree in
architecture, with an intercalated period of professional learning
in a practice;
— The 5-year "bachelor" degrees
in veterinary medicine and dentistry, already mentioned;
— The recognition that some professionally
useful UK HE, at Intermediate level in the FHEQ (such as HND,
HE Dip and FD), does not easily fit into the Bologna "cycle
system"; and
— The need to see that UK HEI administration
can formally record the professional status of accredited or approved
professional HE on Diplomas Supplements. It often defaults because
if internal communication difficulties between Schools and Registries.
33. The Bologna Process does offer, for
the first time, the opportunity of comparability of HE qualifications
across all the participating countries, providing clarity of qualifications
to candidates, professions, employers as well as government within
a three cycle system. Combined with consistent credit-rating processes,
this should significantly strengthen the opportunities for EU
citizens to work on an equal basis throughout the enlarged Europe.
34. It is, however, regrettable that relatively
little progress appears to have been made in the UK towards the
Bologna ideal since 1999. Indeed, it appears that in some cases,
government policy has led in the opposite direction, making the
attainment of the Bologna Process more difficult. The anomalies
mentioned in section 22 above were initially addressed by the
QAA but have not been resolved. The Inquiry should assess the
action that need to be taken to ensure that the UK can become
a full partner in the Bologna Process by the target date of 2009,
and ensure that the UK can benefit from the reforms that this
will entail. This can be done without prejudice to the special
position of professional qualifying programmes regulated by Directive
2005/36EC.
December 2006
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