Consultation on policy
30. Our final concern on the decision process is
over consultation. We note that following the Secretary of State's
letter of 7 September 2007, HEFCE published a consultation document,
Withdrawal of funding for equivalent or lower qualifications
(ELQs),[54] which
included details of exemptions and transitional arrangements.
In November, HEFCE held consultation events in Manchester, Birmingham
and London to discuss the proposals. In the "admin message"
issued in January 2008 following the consultation, the Board of
HEFCE noted that, while significant concern had been raised about
the ELQ policy, the majority of respondents to the consultation
agreed with HEFCE's proposals for implementation. It therefore
endorsed the proposals for implementing the ELQ policy as described
in the consultation document, subject to some changes to the exemptions
and transitional arrangements.[55]
31. In contrast, there has been no consultation at
all on the policy decision itself. Prior to its instruction to
HEFCE, the Government carried out no public consultation with
higher education institutions or with representatives of students,
employers or professional bodies. We asked the Minister why he
did not consult on the principles before embarking on the ELQ
changes. He replied:
Let me turn that round. Where was the consultation
that the interests of eight million graduates should be put ahead
of the 20 million people in the workforce who do not have degree-level
qualifications? In terms of the priorities that we set out within
the HEFCE grant letter, that has always been a matter for the
Government and ministers to give those steers. What we have done,
however, additionally to that is, rightly, consulted on the detailed
implementation.[56]
32. Commenting on the consultation, Professor Latchman
from Birkbeck College said:
We have not had consultation about what other possible
sources of this hundred million pounds there are, we have not
had clear evidence of student demand, and most importantly [
]
we have not had proper resourcing of the part time sector and
the students who want to study part time in terms of grants so
that we can achieve these hard to reach students.[57]
Many other concerns were raised in submissions to
this inquiry which went far beyond the relatively limited adjustments
the Government was prepared to make to the implementation arrangements.
The Government can, of course, announce its priorities for funding
without consultation but, where it does, it runs the risk of failing
to test its proposals with debate, of unforeseen consequences
and of alienating those who have to implement its changed priorities.
Consultation would have allowed the assumptions underpinning the
switch of funding and the full consequences of the policy to have
been examined and the adequacy of the transitional arrangements
and exemptions to have been tested.
The Committee accepts that the consultation on the implementation
was open and that as a result DIUS and HEFCE have made some changes
to the original package. We conclude, however, that DIUS should
have carried out public consultation about the principle, merits
and consequences of the policy rather than exclusively on the
implementation of the package.
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