Memorandum 10
Submission from the Royal Veterinary College,
University of London
EXECUTIVE SUMMARY
1. The Royal Veterinary College (RVC) strongly
believes that it is in the public interest that government develops
policies which are credible to all stakeholders in higher education.
The RVC believes that the removal of funding for equivalent and
lower level qualifications (ELQs) is clearly contrary to both
the lifelong learning and the widening participation agenda.
2. It is essential that certain categories
of students are exempt from the withdrawal of funding for ELQs.
This must include students studying for a first registerable veterinary
surgeon qualification.
ASSESSMENT OF
THE POLICY
3. The RVC believes the new policy on ELQs
will adversely affect students wishing to retrain and refresh
their knowledge and skills at different points in their lives.
It will have a damaging effect on individual students, institutions
and the economy as a whole. The ELQ pronouncement is analogous
to an 11-plus for widening participation candidates. It implies
that they can have "one go", and if they miss that opportunity,
the government has closed the door on any others. This seems to
be against natural justice and the whole widening participation
agenda.
EXEMPTION FOR
VETERINARY MEDICINE
4. In identifying students who should be
exempt from the withdrawal of funding for ELQs, HEFCE has identified
certain categories of student eligible for exemption in connection
with the Student Fees Regulations and the Student Support Regulations.
These include veterinary students. From the viewpoint of the RVC,
the exemption for all students on courses leading to a first registerable
veterinary surgeon qualification courses is essential. It is clearly
in the public interest for these students to be exempt, given
the continuing national requirement for a skilled veterinary profession
and the fact that the UK remains, despite the recent expansion
of undergraduate numbers, a net annual importer of qualified veterinary
surgeons (source: RCVS Annual Report 2007).
5. Any failure to grant an on-going exemption
to all students studying for first registerable qualifications
in veterinary surgery would seriously undermine progress that
has been made at the RVC, where graduate entry to our professional
veterinary degree, the Bachelor of Veterinary Medicine (BVetMed),
is currently approximately 35 students annually. This entry route
has been running successfully since 2005 and was introduced in
response to the Government's own "Gateways to the Profession"
initiative (which was welcomed by the College). It supports a
much needed diversification of entry routes into the veterinary
profession and provides a further opportunity for underprivileged
groups who develop aspirations for professional education after
a first degree.
6. If the College no longer received HEFCE
funding in respect of graduate entry students, it would be unable
to hold the annual fee level for this course in line with its
other UG level courses, as it has chosen to do in order to support
the diversification agenda. Students would be required to pay
an annual tuition fee of £15,000-£20,000. Only those
from very wealthy backgrounds would be able to consider graduate
entry because of the resulting debt, accumulated on top of first
degree debt. Of our current first year graduate entry cohort,
not one has said that they could have enrolled on the course had
they been required to pay full cost fees. Most found it impossible
to acquire career development loans to cover the full cost fees
cost of a 4 year graduate entry course. Therefore the introduction
of such a policy would be likely to cause a fall in demand that
could force the College to abandon the graduate programme. This
would be a significant blow to efforts to broaden entry routes
into the profession.
7. Furthermore graduate entry represents
a relatively economical means of meeting manpower requirements
in the veterinary profession, since the programme lasts only four
years instead of five. It also contributes in a limited way to
the Government's priority of Widening Participation, through providing
an opportunity to students unable to achieve the very high A-level
entry grades required at the first attempt because of socio-economic
or educational disadvantages. Graduate entry enables these students
to demonstrate that they have the potential to succeed at veterinary
school.
8. The RVC wishes HEFCE to ensure that all
first registerable qualifications in veterinary surgery will be
exempted on an continuing basis. For example, a consistent approach
must be taken to courses where students intercalate and to those
where they do not.
9. The College also wishes HEFCE to ensure
that veterinary medicine is treated on an equivalent basis to
medicine and dentistry. The professional veterinary degree is
in almost all respects similar to degrees in medicine and dentistry,
and produces a professional workforce of vital importance to society
and the economy. The veterinary workforce also has a vital public
health function, being instrumental in protecting the food chain
and working to inhibit the spread of zoonotic diseases, such as
avian influenza. If medicine and dentistry are to be treated as
exceptions, then so must veterinary surgery.
10. Finally, the College would also argue
that the professional veterinary degree is at a level higher than
that of a standard Bachelor's degree. It was recognised as effectively
being at Master's level in the QAA Benchmarking statement for
Veterinary Science. Thus treating it as an ELQ for students holding
a first degree would be inappropriate.
EXEMPTION FOR
FOUNDATION DEGREES
11. The RVC recognises the importance of
continuing to provide public funding for foundation degrees in
relation to promoting access and developing vocational skills.
The RVC's FdSc Veterinary Nursing produces skilled and highly
trained graduates to meet the career demands of a profession in
which the demand for qualified staff significantly and consistently
outstrips supply. This foundation degree regularly attracts applicants
with higher qualifications who wish to retrain and enter the profession
via a fast track route. For example, the current first year cohort
includes a student with a degree in pharmacology.
12. The College notes, however, that there
may be many other higher level training courses (indeed in line
with government initiatives) that would not be covered if this
exemption was applied only to foundation degrees. Therefore supporting
vocational training should not necessarily be linked to a particular
type of award.
EXEMPTION FOR
EMPLOYER CO
-FUNDED PLACES
13. The RVC supports HEFCE's position on
the delivery and funding of co-funded numbers. However, the College
believes this will be a very small element at the moment.
14. The College has recently received accreditation
from the Royal College of Veterinary Surgeons (RCVS) to provide
the RCVS Modular Certificate, a programme of postgraduate CPD
modules that can be taken individually or to achieve the full
Certificate qualification. Although it is difficult to develop
co-funded numbers in a profession where small business and professional
practitioners dominate, it is possible that in the future a co-funded
approach could be taken towards the delivery and development of
modules on this or similar programmes.
EXEMPTION—STRATEGICALLY
IMPORTANT AND
VULNERABLE SUBJECTS
(SIVS)
15. Given the obvious national importance
of SIVS subjects, the College believes that they should be exempt.
An exemption should be introduced rather than an allocation.
16. In addition to SIVS, HEFCE should identify
qualifications relating to shortage occupations, as defined under
the Home Office "Work Permits (UK) Shortage Occupations"
list. This includes veterinary surgeons.
EFFECT ON
PART-TIME
STUDY
17. The area of part-time study will be
disproportionately affected by the removal of ELQ funding. HEFCE's
proposed bridging arrangement to support part-time study is not
a solution to the long term effect of making it, and especially
post graduate vocational training, very expensive to the student.
The College will find this damaging in respect of its part-time
postgraduate courses which enable students to build up a particular
specialism and thus provide added benefits to their employers
and the economy. Within a profession such as veterinary medicine
there is an on-going and increasing need for such post-graduate
specialisation, for example in the area of veterinary epidemiology
and public health.
SAFETY-NETTING
OF INSTITUTIONAL
FUNDING
18. The RVC recognises that it is essential
to safety-net institutional funding to avoid large perturbations
in government grant. However, such safety-netting will take no
account of an institution's loss of future earnings or the fact
that the implementation of the ELQ policy will seriously undermine
some institutional strategic plans for course portfolio development.
In addition the implementation of the ELQ policy will result in
significant additional administration costs to institutions.
IMPACT ON
DIFFERENT GROUPS
OF STUDENTS
19. The RVC notes that the policy may have
a particular effect on people with disabilities who may have to
re-train because of this. For example, a vet who suffers a disability
may wish to re-train as a statistician, but would be caught out
by the ELQ rule
20. In order to adequately assess the possible
differential impact of this policy, HEFCE should analyse the differential
enrolments on vocational courses especially.
January 2008
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