Memorandum 111
Submission from the University of Bolton
WITHDRAWAL OF FUNDING FOR EQUIVALENT OR LOWER
QUALIFICATIONS (ELQs)
BACKGROUND OF
THE UNIVERSITY
OF BOLTON
1. The University of Bolton is one of 13
universities located in the North West of England. It was created
in 2005 when Bolton Institute of Higher Education was granted
University title by the Privy Council.
2. The University has more than 9,000 higher
education students, of which nearly half study part-time. More
than three-quarters of the students are mature on entry and 80%
of its undergraduates live within 50 miles of the University.
The University's student population is one of the most socially
inclusive of any higher education institution in the country with
42% of young undergraduates coming from the lowest socio-economic
groups and 31% from low participation neighbourhoods.
3. The University is committed to part-time
and work-based learning, and to developing provision in partnership
with other providers, public and private sector employers to meet
the higher level knowledge skills needs of Bolton and the wider
North West Region. The University's provision includes teacher
training for the lifelong learning sector; health and social care;
cultural and creative studies; manufacturing, engineering and
technical textiles; and building and construction. In 2006 the
University formulated a new Strategic Plan to create "The
Professional University", which has at its heart the development
of relevant continuing professional development (CPD) programmes
across the full range of its study areas. The University fears
that many of the students seeking CPD programmes, particularly
in the health and lifelong learning sectors, will already have
a qualification at an equivalent or higher level and will not
be eligible for HEFCE funding.
4. The University is actively engaged in
a number of sector skills councils (SSCs) relevant to its provision
and it expects to make a significant contribution to meeting the
training needs of the BBC when it relocates to Salford Quays;
in this context the University anticipates that many potential
students will already have a degree.
5. The analysis of ELQ students undertaken
by the Higher Education Funding Council for England (HEFCE) identified
that in 2005-6 Bolton had 553 full time equivalent (FTE) ELQ students
(before exemptions are applied), which represents 12% of the University's
HEFCE funded student FTE. Just over £1 million of the University's
funding to support teaching is associated with ELQ students. This
represents 5.8% of the University's mainstream funding. With the
exception of the Open University, this is the highest proportion
of any North West University.
ELQ POLICY AND
THE GOVERNMENT'S
SKILLS AGENDA
6. The Government is committed to improving
the skills of the population and has set a skills target of 40%
of the workforce having HE level qualifications by 2020. The Leitch
Review noted that 70% of the 2020 working age population have
already left compulsory education and therefore the focus needs
to be on adults developing economically valuable skills. The Government
justifies the withdrawal of funding for ELQ students by arguing
that the £100 million saved by this change of policy will
be redirected to first time entrants to HE. The Government is
concentrating on increasing the qualification rate at the expense
of ensuring that higher level skills are kept up to date and relevant
to the needs of industry by providing support for lifelong learning
and continuing professional development. This change of policy
is likely to impact significantly on those seeking to acquire
leadership and management training eg an MBA, to complement their
subject specific expertise. The Leitch Review identified management
and leadership skills as a key priority for improving higher level
skills and this is locally reinforced within the NWDA's current
Regional Economic Strategy. Rather than supporting industry to
be competitive this change of policy may have the opposite effect.
7. HEFCE's proposal to deal with the concern
about higher level skills is to allow institutions to bid for
co-funded "employer engagement" Additional Student Numbers
(ASNs). We believe that the exemption of co-funded ASNs by itself
will not provide sufficient protection for HE providers wishing
to develop courses to meet employers' needs for high level skills
training and retraining, particularly in the case of SMEs. There
is a significant risk that employers will not respond to the employment
engagement agenda, which requires them to make a greater contribution
to the cost of training, within the timescales anticipated by
HEFCE. The result may be an overall reduction in investment in
the higher level skills needed to ensure international competitiveness.
THE SCOPE
OF THE
PROPOSED EXEMPTIONS
8. While University supports HEFCE's proposal
to exempt certain subjects and qualifications from the effect
of the changes, we believe there is a case for the exemptions
to be extended. For example, the proposed exemption for Foundation
degrees should be extended to HNC/Ds. In some employment sectors,
these vocational qualifications are well-regarded by employers
as providing high level technical and professional skills closely
matched to their workforce needs, eg the Construction industry.
The University is currently developing an HNC/D programme in Community
Performance with a local Further Education College, in preference
to a Foundation degree, because HNC/Ds are better understood in
this sector. If HNC/Ds are not exempted there is a strong likelihood
that institutions will convert their current HNC/D provision to
Foundation degrees, whether or not such a move would have employer
and industry support.
9. The proposed protection for Strategically
Important and Vulnerable Subjects (SIVS) is also welcome but it
is unclear how the use of a targetted allocation based on 2005-6
student numbers will incentivise universities to increase recruitment
to these programmes.
10. There is a lack of clarity about whether
some qualifications and subjects will be covered by exemption.
These include:
— the new suite of qualifications for
the Learning and Skills sector endorsed by SVUK, vital to developing
teachers of vocational subjects such as engineering, construction,
health, childcare and business;
— in-service teaching qualifications
for the HE sector;
— continuing professional development
programmes particularly in Nursing, Health and Teacher Education
and Management
11. Subjects which are important for the
economic performance are not included within the SIVS definition.
For example, building, construction and IT are not classified
as SIVS.
THE IMPACT
OF THE
ELQ POLICY ON
SPECIFIC GROUPS
12. The University believes that the change
of policy will have an adverse impact on certain groups. Examples
include women returning to work after a career break to care for
children or other dependents and older workers in declining industries
subject to redundancy who need to update their skills or retrain
to obtain employment. These groups will not be protected by the
exemptions currently proposed for employer engagement co-funded
additional student numbers. Therefore, the University would support
suggestion made by Birkbeck that individuals studying for an ELQ
after five years should be exempted.
THE MODELLING
OF THE
IMPACT OF
THE GOVERNMENT'S
ELQ POLICY ON
INSTITUTIONS UNDERTAKEN
BY HEFCE?
13. HEFCE proposes to use 2005-6 HESA data
concerning students' qualifications on entry to determine changes
in funding for 2008-9.
14. The University has a number of concerns
about HEFCE's model:
— HEFCE are using HESA data collected
for one purpose for a different purpose. The highest level of
previous qualification for direct HE entrants (ie non UCAS entrants)
is based on students' self reporting and has not been subjected
to the same level of scrutiny at enrolment as other items of data
eg residential category, which determines fundability. Similarly,
administrative staff are required to code qualifications according
to HESA categories: some categories are not clearly defined eg
professional qualifications. There is considerable scope for misreporting
and inaccuracies in this process yet HEFCE has stated that it
will not permit institutions to revisit this data to assure its
quality.
— There are concerns about the categorisation
of certain qualifications by HESA which make it difficult to accurately
identify genuine ELQ students. For example, the description of
postgraduate qualifications does not differentiate between postgraduate
certificate and postgraduate diploma qualifications with the result
that a student who completes a PG Certificate and then returns
to continue to PG Diploma will be regarded as an ELQ student and
therefore will not be fundable. Students who undertake a Graduate
conversion course (eg in Psychology) may also find that their
subsequent postgraduate course (MSc in Psychology) may be regarded
as an ELQ and therefore not fundable. Another example relates
to students whose previous qualifications are categorised as "Unknown".
This includes OU credits, credits from other UK HEIs and professional
qualifications. HEFCE has assumed that a certain proportion of
these students will be ELQs (based on the proportion of ELQs generally
at the HEI) and has estimated ELQs on this basis. Institutions,
such a Bolton, who admit a high proportion of mature students
with non-standard entry qualifications are likely to be adversely
affected by this approach.
— The "Unknown Level" category
used in the model includes some qualifications where it can be
assumed the level is known as not being equivalent to undergraduate
level. For example, "other non advanced qualification"
is regarded as "Unknown level" when a reasonable interpretation
would be that it is below HE level and therefore should be classed
as "other". Similarly, "mature student admitted
on basis of previous experience (without formal APEL/APL) and/or
institutions own entrance examinations" is classed as "Unknown
level". HEFCE is assuming that a certain proportion of "Unknown
level" students are ELQs. HEFCE should revisit the categorisation
that it has used
— The data used to run the model relates
to the 2005-6 academic year. Although this was the most recent
data available when HECFE was developing the model, more up to
date (2006-7) data is now available.
HEFCE'S PROPOSAL
TO SUPPLEMENT
THE PART-TIME
TARGETED ALLOCATION
TO PROTECT
PART-TIME
PROVISION
15. The University has a long tradition
of providing flexible part-time provision which meets the needs
of employers in Bolton and the wider NW region. The University
welcomes the proposed supplement but notes that it will only be
available for two years—2009-10 and 2010-11—after
which it will be reviewed. This short timescale and the element
of uncertainty about long term funding arrangements for part-time
provision does little to encourage institutions to develop and
grow a sustainable part-time course portfolio.
THE IMPACT
OF THE
ELQ POLICY ON
THE OBJECTIVE
OF REDUCING
THE REGULATORY
BURDEN ON
INSTITUTIONS?
16. In order to assess whether a student
is eligible for mainstream funding institutions will have to collect
much more precise data about a student's previous qualifications
than has hitherto been the case. This information would not necessarily
be declared routinely during the application/enrolment process
as the previous highest qualification may not be needed as an
entry qualification to the ELQ course. Institutions will be reliant
on students accurately declaring their previous qualifications
as there is no central mechanism for checking whether a student
has already gained an equivalent or higher level qualification.
If institutions decide to charge higher fees to non-exempt ELQ
students, then there will be a financial disincentive to disclosing
a previous qualification at the same or higher level. It appears
that institutions will be required to interpret and apply complex
rules relating to exemptions in order to establish whether an
individual is either a fundable or non-fundable ELQ student. This
is likely to require high level decision making skills by Admissions
and Registry staff. This policy, if implemented, will add to,
not reduce, the administrative burden and cost to institutions.
RECOMMENDATIONS
17. The University recommends that the Government's
proposal to withdraw funding for equivalent or lower qualifications
be delayed which would allow:
— HEFCE to undertake more detailed
modelling of the impact policy based on more up to date data which
has been verified by Universities;
— HEFCE provide clear guidance to institutions
to enable them to accurately identify non-exempt ELQ students
— More time for university-employer
engagement initiatives to become established
— Greater clarification of the scope
of proposed exemptions
— Institutions to decide on fee policies
for ELQ students and to provide accurate information to potential
ELQ students and their sponsors.
18. The University recommends that HEFCE
broadens its exemptions to include HNC/D qualifications and a
broader range of subjects to include eg construction, IT, and
management. It also recommends that students who return to study
after a period of time eg five years, should be exempt.
January 2008
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