Memorandum 21
Submission from King's College London
SUMMARY:
King's College London is one of those institutions
significantly affected by the proposed ELQ policy. Such institutions
extend beyond the two hardest hit, Birkbeck and the OU, and are
by no means confined to "less research intensive institutions".
Below is our response to the HEFCE consultation. In particular
we have requested that the list of exemptions be extended and
that there be a wide definition of new first learner priorities.
We also request that a chance be given to all affected institutions
to have at least first refusal on the redistributed funds especially
as the policy amounts to a withdrawal of funded HEFCE places—the
key currency of English HE—based on a retrospective count
of a type of student who at the time in question were enrolled
in full accordance with existing HEFCE and Government policy.
1. CONSULTATION
QUESTION 1:
Have we responded appropriately to the Government's
instruction that certain categories of students should be exempt
in the light of the Student Fees (Qualifying Courses and Persons)(England)
Regulations and Education (Student Support) Regulations?
2. Though there are doubts as to whether
the Secretary of State has acted within the provisions of the
Higher Education Act, the College is broadly satisfied that there
is an acceptable rationale for what is being proposed.
3. CONSULTATION
QUESTION 2:
Do you agree with our proposal to continuing providing
public funding for students studying for foundation degrees as
an equivalent or lower qualification (ELQ)?
4. The delivery of the skills agenda provides
the opportunity for universities to engage with employers in order
to understand their needs, to work with them on the design and
delivery of programmes and to use their joint success as a platform
for the development of long-lasting symbiotic working relationships.
Given the breadth of the skills agenda individual university institutions
can identify the level at which they can engage. At King's which
is one of the UK's leading universities, there has been a strenuous
engagement with the delivery of the skills agenda, especially
through its health-related Schools. Through working in tandem
with its partner Foundation Trust hospitals, namely, Guy's and
St.Thomas', King's College and South London and Maudsley, the
College has developed a series of programmes, at a variety of
levels, to address the continuing need for enhanced professional
skills within the National Health Service. The emergence of the
ELQ proposals which is predominantly targeted at the lower end
of the skills agenda, has placed under threat these programmes.
This short-sighted approach not only leaves the College exposed
to significant disadvantage through reduced funding for teaching
but also jeopardises the delivery of higher skills to an NHS which
is under pressure to meet the health needs of the public. Surely
such an outcome was unintended and therefore needs to be addressed
as a matter of urgency.
5. The ELQ proposal runs directly counter
to the Government-supported Layard proposals for increasing access
to specialist therapies such as Cognitive Behaviour Therapy (CBT),
as the postgraduate diplomas which are under threat enable individuals
not only to offer these skills clinically, but to offer specialist
supervision to maintain skills in the wider workforce, and to
ensure high quality therapy is delivered. Similarly, workforce
modelling indicates that over the next decade pharmacist numbers
will need to grow by 5% per annum. The ELQ policy will severely
hamper such growth and, combined with age demographics over the
next 20 years, means that demand will outstrip supply. The inability
of graduates to retrain as pharmacists will place a serious constraint
on health worker development across the NHS. The current proposal
makes it extremely unlikely that a graduate entry programme into
Pharmacy will be developed, such schemes already operate with
great success in Medicine and Dentistry.
6. Clearly there is a need for a more balanced
approach here. HEFCE are encouraged to recognise the potential
disruption the ELQ proposals will bring to the wider skills agenda
and to take action to avoid so doing. At a minimum it should consider
extending the exempt subjects so as not to disrupt other government-sponsored
initiatives and/or to demonstrate its support for well-established
manpower planning mechanisms.
7. CONSULTATION
QUESTION 3:
Do you agree with our proposal to allow students
studying for an ELQ to count towards the delivery of separately
monitored co-funded additional student numbers?
8. Employer engagement represents a significant
challenge, more so if the desired outcome is to encourage co-funding
of provision, and therefore any attempt to limit the negative
impact of the ELQ proposal is welcome. However, it is disappointing
that HEFCE is only addressing a limited aspect of employer engagement,
namely the lower level at which foundation degrees are targeted.
The Government's and HEFCE's desire to see greater employer contribution
towards the cost of developing and delivering programmes does
not seem to extend to those employer organisations which are primarily
funded through the public purse. It is interesting to note that
were, say, the NHS to engage in such an enterprise then that would
fall foul of the ELQ proposals, no doubt to the embarrassment
of all concerned. There seems to an unhealthy fixation with the
promotion of "pet policies" rather than taking a more
holistic approach which would include security of long-term funding
for AimHigher and Lifelong Learning Networks. Such an approach
would lead to the development of opportunities for entry into
Higher Education which are sustainable and which will lead to
those first-time entrants joining institutions with both the skills
and the confidence to succeed.
9. CONSULTATION
QUESTION 4:
Do you agree with the proposal to introduce an
allocation for strategically important and vulnerable subjects
(SIVS), calculated on the basis of ELQ numbers studying SIVS?
10. The proposal to support SIVS is generally
welcomed though there are opportunities here to improve the nature
of the support. It would be timely for a review of the academic
disciplines to be included in the definition of SIVS as there
are compelling cases for expansion. One such example is the Cultural
and Creative Industries which is of strategic importance to the
UK generally and London in particular. Given that London is disproportionately
affected by the ELQ proposal (see later) this would be one way
of mitigating that effect. Also, the introduction of an allocation
which is based on historical data does not offer any scope for
expansion, if these subjects are strategically important what
then is the rationale for restricting the support?
11. CONSULTATION
QUESTION 5:
Do you agree that we should provide a supplement
to the part-time allocation?
12. While the provision of supplemental
support for part-time study is to be welcomed it is, at the same
time, disappointing that such support is transitional. This is
another illustration that HEFCE is focusing on the lower levels
no doubt with the intention of securing the outcome of greater
numbers entering Higher Education. While such an outcome would
attract broad support the concern is that this will achieved at
the expense of a loss of skills training and professional development
in other, higher areas. This remains a fundamental flaw in the
ELQ proposals and as such needs to be addressed.
13. CONSULTATION
QUESTION 6:
Do you agree with our proposal to provide "safety
net" funding to maintain each institution's grant at a comparable
2007-08 level in cash terms?
14. The safety net proposal seems reasonable.
However, due to the fact that institutions will be affected to
varying extents under the proposed new policy and because of the
fact that the permanent removal of student numbers is based on
an historic position that institutions have not been given the
opportunity to rectify, we propose that those institutions most
affected by the loss of funding are given the opportunity to bid
for new places before the numbers are put into the general pot
to be made available to the sector as a whole. In doing so, HEFCE
should take due notice of the nature and stated mission of the
individual institutions rather than restrict any reinvestment
funding to ASNs which are linked only to Foundation Degrees or
strictly defined employer co-funding. The lack of a flexible approach
here has the potential to seriously damage the funding base for
teaching in certain institutions of which King's would be one.
15. CONSULTATION
QUESTION 7:
Do you consider that the ELQ policy outlined in
this document is likely to have a differential affect on students,
depending on their gender, race, whether they have a disability,
or any other extraneous factors? If so, how might this be mitigated?
16. Although no formal impact analysis has
been undertaken there is a view that the proposal will impact
negatively on certain ethnic groups who are apply in larger proportions
for those programmes which are vocationally or professionally
orientated. HEFCE has acknowledged the negative impact on part-time
students.
17. CONSULTATION
QUESTION 8:
Do you have any further comments?
18. The College wishes to comment further
thus:
— it shares the general disappointment
that the Government chose to impose this policy without any form
of consultation with the Higher Education sector. This disappointment
is compounded by the proposed HEFCE approach which it believes
lacks balance and in some respects is poorly framed. The College
would prefer to see a more holistic approach which recognises
and protects the contribution made by universities to the higher
levels of the skills agenda. The effect of the policy on the development
of higher professional skills and their delivery for the general
good should not be misunderstood or worse ignored;
— the proposed policy will have a disproportionate
effect on London—data produced by London Higher shows that
the London region bears the brunt of the policy. This reflects
the national role played by London in not only developing the
skills agenda but also providing skilled personnel for the country
as a whole. The policy will reduce London's capacity to provide
these skills and while this will have a negative impact locally,
it will also impact nationally. London is the driving force behind
the nation's economy—especially vis-a"-vis international
competitiveness—and the policy should recognise this;
— there is a urgent need to consider
extending the list of exempt subjects in order to protect the
skills base and to support manpower planning in major organisations
such as the NHS. In particular, consideration needs to be given
to the inclusion of Pharmacy and Clinical Psychology as well as
the clinical aspects of certain subjects which have been included
in the exempt list such as Nursing, Medicine and Dentistry. HEFCE
should be encouraged to model the impact of the proposed policy
on these subjects and evaluate them in consultation with key stakeholders
such as the Department of Health and the strategic arm of the
NHS. In delivering its intended outcomes the ELQ policy should
not impact adversely on others;
— having withdrawn a substantial tranche
of funding from institutions, due care needs to be given to how
those institutions might be financially compensated. As stated
above, to place the reallocated resource only into the funding
of existing policies such as co-funding with employers and Foundation
Degrees is somewhat short-sighted in that it does not reflect
the core missions of some of those institutions which have been
significantly affected. The lack of engagement with these areas
should not be misinterpreted as a failure on the part of institutions
to involve themselves with the widening participation agenda.
Indeed the College is proud of its continuing and developing engagement
in this area and can demonstrated a broad and diverse portfolio
of activities which including leading an LLN, the "Access
to Medicine" programme and City Academies. Indeed, amongst
the Russell Group of institutions King's can demonstrate the most
comprehensive and diverse widening participation portfolio. It
is the College's expectation that the nature of any additional
funding will be based on discussions with HEFCE rather than some
preferential treatment for existing policies;
— the proposed policy is framed in
too blunt a fashion and would benefit from a more detailed exposition.
For instance, rather than excluded those whose studying and thus
engagement with ELQs is a continuum, introduce restrictions which
would apply for a limited time period, say five years. This would
allow individuals to plan their career development as well as
not unnecessarily preventing those who wish to return to learning.
— the bundling together of postgraduate
certificates, diplomas and masters qualifications shows some misunderstanding
of or disregard for the qualifications framework on the part of
HEFCE. There are clear and demonstrable distinctions between this
trio of qualifications which can be demonstrated in both curricula
and credit terms. For instance, in order to encourage engagement
from busy practitioners a "nested series of programmes"
at postgraduate certificate, diploma and masters levels in Gerontology
has been designed to promote their continuing professional development.
Under the ELQ proposals there is now a significant financial disincentive
for these practitioners to engage with this initiative.
19. The College hopes that HEFCE finds these
additional comments welcome and would be happy to engage in a
dialogue to discuss the details.
January 2008
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