Memorandum 25
Submission from the University of East
London
EXECUTIVE SUMMARY
— The implementation of this policy
may contravene provisions in the 1992 Act which were designed
to preserve the academic freedom of British universities;
— Based on University of East London
data, it seems that funding is being withdrawn disproportionately
for collaborative, employer-focused provision;
— Publicly-available data shows that
the worst-affected institutions are disproportionately London-based
universities with a WP mission;
— The policy would seem to have a discriminatory
effect against women, older learners and migrant communities,
and perhaps against Black & Minority Ethnic students more
broadly.
1. THE DECISION
TO PHASE
OUT SUPPORT
FOR ELQS
1.1. The Government's decision seems to
be in conflict at very least with the spirit of the Further &
Higher Education Act. The 1992 Act clearly and explicitly forbids
the Secretary of State from imposing terms and conditions [on
grants] . . . framed by reference to particular courses of study
or programmes of research (including the contents of such courses
or programmes and the manner in which they are taught, supervised
or assessed) or to the criteria for the selection and appointment
of academic staff and for the admission of students.
Students' entry qualifications are normally
considered among the criteria for their admission.
1.2. HEFCE have been very clear that the
decision to withdraw funding from ELQs is the Secretary of State's
decision, and they have consulted only on the implementation of
that decision, whilst the Secretary of State has not consulted
at all. We therefore welcome the Committee's inquiry into the
arguments for and against the decision.
1.3. It is clear from our analysis of the
UEL data that the ELQ policy withdraws funding disproportionately
from collaborative, employer-focussed provision. As examples,
the ELQ policy will cost UEL:
— £612,000 for postgraduate programmes
delivered to highly-skilled mental health workers in collaboration
with the Tavistock & Portman NHS Trust, and other NHS organisations;
— £240,000 for postgraduate programmes
in Clinical Psychology, Educational Psychology, Counselling and
Occupational Psychology delivered in partnership with LEAs, NHS
Trusts and other employers;
— £62,000 for Biomedical Science
at postgraduate and undergraduate levels, although this provision
is solely focussed on providing laboratory scientists for NHS
employment.
Perhaps we will be able to bid back for these
as co-funded numbers, but smaller sums of money will still have
negative impacts on specific employer-related projects which we
have previously managed within our contract range. For instance
57% of the learners on our MBA (Public Services) with London Borough
of Tower Hamlets and 35% of learners on our Masters in Health
Services Management are negatively affected by the proposed ELQ
policy. The impact here will be to make similar provision unviable
in future unless we are able first to secure greater contributions
(and longer term commitments) from employers and then win co-funded
Additional Student Numbers (ASNs) from HEFCE. For most programmes
at the PG level the effort involved will be disproportionate,
in particular where the provision currently supports SMEs or professionals
with portfolio careers, who will not be able to make the commitments
implied by co-financing. Even where co-financing is agreed, the
growth of successful programmes will be constrained by the availability
of Additional Student Numbers as we will have lost the flexibility
to accommodate such numbers within our contract range.
1.4. If the Government's intention is to
redirect this funding into Widening Participation by allowing
more students to have a first experience of Higher Education,
it is surprising that the funding is being withdrawn so disproportionately
from institutions with a WP mission. The "top ten" losers
are as follows:
Institution
| ELQ funding to be phased out |
Open University | 31,628,519
|
| Birkbeck College | 7,866,367
|
| London Metropolitan | 6,191,987
|
| University of Oxford | 4,151,668
|
| University of East London | 3,774,215
|
| Thames Valley University | 3,630,467
|
| London South Bank | 3,476,541
|
| City University, London | 3,191,136
|
| University of the Arts London | 3,122,340
|
| University of Westminster | 2,966,099
|
1.5. The majority of these (certainly including UEL)
could reasonably claim to be among the sector leaders for WP activity.
The London institutions in this group are particularly important
for their contribution to ethnic minority participation in HE.
1.6. The government claims that the money saved would
be directed towards supplying 20,000 additional student places.
There is no evidence that the demand is there from students nor
that the ELQ students are taking places that would otherwise have
gone to first time entrants.
2. THE TIMING
AND IMPLEMENTATION
OF THE
DECISION
2.1. The decision of the Secretary of State was announced
on 7 September, a consultation was launched on 27 September to
close on 7 December (although data on the technical definition
of ELQs, allowing the policy impact at individual student and
institutional level to be understood, was only made available
in mid-October), and decisions will be taken by the HEFCE Board
in February. Implementation of the policy will then be phased
in over six years. It might make more sense to think for longer
and then act more quickly.
2.2. The haste to begin implementation has meant, for
instance, that HEFCE are using 2005-6 Higher Educational Statistics
Agency (HESA) data to calculate the funding to withdraw, although
the data collected was not designed for this purpose, and doesn't
allow the level of input and output qualifications to be compared
without a whole set of assumptions and approximations by HEFCE.
HESA will collect data on the level of courses in a new and much
more detailed way this year, but that data will be too late for
use in the current timetable.
3. EXEMPTIONS PROPOSED
BY HEFCE
3.1. The exemptions proposed by HEFCE seem to be a bit
of a grab-bag of their existing initiatives. Much of our employer-related
provision will be badly affected, and from the employers' perspective
they will either have to change their skills needs (so that we
can provide a Foundation Degree instead of what they really need)
or pass through a HEFCE bidding process to get the Employer Engagement
exemption (which also implies a lower grant rate than previously).
It will surprise employers that we are implementing Leitch by
giving them more bureaucratic hurdles, and less money.
3.2. An example is our Primary Classroom Support for
Teaching Assistants programme delivered in partnership with the
Centre for Literacy in Primary Education, local FE colleges and
Newham Local Authority. It is a 2-term "Other UG" programme.
Would it really help employers to withdraw this provision we have
developed in collaboration with them and offer only 2-year Foundation
Degrees? Yet 55% of the learners are affected by the ELQ policy,
either because they are qualified to UG level already, or because
they have qualifications treated by HEFCE as "unknown".
4. IMPACT ON
STUDENTS
4.1. About 2,000 of our students (roughly one in six
of all HEFCE fundable students) will fall under the ELQs regulations,
although some will be covered by exemptions. Not all the exemptions
cover individual students. For instance the "exemption"
for Strategically Important and Vulnerable Subjects (SIVS) actually
takes the form of an additional cash grant to UEL. The individual
students we recruit to SIVS subjects in future will still be unfundable
4.2. The policy can be expected to have a negative impact
on women, older learners and some migrant communities, and may
have a negative impact on ethnic minority students more broadly.
4.3. Our analysis of UEL data shows that both the ELQ
policy and the proposed exemptions have an apparent discriminatory
effect against women. This is to be expected as women are more
likely to return to the workforce after a prolonged career break,
and will accordingly often need to retrain at an equivalent level
in order to refresh skills, or enter a professional area more
appropriate to their changed circumstances. It would therefore
be surprising if the policy did not discriminate against women
across the sector as a whole. There will be an obvious impact
on older learners wishing to retrain in a new area, since they
will be penalised for possession of HE qualifications which may
be very old and of little relevance to the workplace.
4.4. Migrant communities are likely to be negatively
affected because of the discriminatory treatment accorded to overseas
qualifications. HEFCE are treating overseas degrees as ELQs even
though this is not the way they are treated in the Fees Regulations,
and many overseas degrees are not truly equivalent to a UK degree.
Treating "other non-UK" qualifications as of unknown
level also results in withdrawal of funding for many of these
students too.
4.5. Given the disproportionate impact of the policy
on London overall, and the fact that ethnic minority students
are more likely to pursue further study to help overcome the discrimination
they experience in the workplace, we feel that it is likely that
the policy will impact unfairly on BAME students. HEFCE has the
data to confirm the impact for the sector as a whole and we would
be glad to see an analysis of the data published before the policy
is implemented.
5. IMPACT ON
INSTITUTIONS
5.1. The financial impact on institutions such as UEL
is large. We have not yet had an opportunity to consider our strategic
response in detail: like many institutions we will wait the final
HEFCE announcement before we do so, however all institutions will
feel pressure to take a number of steps:
— Withdrawing from lifelong learning activity, since
many learners on such provision will cease to be fundable, whilst
no learners on provision aimed at school-leavers will;
— Withdraw from PT provision, since this is disproportionately
affected by ELQs and in any case much less well funded under the
current fee arrangements;
— Withdraw (or downsize) professionally-accredited
provision (such as in Psychology or Law) where a significant proportion
of entrants already have a degree without professional recognition;
— Reduce employer engagement, since the opportunity
to manage small projects within the contract range has gone, and
the grant rate for HEFCE "Employer Engagement" numbers
is lower than for other numbers.
6. CASE STUDIES
6.1. Students undertaking ELQs do so for a variety of
reasons but at UEL it is most commonly linked with gaining employment.
Below are three case studies which are in many ways typical.
— X came to us in 2003 with a degree in English
at Oxford and many years in and out of work. She was determined
to retrain as clinical psychologist, joined our Graduate Diploma
in Psychology and is now in the final year of her clinical doctorate,
treating patients at hospitals in London and Bristol.
— Y graduated this year with first-class honours
from his BSc (Hons) degree in Physiotherapy at UEL and is now
working as a Junior Physiotherapist at Addenbrooke Hospital in
Cambridge. Y won the London Region and Ian Ramsden prizes for
best Physiotherapy project and presentation. He had previously
completed a degree in Sports Science at a different university,
but wanted to retrain as a Physiotherapist to work in healthcare.
It is very unlikely he would have been able to do so without funding.
— Z a welfare adviser at our Students' Union, is
completing his LLB Honours degree in Law this year. Leaving school
at 17 with unidentified dyslexia and bare minimum GCSEs, he joined
the army and served 5 years as a plant operator mechanic in Royal
Engineers. Here he suffered a fractured spine and was left physically
unable to work. He decided that rather than rely on his disability
pension, he would retrain: at his local FE college he studied
for his HNC in IT, followed by a degree in E-commerce. However,
this did not lead to employment as he had hoped, so he came to
UEL to study Law. He is now no longer claiming incapacity benefits
and is in work. Z could never have afforded to do this under the
proposed regime. Without the opportunities provided by university
education, he believes he would still be on benefits—a drain
on the taxpayer, rather than a skilled and valuable member of
our community.
6.2. And there are thousands more, each with their own
story to tell and each demonstrating that education is not some
linear route as the Government has suggested but one which does
and should offer opportunities to re-skill, progress and make
something more of your life.
January 2008
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