Memorandum 43
Submission from the University of Kent
Thank you for the opportunity to comment on
the Government's proposal to withdraw funding for students undertaking
equivalent or lower qualifications to those they already hold.
We have structured our comments according to
the key focuses of the enquiry, but would particularly draw your
attention to Section 5 where we articulate the impact of the change
on institutions.
1. ARGUMENTS
FOR AND
AGAINST THE
GOVERNMENTS DECISION
TO PHASE
OUT SUPPORT
TO INSTITUTIONS
FOR STUDENTS
STUDYING ELQS
(a) We are baffled by the both the thrust
of this directive which appears to have been taken in isolation
without thought for the impact on, or implications for, other
Government agendas, namely Life Long Learning (LLL) and Widening
Participation (WP).
(b) We believe that these proposals will
act as a barrier to LLL since the cost of further study for ELQ
students will be prohibitive. This will hinder the re-skilling
of the work force and result in a less flexible working body unable
to adapt to the needs of the nation.
(c) This initiative will have serious unforeseen
consequences for widening participation, reversing the progress
made by the sector in recent years. The closure of swathes of
part time provision is inevitable because the removal of ELQ students
(who will not pay the increased tuition fees necessary for universities
to cover their costs) will render programmes non viable. Non ELQ
students and local community work will suffer.
(d) We are extremely concerned that the
current proposals for withdrawing and re-distributing £100
million of funding will lead to serious de-stabilisation of the
sector. This will fall at a time when the introduction of the
new Teaching funding methodology by HEFCE is already causing instability,
with more targets to achieve to retain existing funding. Many
institutions will be seriously affected by both the claw back
of grant and the costs of the additional bureaucracy of identifying
and correctly invoicing ELQ students.
(e) Institutions will be placed in the front
line in terms of justifying the fee differentials and inequality
claims between ELQ and non ELQ students.
(f) We believe these ELQ proposals "fail
the test" in that they are not in the public interest and
will impose significant additional administrative burdens both
during implementation (bidding for replacement numbers/provision
of information) and longer term in identifying, invoicing and
processing ELQ students.
2. THE TIMING
OF THE
DECISION AND
THE IMPLEMENTATION
OF THE
CHANGE
(a) By the time the ELQ decision was announced,
the admissions process for 2008 was already in full swing. Institutions
do not necessarily have the data to hand to identify ELQ students
prior to making an offer of admission, nor do they have the appropriate
process and external interfaces in place to collect this data.
Identifying ELQ students, for the purpose of fee billing prior
to students' arrival on course, will be problematic. Any system
would rely heavily on the honesty of individuals who have an incentive
to withhold information. The existence of previous qualifications
may only come to light retrospectively through HEFCE monitoring
of HESA data. Retrospective exclusion of students from funding
would leave institutions to recover fees.
(b) HEIs manage on tight surplus/deficits
and, though from a HEFCE point of view this figure represents
a small percentage of its allocations, for individual institutions,
this reduction in funding will have an amplified marginal impact
and may well turn narrow net surplus positions into deficits.
The short timescale for implementation (notification of the financial
position to institutions in March 2008 well after the UCAS applications
deadline for the following September entry) means that there will
be little practical mitigation possible for 2008-09.
(c) There remains a large exercise with
other Government departments (to include LEAs) and bodies within
education (including UCAS) to co-ordinate the publicity, explanation
and system modifications needed to introduce this directive. The
window of opportunity for 2008-9 entry has in many cases already
passed. It is highly unlikely that HEIs will offer bursaries to
ELQ students—they are not a priority group and it would
add a net cost of operation at a time of tightening budgets due
to the introduction of the national pay framework and reduction
in the opportunity to acquire ASNs.
3. THE EXEMPTIONS
FROM THE
WITHDRAWAL OF
FUNDING PROPOSED
BY HEFCE
(a) We do not believe that sufficient exemptions
have been granted, both in terms of type of provision and specific
subject areas. The SIVS concession is not sufficiently broad enough
to encompass medically related activity such as Pharmacy where
there are major shortages of practitioners
(b) The proposals hit subjects that involve
retraining in a disproportional way. Such subjects include Law,
Theology and Education. The latter is protected at the school
level but not the training of our own lecturing staff to ensure
maximum efficiency in the teaching function of the University!
(4) THE IMPACT
UPON STUDENTS,
INCLUDING WHETHER
THE CHANGE
WILL AFFECT
SOME GROUPS
MORE THAN
OTHERS
(a) There is a real danger that PT provision
will see a significant reduction as a result of the ELQ directive.
The £20 million available across the sector is unlikely to
effect what we believe are the inevitable consequences of this
directive—namely the closure of swathes of PT provision
(particularly those addressing the needs of Adult learners) and
with it opportunities for flexible learning. There will be knock
on effects for local communities and non-ELQ students. The theory
of levying higher fees at this group will not match the reality
of students' ability to pay which is already constrained at current
fee levels. This is likely to have ramifications for both the
LLNs and WP agendas.
(b) We are surprised that those holding
Professional qualifications, but not through publicly funded study,
should not be exempted from this policy. Many of those who study
for professional qualifications without having a degree first
are often those who have left school early and have later funded
their own up—skilling or received employer support. If they
choose to take a degree after this study they will not be supported
by the state but if they follow a traditional route and study
for an HE qualification first, they will receive funding. This
seems illogical and unfair on those from non- traditional backgrounds.
In addition there is the practical difficulty of equating professional
qualifications to HE qualification levels.
(c) Postgraduate taught study (PGT) is particularly
affected by this directive because of the lack of articulated
progression. All PGT repeat study falls within the definition
of EQL whether at a higher level or not (eg Diploma—Masters).
(d) Women returning to work are a group
that will be affected, with little prospect of finding employers
willing to sponsor retraining.
5. THE IMPACT
OF CHANGE
ON INSTITUTIONS
(a) Should the ELQ directive go ahead, then
we believe that the effect on most institutions could be minimised
by an alternative approach that withdraws funding for new entry
ELQ students from 2008-9 but allows institutions the opportunity
to substitute replacement non-ELQ numbers. The university sector
is well aware of Government priorities and can be trusted to deliver
against these. The University of Kent in particular has delivered
substantially against these priorities, and will continue to do
so.
(b) Key advantages are that institutions
remain in charge of their own destiny without the uncertainty
of a costly and late student number bidding process to try and
recoup the loss of income stream. Bureaucracy is minimised for
an initiative that represents savings of just 1% p.a.of HEFCEs
total annual teaching grant, yet threatens to consume a considerable
amount in implementation.
(c) The long term effect of this initiative
will not just affect big specialist institutions. It is likely
to lead to the general withdrawal of PT programmes, thereby negating
much of the work undertaken over the last 10 years that was specifically
aimed at the WP agenda. The University of Kent is seriously considering
the future of our part-time provision.
January 2008
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