Submission from London Higher
INQUIRY ON ELQ FUNDING
1. London Higher contends that the proposed
withdrawal of support for ELQs is a policy change based on no
evidence and rushed through with minimal consultation. Little
thought appears to have been given on the ramifications for individuals
2. There are regional aspects to the ELQ
proposal which have seemingly not been considered. The proposal
will have a disproportionate impact on London, with unintended
social consequences especially for ethnic minority, refugee communities
and for women HE students. Through knock-on effects, the ELQ changes
will undermine London's role in driving the national economy,
reducing its status as a world capital city.
3. We strongly urge the Secretary of State
to defer implementation of the ELQ proposal until such time as
a full, comprehensive study has been carried out with the involvement
of the HE sector and institutions have had time to develop appropriate
and sustainable adjustments.
4. London Higher is the Higher Education
Regional Association (HERA) for London and represents over 40
London universities and specialist colleges.
5. Our remit includes promoting London's
universities and colleges, coordinating strategic London higher
education (HE) campaigns and disseminating information.
6. Overall, the ELQ proposal threatens to
undermine vitally important parts of the London economy and skills
base. By diverting resources to lower level skills (Foundations
Degrees) rather than higher level skillswhich are already
in critical demand in London's economythe changes will
effectively devalue London's workforce. This will both make the
capital less competitive in the world economy and will result
in equally detrimental social impacts. The economy of London is
the powerhouse behind that of the UK; damage to the former will
adversely affect the latter.
7. Career progression in many professions
is highly fluid but the ELQ proposal views it as rigidly linear.
Recent surveys indicate that 43% of jobs in London require higher
level skills (HLS), compared to just 30% in the rest of England
and Wales. The HLS requirement in London is projected to increase
to around 50% in 2020, higher than the expected 42% average across
the UK. ELQs are vitally important for acquiring HLS, for example
by graduates who may have completed a degree 5-10 years previously
and wish to obtain a vocational skill but not at Masters or PhD
8. ELQs are also highly necessary for updating
skills in many sectors as new practices or processes are introduced,
eg health, teaching, business. Continuous Professional Development
needs to occur for all levels of qualifications. London is a centre
for professional specialist and postgraduate training, much of
it based around the world class research infrastructure that exists
in the capital. Analysis of the limited data available indicates
subjects with a strong tradition in these areas, for example several
subjects allied to medicine and in education, will be markedly
affected to the detriment of the individuals concerned.
9. There is no substantive evidence to prove
the so called "build-back" from Foundation Degrees and
employer co-funding will succeed. For example, in London's creative
sectorthe second largest sector in the capitalbusinesses
lack the capacity to co-fund. Eight of the top 20 London HEIs
affected by the proposals are creative arts institutions. In addition,
it is doubtful that large companies in London will invest in higher
education, since the economic and cultural benefits of working
in the capital mean that recruitment is often global. Hence there
is little incentive for employers to upskill/retrain staff as
opposed to seeking overseas candidates with appropriate higher
level skills, to the detriment of London's work force.
10. The introduction of these proposals,
without previous comprehensive impact analyses will risk unintended
consequences for London's large ethnic minority and refugee communities
as well as a likely disproportionate impact on women students.
Many refugees arrive with degrees but need to retrain at lower
levels, for example in health (eg pharmacy, nursing) or education.
Furthemore, shared teaching on some courses may mean that the
reduction of ELQs in one subject area leads indirectly to possible
course closures in related subjects, undermining the core missions
of several London HE institutions. HEFCE are due to report on
an impact analysis this month (January 2008) but it remains to
be seen what concessions will be made. Why were these analyses
not done before the policy change was announced rather than during
the very brief consultation period?
11. Based on HEFCE data, London HE institutions
will lose £54 million at ELQ level, a third of all national
losses. Besides Birkbeck and Open University in London, other
London HEIs severly affected (>10% ELQ loss) include Conservatoire
for Dance and Drama (26%), London Business School (25%), School
of Pharmacy (15%), London School of Hygiene & Tropical Medicine
(14%), Thames Valley University (13%), City University (13%) and
University of East London (11%).
12. Overall, 54,504 students will be affected
nationally by these changes, based on HEFCE data. DIUS claims
20,000 new students will benefit from ELQ changes. Besides asking
how precisely the latter figure has been determined, this does
not seem to be a reasonable balance in provision of funding resources.
13. Finally, little mention has been made
so far on how qualifications will be recorded and verified. Is
a secure national database required and how retrospective will
the data collection be?
14. We strongly urge that implementation
of this policy should be deferred until questions are resolved
on issues such as effects on students (especially women and ethnic
minorities) and financial adjustments by HE institutions.
15. We believe that the proposals have been
formulated without sufficient regard to the likely impacts across
a range of areas and are detrimental to a number of longstanding
Government and national as well as regional interests. The proposals
clearly impact disproportionately on London and on London's HE
sector. They have also been introduced with undue haste and are
being pushed through far too quickly for institutions to adapt
to them without unnecessary risk.