Submission from Bradford College
1. While sympathetic to the government's
motives, the College believes that the ELQ policy introduces a
perverse and irrational series of consequences that will particularly
impact upon FE colleges and other institutions with a commitment
to lifelong learning. The exemptions policy excludes a number
of key areas, particularly BTEC HNC/Ds, youth work and counselling
qualifications. The College believes the administrative burden
will be great and that the checking of prior qualifications is
unenforceable. The College would support a postponement of the
implementation pending further analysis and development of the
policy into a more workable solution.
2. Bradford College is a large general FE
sector college with a substantial range of HE programmes. The
College receives the largest funding of all FE Colleges from HEFCE
and is the only one with a substantial contract from the TDA.
The College's HE provision dates back over 30 years and the College
currently has around 3,500 HE students on awards ranging from
BTEC HNC/D, through Foundation Degree, DipHE and bachelor's degree
awards to PGCE, professional and Masters level. A majority of
students are full time and the College's focus is on Skills and
Widening Participation, with a substantial number of students
from disadvantaged backgrounds and minority ethnic groups, drawn
from Bradford and beyond. The College's degree courses are currently
awarded by Leeds Metropolitan University, but the College is well-advanced
to apply for Taught Degree Awarding Powers in its own right.
3. The College supports the government's
desire to focus on attracting first time learners but believes
that the decision to phase out support for students studying ELQs
will produce a series of perverse and unintended consequences
and is therefore misguided and wrong.
4. Lifelong Learning involves a series of
ladders and bridges, using qualifications to improve skills and
support economic development of both individuals and benefit wider
society. Learners are increasingly traversing these ladders and
bridges in complex ways and to suit the needs of localities. The
ELQ policy, as currently formulated, will create a series of obstacles
to the development of skills. Additionally the policy will add
an administrative burden to institutions, particularly those most
heavily engaged in widening participation and lifelong learning
such as FE Colleges.
5. Ultimately the policy is unenforceable,
as ELQ students who will be expected to pay higher fees will be
required to prove they have the higher qualifications, whereas
those paying lower fees can do so by simply denying to colleges
and universities that they have anything higher. While most students
studying in Higher Education are honest about their prior qualifications,
institutions have no sanction if they claim not to have a prior
qualification. This will be a particular issue for those institutions
with mature students and those from diverse backgrounds.
6. The rapid increase of immigrants will
lead to a much larger group of learners for whom equivalence is
a complex issue anyway, due to the language barriers. Newly arrived
workers from places such as Poland will have qualifications delivered
and certificated in other languages that will often be unknown
in the UK context. Employers will wish them to obtain UK recognised
qualifications but the burden of determining their prior qualifications
will fall upon the College or University. At the higher levels
this may be easier, but at technician and professional levels
that are mainly delivered in FE this will be a significant additional
7. The College believes that the decision
has been too rushed and the consultation period inadequate for
detailed consideration of the perversity of some of the consequences.
The College would support a deferral of the decision pending the
review of fee levels and a separate look at part time and mixed
mode study. For FE Colleges the timing also comes on the back
of the proposed changes to FE funding and the creation of separate
ministries. The College will soon find its funding split across
four agencies reporting to two different government departments
(DSCF14-19 and TDA, DIUSHEFCE and LSC). The governments
laudable aims of reducing unnecessary bureaucracy do not appear
to be thought through in relation to this policy.
8. The exemptions do not include BTEC Higher
National Certificates and Diplomas. These are very significant
vocational qualifications in FE institutions funded by HEFCE,
including Bradford College. While there has been a slow historic
decline in enrolments to BTEC awards, they have the advantage
of being well-recognised and enable FE Colleges to develop HE
offerings to meet local needs in a speedy and responsive way.
FE Colleges are developing Foundation Degrees, but HNC/D still
remain important awards. An advantage of the HNC in particular
is that students can obtain a well-recognised national qualification
in only two years of part time study, whereas a Foundation Degree
will take at least three years. Since Foundation Degrees will
be exempt but HNC/Ds will not, an unintended consequence of the
policy will be to encourage FE Colleges to abandon HNC/D in favour
of Foundation Degrees, regardless as to the merits of the situation.
This may suit the government as a vehicle for enforcing the take-up
of Foundation Degrees, but one has to question whether it will
deny learners a choice. An example at Bradford College is the
HNC in Textile Design. This two year part time course is well
reputed and popular with students who have already undertaken
HE study, often several decades ago in subject areas in which
they are unable to gain employment locally due to industrial decline.
Students on the course wish to gain employment in a still important
local industry and regional speciality, often as self-employed
designers. Fees are currently £800 per year, but a fee of
£3,000 would exclude all but the most wealthy from the course.
9. The College is active in a number of
vocational areas that are exempted from the policysocial
work and teacher training in particular. However a number of important
related areas are not exemptedincluding the training of
youth and community workers and the training of qualified counsellors.
For these two professions the possession of an accredited "Diploma"
qualification is essential (DipHE, typically taken full time).
Many of the students attracted to these courses already have significant
life experience and have completed higher education study. The
Youth and Community Services are desperate to attract such people
into the profession, but withdrawal of funding and a tuition fee
of £6-7,000 per year will make the course prohibitively expensive.
10. The College is anxious to improve the
uptake of Science, Technology, Engineering and Mathematics (STEM)
subjects, part of the Strategically Important and Vulnerable Subjects
area proposed by HEFCE. Numbers of ELQ funded students on these
courses will be pegged at 2005-06 levels. This allows very little
flexibility to expand STEM provision particularly through HNC/D
and BSc courses. It is not clear how Colleges are expected to
allocate their protected ELQ numbers and invidious to determine
that students on one course are more deserving of ELQ funding
than others. In a large HEI this might be more manageable but
for smaller providers the system proposed by HEFCE will be very
difficult to operate.
11. The SIVS exemption appears to many in
the FE sector to be counter-intuitive. Traditional degree courses
in minority languages, often in elite institutions dominated by
middle class students, to meet the needs of the Foreign and Commonwealth
Office are exempted. Whereas students on HNC/D courses in FE Colleges
trying to meet local economic need and regeneration in disadvantaged
working class areas are not exempted. This seems a perverse outcome
of different government policies conflicting.
12. All the evidence is that the ELQ policy
will affect the following groups more:
(c) Learners on non-exempted professional
training particularly in the public sector, such as youth work,
where future financial benefits are not great.
(d) Learners from deprived and disadvantaged
areas with declining industries where new skills are needed.
However this is not easy to quantify or produce
evidence on. Therefore, before embarking on such a radical change
of policy a full equality and diversity impact analysis should
be carried out by the government.
13. As a comprehensive institution offering
wide range of both FE and HE skills-based provision, the ELQ policy
will be very difficult for Bradford College to operate and advise
potential students. A student who has PhD can take an A level
course at the College and be eligible for funding by the LSC,
whereas a student who went to university for just one year 20
years ago (if they tell the college) is not funded on a vocationally
relevant HNC course and would be expected to pay over £3,000
per year. A student who already has a degree who wishes to study
for a three year BA in Social Work is fundable, but a student
who has an HNC in Business Studies taken part time and 20 years
work experience, who wishes to study for a two year full time
Diploma to become a Youth Worker is not fundable in the first
year and will have to pay £6-7,000 in fees.
14. Bradford College, along with other FE
colleges, will have to devote more resources to monitoring entry
qualifications more closely (with no sanctions for non-declaration),
monitor HEFCE contracts (and their audits) more closely and advise
potential students through the labyrinth of exemptions in an already
over complex system .The ELQ policy will therefore particularly
hit most those institutions who are trying to do most to deliver
the government's skills and widening participation agenda.