Select Committee on Innovation, Universities and Skills Written Evidence

Memorandum 60

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 burden.

  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 (DSCF—14-19 and TDA, DIUS—HEFCE 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 policy—social work and teacher training in particular. However a number of important related areas are not exempted—including 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:

    (a)  Part time learners.

    (b)  Women returners.

    (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.

January 2008

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