Select Committee on Innovation, Universities and Skills Written Evidence

Memorandum 62

Submission from GuildHE


  1.  GuildHE broadly supports the policy proposal on ELQs, recognising the need to prioritise spending in a financially constrained environment. It is important to encourage more first time entrants into higher education and to support this through incentives for educational providers to respond to their needs through both subject provision and mode of study. In order to support those students who will be facing an increased financial burden, a national loan scheme or similar should be considered.

  2.  We support the public interest argument of protecting certain subject areas but would ask that the exemptions framework be reviewed to ensure that there is consistency across a range of policy initiatives, including those from outside of DIUS, particularly DCSF, DoH and DCMS.

  3.  We are also concerned that a consequence of the policy may be for foundation degree places to be filled by displaced ELQ students on financial grounds. Similarly, there are likely to be repercussions for postgraduate registrations if all taught postgraduate provision is considered as of an equivalent level.

  4.  Support for employer co-funded arrangements is welcomed but it should be noted that the ability of employers to contribute to collaborative arrangements varies considerably and an institution's capacity to benefit from these initiatives will very much depend upon their geographical location, regional priorities, current portfolio and institutional mission.

  5.  We would ask that consideration be given to delaying implementation for 12 months to enable institutions to properly assess the impact of the proposals and to plan appropriately, minimising instability within the sector. Similarly, we would argue that safety net funding should apply to all affected institutions with support for an extended period for those particularly impacted.

  6.  Differential impact on particular student groups is inevitable and future provision for mature and part-time students will be very important. In particular, the funding of part-time students needs to be adequate to support this mode of study. ASNs should be directed towards those institutions with genuine widening access initiatives as well as for employer co-funded courses and not just those who are likely to suffer the most under this policy. The Open University and Birkbeck College lead the field in provision for mature and part-time learners and should be in a good position to benefit from the redirection of funding.


  1.  GuildHE is one of the two recognised representative organisations within the higher education sector and the key advocate for the importance of institutional diversity. GuildHE is an inclusive body, with members across universities, university colleges and specialist institutions. Other key characteristics are briefly set out below:

    —  most member HEIs are smaller than the average university;

    —  they include major and world-class providers in art and design, music and the performing arts, agriculture, education and the health professions (for example, the specialist HEIs provide 28.8% of all Agricultural Sciences students, 21.3% of all Creative Arts students and 12.5% of all Education students);

    —  they embody communities of practice, with a clear commitment to high quality teaching enriched by research and knowledge exchange; and

    —  they make a particular contribution to local community capacity-building thus contributing to social and economic regeneration.

  2.  GuildHE welcomes the opportunity to contribute to the Innovation, Universities and Skills Committee's inquiry into the proposed withdrawal of funding for equivalent or lower level qualifications (ELQs). It should be noted that we have used the consultation period set by the Funding Council to raise issues and expect to work with colleagues at both HEFCE and the Department for Innovation, Universities and Skills to find appropriate solutions, as they respond to the points raised.


  3.  GuildHE broadly supports the decision on ELQs. We have a vision for higher education in which a sustainable, diverse and dynamic higher education sector plays a full part in the development of a well-educated and socially inclusive nation, enhances the UK's economic competitiveness, and fosters cultural engagement, knowledge creation and exchange in a global context.

  4.  We appreciate the scale of the CSR settlement and recognise that, in an environment of increasing competition for Government funding, it is necessary to prioritise spending in order to meet particular objectives. Given these constraints, we endorse the underlying position of the policy ie that those who have already received public funding to gain a particular level of qualification should not expect further support but rather should pay the full price of their studies themselves or via their employers. The redirection of the funds saved towards those who have not yet had a chance at gaining higher level skills will help the widening participation objectives of GuildHE members. Our HEIs are already successful in delivering to this group of students. We are confident that DIUS plans mean no reduction on the total funds being spent, rather a change in emphasis of who will benefit.

  5.  It is probable that fee levels in the region of £5k-£10k for ELQ students will result from this policy. Those studying for an ELQ are already largely ineligible for student support and are now likely to face an additional financial burden. The majority of those affected are unlikely to be able to afford the increased costs unless some form of financial support mechanism is put in place. The provision of a student loan facility to this group of students, perhaps sourced through the private sector but nationally managed, may help to alleviate this. Taking a positive interpretation, if places vacated by ELQ students are filled by those "First to go" students and a large proportion of ELQ students can find a way to fund themselves, in fact there will be more income to the HE sector.

  6.  The DIUS proposals support the objective of promoting employer engagement and co-funding. For these courses they place no greater burden on the ELQ participant than the first time qualifier. GuildHE recognises the argument that employers are current spending a significant amount on training but are not spending it with higher education providers. The challenge to our members is to develop education in a demand led context. It is essential that employers are able to maintain confidence in the relationships that have already been built with the sector. Our concerns relate more fundamentally to the challenges of employer co-funding, not least because employers are not a homogenous group and their ability to contribute to collaborative arrangements varies considerably.


  7.  GuildHE recognises the importance of acting quickly to implement any changes and our members have not indicated any particular difficulty with the timescales. However, in order to protect the reputation of the sector, we suggest that consideration be given to delaying this for 12 months to allow time to plan appropriately and for further work to be carried out on the data management and impact assessment. There is also a question whether information given to students for admission in 2008 can be withdrawn or altered so significantly without falling foul of some legal challenge. Particularly for mature students, there may be a wider family impact.

  8.  The implementation of this policy will rely heavily on the gathering and monitoring of data and we are concerned that the data on which the assumptions are based is not sufficiently robust. It should also be noted that the definition of a student as an ELQ is dependent upon the accuracy of the data the student provides, when it is clearly not in their financial interest to do so, and there is no easy means of verification. HEIs potentially face a heavy additional burden in verification of previous qualifications and determining equivalence and this impact is worse for HEIs where students have studied overseas. There could also be a public interest argument that some workers from abroad are required to undertake further training as their existing qualifications do not enable them to practise fully in the UK. This is often more significant in the case of refugees and migrant workers.

  9.  It appears that all postgraduate taught provision is being regarded as at an equivalent level for the purposes of this policy when the reality is that students are often only prepared to commit to a certificate programme on the basis that they can then progress to a diploma and then a master's degree, particularly in the case of part-time students. These students would be classed as ELQs whereas those who register initially for the masters degree may follow the same path but would not be ELQs. Any solution needs to limit game playing.


  10.  In general terms GuildHE supports the list of exemptions within the proposals but offers the following comments on specific areas:

11.   Teacher Training and Development

  We believe the exemptions should be extended to include all teacher training in order to support the aim of professionalising teaching staff at all levels of education; many of whom would be classed as ELQs. Excluding CPD qualifications would seem to run counter to DCSF policies such as the recent Children's Plan, 14-19 changes and the raising of the participation age, all of which have implications for post-professional development. There are also a number of HEFCE funded professional qualifications which underpin the development of integrated teaching and education support services.

12.   Health Education

  12.1  We welcome the support for nursing and other health professions but believe that the exemption should also extend to other health care professionals training in those disciplines that are presently regulated by statute, which includes the chiropractic and osteopathy professions. This should ensure that they are in an equitable position that will attract the best quality entrants into our healthcare professions.

  12.2  The inclusion of exemptions for medicine, dentistry, veterinary surgeons and other similar training where there is a quota and demand exceeds supply, may need to be revisited. It could be argued that an ELQ student on one of these courses is taking the place of a student entering higher education for the first time and in an area where the opportunities for widening participation students are already constrained due to the very high entry requirements.

13.   Creative Industries

  The emphasis on employer funding as the alternative source of finance is problematic for the creative industries where there are many SME's and concept of the "employer" is different to many other sectors and it will be important that this policy does not run counter to the work being done by DCMS to preserve and build upon excellence in this sector.

14.   Foundation Degrees

  14.1  The development of foundation degrees is a key element in the building of relationships between HEIs and business and industry to deliver more vocationally oriented training. Many of these relationships are still at an early stage and GuildHE welcomes the proposal to protect funding for these courses. These types of programmes are likely to become a core component of the upskilling/reskilling agenda and need to be supported if they are to succeed and become embedded in the higher education and training landscape. We hope that some of the funding released through this policy change may be directed towards ASNs for foundation degrees, especially in areas with high SME economic activity or in third sector environments where the capacity for employer co-funded development may be limited.

  14.2  It is a concern that an unintended consequence of the exemption for foundation degrees may see displaced ELQ students filling up places on foundation degrees at the expense of widening participation students and other, more appropriate first-time entrants to higher education. It should also be noted that foundation degrees are not the only programmes that offer the skills demanded by employers and they will not always be the most appropriate choice for all students, particularly those returning to work after a career break or needing to retrain to accommodate changed circumstances. It would be unfortunate if the withdrawal of funding encouraged students to enrol on courses for primarily financial rather than educational reasons.

  14.3  There will be a number of ELQ students currently working towards Foundation Degrees who were recruited on the basis that they would be able to progress to an honours degree that will find themselves without funding for the "top up" course as a consequence of these proposals. Consideration should be given to honouring the promises made to this group through exemption for those directly progressing at the end of their initial course.

15.   Strategically important and vulnerable subjects

  GuildHE welcomes the exemption for SIVS but acknowledges that a number of other subjects may also be at risk. In this context, we would ask that a clearer mechanism should be developed to ensure that over time new SIVS can be identified and supported and that those subjects that are successfully "rescued" are then treated equally with mainstream courses.

  Similarly, it will also be important to protect new and emerging subjects and a mechanism is needed to ensure that these can also be identified and supported appropriately. Indeed it is likely that some prospective students for these subjects will be ELQs as these subjects were not on offer when they were studying first time around. Funding for new and emerging subjects could be provided through specialist premia for HEIs supporting certain subjects.


  16.  GuildHE is committed to the principle of opportunity for all. We accept that this policy change is likely to have a differential impact and that further work is necessary to understand how this will manifest itself and the steps needed to mitigate this where desirable.

  17.  The most obvious group to be affected is mature students who are wishing to change career direction, where current employers would have no reason to give them financial support. They may be those most likely to hold a previous award; however, unlike today's graduates, they may not have been expected to contribute to the cost of their initial award. The differential impact on these mature students creates an inevitable tension between the proposals and the priorities of lifelong learning.

  18.  We believe that the position for middle-aged and older people will only be partially offset by the current proposals for exemptions and targeted funding. To address these concerns, we propose that a time limit be set on the previous qualifications whereby, for the purposes of this policy, those that were obtained some time ago (say 15 or 20 years) would be disregarded. This would support the Leitch Skills agenda and recognise lifelong learning objectives, enabling the workforce to respond to a changing employment landscape.

  19.  Education is often used by elderly people and those with disabilities that prevent them from working as a means of keeping themselves mentally and socially active. The ELQ proposals could impact adversely on this group and have consequences for other policy areas eg additional burdens on health budgets. Consideration should be given to exempting these groups.

  20.  The proposed support for part-time students is welcomed by GuildHE, in line with its commitment to diversity and student-centred learning, but it is important that the amount reflects the potential impact of the policy change on part-time study. We hope that the relative costs of part-time versus full-time provision will be addressed in the forthcoming fees review. This mode of study is used to deliver most CPD and vocational training and provides a route of access to higher education for many widening participation students. Short courses enable many of these students to gain initial confidence in higher education. We believe that part-time study could be disproportionately affected and it is possible that some courses could be rendered unviable following the removal of funding for ELQ students if the income shortfall cannot be met through the application of higher fees.


  21.  Whilst most GuildHE HEIs appear not to be as seriously affected as those who have larger numbers of ELQ students, we recognise that this policy change will have a significant impact in some parts of the sector. Safety net funding will therefore be important in helping to maintain stability. In most cases, three years should be sufficient to allow HEIs to accommodate the market impact but, it may be that support for a fourth year and beyond will be necessary in some cases. This takes account of four year courses and deferred entry commitments. At the same time, in order to encourage HEIs to respond quickly and effectively to the new arrangements, any extension of transition arrangements should be applied only in exceptional circumstances.

  22.  The modelling included in the proposals shows that some HEIs are expected to continue without safety net funding and this will impact differently depending upon their size and capacity to benefit from additional ASNs. We would argue that the transitional support should have a lower cut off point and preferably be applied to all.

  23.  The ability and capacity of institutions to recover funding through ASNs will vary considerably and we would be concerned if the funding recovery process simply returned funding to those HEIs who had lost it and would rather it was used to support initiatives to recruit students from the harder to reach groups. If stability is to be achieved primarily through employer co-funded provision, this could have a particular impact on the smaller and specialist institutions who may not have the range of courses to enable them to benefit from these funding streams. This also applies to those whose employer community is largely public sector, particularly teaching and NHS.

  24.  We acknowledge that the Open University and Birkbeck College appear to be particularly affected but conversely they may also be best placed to benefit from the policy. Their mission and existing, flexible operating structures particularly in the areas of mature and part-time student education, where they are acknowledged as leading the field, are likely to be the focus of targeted initiatives. Whilst the objectives of lifelong learning are clearly important, the serial "hobby" learners (many of whom were fully funded and supported for their initial qualifications) should not benefit from public funding at the expense of those who have yet to access higher education.

January 2008

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