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
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
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
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
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
15. Strategically important and vulnerable
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
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.