Memorandum 65
Submission from the Universities Association
for Lifelong Learning
1. The Universities Association for Lifelong
Learning has grave concerns not only about the underlying assumptions
of the ELQs policy but also about the unintended consequences
resulting from its introduction. The agenda underlying the policy,
to provide for those who have not yet had the benefit of higher
education study, is laudable in itself, but the proposals for
implementation will impede this aim. (paragraphs 10-14)
2. The policy fails to recognise the "shelf
life" or obsolescence of qualifications and the rapid changes
in skills needed in an information age, depriving second time
learners of opportunities to re-skill at a time when 70% of the
2020 workforce is already in employment. It is a policy which
will apply to a diverse range of HE provision, including short
training courses, not only second degrees. (12, 15, 28)
3. It appears to attack the long-established
concept of public services provision on the basis of need, and
introduces the concept of one-chance-only in relation to a crucial
public good. If the policy is to limit public funding entitlement
to same level HE experience then any reduction in funding should
be focused on full-time study. That is where the bulk of the existing
subsidy is made, through grants, loans, and funded places. (24)
4. The cost of funding a further 20,000
first degree students, will be the denial of funding for up to
200,000, mainly part-time, students, who are re-skilling or updating
their qualifications in order to benefit both themselves, their
families, and the economy.[55]
(25—27)
5. Those universities which are working
most effectively to implement Government agendas of lifelong learning
and skills for employment will be among those most badly hit by
these proposals. In practice, provision of this type attracts
a mix of first time entrants and those who have already benefited
from higher education, and that mix has educational benefits for
the students, creates a critical mass for the programmes, and
provides financial viability. (13-15, 28-29)
6. It will disproportionately increase bureaucracy.
There would be administratively simpler, fairer and a more effective
way to save £100 million if a simple across-the-board efficiency
gain was applied to the whole of the HE sector. This would ensure
that those universities which are trying to respond to Government
agendas will not be disproportionately hit and would ensure that
all universities will thereby contribute to the up-skilling agenda.
(30-31)
7. It will be perverse in its application:
— EU students will benefit but UK ones
will not.
— Wales, Scotland and Northern Ireland
will not be affected but England will, increasing further the
existing disparities for HE support between constituencies of
the UK. (16)
8. UALL strongly recommends that the policy
is: (para. 32)
— deferred until the 2009 Fees Commission
review, or until the Select Committee reports;
— only applied to those whose qualifications
are of less than five years standing;
— applied to same level full-time study
only, and exempts part-time study; and
— funded by an across-the board HE
sector efficiency gain.
INTRODUCTION
9. The Universities Association for Lifelong
Learning is a long-established organisation, dating from the early
1950s, representing academic and administrative staff who work
with part-time and mature students in higher education, in over
a hundred universities in the UK. The organisation has professional
networks which include, inter alia, continuing professional
development for managers, and work-based learning. Its members
are opposed to the proposed policy on ELQs, as it currently stands,
believing it to be flawed and restrictive, both in concept and
in practical implementation.
THE ARGUMENTS
FOR AND
AGAINST THE
GOVERNMENT'S
DECISION TO
PHASE OUT
SUPPORT TO
INSTITUTIONS FOR
STUDENTS STUDYING
ELQS
10. The impact of the policy, and the unintended
consequences that follow from it, fly in the face of Government
policies on employability, social cohesion and civic engagement,
and, most damagingly for institutions and individuals alike, the
widening participation agenda. In contrast to the ELQ policy,
the Prime Minister stated that the starkest challenge is to provide
"not one chance but second, third, fourth and lifelong chances"
in a society that places "the highest possible cultural value
upon learning".
11. Removing funding from those undertaking
ELQ courses is not the solution: it will damage initiatives to
improve the country's level of vocational skills, economic regeneration,
and the general health and well-being of the population.
12. The policy falls into the trap of addressing
up-skilling needs whilst failing to recognize the importance of
re-skilling in a dynamic economy. It assumes first time learning
is sufficient for life. The ELQ policy fails to recognise the
"shelf life" or obsolescence of qualifications and the
rapid changes in skills needed in the information age, and will
deprive many second time learners of opportunities needed to re-skill
at a time when 70% of the 2020 workforce is already in employment.
13. Allowing, as an exception to the ruling,
those courses carrying employer co-funding is likely to have limited
applicability. Employer contributions to co-funding level 3 students
may work well in regions of the UK where large corporate or industrial
bodies are willing, and can afford, to contribute funding to employees'
education. It will not work in areas where there is a dearth of
such employers, and the SMEs and micro-businesses operating in
economically disadvantaged regions cannot afford contributions
either in funding or in time.
14. The proposal fails to recognise the
reality of people's lives in a rapidly-changing economic/technological
world. Given the diversity of motivations and circumstances under
which people choose to take a second qualification, any damage
done to the re-skilling and continuing professional development
will be difficult to gauge in advance: it is likely only to become
apparent some years down the line when we discover shortages in
skilled personnel. Furthermore the attempt to mitigate the worst
effects of the policy solely though exemptions is likely to create
anomalies within a changing economy.
15. It is both commonplace and entirely
proper to gain an equivalent or lower qualification. For example:
— Mid-career graduates will need, and
indeed should be encouraged, to undertake intensive updating courses.
— Higher skills shortages often have
to be addressed through conversion courses/programmes to enable
movement into industries, eg chemical process industries, and
commerce.
— Many adults are graduates seeking
to re-skill themselves for a career change.
— Large numbers of retired students
in University lifelong learning centres are graduates. After a
lifetime of work, and paying taxes, they can seize the chance
to pursue study for personal interest, but there are significant
economic and community too. They will be healthier, and less likely
to be a burden on health or social services budgets, more likely
to work voluntarily for the public good, and to be a positive
influence on younger family members' attitudes to education.
16. It should be noted that this proposal
will not apply to adults in Scotland, Wales, or Northern Ireland,
thereby creating further higher education inequalities between
the nations which make up the United Kingdom.
THE TIMING
OF THE
DECISION
17. The Fees Commission review will scrutinise
funding for HE students next year (2009). Could not this policy
be deferred and included within the purview of that review? It
would allow more time to appraise the likely impact of the policy
and place it in the context of the totality of future funding
arrangements.
18. At the very least could not the introduction
of the policy be deferred until the report of the Select Committee,
which could be asked to produce its deliberations as a matter
of urgency?
THE TIMING
OF THE
IMPLEMENTATION OF
THE CHANGE
19. The policy is being introduced as a
"fait accompli" and the consultation relates
only to its implementation. The speed with which the policy will
be implemented—from Autumn 2008—means that Universities
are unable to plan for it with due care. Institutions still await
definitive advice as to which students will be penalized by the
policy but will be expected to implement the proposal shortly.
20. The speed with which the proposal is
to be implemented will cause problems for universities. The volume
of employer co-funded and foundation degree programmes, which
will be needed to make up for the shortfall in funding, cannot
be introduced at a speed which will correlate with the timing
of the introduction of this policy.
THE EXEMPTIONS
FROM THE
WITHDRAWAL OF
FUNDING PROPOSED
BY THE
HIGHER EDUCATION
FUNDING COUNCIL
FOR ENGLAND
21. Statistical analysis of which academic/discipline
fields will be hit show a variation between universities, but
some training fields which have currently been identified are:
— some professions allied to medicine,
eg pharmacy;
— teacher training for those entering
post 18 teaching;
— public sector fields, eg police force,
and social work training;
— professional retraining; and
— culture and creative sector, vital
for regional economic regeneration.
22. While we entirely support the notion
of co-funding by employers we know that in some skill sectors
and occupational fields, and some geographical areas of the country,
this culture change will take time. For some areas with few large
corporate employers, and many more SMEs and micro-businesses it
will be difficult to generate co-funding for programmes. The voluntary
and public sector will have difficulty in co-funding without additional
training budgets.
THE IMPACT
UPON STUDENTS,
INCLUDING WHETHER
THE CHANGE
WILL AFFECT
SOME GROUPS
OF STUDENTS
MORE THAN
OTHERS
23. No impact analysis of the policy appears
to have been taken, although HEFCE have acknowledged that part-time
students will be disproportionately affected.
24. However, the effect of the introduction
of the ELQs ruling will mean that a third funding strike, or triple
whammy, will disproportionately harm part-time students. of the
three areas of financial support for students—loans for
fees, direct financial support, and funding—part-time students
are already disadvantaged by the first two.
(i) When the new loan support system for
HE students was introduced this was restricted to full-time students
only. While the government did recently introduce the welcome
provision of some support for those part-timers studying 50% of
a full time course, this did not affect the majority of part-time
HE students.
(ii) With the introduction of top-up fees,
the fee levels for part-time students, though unregulated, inevitably
have risen towards pro-rata against full-time fees, with the result
that part-timers had to pay large fee increases but without access
to the degree of financial support available to full-timers.
(iii) HEFCE funding for programmes was the
one leg of financial support for students which did not discriminate
against part-time or lifelong learning students. With the introduction
of the ELQs ruling, such funding will be removed for ELQs students,
the majority of whom will be part-time.
This policy threatens 20% of part-time
study compared with 2% of full-time study, but the former is the
route which Leitch recognizes will spearhead growth in skills
in the workforce by the 2020 target date.
25. Continuing Education departments within
the pre-92 HEIs, both Russell Group and civics, and analogous
units within the post-92 new universities are citing figures which
indicate that anything from 25—75% of their student populations
will be hit by the ELQs ruling.
26. Case studies of students from our member
HEIs are already demonstrating that the following groups will
be disproportionately disadvantaged:
— women returning to employment, having
brought up children after graduating many years before. In a number
of our member HEIs the percentage of female students who would
be hit by the ELQs ruling ranges from 58-65%;
— learners in small or rural communities
where the choice of provision is limited;
— all those wishing to update the currency
of their skills training and knowledge of developments in their
vocational fields;
— older learners wishing to keep active,
healthy and be contributors to their communities; and
— carers returning to the employment
market;
all these stand to lose disproportionately
from these proposals.
27. The potential damage to these and other
cohorts of learners, and to universities and colleges providing
for them, poses a very serious threat. The following examples
are illustrative of the type of students who would no longer be
funded to undertake HE level study, with obvious consequences
for the individuals, their families and the economy.
(i) Susan, age 39, currently unemployed single
parent with two children:
— gained a BA degree in English at
21;
— wants to rejoin the labour market
now the children are both at school;
— wishes to study a vocational BA programme
part-time at her local University.
— ELQ—Cannot be funded by
HEFCE
(ii) Ian, age 51, currently working in the
private sector:
— gained a MSC in Business Management
aged 35;
— wants to "change direction"
and "put something back" into the community;
— wishes to retrain as a youth worker
to work with disaffected Muslim youths.
— ELQ—Cannot be funded by
HEFCE
(iii) Rita, age 47, long-term unemployed
due to disability sustained in the workplace; and currently volunteering
in a local voluntary organization:
— gained a BA through the OU in her
30s;
— would like a qualification in community
development, with the aim of paid employment using the skills
and knowledge gained through volunteering;
— wishes to study for a BA in community
development.
— ELQ—Cannot be funded by
HEFCE
(iv) Mary, age 44, currently working in Tesco
on the checkout, with a history of mental health difficulties
resulting in a much disrupted experience of employment:
— gained a BA in History aged 21;
— wants a vocational qualification
in business studies to improve her employment prospects and to
encourage her children to see "you don't have to end up in
Tesco's";
— her employer is not interested in
financing her study as she clearly wishes to improve her opportunities
to leave the company.
— ELQ—Cannot be funded by
HEFCE
(v) Fred, age 52, made redundant and finding
it impossible to gain employment in an industry that no longer
needs his skills; has lost confidence and motivation:
— gained an HND in electrical engineering
aged 20;
— wants to reskill in ICT;
— wishes to study for a degree in computer
technologies and artificial intelligence.
— ELQ—Cannot be funded by
HEFCE
THE IMPACT
OF THE
CHANGE UPON
INSTITUTIONS
28. It is clear that those institutions
which have enthusiastically embraced the Government's agendas
of lifelong learning and higher skills for employment will be
among those most badly hit by this proposal, and that the provision
of such opportunities will be undermined. In practice, provision
of this type attracts a mix of first time entrants and those who
have already benefited from higher education. If some students
can no longer be funded for this provision then demand will be
adversely affected and some courses will have to close because
of a dearth of a critical mass of students for that course. For
example, a course normally enrolling fifteen students will not
run if six are unfunded owing to ELQ changes, however deserving
the remaining nine learners may be. The resulting major reduction
in provision will seriously damage the infrastructure necessary
to a lifelong learning culture, and in particular, to part-time
students. It carries too many risks both to the economic regeneration
of the country and to the general well-being of the adult population.
29. While the proposals for planned allocations
for part-time study are to be welcomed, the proposed re-allocation
of £20 million is unlikely to be sufficient to compensate
for the withdrawal of funding.
30. The practical implementation of this
policy will create a major bureaucratic burden which would negate
many of the benefits of reduced regulation achieved in recent
years, as promoted by the Higher Education Regulations Review
Group (HERRG). There will be a need to undertake further checks
on the qualifications of students, beyond what is currently needed
for admissions purposes, and to ensure that they are correctly
interpreted and accurately recorded. In particular, we believe
that:
— non-disclosure of qualifications
will become a significant issue. If students choose not to disclose
their previous qualification levels universities currently have
no way of making them do so. institutions will need good practice
guidance as to how far they are expected to probe an applicant's
entry qualifications; and
— institutions will need access to
a central database of current and past qualifications and their
equivalences, including European as well as UK qualifications,
to enable the policy to be implemented equitably;
31. In order to raise the funding for the
Government's up-skilling agenda, it would be an administratively
simpler, fairer and more effective way to save £100 million
if a simple across-the-board efficiency gain was applied to the
whole of the HE sector.
THE RECOMMENDATIONS
FOR CHANGES
WE WOULD
WISH DIUS AND
HEFCE TO INTRODUCE
TO THE
POLICY
32. UALL would urge the Select Committee
to recommend that the policy is:
— deferred until the 2009 Fees Commission
review, or at least until the Select Committee has reported on
its inquiries;
— only applied to people who are graduates
of less than five years standing. It should be confined to those
whose qualifications were awarded less than five years previously.
After that period beyond graduation, people should be entitled
to a supported PT place in HE;
— applied to same level full-time study
only, and exempts part-time study. If the policy is to limit public
funding entitlement to one HE experience then this should be focused
on FT. That is where the bulk of the subsidy is made, through
grants, loans, funded places; and
— funded by an across-the board HE
sector efficiency gain. It disproportionately affects those universities
which are succeeding in engaging employers, particularly through
part-time provision. Ensure that all universities will contribute
to the up-skilling of those students identified by Government.
January 2008
55 estimate based on UUK figures for 2005-06 showing
the 108% increase over the previous decade of the numbers of PT
students in HE as opposed to the 27% increase in FT students. Back
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