Memorandum 68
Submission from the Institute of Education,
University of London
The Institute of Education is a specialist institution
and a world class centre of excellence for teaching, research
and consultancy in education and related areas of social science
and professional practice.
EXECUTIVE SUMMARY
Much of the public debate around this policy
has focused on the impact of ELQ proposals on under-graduate provision
and, in particular, on students and providers of part-time courses
such as those offered at Birkbeck and the Open University. It
is clear, however, that a number of other institutions will be
negatively affected, such as those with specialist missions, a
predominantly post-graduate focus and those offering professionally
relevant qualifications. Although this may be an unintended consequence
of the ELQ proposals, it is crucial, amidst the current attention
to large-scale providers of part-time undergraduate degrees, that
we do not lose sight of the important policy ramifications for
specialist institutions.
The Institute welcomes the proposed provision
of "safety net" funding to maintain each institution's
grant at a comparable cash level to that of 2007-08, but is concerned
that this would, in fact, represent a reduction in institutional
funding in real terms.
We have a number of further concerns about the
proposals as they currently stand. In particular, there is a need
to:
— Clarify the notion of "level"
in the application of the policy in order to address those instances
where an apparently equivalent or lower qualification represents
a genuine and necessary progression from a previously held qualification.
— Clarify the status of teachers and
lecturers in Further Education (FE) in terms of:
(a) confirmation that Initial Teacher Training
(ITT) for FE teachers (whether via the PGCE or through other routes)
will be covered by the exemption that is proposed for school teachers
whose funding is provided by the Training and Development Agency
for Schools (TDA).
(b) confirmation of support, equivalent to that
proposed for school teachers, for qualifications that develop
FE teachers' professional understanding and skills.
— Confirm that the exemption of ITT
for school teachers applies not only to entry to study for an
"M" level PGCE, but also to students' future study at
"M" level in the context of a professionally relevant
Master's degree.
— Clarify whether HEFCE plans to provide
an alternative funding stream to enable institutions to fund courses
for university lecturers studying for ELQs which support the development
of their teaching skills.
RESPONSES TO
THE COMMITTEE'S
QUESTIONS
1. ARGUMENTS
FOR AND
AGAINST THE
GOVERNMENT'S
DECISION TO
PHASE OUT
SUPPORT TO
INSTITUTIONS FOR
STUDENTS STUDYING
ELQS
1.1 In this submission, however, we address
those issues which, in particular, affect the Institute of Education
and similar institutions.
1.2 Our own concerns nevertheless reflect
a more widespread unease that the Government's decision is at
odds with a broad range of national educational priorities, not
least the recommendations of the Leitch Review, the need for a
professionalised teaching force in the post-compulsory sector,
the Government's 14-19 agenda, and the widening participation
agenda for the university sector.
2. TIMING OF
THE DECISION
AND OF
THE IMPLEMENTATION
OF THE
CHANGE
Timing
2.1 The Government's decision came at extremely
short notice, with the consequence that the Institute and other
education providers were obliged to complete a great deal of detailed
and considered work in a very short space of time. The policy
process itself might have benefited from a consultation with education
providers a year in advance of the decision, rather than the retrospective
HEFCE consultation on the interpretation and implementation of
the Government's policy. Whilst HEFCE was able, within the limited
consultation period, to carry out some analysis of the impact
of their proposals on disproportionately affected students (eg
in terms of gender, age, regional differences), these issues would
certainly benefit from further detailed analysis.
Implementation
Safety net funding
2.2 We welcome the proposed provision of
"safety net" funding to maintain each institution's
grant at a comparable 2007-08 level in cash terms. It is vital
for institutional stability, and consistent with HEFCE policy,
that "safety net" funding is provided. However, this
"real terms" allocation would, in fact, represent a
loss of institutional funding. We would also like the IUS committee
to note that not all institutions have equal flexibility with
regard to the re-orientation of their business over the period
in which "safety net" funding is provided. Specialist
institutions, in addition to being disproportionately affected
by the policy, are particularly limited in this respect, and further
mitigation may be required in these instances to maintain institutional
stability.
Level of qualification/progression
2.3 We are also concerned about the crude
notion of "level" being employed by HEFCE in its interpretation
of the proposed policy. There are clear instances where an apparently
equivalent or lower qualification represents a genuine and necessary
progression from a previously held qualification. The Institute
believes that the definition of level being applied will prove
a disincentive to institutions offering qualifications that provide
a bridge between levels (eg specialist post-graduate certificates
and diplomas) which aid progression and skills development. A
more sophisticated model for qualifications is needed which recognises
that some of the courses likely to be adversely affected by the
policy as it stands actually aid the development of professional
skills and understanding and thus constitute genuine progression
for the individuals concerned.
3. EXEMPTIONS
FROM THE
WITHDRAWAL OF
FUNDING PROPOSED
BY THE
HIGHER EDUCATION
FUNDING COUNCIL
FOR ENGLAND
3.1 This submission highlights a number
of neglected issues concerning the ELQ proposals. These include
the impact of the proposals on post-graduate study and the development
of high level skills in general, as well as on specialist institutions
pursuing the delivery of professionally relevant qualifications.
3.2 While we welcome the proposed exemptions,
not least in relation to school teaching, we believe that the
impact of the proposals on the sector as a whole may not be susceptible
to adequate mitigation through the application of exemptions.
Nevertheless, if exemptions are to provide a way forward, HEFCE
should at least develop a broader set of exemptions which acknowledges
that the ELQ proposals will adversely affect a wide range of public
service professionals, including educational psychologists and
pharmacists.
3.3 The Institute wishes to draw attention
to three areas of particular concern for the education sector:
— the position of teachers and lecturers
in Further Education;
— the implications for professionally
relevant further academic study on the part of qualified teachers
generally; and
— the professional development of university
teachers.
The impact on Further Education (FE)
3.4 FE provision constitutes a key element
in the delivery of the Government's 14-19 and skills agendas.
The professionalisation of the skills workforce has been identified
as a policy priority. However, in spite of a number of requests,
DIUS has so far refused to confirm that Initial Teacher Training
(ITT) for FE teachers (whether via the PGCE or through other routes)
will be covered by the exemption that has been announced for trainee
school teachers funded through the Training and Development Agency
for Schools (TDA).
3.5 Furthermore, while the TDA have an identified
funding stream for Post-graduate Professional Development for
school teachers, which the TDA believes will be exempted from
the policy, it is not clear that HEFCE will be able to fund FE
teachers studying for ELQs to develop their professional understanding
and skills and who would previously have taken up publicly-funded
places. As a consequence, teachers in the FE sector could find
themselves disadvantaged in comparison with their colleagues in
statutory education, in terms of their professional standing and
development, at a time when both groups are being encouraged to
collaborate, eg in the development and provision of the Government's
new Diploma qualifications.
3.6 As FE providers are likely to be key
partners in delivering the further widening of participation that
the ELQ proposals are designed to promote, these likely impacts
on FE provision appear to be a wholly counter-productive unintended
consequence. As a result, the explicit exemption of ITT provision
for the FE sector, together with confirmation that the professional
development of FE teachers will be given equal priority to that
of school teachers, are urgently needed.
Professionally relevant further academic study by
qualified teachers
3.7 The exemption of ITT for school teachers
(and hopefully for FE teachers) appears to be predicated upon
the PGCE being equivalent to an undergraduate award. The exemption,
therefore, applies upon entry to a PGCE course. Thus holders of
undergraduate degrees who later take a PGCE will be deemed to
be studying for an ELQ but subject to an exemption. Across Higher
Education ITT providers, the PGCE qualification has, in most cases,
recently been formally defined as an "M" level award,
either in whole or in part. It is therefore vital that the exemption
for ITT applies not only on entry to study for a PGCE (or other
ITT qualification), but also in relation to students' future study
at "M" level, so that they can continue to be funded
to complete a full Master's degree in a professionally relevant
field.
3.8 Without this exemption, the policy is
likely to have negative consequences for professional progression
beyond the PGCE for teachers taking courses that will develop
their professional understanding. This would impact negatively
upon the professionalisation and development of the compulsory
and the post-compulsory teaching workforce at a time when a highly
qualified teaching force has been recognised as a key element
of world class education systems.
Training for teachers in Higher Education
3.9 The logic applied to the compulsory
(and hopefully the FE teaching workforce) in relation to the ELQ
policy is not being applied to university teachers seeking to
develop teaching skills. Under the current proposals HEFCE would
not fund HE lecturers with high level qualifications in their
academic subject specialisms studying for ELQs which support the
development of their teaching skills. Such students would previously
have taken up publicly-funded places. In the absence of alternative
funding streams to support this unplanned change, this threatens
the future viability of programmes supporting the development
of university teachers and will thereby undermine the professional
development of university teachers and lecturers, many of whom
will be instrumental in the successful delivery of the Government's
skills and widening participation agendas.
4. IMPACT UPON
STUDENTS, INCLUDING
WHETHER THE
CHANGE WILL
AFFECT SOME
GROUPS OF
STUDENTS MORE
THAN OTHERS
4.1 The Government's decision is likely
to affect a number of students disproportionately. In particular,
there appears to be a differential impact on students studying
in London. Analysis by LondonHigher shows that, of the institutions
most affected (in terms of the percentage of income), eight of
the top 10 and 15 of the top 20 are London institutions. In the
majority of these cases, the institutions affected are also those
with a specialist remit. There is thus a disproportionately negative
impact on the London offer and more specifically the specialist
offer. This runs contrary to the public interest as these offers
provide skills for the London workforce (43% of jobs in London
require higher-level skills, compared to 30% in the rest of England
and Wales). As a consequence, these proposals are likely to result
in a significant reduction in choice and access to appropriate
level courses for London students.
4.2 Gender and age participation is also
likely to be negatively affected. Female graduates re-entering
the job market after raising a family and/or older graduates needing
to up- or re-skill will usually not have the benefit of employer
support in doing so. The impact on older students is especially
relevant to this Institute. Of all our students on Master's courses,
32% are over 40 and 12% are over 50 years of age. However, 49%
of ELQ students on Master's courses are over 40 and 18% are over
50. Consequently, our older students will be disproportionately
affected by the introduction of the ELQ policy as currently defined.
5. IMPACT OF
THE CHANGE
UPON INSTITUTIONS,
WITH PARTICULAR
REFERENCE TO
THE LONG-TERM
IMPLICATIONS FOR
SPECIALISED INSTITUTIONS
SUCH AS
THE OPEN
UNIVERSITY AND
BIRKBECK COLLEGE
LONDON
5.1 We would like the IUS Select Committee
to keep in mind that specialised institutions are diverse. Thus,
an institution may have a specialism which is disciplinary and
not simply related to mode of study. The ELQ proposals may have
different consequences for institutions with a specialist disciplinary
focus than for institutions with a specialist mode of study. The
legitimate highlighting of challenges faced by institutions, such
as Birkbeck and the Open University must not be allowed to divert
attention from the equally important challenges faced by subject
specialist institutions, such as the Institute of Education.[83]
This is particularly important given that institutions with a
disciplinary focus often serve predominantly post-graduate students,
or offer post-graduate courses with professionally relevant qualifications,
and as such tend to have a significant impact on the UK's economic
competitiveness.
5.2 It is clear that the ELQ proposals will
impact disproportionately on these specialist institutions. Specialist
institutions would make up over half those institutions experiencing
the largest drop in income as a result of the current proposals.
The weakening of their financial sustainability would have a number
of consequences for the sector and for the delivery of several
Government educational priorities. The policy would undermine
HEFCE's strategic aim to maintain a diverse sector. The proposals
threaten the skills agenda by undermining some of the institutions
most able, through their specialist missions and professional
links, to contribute to its development and delivery.
5.3 Specialist institutions are not easily
able to mitigate the consequences of the ELQ proposals. One option
would involve developing their offer in a way that would access
funding diverted from ELQ students. However, the nature of specialist
institutions and their markets is inherently less flexible than
that of multi-faculty providers. It has been suggested by DIUS
that this Institute might develop significant under-graduate level
provision in response to the ELQ policy. However, there is limited
scope to develop such courses without diluting the Institute's
specialist mission in a way that is unlikely to be in the public
interest. Such a development is also unlikely to be cost-effective.
For example, transforming the Institute's world-leading research
library into an undergraduate library for a relatively small number
of students would not seem a sensible use of limited resources.
January 2008
83 In fact, some institutions, including this Institute,
have both a specialist subject focus and a predominantly part-time
student body and are therefore affected by the policy in both
respects. Back
| 
