Select Committee on Innovation, Universities and Skills Written Evidence

Memorandum 71

Submission from the University of Liverpool


  The submission below forms an institutional response from the University of Liverpool to the call for evidence made by the Innovation, Universities and Skills Committee, to inform the Committee's inquiry into the Government's decision to phase out support given to institutions for students taking equivalent or lower qualifications.

  The submission highlights the University's views that:

    (i)  The ELQ policy appears inconsistent with other stated aims for the Higher Education sector, particularly around lifelong learning and reskilling.

    (ii)  The absence of consultation on the policy, other than its implementation, has been unhelpful.

    (iii)  The timing of the policy's implementation will penalise institutions for strategic decisions taken in good faith prior to its announcement.

    (iv)  The methodology proposed to inform this policy's implementation raises issues.

    (v)  It would welcome a broadening of the range of subjects exempt from this policy.


  1.  The University of Liverpool is deeply concerned about the decision to withdraw the support given to institutions for students taking equivalent or lower level qualifications (ELQs) to that which they have previously attained. We consider the policy to be undesirable in itself and inconsistent with previously stated policy aims for the Higher Education sector. Moreover, the proposed methodology for its implementation raises a number of concerns.

  2.  Guidance notes suggest that the inquiry will focus on five key areas, which we address in turn below.


  3.  Whilst we can see how on the face of it this policy may look attractive, we consider it to be contrary to other goals set for the Higher Education sector by government around lifelong learning.

  4.  The Government, HEFCE, universities and employers have all consistently expressed their support for the concept of lifelong learning, particularly in the context of a knowledge based economy.

  5.  Universities have a vital role in the above, skilling and then re-skilling the workforce. Their capability to do this would be severely damaged should the policy to withdraw funding from ELQs be implemented. Almost by definition, those members of the workforce who are re-entering HE, either to requalify, or for continuing professional development purposes—that is the very same individuals that the Government is relying on to provide the flexibility and responsiveness necessary to keep the UK economy competitive—will find state support for their efforts withdrawn.

  6.  It has been suggested in the past that co-funding from employers may go some way to meeting this funding shortfall. However, we are still a long way from a culture where co-funding is common, and it seems unfortunate to move forward in this way before this method of funding has been more fully developed. It is also important to remember that not all students studying for an ELQ to retrain will currently be in employment and will therefore not have access to employer co-funding. We will return to matters of funding, and the impacts this will have on students and universities in sections E and F below.


  7.  The lack of notice given prior to this policy announcement and the subsequent timescale for its implementation are problematic in the extreme. In this context, we wish to register our strong and clear objection to the fact that, until now, there has been no wider consultation with universities on the policy itself, discussion being confined to its implementation. We find this wholly unacceptable.

  8.  That the policy's implementation will begin in 2008 is a particular issue. The fact that the funding environment has been changed without institutions having the opportunity to realign their plans means that institutions have effectively been penalised for following strategic plans they have created and begun to implement in good faith.

  9.  In order to compensate for the lost income, institutions may wish to increase fee levels for ELQ students. There is only a short timescale for institutions to consider this if they are to take decisions that will inform their fees policies for 2009 entry.

  10.  Should the policy proceed, the way HEFCE intends to implement it also raises a number of issues.

  11.  HEFCE proposes to use 2005-06 HESA and ILR data to model the number of ELQ students in the system. This data is imperfect and gives rise to three key concerns:

    (i)  A large number of students whose records were interrogated do not contain information on their previous qualification. This prevents an accurate set of ELQ data from being obtained. We would therefore view as essential the need to refine existing modelling. However, whilst we strongly support the need for this process to be undertaken, we are concerned about the additional administrative burden which will be placed on HEIs in clarifying these "unknowns" and that this appears to be disproportionate in the context of better regulation.

    (ii)  There has been no reassurance given that sufficient analysis has been undertaken to determine that 2005-06 can be assumed to be representative of a typical year in terms of the overall proportion of students in higher education registered for ELQs.

    (iii)  We would like to see clear evidence that robust trend analysis has been undertaken to determine the proportion of ELQ students registered at individual institutions. Without this, there is the potential for funding to be based on one year's data (2005-06) which represents a mid-point in a migratory trend, resulting in inappropriate levels of core T funding being withdrawn from individual institutions.

  12.  HEFCE proposes to provide safety net funding to ensure that institutions' funding remains at least at 2007-08 levels. We strongly support the proposal to provide safety net funding to protect universities' core income. However, we would argue that, in order to ensure existing levels of activity can be maintained, this guarantee should be provided in real terms rather than in cash terms.

  13.  HEFCE has yet to indicate what the resource saved through this policy will be used for. We would strongly suggest that it should be redistributed directly to the sector, and that reassurances should be provided to this effect, along with a clear indication of the areas that HEFCE would anticipate supporting. (In this context, we note that the amount of savings made through implementation of this policy will, according to HEFCE modelling, far outstrip the £100 million saving estimated by Government).


  14.  Whilst noting that using the Student Fees Regulations to identify exemptions to the ELQ policy, as HEFCE proposes, provides at least an initial base from which to progress if the policy must be implemented, we would argue that useful consideration could be given to broadening these criteria. Given that the premise underlying exemptions is clearly concerned with the wider national interest, national infrastructure and contribution to the economy, it would seem appropriate at the very least to look at other professionally accredited subject areas. At Liverpool, for instance, provision that is fully professionally accredited, but not exempt from this policy, includes amongst others Engineering, Psychology and Archives Management. The skills with which we equip our graduates in these areas will in many cases flow directly into the relevant sectors of the workforce and the economy.

  15.  We would also contend that it is inconsistent to exempt Foundation Degrees as a class of award, whilst limiting other exemptions to a very limited range of subjects of study. We see little difference between an ELQ student registered on a Foundation Degree (ie one that will provide the student with a particular work-relevant set of skills) and one registered on a full degree which will also provide them with an—albeit different—set of skills to take into the workplace.


  16.  The obvious result of this policy is that, in order to make up the loss in funding, institutions will increase fees for ELQ students and that these individuals will subsequently be discouraged from applying to return to university to retrain or pursue continuing professional development. This policy would make lifelong learning an increasingly costly habit.

  17.  We also have a particular concern about a secondary impact of this policy—the way that it will, due to the disproportionate affect it has on part-time provision (see F below), have a differential impact on those groups of students who are only able to access higher education by this means. In this way there could conceivably be a negative impact on the widening participation cohort, and for the same reasons, we can expect this policy to have a significant gender bias. By limiting the scope for universities to offer cost-effective part-time provision, we limit access to HE for those with family and other carer responsibilities, a group that is still predominantly female.

  18.  We appreciate that these consequences are entirely unintended and can seem counterintuitive (particularly in respect of widening participation), but it remains the case that anything that impacts negatively on part-time provision, as is the case with this policy, will make it difficult for those students for whom the choice is between part-time study or no study at all.


  19.  This policy and its implementation will have four key effects on institutions:

    (i)  The policy will make it harder for them to contribute to the lifelong learning agenda:

    We believe that the case for this (discussed in B above), is self-evident, and consider this to be the key failure of this policy.

    (ii)  It will force institutions to consider whether it is appropriate to charge differential fees for different categories of home student, and if so at what level:

    As previously noted, it is only to be expected that universities will seek to make up the shortfall in their income caused by this policy. (Even though, HEFCE have indicated that the savings generated by this policy will remain in the sector, there is no guarantee that institutions will have returned to them their lost funding in another form). The obvious way to do this is for institutions to charge differential fees for ELQ students. This would lead to a divisive situation whereby students would be paying different fees to undertake precisely the same programme of study.

    (iii)  It will limit their capability to provide or grow cost effective part-time provision:

    The withdrawal of funding for ELQs is particularly relevant to the part-time market (approximately 70% of the number of ELQ students that the reduction of funding will be based on is part-time). In providing a supplement to core funding for teaching to support part-time provision to mitigate the effects of this policy, HEFCE has acknowledged the implementation will make it harder for universities to offer cost effective provision in this way. More worryingly, if an institution wished to grow in this area, for example to support lifelong learning or widening participation, any additional numbers would inevitably include ELQ students. As such the current proposals will require the institution in question to take a strategic decision to either subsidise any increase in student numbers or to charge a higher, differential fee to ELQ students and risk suppressing demand, again damaging the cost effectiveness of the provision. It is also worth remembering that in the same way that students particularly associated with part-time provision will be disproportionately affected as a result of this policy, so too will those institutions that specialise in this area, Birkbeck and the Open University being the two most obvious examples. Even if money is earmarked for recycling back to these institutions through additional student numbers or any other means, presumably it will take a fundamental shift in mission for them to be able to refocus provision in a way that will qualify for state support.

    (iv)  It will limit institutions' capability to grow strategically important and vulnerable subjects.

    A similar logic applies to strategically important and vulnerable subjects. The supplement to core funding for teaching in respect of these subjects protects this type of provision, but masks the fact that the amount of growth available is limited. Again, if an institution wished to develop provision in one of these areas it would have to take a strategic decision to either subsidise any increase in student numbers or to charge a higher, differential fee to ELQ students and risk suppressing demand.

  20.  Whilst we acknowledge HEFCE's desire is to support rather than incentivise provision in both the part-time and SIV areas, the proposals as put forward limit the range of strategic options available to institutions.


  21.  We have included many of the remarks made above in our response to HEFCE's consultation on the policy's implementation and hope they will be considered as part of that process, but would like to record how valuable we have found this opportunity to discuss the desirability and effects of the policy itself—for the first time—as part of the Committee's work.

  22.  In concluding, we wish to reaffirm our strong objection to:

    (i)  The policy itself and the way it makes it increasingly hard for universities to achieve their missions and the tasks required of them by government and the economy, particularly around lifelong learning and reskilling.

    (ii)  The absence of any consultation on the policy, other than over its implementation, and that only months before its effects would begin to be felt.

    (iii)  The questionable basis on which the policy will be implemented.

    (iv)  The way it in some cases penalises strategic decisions taken in good faith by institutions prior to its announcement.

    (v)  The way the policy limits the range of strategic options available to institutions.

  23.  We hope that the Committee finds this submission useful, and would be happy to give further information if required.

January 2008

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