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
(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
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 purposesthat
is the very same individuals that the Government is relying on
to provide the flexibility and responsiveness necessary to keep
the UK economy competitivewill find state support for their
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.
C. TIMING OF
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
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 analbeit
differentset of skills to take into the workplace.
E. THE IMPACT
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 policythe 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.
F. THE IMPACT
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
(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
itselffor the first timeas part of the Committee's
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