Memorandum 73
Submission from Universities UK
EXECUTIVE SUMMARY
Universities UK welcomes the opportunity to
make a submission to this Enquiry. It is clear from our member
higher education institutions (HEIs) within England that these
proposals have caused considerable unease.
Universities UK understands the principle behind
this policy which is to provide more opportunities for students
wishing to take a first degree, but we are concerned that there
will be the unintended consequences in taking this approach. We
are also concerned that it may damage the Government's efforts
to promote lifelong learning if the change means potential students
cannot afford to pay to re-skill with relevant qualifications
and professional development. First time students may also be
denied opportunities, as some courses may no longer be viable
without funded ELQ students.
Universities UK has a number of specific concerns
with this policy:
— The lack of prior consultation with
the sector.
— Universities are effectively being
"fined" retrospectively for decisions they made in good
faith to admit ELQ students in previous years.
— The impact on (i) part-time provision,
and (ii) on universities specialising in part-time provision.
This is likely to have an especially disruptive effect on the
Open University and Birkbeck College, but also a significant impact
on a large number of other institutions.
— The adverse effect of (i) failing
to exempt specific subjects and courses which are of acknowledged
economic, social and cultural value to the UK, and (ii) the impact
on the universities which deliver this provision.
— A potential permanent increase in
the administrative and regulatory burden on universities across
a range of activities, which will divert resources from other
key activities.
UUK's proposals to mitigate the effects of the
policy are:
— That universities that have lost
ELQ student numbers and funding should be given "preferential
status" to bid for an equivalent number (and value) of funded
additional student numbers against the Government's re-stated
priorities (when these are known). These priorities should be
defined broadly (within the category of first time learners) so
that a diverse range of affected HEIs have a realistic change
to recoup the funded HEFCE places they are losing under this policy.
— That consideration should be given
to a number of additional exemptions of subject areas that are
reliant to a significant extent on ELQ recruitment, and which
are of particular value to the economy, society and culture of
the nation.
INTRODUCTION
1. The university sector has a long-established,
key role in supporting the Government's economic, social and cultural
policies. Universities have successfully carried out this role
over many years, through a process of ongoing dialogue and timely
consultation with Government and its agencies. This close relationship
has allowed universities to plan on an individual, autonomous
and entrepreneurial basis how best to respond to Government policy
objectives, given their particular profiles and missions. Universities
are able to deploy effective solutions in support of Government
policy, provided that institutions are consulted early and hence
are able to plan their responses in an efficient and timely manner.
For example, universities have developed a range of effective
and flexible responses to work towards Government objectives in
the areas of life-long learning, up-skilling and re-skilling of
the workforce, demand in key shortage subjects, and increasing
and widening participation in higher education, amongst others.
2. Universities understand the Government's
stated principle of re-directing public money from funding ELQ
students to those who do not have a first HE qualification. It
is against this background that UUK consulted its HEI members
to seek their views on the ELQ proposals. UUK's members are drawn
from a diverse HE sector, and the impact of the ELQ proposals
will have a similarly diverse effect right across the sector.
Many universities indicated they have major issues with the proposals,
such as (i) those teaching large numbers of part-time students,
and (ii) those HEIs that are significant providers in the health
sciences, business studies, creative & performing arts, and
other areas, including highly specialist "niche" providers
such as the conservatoires.
3. UUK also notes that the phasing-out of
ELQ funding in England will widen still further the methodological
differences between HE funding in England, Scotland, Wales and
Northern Ireland.
IMPACT OF
THE WITHDRAWAL
OF ELQ MAINSTREAM
FUNDING
4. Whilst acknowledging the Government's
intention to re-focus £100 million of mainstream funding
by 2010-11, the Government's recent decision to phase-out funding
to universities from 2008-09 for students pursuing ELQs could
seriously hinder many universities' efforts to meet Government
objectives across already established key policy areas such as:
— The life-long learning agenda.
— Important shortage subjects.
5. Universities are concerned about the
sudden and adverse impact on their strategic plans in terms of,
for example:
— Admissions policies for Home/EU students.
— Course delivery and viability, particularly
as regards flexible and part-time provision.
— The overall student learning experience.
— Staffing levels and infrastructure
usage.
— The integrity of universities' financial
and academic plans generally.
6. According to HEFCE's figures, it is clear
that some universities will be more seriously affected than others,
particularly those with large numbers of part-time undergraduate
and (notably) postgraduate taught students. Some regions also
appear to be disproportionately affected, such as universities
across London and the South East.
For example, UUK understands that:
— 71% of Full Time Equivalent students
modelled as affected by the ELQ policy will be part-time students.
— 29% of all student FTEs modelled
as affected by this policy will be postgraduate students.
— The London and South East regions
together will account for 41% of the ELQ monies to be phased-out.
7. HEFCE's proposals to apply mitigatory
factors selectively across the sector are helpful as far as they
go towards alleviating the impact of elements of the ELQ policy.
However, these mitigatory factors appear to be limited in their
scope, and consequently in their effectiveness, because of the
tight financial constraints on HEFCE to deliver the £100
million target saving (Section 11, HEFCE ELQ "FAQs"
http://www.hefce.ac.uk/faq/elq.htm). For example, although HEFCE's
proposed £20 million supplement to the part-time targeted
allocation is welcome, it will only partly alleviate the impact
of the ELQ policy on part-time funding in HEIs.
KEY ISSUES
AND PRINCIPLES
"Retrospective Fine"
8. The Government's decision to phase-out
mainstream funding for ELQ students from HEFCE funded courses
at universities sets a worrying precedent. The net effect of the
policy will be to "fine" individual universities retrospectively
for decisions each made legitimately and in good faith to admit
ELQ students in previous years.
9. This retrospective "fine" is
predicated on 2005-06 student data which lacks sufficient detail
(particularly with regard to discriminating between postgraduate
qualifications), is possibly unrepresentative of the current student
profile (due to the subsequent introduction of variable tuition
fees), and was not originally collected for the purpose to which
it is now being applied. Neither the Joint Academic Coding System
(JACS) for subject classification, nor Higher Education Statistic
Agency (HESA) data collected for 2005-06, can necessarily be regarded
as being fit for the purpose of implementing this policy.
10. The policy is being imposed on universities
through a reduction in their core public funding allocation for
teaching (ie "HEFCE funded places"). Without prior consultation
individual universities were unable to (i) evaluate and discuss
with HEFCE the impact of this policy change on their strategic
plans, and (ii) raise any issues of course provision, academic
planning, and financial sustainability.
Lifelong Learning
11. The ELQ funding policy could run counter
to the furtherance of a number of stated Government policies.
The Government's agendas to promote life-long learning and re-skilling
(and in some cases up-skilling) of the workforce could be adversely
affected, since the proposals will impact particularly on part-time
and flexible-study students who are seeking to re-train and acquire
new skills within a rapidly developing, flexible, knowledge-based
economy.
12. There are several examples of particular
professions of value to the economy, society and culture where
recruitment will be affected by these proposals. These include
pharmacy, clinical & other psychology courses, creative &
performing arts, and continuing professional development for education
workforce and healthcare professions. These are all courses where
high proportions of students are either (i) undertaking re-training
in order to embark upon a change of career (for example, many
students in the performing arts in general, and actors and singers
in particular, need to undergo vocational training after their
first degree), or (ii) require a further qualification (for example,
continuing professional development study in the education workforce
and health professions, where individuals undertaking post-qualification,
professional studies to enhance their expertise will no longer
be eligible for public funding).
13. The consultation being conducted by
HEFCE concerns only the specific proposals to implement the withdrawal
of funding for ELQ students, and offers scant opportunity for
the sector to offer strategies or initiatives as an alternative
to HEFCE's methodology. Universities have suggested that the implementation
of the withdrawal of ELQ funding should be delayed, possibly until
2010-11, to allow institutions to manage their own transition
to a new steady state. They have also suggested that withdrawal
of funding should be for only five years or so after which ELQ
students would become eligible for further public funding, thus
limiting the impact on those in mid career or returning after
raising a family.
Part time Students
14. The withdrawal of ELQ funding will have
(per HEFCE's figures) a serious and disproportionate effect on
part-time and flexible provision across the sector, and a particularly
marked effect in universities, such as the Open University and
Birkbeck College, whose mission and profile have led them to specialise
in this area, The provision by HEFCE of a £20 million supplement
in 2009-10 is to be welcomed, but the review of this supplement
in 2011-12 introduces uncertainty, given the lead-time necessary
for universities to secure other sources of income for this provision,
or secure additional non-ELQ student numbers through competitive
bidding.
Regulatory Burden and consultation
15. Because of the lack of prior consultation,
consideration of the impact of the ELQ proposals has already required
much staff input in terms of time and effort over a concentrated
period. The implementation of the Government's policy will divert
universities' resources and permanently increase the administrative
and regulatory burden across a range of activities, by, for example,
adding further complexity to the business planning and marketing
of courses, and the recruitment and enrolment of students. Further
issues surround how HEFCE will address cases where a student has
been admitted as a non-ELQ student eligible for public funding
by a university acting in good faith and based on information
available at the time, but is subsequently identified as falling
within the non-fundable ELQ criteria.
16. Universities UK would encourage Government
to engage constructively with the sector on all future policy
proposals prior to their adoption, using established consultative
mechanisms. This will enable universities to pro-actively inform
policy decisions, strive to avoid any "unforeseen consequences"
in their implementation, and plan to implement Government policy,
in an effective, efficient, timely manner.
KEY MITIGATORY
PROPOSALS FROM
THE HE SECTOR
UUK has strongly urged HEFCE and the Government
to consider adopting a number of sector-led proposals in order
to ameliorate some of the most damaging aspects of the policy.
These are as follows:
Preferential funding
17. Universities that have lost ELQ student
numbers and funding should be given "preferential status"
to bid for an equivalent number (and value) of funded additional
student numbers against the Government's re-stated priorities
around widening participation and employer co-funded provision.
These priorities should be defined broadly enough to allow the
diverse range of HEIs affected by the ELQ policy a fair chance
to bid successfully under the new priorities. This would be on
the basis that only if that university's bid were unsuccessful
would numbers of additional student numbers be released into a
wider "pool" open to other universities to submit competitive
bids. This modification would help to reduce the relative impact
of the ELQ funding decision on a given university in a proportionate
manner, assist with sustainability, and enable a university to
plan the re-alignment of its strategic plan with the Government's
new policy emphasis
Additional Exemptions
18. Consideration should be given to a number
of additional exemptions of subject areas that are reliant to
a significant extent on ELQ recruitment, and which are of particular
value to the economy, society and culture of the nation. Examples
of these (each supported by substantial evidence from the profession
in question) include pharmacy courses, psychology courses, a range
of provision across the creative & performing arts, and continuing
professional development activities in the teaching and healthcare
professions.
19. The exemptions for medicine, teacher
training, social work and nursing identified so far must be retained,
and in some cases extended, if recruitment into these professions
is to be unaffected by the ELQs policy. As the Council of Deans
for Health has emphasised, it is important that HEFCE make clear
the full extent of the exemptions for all the health professions
covered by the relevant student support regulations ie Medicine,
Dentistry, Allied Health Professions, Audiology (BSc route), Chiropody
(including Podiatry), Dental Hygiene, Dental Therapy, Nutrition
and Dietetics, Nursing, Midwifery, Occupational Therapy, Physiotherapy,
Prosthetics/Orthotics, Orthoptics, Radiography, Speech and Language
Therapy. Consideration also needs to be given to adding Operating
Department Practitioners as well.
20. There is a strong case for a wholesale
exemption of professional courses relating to the education workforce.
Although the HEFCE consultation documentation outlines that teacher
training will be exempt from the withdrawal of funding for those
pursuing an ELQ, there are some areas of provision that are in
danger of falling outside of this category, for example:
— Professional courses for graduates
and postgraduates: This includes conversion courses for educational
psychologists or to enhance professional understanding of key
policy issues (eg the nature of the social class achievement gap).
— Training for the wider school
workforce: As part of the school workforce reform, new programmes
for classroom assistants are currently developing, which may overlap
with previous NVQ 4 or HNDs, and hence would be classified as
"ELQ".
— Post-compulsory education: It
is important to ensure that training for university teachers is
exempted. Almost all of these teachers will have higher level
qualifications in their specialist subjects, will be able to receive
funding for HEA-accredited Certificate, Diploma and Masters courses
in university teaching, which are now required of new entrants
to the profession.
— Research Masters: We are concerned
that students with a taught Masters degree (MA/MSc) will not be
funded for a research Masters degree (MPhil/MRes/MSc). It will
also be important to ensure that the holder of a subject specific
PhD will still be able to receive funding for a professionally
relevant EdD or DEdPsy qualification.
Further considerations
21. UUK would welcome further discussion/impact
analysis of the ELQ proposals before they are implemented, specifically
regarding any disproportionate effects on regions, gender, age,
and socio-economic groups.
22. UUK would also welcome consideration
of suggestions from universities set out in paragraph 13 above
that (i) the implementation of the withdrawal of ELQ funding should
be delayed, possibly until 2010-11, to allow institutions to manage
their own transition to a new steady state; and (ii) that a time-limit
of five years or so be imposed, after which ELQ students would
become eligible for further public funding.
January 2008
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