Select Committee on Innovation, Universities and Skills Written Evidence

Memorandum 73

Submission from Universities UK


  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.


  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.


  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.

    —  The skills 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" 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.


"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.


  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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