Submission from the University of Teesside
1.1 The Government's proposals on the funding
for Equivalent or Lower Qualifications (ELQs) will have a significant
impact on part time and sub-degree study opportunities, which
support the Government's policies on lifelong learning and on
re-skilling and upskilling for employment.
1.2 The University of Teesside accepts that
it may be reasonable to find savings of £100 million from
the higher education budget to invest in new initiatives. However,
we do not believe that these proposals are the best way to achieve
this, as they will have significant unintended consequences particularly
in inhibiting the delivery of other policies which the Government
wishes to promote. They will also limit personal and professional
development opportunities amongst adults and create a significant
bureaucratic burden for individuals and universities.
1.3 The principal issues of concern to the
The impact on part time students,
who do not benefit from deferred tuition fees or maintenance grants.
The impact on opportunities for lifelong
learning and developing skills in employment.
The limited range of exemptions proposed.
Implications for equal opportunities,
especially for female and mature students.
The bureaucracy required to implement
the policy, and the potential for evasion and unfairness.
Technical defects in HEFCE's modelling
of the funding changes which are necessary to implement the policy,
and their likely consequences, particularly for flexible study
patterns through credit accumulation and transfer.
1.4 We believe that if the policy is to
limit public funding to one experience of higher education at
any one level, then this should be focused upon full time study.
This is where public subsidies are already concentrated, through
grants, loans and funded places. There should also be a time limit,
perhaps five years after graduation, beyond which there should
be an entitlement to public support for part time education at
the same level, in order to facilitate reskilling. However, any
review of the balance of public and private funding should wait
until the review in 2009 by the Fees Commission.
1.5 We therefore urge the Committee to include
recommendations which will support our proposals in its report.
2. ABOUT THE
2.1 The University of Teesside, based in
Middlesbrough with University centres across the Tees Valley,
achieved University status in 1992, but has a history stretching
back to 1930, as Constantine College of Technology and then Teesside
Polytechnic. In 2006-07, the University recruited over 9,700 full
time students and over 12,600 part time students.
2.2 The University has a long standing reputation
in providing higher education opportunities for all those with
the potential to benefit, particularly in a region with considerable
educational disadvantage. It also has a strong tradition of high
quality HE courses and post graduate provision relevant to professional
and industry needs. In particular, teaching areas ranked as top
quality include Computing, Nursing and Midwifery, Professions
Allied to Medicine, Art and Design, Sport and Exercise, Electrical
and Electronic Engineering, History, Social Work and Chemical
2.3 Teesside has been named as the top modern
University in a new national student survey commissioned by the
Times Higher Education Supplement (18th overall). It is also ranked
within the top ten modern universities for graduate prospects,
according to The Times Good University Guide 2008 and joint tenth
in the Good University Guide produced by Mayfield University Consultants.
2.4 According to the 2007 National Student
Survey, Teesside is in the top 25% of English universities for
student satisfaction and is the second highest modern university.
2.5 It has a strong focus on providing accessible,
relevant and flexible HE for people in work with a strong emphasis
on raising skills and educational levels within the workforce.
This is exemplified by many successful partnerships with employers
and representative bodies such as the North East Chamber of Commerce,
the North East Process Industries Cluster, Cleveland Police, West
Mercia Constabulary and the Metropolitan Police, and many other
companies and public bodies. Consequently, the University has
a high proportion of part-time students.
3.1 Impact on Part Time and Sub-Degree Students
3.1.1 HEFCE's analysis has indicated that
the ELQ policy will affect around 20% of current fundable part
time places, compared with 1.9% of the total for full time study.
The total funding to be withdrawn is equivalent to £50 million
from full time study and £95 million from part time study
(at 2005-06 prices and levels of activity); the total of £145
million exceeds the required net saving of £100 million because
of the need to fund the targeted allocations for strategically
important and vulnerable subjects (SIVS) and part time study.
Only one-third of the funding withdrawn is from full-time study
the area with the greatest public subsidy, in the form of grants,
loans and funded places.
3.1.2 Our own information, based on 2006-07
student population, shows that there were 142 fundable full time
ELQ students (2.1% out of a total of just over 6,800) and approximately
2,000 fundable part time ELQ students (21% out of nearly 10,000
students) who would not be exempt, of which 1,650 were on sub-degree
programmes across all subjects.
Therefore the student groups which have not benefited from deferred
tuition fees or maintenance grants will be among the worst affected.
3.1.3 Examples of groups of students who
might be particularly affected include:
Nurses, holding pre-registration
qualifications, who choose programmes to enhance specific skill
sets relevant to their profession, such as BSc Promoting Practice
Students undertaking a variety of
Education qualifications, such as Masters degrees and Certificates
in Post-Compulsory Education.
Students with a law degree who wish
to enhance their skills through the Senior Status LLB.
Graduates undertaking conversion
courses to work in industries seeking specialist skills (the Process
Industry is encouraging such programmes to address the shortage
of engineering graduates).
3.1.4 It is clear that institutions which
have enthusiastically embraced the Government's agendas of lifelong
learning and increasing higher level skills for employment will
be among those worst hit by these proposals, and that the provision
of such opportunities will be undermined. Provision of this type
generally attracts a mix of first time entrants and those who
have already benefited from higher education. There are few self-contained
programmes which attract only first time entrants or only returners.
The danger is that, if fees have to be increased, whether for
all students or differentially for ELQs, demand will be adversely
affected and some courses will have to close.
3.1.5 Employer co-funding is likely to have
limited applicability, at least in the North East. In our experience,
employers are reluctant to contribute to the level of cost of
higher education provision which the Government and HEFCE expect
(up to 50%). Moreover, many of the region's larger employers are
public sector, so co-funding arrangements merely transfer the
burden from one public funding pocket to another.
3.1.6 Many returners to HE do not benefit
from employer contributions to the cost of their HE. We keep the
PT fee low to provide more learning, and often vocationally related,
opportunities for individuals in the region. The removal of funding
grant will require substantial increases in fees for such individuals
to cover the costs of provision, and for many this will be unaffordable.
3.2 Range of Exemptions
3.2.1 The exemptions currently proposed
could be considered to be somewhat arbitrary, and could lead to
3.2.2 The proposed exemptions for students
studying courses which are treated as special cases by the Governmentmedicine,
teacher training, nursing and social workdoes not cover
other parts of the public sector. For example, police forces,
other areas of education and health carers are increasingly seeking
training from higher education institutions, with programmes leading
to qualifications at various levels.
3.2.3 The planned exemption for students
studying foundation degrees is welcome, but is likely to lead
to wholesale reworking of other programmessuch as HNCs
or HNDs, which continue to have a strong followingas foundation
degrees, in order that all the students can continue to attract
funding. The University has over 700 students on part time HNC/Ds
in Engineering and Computing, across 12 programmes, some delivered
in several partner FE colleges or by distance learning. Without
converting to foundation degrees, the range of programmes or venues
available to students and their employers might have to be curtailed.
Industry would be hard pressed to understand such a switch in
qualifications in order circumvent funding policy rules.
3.2.4 The proposal to exempt co-funded students
is illogical, and appears to be a matter of expediency. The planned
allocations to support strategically important and vulnerable
subjects (SIVS) and part time study are welcome, but we are concerned
that the part time allocation of £20 million is insufficient
to compensate for the withdrawal of funding, which is shown by
HEFCE's own analysis to total £95 million, while the SIVS
allocation will be fixed in cash terms, and so will not encourage
growth in these subjects.
3.3 Equal Opportunities
3.3.1 The dataset provided to the University
by HEFCE for modelling the impact of the policy suggests that
there will be adverse impacts on female and mature students.
3.3.2 For example, the University's fundable
student population in 2005-06 was split almost equally between
male and female students by FTE (though in headcount terms, female
students were in the majority). However, among students assessed
as ELQ students on the basis of known qualifications, the female
share of the total FTE is 58.6%, and the effect of exemptions
only reduces this to 56.7% of the FTEs who would not be exempt.
This is consistent with the University's own information about
the proportions of part time and sub-degree students who are likely
to be affected, as some of our most popular lifelong learning
and continuing professional development programmes attract a majority
of female students.
3.3.3 Analysis of age on entry shows that
the percentage by FTE of mature students (aged 25 or over on entry)
assessed as ELQ students is double the rate in the total fundable
population (which is 38%), and that the exemptions have little
3.3.4 The differential on race is less dramatic,
but probably not negligible. The percentage of ethnic minority
students by FTE among the University's fundable population in
2005/06 was 7.2%, but among those ELQ students with known qualifications
and not exempt, it was 7.8%.
3.3.5 These gender and age differentials
appear to be an inherent consequence of the policy as applied
to part time study.
3.4 Bureaucracy and Associated Problems
3.4.1 The extra bureaucracy created by this
policy will negate many of the benefits of reduced regulation
achieved in recent years. Although we are as yet unable to quantify
the extra staff effort required, or the risks associated with
diverting effort from other tasks, we expect these to be substantial.
We also expect that some resources, such as a qualifications database,
will need to be provided by representative bodies on behalf of
3.4.2 This is because of the need to check
the qualifications of students, beyond what is needed for admissions
purposes, and to ensure that they are correctly interpreted and
accurately recorded. Effort will also be needed to ensure that
the exemptions required by the Government and HEFCE are correctly
applied. In particular, we believe that:
non-disclosure of qualifications
will become a significant issue;
institutions will need good practice
guidance as to how far they are expected to probe an applicant's
entry qualifications; and
institutions will need access to
a central database of current and past qualifications and their
equivalences, including European as well as UK qualifications,
to enable the policy to be implemented equitably.
3.4.3 There appears to be potential for
confusion and unfairness in relation to students who have achieved
partial completion of an earlier HE programme. It appears that
students who have chosen to accept an intermediate award (eg a
Cert HE or Dip HE for the completed part of a first degree) could
be penalised relative to those who have simply dropped out. This
would be perverse.
3.4.4 Further confusion and unfairness could
be created if the ELQ policy is applied only to England, and not
to the other parts of the United Kingdom, as seems likely at present.
3.5 Defects in HEFCE's Modelling of Funding
3.5.1 In deciding what counts as an equivalent
qualification, no distinction has been made between intermediate
qualifications which can either be taken as an end in themselves
or successively on the way to a final qualificationeg Cert
HE and Dip HE as stages of an undergraduate degree; postgraduate
certificates and diplomas as stages of a masters degree.
3.5.2 This means that the proposals as they
stand will inhibit much of the flexibility which institutions
like ours have built into their programmes to facilitate progression
through successive stages of study, to allow students to take
temporary study breaks to fit their personal circumstances and
to encourage mobility between institutions. The concept of Credit
Accumulation and Transfer to aid such flexibility could be set
3.5.3 It is unsatisfactory that HEFCE have
based their modelling on 2005-06 student data, and have no plans
to revisit it using more recent data. Apart from not being up-to-date,
this data as a whole is unlikely to be fit for the purpose for
which it is being used. The HESA coding framework was not designed
with this purpose in mind, so that some of the categories, such
as "Open University credits", "Other credits from
UK HEIs" and "Professional qualifications", do
not distinguish between different levels of study. Also, although
institutions aim to make their data as accurate as possible, it
is logical for them to prioritise those items which affect their
funding, and, so far, the entry qualifications of students have
not been used for funding purposes. The reliability of entry qualification
data could be improved significantly by 2009 (at a cost in extra
resources, or diversion of effort) if there is a funding incentive.
4.1 We urge the Committee to consider including
some or all of the following recommendations in its report:
That the introduction of the ELQ
policy should be deferred, and referred to the 2009 Fees Commission
for proper scrutiny. This would also allow time for improvements
in data quality and procedures to support the implementation of
That the ELQ policy be restricted
to full time students (for whom the principle of a single entitlement
to public funding at each stage of study can be supported), and
that any further savings required be secured by an across-the-board
efficiency gain. This will be more equitable between different
types of student and institution.
That the ELQ policy be restricted
to qualifications obtained within a defined period, such as the
previous five years, and so assist necessary reskilling by qualified
136 Approximately half of these full time students,
and one-third of the part timers, are in strategically important
and vulnerable subjects (SIVS), for which HEFCE proposes to provide
a targeted funding allocation. Back