Submission from Anglia Ruskin University
It is the belief of our University that this
policy is misguided and hurredly thought through. It goes against
the grain of widening access, lifelong learning and upskilling
the nation. As a University we are mainly concerned about: the
differential impact on certain groups of students, including female
students; that many of our part time courses, including Professional
training courses, will be non viable in the future and the methodology
applied by HEFCE to the classification of "known" or
"unknown" qualifications on entry
Anglia Ruskin University is one of the most
adversely affected HEI's (top 15) by these proposals, and as a
University we are projected to lose £2.2 million from our
teaching grant as a result of ELQ by 2011-12. From ELQ funding
alone the loss will be £2.9 million but the part time targeted
allocation received will reduce this loss to £2.2 million.
Some of the major concerns of our University
are as follows:
HNC/D's are treated in a different manner to
Foundation degrees in the consultation and are not exempted. However,
HNC/D's remain a popular vocational qualification and have currency
with employers who understand their purpose and remain committed
to supporting employees through their studies of HNC/D's. The
HNC/D framework still plays a major part in meeting the governments'
skills agenda and so should be considered for exemption alongside
the Foundation degree framework.
The key determinant of whether a student should
be considered an ELQ or not is based on the equivalence of level
of their previous qualifications, however in practice it is very
complex to establish how partial completion of previous qualifications
should be considered.
Additionally, for students who have a higher
professional qualification such as CIMA (potentially achieved
through a private provider with no HEFCE funding) and wish to
undertake a HND or undergraduate degree in a further vocational
area, such as Business Studies, with some prior credit, (at a
HEFCE funded HEI) would potentially be classified as an ELQ student
and denied their first opportunity to obtain HEFCE funding.
A further issue with HE Professional qualifications
is the large range and their lack of categorisation. It is likely
that where the discipline of study in which the student has previously
achieved their Professional qualification is not linked to a further
qualification it will be very "hit and miss" whether
this Professional Qualification is correctly categorised. For
example, where some professional qualifications encompass level
2/3 awards (A level equivalent) and Level 4 (HE level equivalent),
it would be difficult for admissions staff to be expected to check
a non-related qualification and determine whether the student
should be classified as ELQ or not.
2005-6 student data is to be used to determine
the targeted allocations for SIVS and HEFCE make clear that this
will be limited to maintaining the numbers in 2005-6 and not incentivising
future growth. By taking one year's students numbers only there
is a risk of distortion of allocations that do not reflect new
priorities and opportunities in 2008-9 to 2010-11.
Additionally, our University offers a range
of highly regarded courses in Optometry, Quantity Surveying, and
Theology, all of which are necessary to re-train and upskill students
to sustain the supply of Professionals in these subject areas.
It is the claimed intention of HEFCE and DIUS
to reduce the burden of bureaucracy on HEI's. However, as described
above, implementation of the ELQ consultation will result in a
significant increase in the checking and verification of prior
qualifications; determination of their equivalent level; the interpretation
of funding rules and communication to students of this implication
of these rules on tuition fees, as well as the risk of perversity
and contradictory nature of different policies.
The combined impact of all these aspects should
surely result in a major increase in administrative and bureaucratic
burdens on a HEI. As an institution we do not consider that the
costs of implementing the policy will be proportionate to the
intended advantages that are to be gained from it.
For all of these reasons, we also believe that
this policy, if implemented will have unintended consequences
for widening participation and the economic wellbeing of England