Submission from the University of Sunderland
" . . . a bad policy . . . based on a false
choice" (Lord Puttnam of Queensgate, House of Lords, 3rd
This University deprecates the fundamental
premise of the ELQ directive.
Whilst acknowledging the importance
of ensuring HE's responsiveness both to the Access agenda and
to the development of employer facing provision we do not believe
that this directive to the HEFCE will enhance those purposes.
Rather we suggest that it will militate
against important challenges of re-skilling the workforce and
in so doing will also discriminate against the needs of particular
groups of workers including women and others.
The removal of provision for lifelong
learners will also imperil that provision for first time learners,
including access students, where critical masses are delicately
poised. Such outcomes can not be justified on the grounds of fairness.
Where Universities are already active
in widening participation and work based learning in challenging
regional contexts the suggested redirection of funding to those
needs will not easily be realised. Instead, the benefit of this
redirection will be to Universities in more prosperous regional
contexts where targeted ASNs are more easily realisable.
The available information in respect
of exemptions from the ELQ directive is eccentric in its detail.
We urge the inclusion of, for example, Pharmacy as a subject where
national shortages are evident. Equally, the laudable inclusion
of Islamic Studies is not complemented by the inclusion of other
theological traditions or indeed philosophical studies.
1. THE RATIONALE
FOR ELQ MEASURES
1.1 This move is intended prima facie
to redirect a resource within HE funding away from those who
are already graduates towards a) others who have not studied at
HE level and b) selected categories of learners in work or in
subjects of strategic importance and interest. We suggest that
this premise is misconceived because as well as not necessarily
providing additional benefit to those categories identified it
specifically removes opportunity from those currently benefiting.
Universities are very alive both to the access agenda and to the
work based learning agenda. Incentives in respect of both priorities
already exist via ASNs explicitly, via Aim Higher and similar
activity and in the sector's own acute sensitivity to the Higher
Skills agenda. It is not the case that Universities are currently
prevented from responding to these drivers. It is the case, however,
that Universities provide sophisticated higher skills opportunities
and re-skilling opportunities to those whose qualifications are
outdated, redundant or otherwise unsuited to their career needs,
their employer's development agenda or a particular regional economic
context. Very many of these learners will be excluded by the ELQ
directive since it assumes a one-chance opportunity for those
without degrees. Such thinking runs counter to most publicly expressed
and commonly held understandings about the relationship between
a vibrant economy and its re-skilling challenges.
2. THE IMPACT
ON ECONOMIC RESPONSIVENESS
2.1 Universities have a very good track
record in providing higher learning to students at different career
stages. Such learning is not, however, necessarily sequential
in level. Early careers do often develop by level within sectorsfor
example lawyers from UG to PG study, graduates to MBAs and so
forth. Nevertheless re-skilling at UG level is extremely common
where local economies evolve and change direction and where individuals
in the workforce undergo planned and unplanned career breaks and
2.2 In the North East, for example, the
massive tasks of re-skilling pursuant to the demise of mass employment
in heavy industry and mining drew heavily on the Universities'
capacity and in the process provided important new opportunities
to many existing graduates.
2.3 It is also the case that established
sectors have re-skilling needs resulting from technological change,
surges in expertise bases or the influx of specialist employers.
With the increase in the numbers of graduates in the workforce
generally it is the case that most re-skilling agendas therefore
involve those with ELQs. In the North East, for example, the Cultural
and Creative sector which is playing such a significant role in
regeneration comprises diverse workforces with, typically, a 50%
population educated to NVQ level 4 including degree level study
(North East Skills Action Plan, Bowman Solutions 2005).
2.4 There is an obvious and particular impact
on those whose career breaks and moves are dictated by personal
circumstance such as child bearing. The ELQ directive has therefore
a singular discriminatory impact on women who began one career
after graduating when young but who find themselves uncompetitive
on returning to the workforce a decade lateror indeed whose
employment sector has now disappeared or evolved in new directions.
It is invidious to expect such people to settle for less than
their capacity merits when a programme of PT UG study, for example,
could transform their employability. Equally it is inappropriate
to expect these learners to make artificial choices simply because
a choice is funded. Thus the blanket exemption of Foundation Degrees,
whilst laudable, will not make up for current opportunities soon
to be lost. We would also point out that vibrant lifelong learning
portfolios with a strong Access mission, such as Sunderland's,
provide significant opportunities for those with a range of disabilities
and health problems to re-enter the workforce with relevant and
fresh skills and knowledge. Equally, the currency of much graduate
level capacity has a briefer lifespan in sectors where change
is rapid. Insofar as we have been able to map the trajectories
of current ELQ students at Sunderland, it appears to be the case
that the majority acquired their degrees more than ten years ago.
We suggest that this pattern is likely to be repeated nationally.
3. IMPACTS ON
THE HE CURRICULUM
3.1 Where Universities have developed large
and diverse programmes of PT study they have continued to plan
and to manage this provision alongside expertise bases and infrastructure
which support FT programmes. Thus where an expertise base around,
for example, accountancy or public health serves a mixed population
of PT and FT students there are economies of scale which enable
niche or specialist studies at modular level to remain viable.
The ELQ directive will remove large numbers from the funded pool
in many instances and will also therefore make much niche or specialist
provision unviable for FT as well as for the ELQ PT students.
Thus there will be unintended impacts for existing FT students
as the portfolio adjusts to these pressures. As is widely known,
the University of Sunderland has one of the best widening access
records in the country. A key strategy of the University is for
much part-time provision to be delivered by a specialist Centre
for Lifelong Learning. This ensures that provision is responsive
to the availability of part-time students (an express aim of the
government policy) and is also tailored to the needs of mature
students. This model facilitates outreach provision, and is particularly
important in delivering to communities without a tradition of
HE participationparticularly for those who may have missed
out on study before or who have had unsuccessful experiences of
learning. However, the loss of ELQ funding in the creative arts
and cultural areas may make this delivery model unviable in precisely
the areas which have proved most successful in attracting disadvantaged
students back to learning. The Sunderland University programme
of courses at Blyth in Northumberland, delivered in partnership
with the Blyth Resource Initiative Centre, has delivered HE level
learning to over 2000 students in an area of multiple deprivation
since the inception of the partnership. This learning would not
have been possible had the ELQ policy been in place: outreach
work takes place in over 40 venues in the North East, and the
loss of even a small number of ELQ students makes ensuring critical
mass everywhere impossible.
3.2 The DIUS/HEFCE's intention to vire the
ELQ savings to fund further access and employer-facing provision
via ASNs and other devices will also impose curriculum and infrastructure
burdens on Universities. For example, the expertise base, pedagogic
sophistication and facility with learning technology needed to
support higher learning in the work place differs from that required
to support other forms of PT learning. Universities welcome these
challenges and are already very active in work based learning
more generally. However, the scale and pace of the redirection
required will not be achieved easily where large numbers are involved.
4.1 It is axiomatic that the ELQ directive
will impact more significantly on those Universities with large
and diverse PT portfolios than on those with restricted PT offers.
The published list of financial impacts illustrates this very
well. Thus many Universities will face major challenges of readjustment
which will only partially be ameliorated by the suggested palliatives
of freezing the teaching grant temporarily at 2007 levels and
tapering the full implementation.
4.2 More subtly it is the case that even
amongst the population of major "loser" Universities,
there are differential capacities for capitalising on the supposed
new funding opportunities available via the redirection of ELQ
savings into Access and Employer Facing provision. Where such
Universities are located in regional economic contexts of high
demand and high ability-to-pay, the redirection offered will be
achievable often through the addressing of unmet demand locally.
Where Universities, however, are already at the limits of exploiting
the Access agenda and where they are already extremely active
in partnering locally on work based learning and have difficulty
in drawing on existing ASN offers, then this redirection of funding
will not be available to them. Thus a further consequence of the
ELQ directive will be, over time, to redistribute HE funding away
from Universities in challenging regional economic contexts to
the further advantage of Universities in more prosperous contextsparticularly
in Southern England. This redirection of funding thus impoverishes
the capacity of, for example, North East Universities to play
the necessary role in economic regeneration more broadly.
5. ELQS AND
5.1 It has been noted passim in the
responses to the ELQ directive that the list of exempted subjects
is eccentric. Whilst acknowledging that such lists draw on existing
taxonomies of subjects and disciplines which have been noted previously
as either vulnerable or of strategic importance to the economy,
we suggest that the extant list nevertheless attracts obvious
opprobrium when seen in the specific context of ELQs.
5.2 There are many examples where subjects
of clear national strategic importance have not been acknowledged.
We point to the specific example of Pharmacy, inter alia.
There is an accepted national shortage of expertise in Pharmacy.
The planned expansion of provision to meet need is imperilled
by the withdrawal of some Universities from the development of
new Schools of Pharmacy. The role of Pharmacists in wider public
health agendas is widely acknowledged. Very many people enter
Pharmacy as a re-skilling or retraining move. Thus the ELQ directive
in even this one clear instance will remove scarce skills from
the economy and from an important public policy imperative.
6.1 In conclusion, the University would
wish to note that the whole orientation of the policy misunderstands
the nature of the learning required to maintain the prospects
of individual students and the economy as a whole. The policy
assumes that value to the economy will come from the maximum number
of students educated to the highest specialist level in subjects
chosen on a one-chance-only basis. However, our experience, as
a key lesson of Leitch is that the economy needs students to be
educated to optimal level in relevant skills areas as circumstances
dictate and crucially to be able to update those skills. A further
Leitch conclusion is the linkage of rising productivity with effective
skilling of the workforce. This will not alwaysor necessarilybe
achieved by workers upskilling sequentially by level. A worker
who finds her true potential in parallel retraining may be at
least as productive.
6.2 The University asks the committee to:
(a) request that government review the policy
to suspend ELQ funding, and instead look at alternative ways of
working with HE on the work-based learning agenda.
(b) request that the government at the very
least mitigate the damage to vulnerable groups and key economic
areas by extending the range of exemptions as follows:
the proposed Subject based exemptions
to be supplemented by additional subjects required by regional
needs as identified by regional SSCs or RDAs (for instance, the
Culture and Creative Sector and Pharmacy would be expected to
be priorities in the NE).
degree level qualifications to be
ignored after 5 years for the purposes of ELQ assessment.
full exemption from ELQ designation
for all sub-degree awards to level 1 (HE).