Memorandum 10
Submitted by: Jane Hoar, Planning and Governance Officer
Executive Summary
1. The Royal Veterinary College (RVC) strongly believes that it is in the public interest that government develops policies which are credible to all stakeholders in higher education. The RVC believes that the removal of funding for equivalent and lower level qualifications (ELQs) is clearly contrary to both the lifelong learning and the widening participation agenda.
2. It is essential that certain categories of students are exempt from the withdrawal of funding for ELQs. This must include students studying for a first registerable veterinary surgeon qualification.
Assessment of the policy
3. The RVC believes the new policy on ELQs will adversely affect students wishing to retrain and refresh their knowledge and skills at different points in their lives. It will have a damaging effect on individual students, institutions and the economy as a whole. The ELQ pronouncement is analogous to an 11-plus for widening participation candidates. It implies that they can have "one go", and if they miss that opportunity, the government has closed the door on any others. This seems to be against natural justice and the whole widening participation agenda.
Exemption for Veterinary Medicine
4. In identifying students who should be exempt from the withdrawal of funding for ELQs, HEFCE has identified certain categories of student eligible for exemption in connection with the Student Fees Regulations and the Student Support Regulations. These include veterinary students. From the viewpoint of the RVC, the exemption for all students on courses leading to a first registerable veterinary surgeon qualification courses is essential. It is clearly in the public interest for these students to be exempt, given the continuing national requirement for a skilled veterinary profession and the fact that the UK remains, despite the recent expansion of undergraduate numbers, a net annual importer of qualified veterinary surgeons (source: RCVS Annual Report 2007).
5. Any failure to grant an on-going exemption to all students studying for first registerable qualifications in veterinary surgery would seriously undermine progress that has been made at the RVC, where graduate entry to our professional veterinary degree, the Bachelor of Veterinary Medicine (BVetMed), is currently approximately 35 students annually. This entry route has been running successfully since 2005 and was introduced in response to the Government's own 'Gateways to the Profession' initiative (which was welcomed by the College). It supports a much needed diversification of entry routes into the veterinary profession and provides a further opportunity for underprivileged groups who develop aspirations for professional education after a first degree.
6. If the College no longer received HEFCE funding in respect of graduate entry students, it would be unable to hold the annual fee level for this course in line with its other UG level courses, as it has chosen to do in order to support the diversification agenda. Students would be required to pay an annual tuition fee of £15,000 - £20,000. Only those from very wealthy backgrounds would be able to consider graduate entry because of the resulting debt, accumulated on top of first degree debt. Of our current first year graduate entry cohort, not one has said that they could have enrolled on the course had they been required to pay full cost fees. Most found it impossible to acquire career development loans to cover the full cost fees cost of a 4 year graduate entry course. Therefore the introduction of such a policy would be likely to cause a fall in demand that could force the College to abandon the graduate programme. This would be a significant blow to efforts to broaden entry routes into the profession.
7. Furthermore graduate entry represents a relatively economical means of meeting manpower requirements in the veterinary profession, since the programme lasts only four years instead of five. It also contributes in a limited way to the Government's priority of Widening Participation, through providing an opportunity to students unable to achieve the very high A-level entry grades required at the first attempt because of socio-economic or educational disadvantages. Graduate entry enables these students to demonstrate that they have the potential to succeed at veterinary school.
8. The RVC wishes HEFCE to ensure that all first registerable qualifications in veterinary surgery will be exempted on an continuing basis. For example, a consistent approach must be taken to courses where students intercalate and to those where they do not.
9. The College also wishes HEFCE to ensure that veterinary medicine is treated on an equivalent basis to medicine and dentistry. The professional veterinary degree is in almost all respects similar to degrees in medicine and dentistry, and produces a professional workforce of vital importance to society and the economy. The veterinary workforce also has a vital public health function, being instrumental in protecting the food chain and working to inhibit the spread of zoonotic diseases, such as avian influenza. If medicine and dentistry are to be treated as exceptions, then so must veterinary surgery.
10. Finally, the College would also argue that the professional veterinary degree is at a level higher than that of a standard Bachelor's degree. It was recognised as effectively being at Master's level in the QAA Benchmarking statement for Veterinary Science. Thus treating it as an ELQ for students holding a first degree would be inappropriate.
Exemption for Foundation Degrees
11. The RVC recognises the importance of continuing to provide public funding for foundation degrees in relation to promoting access and developing vocational skills. The RVC's FdSc Veterinary Nursing produces skilled and highly trained graduates to meet the career demands of a profession in which the demand for qualified staff significantly and consistently outstrips supply. This foundation degree regularly attracts applicants with higher qualifications who wish to retrain and enter the profession via a fast track route. For example, the current first year cohort includes a student with a degree in pharmacology.
12. The College notes, however, that there may be many other higher level training courses (indeed in line with government initiatives) that would not be covered if this exemption was applied only to foundation degrees. Therefore supporting vocational training should not necessarily be linked to a particular type of award.
Exemption for Employer Co-funded places
13. The RVC supports HEFCE's position on the delivery and funding of co-funded numbers. However, the College believes this will be a very small element at the moment.
14. The College has recently received accreditation from the Royal College of Veterinary Surgeons (RCVS) to provide the RCVS Modular Certificate, a programme of postgraduate CPD modules that can be taken individually or to achieve the full Certificate qualification. Although it is difficult to develop co-funded numbers in a profession where small business and professional practitioners dominate, it is possible that in the future a co-funded approach could be taken towards the delivery and development of modules on this or similar programmes.
Exemption - Strategically important and vulnerable subjects (SIVS)
15. Given the obvious national importance of SIVS subjects, the College believes that they should be exempt. An exemption should be introduced rather than an allocation.
16. In addition to SIVS, HEFCE should identify qualifications relating to shortage occupations, as defined under the Home Office 'Work Permits (UK) Shortage Occupations list. This includes veterinary surgeons.
Effect on Part-time Study
17. The area of part-time study will be disproportionately affected by the removal of ELQ funding. HEFCE's proposed bridging arrangement to support part-time study is not a solution to the long term effect of making it, and especially post graduate vocational training, very expensive to the student. The College will find this damaging in respect of its part-time postgraduate courses which enable students to build up a particular specialism and thus provide added benefits to their employers and the economy. Within a profession such as veterinary medicine there is an on-going and increasing need for such post-graduate specialisation, for example in the area of veterinary epidemiology and public health.
Safety-netting of institutional funding
18. The RVC recognises that it is essential to safety-net institutional funding to avoid large perturbations in government grant. However, such safety-netting will take no account of an institution's loss of future earnings or the fact that the implementation of the ELQ policy will seriously undermine some institutional strategic plans for course portfolio development. In addition the implementation of the ELQ policy will result in significant additional administration costs to institutions.
Impact on different groups of students
19. The RVC notes that the policy may have a particular effect on people with disabilities who may have to re-train because of this. For example, a vet who suffers a disability may wish to re-train as a statistician, but would be caught out by the ELQ rule
20. In order to adequately assess the possible differential impact of this policy, HEFCE should analyse the differential enrolments on vocational courses especially.
January 2008 |