The Future of Higher Education

Supplementary written evidence submitted by the Association of Colleges

‘Students at the Heart of the System’ – the Higher Education White Paper

1. The Association of Colleges (AoC) represents Further Education, Sixth Form and Tertiary Colleges and their students. Colleges provide a rich mix of academic and vocational education at all levels. As independent, autonomous institutions established, under the Further and Higher Education Act 1992, they have the freedom to innovate and respond flexibly to the needs of individuals, businesses and communities.

2. This submission should be read alongside our original submission to the Select Committee’s inquiry into higher education and the oral evidence given by AoC Chief Executive, Martin Doel, on 3 May 2011.

Executive summary

3. AoC welcomes the Government’s decision to re-allocate 20,000 higher education places to students who wish to pay less than £7,500 per year. We look forward to significant input into discussions about the criteria which HEFCE use to distribute the additional places.

4. The Government’s stated desire to see more higher education in FE Colleges [1] may be threatened by universities withdrawing student numbers in the forthcoming academic year and/or universities dropping validation arrangements. It is essential that Colleges are able to operate effectively and fairly in the higher education ‘market’.

5. We welcome proposals to ensure the higher education system is more responsive to students and employers through improved information. We remain broadly supportive of the new fees regime, which places greater power in the hands of students, but regret the decision to reduce the teaching grant by 80%. We think this cut is too large and has been introduced too quickly.

6. We are concerned that the decision to require students aged over 24 to take on a loan to finance an Access to HE Diploma may threaten the success of this qualification in helping non-traditional students start higher education.

Comments on each chapter of the White Paper

Chapter 1 – Sustainable and Fair Funding

7. AoC remains broadly supportive of the new fees regime, although we are concerned that the very high fees set by many universities could have a detrimental impact on applications from sections of the community which Government and others wish to seek to increase.

8. We also regret the decision to reduce the teaching grant by 80%. We think this cut is too large and has been introduced too quickly.

Chapter 2: Well-informed students driving teaching excellence

9. AoC fully supports the Government’s aim to improve the information available to potential higher education students in order to create a more informed ‘consumer’. We welcome efforts to make the higher education system more responsive to students and employers.

10. We are, however, concerned about the resourcing and statutory basis for careers information, advice and guidance provided in schools. The Education Bill, currently being considered by Parliament, removes the statutory duty on schools to provide careers advice and says they must secure independent advice for their 14 and 15 year old pupils. Although this is the right decision in principle, we fear it will not lead to an improvement in the advice provided. Ofsted will not assess the success, quality or nature of the advice the school secures and a school may, if it wishes, solely refer their pupils to a website rather than ensure they receive face-to-face guidance. It is extremely important that the decisions taken at 16 are based on good advice because they can have a considerable effect on students’ ability to enter higher education at 18.

11. We think that consideration should be given to including weekly student contact hours for different courses in the new Key Information Set. It is common practice in schools and further education to delineate class contact hours per week for subjects and courses, and we see no fundamental pedagogic issues why this cannot also be achieved in the higher education sector. Indeed, it seems difficult to see how applicants can compare the quality of the subject courses at different institutions without a clear idea of the amount of teaching they will receive.

Chapter 3: A better student experience and better qualified graduates

12. AoC welcomes measures in the White Paper to improve the student experience although we believe that the biggest driver for change will be greater competition between institutions.

13. The sections on employer engagement are sensible and AoC looks forward to taking part in the Wilson Review on university-industry collaboration, an area in which FE Colleges’ specialise and are rightly proud. Employer sponsorship is also a feature of many higher education courses provided in FE Colleges and we support the continued expansion in this area as set out in Chapter 4.

14. AoC notes the sections on initial teacher training (ITT) and healthcare courses but is concerned about the future funding of ITT for the learning and skills sector.

15. The majority of teachers in Further Education train through an in-service route. They are often working part time and teaching in their vocational expertise. They will have to take out a loan to finance their initial teacher training from 2012 whether through an in-service or pre-service route. Higher tuition fees will also impact on their employers (the Colleges) ability to pay fees for all of their staff. AoC would like Government to create similar support and incentives for College teacher trainees as are in place for school teacher trainees.

16. We would emphasise that the majority of 16-18 year olds are taught in Colleges rather than schools. The Government’s Skills Strategy is dependent on a supply of high quality vocational teachers.

Chapter 4: A diverse and responsive sector

17. This chapter proposes a system through which popular courses and institutions can expand to meet student demand. As it makes clear , not all students enter higher education through the traditional A-level route. This is especially the case for those studying higher education in an FE College.

18. 128,000 students study HEFCE-funded higher education in a College [2] . There are also ‘non-prescribed’ HE programmes, funded by the Skills Funding Agency, employers or by the students themselves, usually on a part-time basis around work or family commitments.

19. Higher Education has changed dramatically in the past twenty years in England with a variety of modes of study and less reliance on full-time residential bachelor degrees:

· 17% of Bachelor degree students now study part-time;

· 28% of higher education students below postgraduate level study short cycle courses such as foundation degrees, HNC/D and Diploma in HE;

· 45% of all higher education students below postgraduate level are aged 21 and over and 32% are aged 25 and over [3] .

20. Between 1994 and 2008 there was a 106% increase in part-time degree level students. [4]

21. Therefore the Government’s aspirations to enhance and expand opportunities for part-time students, particularly adults, are being built on a solid foundation. Similar trends can be observed in the USA, Australia and Canada and, to a lesser extent, countries in the EU.

22. The following statistics, which refer to higher education below postgraduate level in FE Colleges, demonstrate that College provision is focused , to a large extent , on different potential students to those interested in studying at traditional university:

· 46% are part-time;

· 64% are aged 21 and over ;

· 46% are aged 25 and over [5] .

23. In addition, Colleges are proud that they provide opportunities for local people to study higher education and that that choice of destination is often their first, and only, choice:

· Over half of HE in FE applicants only apply to a single choice
(compared to only 15% of all applicants)

· Over 70% of those accepted to HE in FE live within 25 miles of their chosen College
(compared to fewer than 40% of all HE acceptances) [6]

24. To illustrate that FE Colleges are not competing with traditional universities it should be noted that over 80% of those accepted to study higher education have qualifications other than A Levels (compared to fewer than 50% of all HE acceptances). [7]

25. The White Paper proposes freeing up around 85,000 student numbers in 2012/13. This system, known as ‘core and margin’ will be administered by HEFCE. There will be an additional 65,000 places, allowing for unrestrained recruitment of high-achieving students, scoring the equivalent of AAB or above at A level. Colleges will play a relatively minor role in recruiting these students at higher education level. However, 19% of students achieving three or more A* or A grades do so at College [8] and therefore 18-year olds leaving College should benefit from these expanded opportunities. AoC is also pleased that high achieving students with vocational qualifications will be included under this proposal.

26. More significantly for higher education provision in FE Colleges is the decision to create a flexible margin of about 20,000 places to support expansion by providers who combine good quality with value for money and whose average fee is at or below £7,500.

27. The vast majority of FE Colleges teaching higher education will be charging fees of £6,000 or below next year. We agree with the Minister for Universities that "perhaps one of the biggest beneficiaries of the 20,000 places that will be more flexible will be higher education delivered in further education colleges". [9] AoC is pleased therefore that the White Paper proposes that this margin will grow in subsequent years, dependent on HEFCE monitoring and review.

28. We would expect significant input into the criteria through which the additional places will be allocated. The membership of the assessment panel is absolutely crucial in this regard. The criteria will need to address the issue of price drift and possible informal cartels where bids move to a point close to the threshold of £7,500. This will be an important test for HEFCE in its emerging role as protector of the student interest.

29. During the Commons debate which followed the Minister’s statement on 28 June, there was some concern from MPs that the fees of less than £7,500 were in some way an indication of lower quality. It is important to note, as we do in this submission, that the higher education provided in FE Colleges is distinct from traditional university education and operates on a different cost basis.

30. For example, Colleges don’t have the cost overheads associated with research, as this is not a core part of their HE offer, nor did they ever receive non-mainstream HEFCE funding which universities are seeking to replace as part of their £9,000 fee.

31. FE Colleges are not choosing to offer HE courses at a lower price because they want to take hundreds of potential students from universities, they are doing so because they want more people, particularly adult students who want to study around work or family commitments, to have the opportunity to study a higher education qualification.

32. The Government’s stated clear wish to increase the number of higher education students in FE Colleges remains dependent on the willingness of universities to allocate student numbers to a local FE College and/or to validate College higher education provision.

33. AoC will be asking HEFCE, as a matter of urgency, to take a firm grip of the behaviour of some universities in withdrawing student numbers and validation services from FE Colleges as described in paragraphs 4.7 – 4.8 of the White Paper both in the interests of students and fair competition.

34. The threat of university withdrawal is now acute because HEFCE will be reducing student number quotas by 8%. Unfortunately the quota stays with the university which holds the contract with HEFCE rather than with an FE College which teaches the student.

35. The White Paper confirms the Government plan to review foundation degree awarding powers (FDAP) in 2012. We are concerned that the system for FDAP does not reflect the different nature of the qualification nor the institution seeking awarding powers and therefore hope that the review takes these factors into account.

Chapter 5: Improved social mobility through fairer access

36. AoC is fully supportive of measures to improve access and widen participation in HE and notes in the White Paper more generous maintenance support for full and part-time students, improved use of contextual data and work on developing alternative routes to the professions.

37. We believe that the evaluation of the first year’s allocation of funds through the National Scholarship Programme (NSP) should be thorough, and depending on the results, consideration should be given to linking the 16-18 Bursary fund (the replacement for EMA) to receipt of NSP funds. This would give individuals requiring the most support some certainty and encourage them to remain in education.

38. AoC believes this is a powerful set of initiatives, backed up by a strengthened OFFA which will be monitoring access agreements with appropriate outreach initiatives, and a commitment from HEFCE to maintain widening participation monies in the new funding system. AoC will want to discuss how the proposed ‘access’ measures can interact to ensure that higher education benefits as many individuals as possible, whatever their background.

39. One major concern however is the demise of Aim Higher and Action on Access and the fact that some of the very successful previous partnerships will be lost. This may impact on those communities and schools who benefit from such activities the most.

40. We are concerned that students aged 24 and over will be asked to take on a loan to support themselves through an Access to HE Diploma. These students have few, if any, qualifications and are under-represented in higher education. Asking them to take on a loan to access higher education and before any subsequent loan for the higher education itself, may act as a disincentive.

41. AoC has always believed that part-time higher education students should have access to loans. It is noteworthy that in the HEFCE consultation paper [10] that there will be no student number controls for part-time students in 2012/13. AoC support this stance but asks the Committee to note that many part-time HE students have different financial needs from full-time students, and may not, for example, want to take out a loan. AoC will seek clarification on the regulations relating to part-time student support.

Chapter 6: A new fit-for-purpose regulatory framework

42. AoC is supportive of the regulatory proposals outlined in the White Paper, in particular a more risk based quality assurance system for successful providers and, initially, a more in-depth process for new entrants. Universities UK, GuildHE and AoC have agreed to discuss how quality assurance and other systems can change to support higher education provided in FE Colleges.

43. AoC supports the new clearer remit for HEFCE relating to lead regulation, oversight over competition issues and promoting the interests of students. We believe there should be a ‘level regulatory playing field’ for those organisations with taught degree awarding powers and institutions designated to receive financial support for their students. We support the principle that application of the new regulatory framework should be appropriate and proportionate to the circumstances of the institution.

44. The White Paper refers to the fact that some in the further education sector have called for the distinctive mission of FE Colleges to be recognised through a distinctive title. Following a speech [11] given by the Minister for Universities where he suggested that Colleges with significant HE numbers could be renamed ‘institutes’, AoC asked its members whether they supported such a change. The response from College principals was mixed and therefore we would support retention of the current system whereby an FE College which meets the criteria can apply to become a College of Further and Higher Education.

7 July 2011