Government reform of Higher EducationWritten evidence submitted by the University of Hertfordshire
Summary
The University of Hertfordshire welcomes the opportunity to submit evidence on the future of Higher Education. We wish to address four key issues: funding and access; research; HE in FE; and public information. These are issues the Government is focusing on in the next four years and will transform the HE landscape.
In terms of fees and access, we raise the issue of the unintended consequences of the current proposals, made as they are in the absence of important information. We are concerned that a “ramping” effect on fee levels could result as universities seek to protect brand and reputation in a context of uncertainty. Any re-drawing of the binary divide that may result would be to the detriment of the student experience, of efforts to open up HE and real social mobility, and of the UK’s economic recovery.
With regards to research, we advise care be taken in any further concentration of funding that would move away from the principle of recognising excellence at departmental level and towards protection of individual institutions.
We express support for the Government’s emphasis on HE in FE and recognise the vital role FE Colleges make in opening up access to higher learning. We suggest that there must be flexibility in driving forward this agenda, however, building on existing models of success where they exist, and innovating where the volume and infrastructure offer potential for a major shift to direct funding for FE Colleges.
Our submission concludes with some comments on public information, the provision of which we fully support, though care needs to be taken to ensure information is readily accessible, comparable and meaningful for students, supporting genuine choice. Contextualisation of information will be key.
Funding and Access
1. Government policy is based on modelling that assumes an average fee of £7,200–£7,500. The expectation that this average fee level will have to be achieved carries the risk of incentivising certain reactions in universities that are then likely to be seen as evidence for the need for Government intervention into the fee market. Brand protection, the setting of fees in the absence of full knowledge of the funding environment, the rules regarding competition that prohibit discussion between institutions, and the increased scrutiny and expectations of OFFA are some of the key issues that may drive fee levels towards the £9,000 absolute limit.
2. The University of Hertfordshire is starting the process of fee-setting from the principle of replacing reductions in teaching grant and the need to be able to continue to invest in physical, academic and social infrastructure to support the student experience in the future. However, we are conscious that competitor institutions may decide to price to establish a “brand”, even if key information would not provide any evidence of higher performance. There is therefore a significant risk of “ramping” of price levels to ensure that institutions are not charging below competitors and therefore regarded as of inferior quality, particularly given the experience of the US. Even in the context of greater transparency in terms of public information about the university experience – which we fully support – universities will be concerned about the use of price as a proxy for quality. A system of price-based reputations would be to the detriment of students, universities, the public purse and the wider good in terms of economic and social benefit.
3. Universities are able to investigate the cost of delivering their programmes and this is a an important element of the fee-setting exercise. However, many of the parameters within which decisions are being taken remain unclear. These include: the extent to which strategically important subjects will retain public funding; the allocation model for the National Scholarship Programme; the Government’s intentions with regards to the movement of numbers into FE.
4. The greatest unknown is of course student demand. While universities recognise the importance of competition law here in terms of discussing fee levels, there is a case for allowing collaboration in research for example around student priorities or attitudes to debt. In the absence of collaboration, institutions’ understandings of potential students’ needs and concerns will be more limited.
5. The flexibility of the new OFFA guidance is to be welcomed. The emphasis that universities with already diverse student populations can put on retention and employability is a positive development. However, there are some concerns from the perspective of such universities, who make the most significant contribution to bringing higher education to students from non-traditional backgrounds.
6. Firstly, there is the issue of the financial cost of match-funding the Government’s National Scholarship Programme with large populations of these students. Around a third of the University of Hertfordshire’s students come from a household with an income below £25,000. There are added costs associated with supporting these students through higher education, but if there was a mandatory additional spend per student defined by the Government, this could materially impact on a university’s ability to invest in other aspects of outreach and retention as required by OFFA.
7. Secondly, in a context of capped student numbers, any success in widening access by the most selective universities will impact on the “performance” of other institutions. Performance against benchmarks may indeed seem to deteriorate, not through a lack of strategic focus or funds, but due to macro effects within the HE system. We are concerned that, without careful interpretation, such effects may be taken as evidence by Government or OFFA that further intervention is needed, particularly in the control of prices. Any intervention to control prices will disproportionately affect the post-92 sector and may re-draw the binary divide.
Research Funding
8. The removal of QR funding for 2* research was expected and we have no issue with that policy decision. We welcome the clarity of the Minister on the importance of funding excellence at departmental not institutional level. It does not seem to be a good use of public funds to subsidise departments not performing to the fundable level in research-intensive institutions while removing funding from internationally excellent units in other institutions. Indeed, there is an argument to be made in the context of the concerns of this Government to widen participation that it is vital that students are able to access institutions where there is world-class research taking place, even if it is in focused areas of excellence.
9. There remains a debate around the issue of “critical mass”. There is no robust evidence, even in the hard sciences, to link larger groups to higher quality research; certainly in the arts, humanities and social sciences, any such measure would be a policy rather than a quality-driven decision and would tend to underfund small, innovative groups in newer universities that are performing at an internationally excellent level.
10. Given the economic environment and the Government’s efficiency drive, we recognise, however, that further concentration through a measure of “critical mass” – affecting research and PhD funding - is a strong possibility. Should this arise, critical mass should be defined at subject level, recognising the differences in research processes and practices between subjects (and certainly not exceed 10 for any subject). Of key significance is the need to avoid institution-wide restrictions, for the reasons given in (8) above.
HE in FE
11. The University of Hertfordshire is part of the longest-standing HE in FE consortium in England, with around 1500 students studying in the four Hertfordshire colleges. We recognise the valuable role that HE in FE can play in the new funding environment as a conduit for widening participation and enhanced student choice, and for reducing loans (through lower charges). Some colleges with substantial HE provision and well-developed HE infrastructure will understandably seek to be directly funded by HEFCE. However, we are conscious of the risks that would arise should this be seen as the only model for increasing HE in FE.
12. This could unintentionally impact on universities such as Hertfordshire that have maintained their student numbers in partner FE Colleges (many pulled their numbers back into the centre in response to HEFCE clawback for over-recruitment). Universities that have behaved in a responsible and collaborative manner by retaining their HE in FE numbers will be concerned that Government policy to promote such provision will lead to these numbers being taken from universities and embedded in FE. In successful consortia such as Hertfordshire’s, where over 16,000 students have graduated from the university having started in one of the FE Colleges, this outcome would not be welcomed by either party. Government needs to take care not to damage such successful arrangements when pursuing its policy to boost HE in FE; direct funding will not deliver for every local context.
13. We are aware that some arrangements are not seen as mutually beneficial and that some FE Principals have lobbied on the lack of investment by universities in return for the top-slice they receive from the Colleges. While this may be the case in some areas, care needs to be taken that this is not assumed to be a universal issue.
14. HE in FE through collaborative franchise agreements have a number of benefits for associated colleges and their HE students. The University of Hertfordshire, for example, charges the four Hertfordshire colleges 15% of total income (HEFCE teaching grant and fee). The University does not make a “profit” on this charge. The fee covers an extensive list of services that are provided to the colleges. Services included in the fee are as follows:
Completion of all necessary Government returns (HESES/HESA) by the University’s Academic Registry.
Collection of fees either directly or through the Students Loan Company.
Support in completing QAA IQER audits. This involves extensive work from our quality and enhancement team.
Access to staff development activities including the Continuing Professional Academic Development programme provided by the University’s Institute for Teaching and Learning. College lecturers delivering HE have the same professional support that is available to University of Hertfordshire lecturers.
Allocation of a careers advisor, who works with college staff on employability and career development issues.
Joint membership of the Association of Collaborative providers (ACP), an umbrella body representing HE in FE institutions, which the University subscribes to on behalf of the Consortium.
In addition, every student at the colleges registered on a HE programme through the University has access to:
StudyNet (our virtual learning environment).
Learning Resource Centres (open 24/7 with computers, wifi, books and journals).
Some HE in FE students attend the university on a regular basis as part of their course to use, for example, laboratory facilities.
Student support facilities (nursery, medical, pharmacy, well-being, mental health, disability, finance).
Access to Learning Fund.
Graduate Futures (our careers and employability service).
Sports facilities, including our multimillion-pound “sports village”.
Social venues including our new Student Forum (entertainments venue).
15. These services reduce the bureaucracy of providing HE in FE Colleges. But more importantly, they enable the colleges to offer a comprehensive Higher Education experience to their HE students. Many of the smaller colleges could not offer the services listed above, and those that do would have to charge more to do so. This is a primary reason why the collaborative approach which we have developed, works so well and why the colleges can, and would in the future be able to, deliver courses at a lower cost than the University.
Public Information
16. We fully support the objective of providing more information for students. This approach is important as it will allow students to make more informed choices, which will drive change and improve the quality of the student experience universities offer. Nevertheless, without offering the context “behind the numbers”, students’ choices and decisions will based on partial information. We believe the following should be considered:
17. For a better understanding of graduate employability, it is important long-term graduate outcomes are published alongside the traditional six-months survey. This is particularly important for graduates from non-traditional backgrounds who may, as a result of their circumstances, find it takes longer to establish careers than other graduates. All jobs that require graduates in their specifications should be defined as a “graduate job”. Research should be undertaken to define a “graduate job” in the context of today’s employment market. This information will need to be updated on a regular basis. The research will also need to consider how “self-employment” is defined, particularly given the need for new businesses to help drive the economic recovery.
18. We support the emphasis on giving students information on contact hours. Definitions of what constitutes each type of contact must be clear and standardised. That way information will not be open to abuse and students will be able to make fair comparisons. We believe these should be defined well in advance of any published information. For the purposes of clarity and simplicity for the prospective student, we suggest the following categories: (1) Formal examinations (eg invigilated, end of semester and time-bound); (2) Written coursework (eg essays, reports, blogs, wikis) and (3) Other assessments (eg in course tests, oral assessments, presentations, crits, practical examinations and competency/skills assessments).
19. In addition to contextualising information, there will need to be a robust approach to delivering information to prospective students. There is a concern that current proposals will not be as transformative for the student as it could, or should, be. For example, by having to work through dozens of links in order to compare institutions’ KIS (Key Information Sets), students may only consider universities they have a preconceived idea about. This approach may also be prohibitive to students who are used to finding information out quickly on social networking sites. We recognise the Government’s desire for entrepreneurs to create user-friendly websites using the information and data publically available. However, information will be partial unless it is contextualised, and private websites working alone would be under no obligation to provide contextualised information. An alternative or additional way to provide information would be for HEFCE, or an alternative sector-based body, to transform the uni-stats website or collaborate with a private provider such as bestcourseforme. This way, the sector could ensure that information was contextualised and made available for the prospective student in an easily assessable format.
10 March 2011