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[11]
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.[12]
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; and
— 45%
of all higher education students below postgraduate level are
aged 21 and over and 32% are aged 25 and over.[13]
20. Between 1994 and 2008 there was a 106% increase
in part-time degree level students.[14]
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; and
— 46%
are aged 25 and over.[15]
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).[16]
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).[17]
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[18]
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".[19]
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[20]
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[21]
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
11 Ministerial Foreword to the Higher Education White
Paper, page 3 Back
12
HEFCE analysis of HESA student record and The Data Service Individualised
Learner Record 2009-10 Back
13
AoC analysis of aggregated HESA student record and The Data Service
Individualised Learner Record data 2009-10 Back
14
HESA (2010) Students in Higher Education Institutions, various
years Back
15
AoC analysis of aggregated HESA student record and The Data Service
Individualised Learner Record data 2009-10 Back
16
UCAS data Back
17
UCAS data Back
18
DfE Statistical First Release GCE/Applied GCE A/AS and Equivalent
Examination Results in England, 2009-10 (Revised) Table 1a Back
19
House of Commons, Hansard, 28 June 2011 : Column 776 Back
20
HEFCE Consultation: Teaching funding and student number controls
(July 2011) Back
21
Speech given by Rt Hon David Willetts MP to AoC HE in FE Conference,
31 March 2011 Back
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