Supplementary written evidence submitted
by million+
ABOUT MILLION+
1. million+ is a university think-tank which
provides evidence and analysis on policy and funding regimes that
impact on universities, students and the services that universities
and other higher education institutions provide for business,
the NHS, education and the not-for-profit sectors.
INTRODUCTION
2. Our previous oral and written evidence to
the BIS Committee on The Future of Higher Education raised concerns
about the impact on students of the removal of the vast majority
of teaching funding from universities in England. This evidence
suggests that the Government's HE reforms risk social mobility,
that overall most graduates will pay more for their higher education
than they do currently and that the reforms represent poor value
for taxpayers.[99]
In other analysis, million+ has highlighted the wider economic
implications of the decision to withdraw the majority of direct
public investment from higher education.[100]
3. Following the publication of the Higher Education
White Paper, Higher Education: Students at the Heart of the
System on 28 June 2011, we welcome the opportunity to submit
supplementary evidence to the BIS Committee. In spite of the emphasis
on students in the title of the White Paper, our analysis suggests
that a number of the proposals set out could undermine the investment
available in universities to promote the quality of the student
experience. Other proposals risk undermining the excellent national
and the international reputation of England's universities. This
reputation has been hard won and is dependent on the maintenance
of standards and the delivery of a quality student experience.
4. The Government now proposes to introduce more
competition between universities from 2012-13 through three measures:
the creation of a price-based "flexible margin" of places,
unrestricted recruitment of "high achieving" students,
and opening up the market to new providers of higher education.
These market-based mechanisms are variously posited as a means
of regulating the costs of the new system to the Treasury ("As
the balance of public investment shifts from grants to loans,
the government must maintain control of its financial exposure")[101]
and enhancing student choice ("We
want to ensure that the new student finance regime supports student
choice").[102]
5. The decision to remove student numbers from
higher-charging universities and to re-offer them at lower prices
raises questions about the Government's commitment to quality
but also runs counter to the communications strategy of Ministers
who have sought to emphasise (correctly) that no matter how much
students borrow in fee and maintenance loans, graduate repayments
above the earnings threshold will be based on actual earnings
rather than the size of the loan. These payments will therefore
be the same each month whether or not students have borrowed fee
loans for a £9,000 a year course or a course priced at £7,500
or less.
TIMETABLE FOR
IMPLEMENTATION OF
STUDENT NUMBERS
MARKET: IMPACT
ON STUDENTS
6. The timeline of the White Paper and various
consultation processes associated with it raise a number of issues
for students. The proposals to create a "market" for
students commencing in the academic year 2012-13 through unrestricted
recruitment of students achieving grades of AAB and above at A-Level
(or equivalent)—estimated to be 65,000 student places—and
the transfer of up to 20,000 places to providers with average
fees of or below £7,500, are of particular concern.
7. Following the parliamentary votes on full-time
tuition fees caps in December 2010 and the publication of guidance
about Access Agreements, university Governing Boards and Councils
set fees for 2012-13 which they considered would promote a high
quality student experience and safeguard institutional financial
sustainability. Universities were required to submit Access Agreements
for 2012 full-time students to the Office for Fair Access (OFFA)
by 19 April. Many of these Access Agreements were the subject
of discussion with student unions prior to their submission to
OFFA which published outcomes on 12 July 2011.
8. Recruitment for the 2012-13 admissions year
began in April 2011. In addition to other outreach activities,
universities have been engaged in activities in schools and colleges
focused on students interested in applying to study at university
in 2012. University open days for the 2012 admissions year commenced
in June 2011 and will continue in through the autumn. In advance
of the OFFA announcement, universities published their fee levels
and have been providing information to prospective students about
courses and the new loan system. For its part, BIS launched its
own communications campaign "Make Your Future Happen"
on 6 May 2011 to promote interest in universities for the 2012
academic year and to allay concerns about the reforms to student
finance.
9. Several months down the road the publication
of the White Paper on 28 June 2011 effectively changes the rules
for 2012 after decisions have been made by universities. It would
appear that Ministers waited until universities published their
fees and then sought to inject additional elements of competition
in order to reduce fees. As a result, one in four university places
will be contestable in 2012-13. This will have variable impacts
on universities but it will also have an impact on student choice
and the investment available in institutions to deliver a high
quality student experience in the short and the long term.
10. Alongside the HE White Paper, Ministers published
a letter inviting consultation responses (Appendix 1).[103]
The consultation on the White Paper commenced on 28 June 2011
and is set to close on 20 September 2011. For this consultation
is to be meaningful, universities, students and other stakeholders
would reasonably expect that BIS would give full and proper consideration
to the responses received by 20 September and then publish its
own response and any decisions or proposals for implementation
eg through primary legislation, amendments to the student finance
regulations or through further consultation by Hefce.
11. However, on the same day (28 June 2011) Ministers
wrote to Hefce requiring the Funding Council to implement a market
in student numbers from 2012-13—the proposals for which
had only appeared in the public domain via the publication of
the White Paper on the same day (Appendix 2).[104]
On 30 June 2011, Hefce issued a consultation on teaching funding
priorities and the market in student number controls in 2012-13
which will close on 2 September 2011. The consultation is restricted
to the detail of implementation and not on the principle of the
decision announced by Ministers. It appears to be designed to
ensure that the market in student numbers will operate from the
2012-13 academic year. It is difficult to see how the decision
of Ministers to require Hefce to implement this market in 2012-13
while at the same time inviting consultation on the BIS White
Paper, provides for proper consideration and full and meaningful
consultation of the impact of the student number market on students
and universities.
IMPACT OF
STUDENT NUMBER
MARKET
12. The student number market will require universities
to compete on grade for approximately 65,000 younger full-time
students who achieve AAB (or above) A-level grades (or their equivalent)
and on courses which will be priced primarily at £9,000 per
year. Other universities, with a strong track record of creating
opportunities for students from a wide-range of backgrounds and
ages, enabling these students to progress to professional careers,
have fewer students with AAB grades at the point of entry and
are unlikely to be able to compete in this market in the same
way.
13. Once AAB students are removed from the core
numbers allocated to universities, a further 20,000 student numbers
will be removed. Universities can compete for these places only
if they can demonstrate that their average tuition fee in 2012
will be £7,500 or less. Based on fee levels announced and
Access Agreements now in place, a small number of universities
could provide places at this level, especially through links with
local colleges. However, there are a variety of operational and
financial reasons why most universities may not wish to bid for
these places and OFFA has estimated that the average tuition fee
in universities is likely to be much higher. Fee levels set by
universities will have taken into account:-
— predicted
student numbers;
— future
strategy and the investment required to maintain and improve the
student experience for current and future students;
— requirements
in respect of Access Agreements including bursary support, outreach
activities (bearing in mind the end of the Aim Higher programme
worth £78 million per annum); improving retention and the
match-funding for the NSP that is a requirement laid down by Ministers;
and
— the
80% reduction in teaching grant.
The removal of core numbers and/or price restrictions
will reduce the unit of resource in those universities with strong
track records in widening participation. This will impact not
only on the number of places available for students from more
diverse backgrounds but also on the income that institutions had
anticipated would be available to invest in the quality of the
student experience for their students.
IMPACT ON
SOCIAL MOBILITY
AND INVESTMENT
IN THE
STUDENT EXPERIENCE
14. million+ welcomes the White Paper's recognition
of higher education as a powerful engine of social mobility. The
commitment to fund elements of the Widening Participation Premium
for universities which teach students from non-traditional and
disadvantaged backgrounds is also welcome.
15. However, million+ remains concerned by the
Government's narrow and partial understanding of social mobility.
The market in student number is likely to undermine efforts to
widen access and take account of the full potential of each applicant.
There is significant tension between the Government's professed
commitment to increase social mobility and the proposals to allow
unrestricted recruitment of the approximately 65,000 students
who achieve AAB or above at A-Level or in equivalent qualifications.
A wealth of research has shown that students from more prosperous
backgrounds and at private schools tend to perform better in standard
examinations. Out of the 54,600 students in England aged 16-18
who achieved AAB or better in A-Levels and AVCEs in 2010, 16,100
(29%) were from private schools even though only around 6% of
all pupils study at private schools. A further 5,420 (10%) of
those achieving AAB were at selective state schools.[105]
The White Paper states that unrestricted recruitment of AAB students
"will create the opportunity for more students to go to
their first choice institution" but it is clear that
this will advantage younger students from more prosperous backgrounds
relatively more than students from more disadvantaged backgrounds.
16. Furthermore, whilst privately educated pupils
tend to outperform their state educated counterparts at school
this situation is reversed at university. Students with lower
A-level grades from state schools are known to equal or out-perform
students from private schools with high A-level grades once they
are at university. A five-year study co-funded by BIS, the Sutton
Trust, the National Foundation for Educational Research and the
College Board that tracked 8,000 A-level candidates found that
a comprehensive pupil with the grades BBB is likely to perform
as well at university as an independent or grammar school pupil
with grades ABB or AAB.[106]
High achievement in school exams is not necessarily a good predictor
of achievement at university.
17. Given the emphasis that Ministers have previously
placed on the use of contextual data in university admissions,[107]
the White Paper is strangely quiet on the subject. The creation
of incentives for universities to focus recruitment on students
gaining AAB at A-Level risks undermining the progress that has
been made in the sector towards the use of contextual data to
assess an applicant's full potential.
18. Once AAB numbers are removed from the core
allocations of universities, 20,000 further numbers will be removed
on a pro-rata basis in 2012. An example of how this is intended
to work is outlined using two "case-studies":
UNIVERSITY CASE-STUDIES
(2012)
University A has 2,000
students with AAB grades removed from its core numbers and has
set its full-time fee at £9,000. University A is allowed
to compete for these 2,000 places at the full-time fee and can
also compete for additional AAB students. University A is left
with 200 numbers in its core allocation i.e. students admitted
without high A-level grades or their equivalent. This core allocation
of 200 numbers is reduced by 8% as a pro-rata contribution towards
the 20,000 numbers which the Government wishes to remove and offer
to lower cost providers. As a result University A loses 16 students
from the core—a potential loss of £144,000 in year
one (2012) rising to £432,000 by 2014-15. It is unlikely
to lower its average fee price but can seek to recruit an additional
16 AAB grade students (or more) at full price.
University B has 100 students
with AAB grades or their equivalent and has set a full-time tuition
fee of £9,000. Once these students are removed it has a core
allocation of 2,000. This number is reduced by 8% as a pro-rata
contribution to the 20,000 numbers for lower cost providers. As
a result University B loses 160 students. Unless it reduces its
average tuition fee to £7,500 or less, University B cannot
compete for any of the 20,000 student numbers. Unless it also
chases AAB students, University B stands to lose £1.44 million
in year one (2012) rising to £4.32 million per annum by 2014-15.
If Ministers remove even more numbers by price from the core in
future years ie in 2013 and beyond, University B will incur a
significant reduction in income from UK domiciled students. This
is in spite of University B's long tradition of creating opportunities
for older students and students from non-traditional backgrounds
as well as investing in a high quality student experience.
19. The new student market "conditions"
applied by Ministers have implications for financial sustainability
and planning and will have an impact on current and future students.
As illustrated in the university case-studies, the reduction in
core numbers, combined with a limitation on price, raises the
prospect that universities will have no means of recovering this
income from other sources over a short timescale (bearing in mind
that Ministers want the changes to operate from 2012-13).
20. Instability will be made worse by the detail
of the timetable for 2012-13 flexible margin proposals. The Hefce
consultation suggests that universities will not know how many
students they will lose into the "flexible margin" at
the point at which they would be required to submit bids for this
pool. Moreover, universities will only receive confirmation of
their core allocation for 2012-13 in March 2012 when the admissions
process for 2012-13 is well-advanced. This is likely to lead to
delays and uncertainties for students or, in the alternative,
universities being cautious about the number of offers and conditional
offers that they make.
21. The proposal to allow unrestricted recruitment
of AAB students and to re-allocate 20,000 places to lower costs
providers also has implications for the range of subjects offered
by universities. It is well known that pupils studying arts and
humanities subjects at A-Level or equivalent tend to achieve higher
grades than those studying science subjects and mathematics in
preparation for degrees in STEM subjects. As a result, STEM courses
tend to have lower grade or tariff requirements. Funding drivers
which incentivise the recruitment of arts and humanities students
may lead to a reduction in the provision of strategically important
STEM subjects.
22. Ministers have also indicated that they want
to increase the number of places re-allocated to providers charging
less than £7,500 in future years. The primary objective seems
to be to cut the costs of the student loan book for the Government.
This is only likely to increase instability in the early years
of the new funding arrangements.
23. Above all, the decision by Ministers reveals
a lack of understanding about quality and what students really
want. As repayments of tuition and maintenance loans are based
on the earnings of graduates rather than the sum of their debt,
there is no immediate financial advantage to students in studying
at a provider that charges £6,000 vis-à -vis one that
charges £9,000. A graduate with a debt of £35,000 who
is earning an annual salary of £24,000 will repay at the
same rate as a graduate with a debt of £50,000 who is also
earning £24,000. The assumption that low cost courses are
the priority for prospective 2012-13 students is misplaced and
belies the fact that many institutions set fees in consultation
with their student unions.
ACCESS AGREEMENTS
AND OFFA'S
"AVERAGE" FEE
24. On 12 July OFFA published its estimate of
the average tuition fee in 2012-13 once fee waivers have been
taken into account. This is the figure which is of interest to
Government Ministers because it gives a very clear indication
of how much more students will have to borrow from the Government
to pay their fees. BIS has consistently estimated that the average
tuition fee for the sector would be £7,500. According to
OFFA's calculations, 106 out of 129 universities and colleges
are likely to have an average tuition fee above £7,500 in
2012. The average tuition fee across all of these institutions
once estimates about fee waivers are taken into account is £8,161.
These fees reflect the impact of the policy of cutting the public
investment in teaching by 80%.
25. The OFFA estimates throw up some interesting
differences in approach and a number of universities have chosen
not to use fee waivers at all. For example, the average estimated
fee for the University of Bradford and the University of Durham
is £9,000. Similarly, the University of the Creative Arts
appears not to be offering any fee waivers because its maximum
fee and estimated average fee remains a constant £8,500.
Meanwhile, the estimated average fee at Cambridge and Oxford are
£8,748 and £8,355 respectively. These universities have
deployed fee waivers as part of their access strategies but they
can also draw on very large endowment funds to help fund large
fee waivers for a relatively small number of students from disadvantaged
backgrounds. In spite of these large endowment funds, Cambridge
and Oxford will also benefit from government funding for the National
Scholarship Programme.
26. The actual average fee across the sector
and for individual universities will not be known until December
2012 at the earliest. The "estimates" published by OFFA
are just that—they are based on assumptions about how many
students from different household incomes will be recruited to
each institution. Universities recruit students on a needs-blind
basis and pay no regard to household income. Neither universities
nor OFFA will know what the average tuition fee is until students
have enrolled on courses and confirmed their household income.
Only then will universities be able to calculate how many students
are actually entitled to fee waivers and / or bursary support.
Some universities also recruit students on more than one semester
i.e. some students may commence courses in January. This will
further delay calculations of an average fee in some institutions.
27. OFFA has also published figures on what it
says will be the estimated average "costs" to students
once bursary support is taken into account. This is potentially
misleading. Bursary support covers a wide range of support for
students, often to cover living costs and other costs associated
with studying at university. The provision of bursaries will not
reduce the fees charged and it is very unlikely to reduce what
students borrow from the Government in terms of fee loans and
maintenance loans and grants. (Maintenance is means-tested according
to household income).
28. Bursaries are known to be highly valued by
students and universities provide bursaries to try and ensure
that students have the support they need while they are studying.
This is a particular concern for universities which provide opportunities
for students from lower income backgrounds whose families are
simply unable to provide additional financial support however
much they might like to do so. The OFFA figures confirm that universities
which teach the majority of students from lower income backgrounds
have sought to ensure that their students are supported with bursaries
in addition to any maintenance loans and grants to which they
may be entitled. These universities are investing in university
bursaries precisely because they understand that support for students
while they are studying is much more crucial than a fee waiver
because graduates can pay back fee loans over 30 years.
29. There is a further reason why universities
have not offered significant numbers of the fee waivers which
bring down the average tuition fee price. EU students studying
at English universities are entitled to access fee loans on the
same basis as UK students ie they are not means-tested. Maintenance
loans and grants are different as they are considered a "benefit"
and are subject to the conditions laid down by the Member State.
EU students have to demonstrate three years residency in the UK
before the can apply for means-tested maintenance loans and grants.
It is more than likely that EU students will be entitled to fee
waivers on the same means-tested basis as UK students. The Government's
policy of promoting fee waivers, including in the National Scholarship
Programme, therefore creates an additional financial liability
for EU students which universities would have to meet.
PRIVATE AND
LOW-COST
PROVIDERS
30. Encouraging the entry of low-cost providers
into the higher education sector may be in the interests of the
Treasury but it is not necessarily in the interest of students.
The creation of a flexible margin of contestable places, based
primarily on price, will inevitably result in the removal of places
from universities with a strong record of quality. Given the price
constraints it seems likely that the flexible margin places will
tend to support the provision of subjects that can be run at lower
cost rather than higher cost subjects that are in greater demand.
Far from enhancing student choice, the Government's proposals
may well lead to less choice for students.
UNIVERSITY TITLE
AND DEGREE
AWARDING POWERS:
IMPACT ON
STUDENTS
31. The White Paper sets out the Government's
intention to relax the criteria for obtaining university status
and to decouple the link between degree awarding powers and teaching
students. At present, the right to use the prestigious university
title is conditional on prior obtainment of taught degree-awarding
powers, the presence of at least 4,000 full-time students and
being able to demonstrate robust systems of governance. An organisation
which does not meet the numbers threshold for "university"
title may be eligible for "university college" title
via the same process. BIS will now consult on changes to the criteria
and process for university or university college status with the
intention of relaxing the existing criteria.
32. BIS will also consult on relaxing the criteria
and process for granting and renewing degree-awarding powers at
undergraduate level. This includes reviewing the need for institutions
to demonstrate a track record of delivering quality higher education
programmes for at least four consecutive years and whether an
overseas track record and reputation should be taken into account
by the QAA. BIS will also propose legislation to allow institutions
that do not teach, to award degrees.
33. The current system for granting university
title and degree awarding powers has, as BIS acknowledges, been
effective in maintaining standards within universities and delivering
confidence in the quality of UK higher education and graduates
of British universities. The primary reason why the UK remains
second only to the United States in terms of the provision of
higher education to foreign nationals—despite growing levels
of international competition for international students—is
that UK universities and graduates of UK universities are highly
regarded within the international community.[108]
34. In the UK, university title is a mark of
quality and reputation which denotes adherence to the highest
possible standards and commitment to rigorous academic governance
to students and employers. Any move to relax the criteria for
university title and degree awarding powers risks damaging both
the quality of the student experience and the strength of the
UK higher education brand. Once lost or diluted, this reputation
may never be regained and graduates of UK universities will lose
currency in the international market.
35. The proposal to grant degree awarding powers
to institutions that neither teach nor carry out research indicates
a lack of understanding of the nature and purpose of higher education—a
form of education that is at the cutting edge of an academic subject
and which demands high levels of research-informed scholarship
from staff and students. It also puts the UK seriously at odds
with the Bologna Process which clearly defines universities in
terms of teaching and research.
STUDENTS STUDYING
PART-TIME
36. million+ has previously welcomed the extension
of fee loans to part-time undergraduates studying at the rate
of at least 25% of a full time degree course. Part-time students
are not confined to "part-time" institutions such as
the Open University and Birkbeck. In many modern universities
more than a third of students study on a part-time and flexible
basis and it is right and proper that part-time students should
have access to fee loans. million+ also believes that part-time
students should be subject to the same repayment regime as their
full-time counterparts rather than being forced, if their earnings
rise above £21,000 whilst studying, to start repaying loans
three years after they start studying.
37. The Education Bill includes a clause that
will enable Ministers to table statutory regulations to introduce
fee loans for part-time students. The explanation provided by
BIS in respect of this clause suggests that maximum fee caps of
£6,750 and £4,500 will operate, reflecting 75% of a
£9,000 full-time fee and 75% of a £6,000 full-time fee
respectively. This proposal is predicated on the assumption that
part-time students do not study at more than 75% intensity. This
represents a fundamental misunderstanding of how part-time students
study. In practice there is a good deal of flexibility which reflects
the differing circumstances of part-time students (for instance
in terms of work and family commitments) and the number of modules
that students have been able to study in previous years.
38. Part-time and full-time study alike is based
on modules and credits rather than on percentage "intensity".
Accordingly it would be greatly to the benefit of part-time students
if part-time fees operated on a pro-rata basis linked to the credits
undertaken and the full-time fee set by the university for the
course in question (with an eligibility floor of 25% intensity).This
would provide much more flexibility for part-time students and
would be no more costly overall in respect of tuition fee loans.
STUDENTS STUDYING
ON ACCELERATED
DEGREE PROGRAMMES
39. The Government is keen to foster the provision
of more flexible forms of undergraduate study including two-year
accelerated honours degrees. However, BIS has not yet resolved
issues around the funding of accelerated degrees from 2012-13.
The full-time fee regulations limit the fees that universities
can charge even though students have to be taught proportionately
more each year than a "standard" full-time student.
If a university offers a three year degree course at £9,000
per annum, the university will receive £27,000 in fee income.
However, if the three year course is taught under an accelerated
programme in two years, the university will only be able to charge
£9,000 pa ie £18,000 for the whole course. This idiosyncrasy
of the funding system belies the fact that the Exchequer benefits
because accelerated degree students would only be eligible to
claim two rather than three years of maintenance loans and grants.
INITIAL TEACHER
TRAINING, MPET FUNDING
AND STUDENT
VISA CHANGES
40. The future of the Department for Education's
Initial Teacher Training (ITT) and the Department of Health's
Multi-Professional Education and Training (MPET) funding streams,
coupled with the changes to Student Visa Regulations have all
added to financial uncertainty as universities make preparations
for 2012-13. This has been acknowledged by BIS and Ministers.[109]
41. Overall there has been a 14% reduction in
ITT places for 2011-12 and there is evidence that some ITT student
numbers have been transferred to lower quality non-university
providers. In addition, the abolition of the Training and Development
Agency for Schools (TDA) appears to be linked with the Teaching
Quality White Paper published in November 2010 and signal
a move from university-based ITT to "Teaching Schools".
The DfE's response to the Teaching Quality White Paper
consultation (27 June 2011) recognises that university-school
partnerships have value, but DfE still appears to regard teaching
as a "craft" to be learnt on the job ie teaching is
about the acquisition of skills and not also about the acquisition
and development of knowledge. The DfE's response also fails to
pay proper regard to the fact that students overwhelmingly value
ITT which is university-led and to the evidence available from
Ofsted inspections of ITT provision. This direction of travel
will have consequences not just for the future training of teachers
and the future supply of teachers, but will also inevitably impact
on universities and student choice.
42. Funding for nursing, midwifery and allied
health professional education (NMET) is one component of the "Multi-Professional
Education and Training" (MPET) budget which is included in
DoH funding of the SHAs. Other components provide funding for
postgraduate medical and dental education (MADEL) and support
for the practice teaching of medical students (SIFT). The current
budget is around £4.5 billion. The DoH in England has signalled
that the MPET budget will be cut by up to 15% over three years
commencing in 2011-12. Universities in England have confirmed
that the number of commissions is likely to decrease by around
10-15%. Some universities receive approximately 25% of their total
income from NHS-funded health professional courses. Uncertainty
about the arrangements for the commissioning and award of these
contracts from 2012-13 is creating a financial risk which will
coincide with the introduction of the new fees and funding regime.
It could result in universities having no option but to consider
making well-qualified and experienced staff redundant. This poses
an obvious risk to future NHS education and training provision
and again to universities and student choice.
CONCLUSION
43. million+ welcomes the emphasis on the student
experience in the Higher Education White Paper, Students at the
Heart of the System. However in spite of the proposals to provide
more information to students, as it stands the White Paper is
unlikely to improve student choice or investment in the student
experience and has the potential to create significant risks for
the domestic and international reputation of England's universities.
14 July 2011
99 million+ (2011) Evidence to BIS Committee Inquiry-The
Future of Higher Education. Back
100
million+ (2011) Has the Treasury done the sums? The economic implications
of the coalition government's withdrawal from the public funding
of higher education. Back
101
BIS (28 June 2011) Higher Education White Paper-Students at the
Heart of the System. Page 67. Back
102
BIS (28 June 2011) Higher Education White Paper-Students at the
Heart of the System. Page 19. Back
103
Ev not printed Back
104
Ev not printed Back
105
House of Common Library (2011) Back
106
Kirkup et al (2010) Use of an aptitude test in university entrance:
a validity study: Final Report. National Foundation for Educational
Research. Back
107
BBC News (9 February 2011) 'Nick Clegg attacks Oxbridge £9,000
tuition fees plans' http://www.bbc.co.uk/news/uk-politics-12409419. Back
108
The presence of international students is vital to the United
Kingdom for social, cultural and economic reasons. See Middlehurst,
Woodfield and Hjerde 'International Higher Education Missing an
Opportunity' (million+ 2011). Back
109
Guardian (14 March 2011) http://www.guardian.co.uk/education/2011/mar/14/high-tuition-fees-university-fine. Back
| 
