Supplementary written evidence submitted
by the National Union of Students (NUS)
RESPONSE TO SECOND CALL FOR WRITTEN EVIDENCE
(HIGHER EDUCATION WHITE PAPER) JULY 2011
SUSTAINABLE AND
FAIR FUNDING
1. NUS' views on the new higher education funding
and student finance system have been widely publicised and were
detailed in our initial submission to the Committee's "Future
of Higher Education" inquiry and through oral evidence.
EFFICIENCY
2. Many students' unions are looking at cost
sharing and in principle we are not opposed to this practice being
in the higher education sector, assuming any such efficiency process
does not impact negatively on the student experience.
3. The concept of shared services should mean
that back office efficiencies deliver cash for a better access
and student experience, not worse or the status quo. We will look
at the Diamond review into efficiency and modernisation more closely
when it is published, and will respond in depth at that time.
HEFCE FUNDING
4. HEFCE has been given a number of priorities,
including considering the higher costs of certain laboratory and
engineering-based courses, support for strategic and vulnerable
subjects, support for certain groups of students such as disabled
students, and supporting certain services for the sector such
as the QAA.
5. Supporting all these priorities will be challenging,
even with a budget that runs into the billions, and it will be
critical that HEFCE funding does not simply flow into a minority
of research-based institutions. We will participate in the HEFCE
consultation and publicise further work on this in due course.
POSTGRADUATE FUNDING
6. It is hugely disappointing that the white
paper has provided next to nothing in the way of proposals that
would help bolster postgraduate study even whilst acknowledging
the potential impact of higher fees for undergraduates on participation
in postgraduate study.
7. Whilst greater HEFCE monitoring of the profile
of postgraduates is welcome, the government must do much more
to tackle the barriers to postgraduate study if the UK is to remain
competitive. The Postgraduate experience is not divorced from
learning and teaching or skills development, so the absence of
proposals here is disappointing.
PHILANTHROPIC GIVING
8. Despite the white paper's warm words on philanthropic
donations there is relatively little content on exactly how this
will be achieved, except a previously announced scheme the Cabinet
Office is launching to encourage charitable giving via payroll,
and the possibility that especially generous philanthropists may
be considered for honours.
9. The match funding scheme is coming to an end
(not that this is made explicit in the text) and this leaves little
concrete activity to encourage further donation, especially as
the huge increase in fees may serve to depress such giving in
the future.
THE STUDENT
LOAN BOOK
10. The student loan "book"—ie
the total amount students and graduates are liable to repay—is
expected to rise to £70 billion by 2017-18. The previous
government had hoped to "monetise" some or all of the
book—in other words, convert the debt owed by students to
cash receipts for the government quicker than would be the case
purely through normal repayment, via sale to a private interest.
The legal powers for this were made by the passage of the Sale
of Student Loans Act 2008.
11. The present government shares this aim, and
in the white paper outlines that it has asked the investment bank,
Rothchild, to undertake a feasibility study into the different
options. What seems to be different to previous proposals is the
aim for the solution to cover all loans "on an ongoing basis"
as opposed to one-off sales of tranches of loans (as occurred
under previous student loan arrangements in the late 1990s). The
report will be published later this year.
12. Our principal concern is of course that any
sale would not result in a change in terms and conditions for
borrowers. The government itself reiterates that this is their
intention in the white paper and we will continue to hold them
to this pledge.
13. More broadly, there is the question of whether
monetisation would result in value for money from the taxpayer,
as a certain level of profit for the purchaser would have to be
built into any sale. We will examine the report from Rothchild
and comment when it is published.
WELL-INFORMED
STUDENTS DRIVING
TEACHING EXCELLENCE
14. NUS welcome the introduction of some of our
suggestions on the Key Information Set and better information
for potential postgraduate applicants. However, we are critical
of the government's lack of consideration for how prospective
students will be guided through this information.
15. Information cannot be seen as an end to itself.
In chapter five of the white paper, plans for a new careers website
and telephone service are outlined, but we are concerned that
this will not go far enough to replace Connexions, even with the
requirement for schools to provide some independent advice.
16. We welcome the government's recommendation
on the release of contact hours information, although warn that
the amount of hours spent in the classroom does not necessarily
reflect the complete learning experience for students and we believe
that unless more information is provided to contextualise this
data, higher levels of contact hours may be seen as better value
for money when this is not necessarily the case.
A BETTER STUDENT
EXPERIENCE AND
BETTER-QUALIFIED
GRADUATES
17. The white paper outlines its vision for quality
assurance and encourages the greater use of students as part of
the QAA institutional review process. The chapter specifically
welcomes the work of the NUS/HEA Student Engagement Project as
a positive move for institutions and students to be working more
closely together, and launches a new NUS/HEA initiative on encouraging
more Student Led Teaching Awards. It also highlights that institutions
should be doing more to support students through welfare services
and recognises that students' unions also have an important role
to play in this.
18. It also welcomes the work of NUS in developing
union capacity, and asks to see more work undertaken by NUS and
individual SUs to strengthen course representation.
19. NUS welcomes the Government's support for
our mission to strengthen the voice of students through our varying
projects and is delighted by the White Paper's recognition of
the student movement as a vital part of achieving a high quality
education provision. We especially welcome the support in strengthening
the student voice in both developing course representation, as
well as specific measures to close the feedback loop where students
are currently informing enhancement activity. We also welcome
the suggested changes to the OIA which NUS have been asking for,
such as setting time targets for the resolution of cases, introducing
standards for how institution deals with complaints and increasing
the membership on the OIA board.
20. The Government suggests the introduction
of a 23rd question in the NSS, as a way for SU's to monitor their
impact and help them to keep developing in line with their members'
needs. We will monitor closely the impact of including this measurement
on students' unions themselves and consider our position during
the review next academic year.
21. Although we welcome the encouragement from
the government for employers to put more money into the HE system,
through sponsorship of individuals and courses, we would be concerned
if employers had the final say in what should be taught on courses.
We must also be careful not to create a two tier funding scheme
where non-traditional students must seek out sponsorship and shoehorn
their own ambitions into what business and charities are willing
to offer, where as students from more affluent backgrounds retain
greater choice.
A DIVERSE AND
RESPONSIVE SECTOR
22. NUS is opposed to the continuing development
of a market-driven system in higher education, and the following
comments do not preclude our fundamental opposition to the current
fees regime and withdrawal of public funding. However within this
new system it is necessary to look again at the issue of numbers
control and the limit on places. The Government has planned very
badly and got into a position where there is widespread concern
about whether the HE budget can be balanced, as a result of institutions
charging much higher fees than expected.
23. The numbers control measures proposed are
relatively moderate compared to some other models. It is to be
welcomed that a substantial core allocation to all currently funded
institutions will remain in place and that HEFCE will be responsible
for managing the allocation of the margin over time. We understand
that HEFCE will now consult on the detail of this mechanism and
how it will work, and we will respond to that consultation.
24. We have serious concerns over the use of
an attainment threshold for creating new opportunities. By allowing
unrestricted expansion of recruitment at AAB level, there is a
risk that institutions will dedicate large amounts of time and
resource to chasing highly-qualified applicants rather than concentrating
on teaching and quality improvement. We will be looking for cast-iron
assurances on the suitability of alternative qualifications to
A-levels at the same tariff-point level for entry into this unrestricted
band, and also for institutions to declare an applicant as an
AAB applicant if they have lower grades but are admitted under
a contextual data policy.
25. We welcome further exploration of new routes
to qualification, including the possibility of creating national
degree awarding bodies to give alternative options to HE in FE
providers and individual students as to where they gain their
qualifications, but we are concerned about the possibility of
these structures being driven for profit at the expense of creating
new qualification options of equal esteem. We would be very concerned
at the prospect of institutions established as charities and supported
with public money for many years being allowed to become profit-earning
companies.
ASPIRATION RAISING
& ADMISSIONS
26. We welcome Government support for contextual
data and aspiration raising schemes, of which we have campaigned
for a long time to see implimented. The loss of AimHigher will
be a significant blow to widening participation agenda, and we
urge the Government to rethink its decision to cut all AimHigher
funding instead of implementing transitional arrangements and
supporting knowledge transfer from the AimHigher Partnerships.
Without any form of transitional support, all the work of AimHigher
risks being lost.
27. We also welcome, and have been involved in
UCAS' review of its admissions processes. We support the idea
of implementing Post Qualification Application (PQA), and look
forward to being involved in the development of this.
WIDENING PARTICIPATION,
FAIR ACCESS
& OFFA
28. We welcome the potential strengthening of
the powers of OFFA, and have called on many occasions for OFFA
to have greater capacity to increase fair access. We are also
very interested to see more details regarding the proposed widening
participation framework.
29. The monitoring of postgraduate participation
is also welcomed, although we are concerned that by the time there
is enough data to see a trend, it will be too little too late.
NATIONAL SCHOLARSHIP
PROGRAMME
30. By requiring institutions to pay into the
fund (in addition to other commitments in their Access Agreements)
and expecting them also to look for charitable donations, the
Government is masking the fact that the £150 million National
Scholarship Programme is not nearly enough to cover the access
needs of the student population.
31. As bursary awards under the NSP will only
made once a confirmed student has applied, this will do nothing
to influence the application behaviours of the students it is
designed to target.
REGULATORY BODIES—A
REVISED ROLE
FOR HEFCE
32. NUS welcomes a new regulatory focus for HEFCE,
having repeatedly called for better student rights and protections.
33. The Government has made much in the press
of HEFCE's new role of "consumer champion". We are not
at all convinced that this concept is in the best interests of
students, and even if we did, there is little detail on how this
will give more protection or power to individual students in the
white paper. In fact there appears to be a lazy assumption that
merely having a regulator, giving it mysterious "reserve
powers" (which would only apply in the case of widespread
poor treatment) somehow will improve quality or student power.
34. There is welcome text on HEFCE's role in
ensuring financial sustainability, but giving HEFCE the role of
"orderly wind down" of institutions that fail or become
non-viable will do little to comfort the students involved.
REGULATORY BODIES—A
MORE TRANSPARENT
FRAMEWORK
35. NUS has repeatedly called for private providers
to be brought into the regulatory system, although we remain fundamentally
against the concept of private providers benefiting from public
finance.
36. We believe that any institution offering
a degree should have to participate in the OIA—not just
those using the student loans and grants scheme. We called for
only non-profit providers being able to access limited teaching
grants, and welcome this news.
8 July 2011
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