Response ID ANON-J6XW-KFVJ-Z
Submitted to Higher Education Reform
Submitted on 2022-05-05 09:05:00
Foreword from the Secretary of State and Minister of State for Higher and Further Education
Responding to the Independent Panel that reported to the Review of Post-18 Education and Funding on higher education Executive Summary
About you:
1 What is your name?
Name: Anne Sheppard
2 What is your email address?
Email: a.sheppard@rhul.ac.uk
3 Are you responding as an individual or on behalf of an organisation?
Organisation
If you selected organisation, please provide the name of that organisation. :
Council for the Defence of British Universities
4 Would you like us to keep your responses confidential?
No
Reason for confidentiality:
5 Do you consent to the data you provide being held in accordance with UK GDPR as covered in the Department for Education’s personal information charter?
Yes
Part 1: Policy statement on higher education funding and finance
Part 2: Consultation on potential reform areas (Section A)
6 What are your views of SNCs as an intervention to prioritise provision with the best outcomes and to restrict the supply of provision which offers poorer outcomes? If you consider there are alternative interventions which could achieve the same objective more effectively or efficiently, please detail these.
Please explain your answer and give evidence where possible:
The problems created by the removal of SNCs have been well documented in the review by the Independent Panel. Restoring SNCs in some form seems desirable as a way of stabilising the market in HE. However more work is needed on the definition of ‘the best outcomes’ and ‘poorer outcomes’. While the categories of quantifiable and strategically important outcomes are well defined in the documentation accompanying this consultation, the societal outcomes are defined in too limited a way. The purpose of SNCs needs to be considered more carefully before they are re-introduced. Given the pre-eminence of the Russell Group, for example, and the ability of its institutions to attract applicants irrespective of the quality of its individual programmes, there is evidence that removing SNCs has reduced effective competition between Russell Group and non-Russell Group institutions to the detriment of the sector overall.
7 What are your views on how SNCs should be designed and set, including whether assessments of how many students providers can recruit should be made at:Sector level? Provider level?Subject level? Level of course? Mode of course?
Please explain your answer and give evidence where possible:
In order to stabilise the market in HE, SNCs should be designed and set at sector level and then at provider level. Such a stabilisation of the market will in itself improve the quality of provision, for example by discouraging HEIs from admitting larger numbers of students than they are equipped to teach, and contribute to retain regional spread of provision in key and vulnerable areas. However designing and setting SNCs at subject level, level of course or mode of course would mean attempting a level of control which would be unhelpful and unproductive; it is simply not possible to predict how many graduates in a specific subject or course will be required at any one time, given the diversity of graduate employment and the changing needs of society. Such an approach is only appropriate for strictly vocational programmes such as medicine and dentistry; it cannot readily be transferred to other types of course.
8 The Government is considering which outcomes should be used if SNCs are introduced and has identified the three broad categories as quantifiable, societal, and/or strategically important. What are your views of the merits of these various approaches to consider outcomes and/or do you have any other suggestions?
Please explain your answer and give evidence where possible:
As noted above, the categories of quantifiable and strategically important outcomes are well defined in the documentation accompanying this consultation but the societal category is at present too narrowly defined. It is very disappointing that the documentation shows no real understanding of higher education as a public good which produces better informed and more enlightened citizens, so benefiting our democracy and society as a whole.
9 Do you have any observations on the delivery and implementation of SNCs, including issues that would need to be addressed or unintended consequences of the policy set out in this section?
Please give evidence where possible:
The documentation accompanying the consultation sets out clearly the history of SNCs since 1994/5. Each phase of that history had its own advantages and disadvantages. These need to be studied in more detail so that lessons can be learned.
10 Do you agree with the case for a minimum eligibility requirement to ensure that taxpayer-backed student finance is only available to students best equipped to enter HE?
No
Please explain your answer and give evidence where possible:
Research by the Institute of Fiscal Studies (see https://ifs.org.uk/publications/16039) indicates that minimum eligibility requirements risk diminishing the access to Higher Education of minority groups, including those from a lower socio-economic class. By the time allowance is made for exemptions, the number of students excluded by a minimum eligibility requirement will be very small, as the second paragraph on ‘Exemptions’ above explains. This proposal has hit the headlines in the media and is politically divisive. It is far from clear that it will be effective.
11 Do you think that a grade 4 in English and maths GCSE (or equivalent), is the appropriate threshold to set for evidence of skills required for success in HE degree (level 6) study, managed through their eligibility for student finance?
No
Please explain your answer and provide reference to any pedagogical or academic sources of evidence to explain your reasoning:
Please see our answer to the previous question: the case for a minimum eligibility requirement is not satisfactorily made in the documentation accompanying the consultation.
12 Do you think that two E grades at A-level (or equivalent) is the appropriate threshold to set for eligibility to student finance, to evidence the skills required for success in HE degree (level 6) study?
No
Please explain your answer and provide reference to any pedagogical or academic sources of evidence to explain your reasoning. : Our answer to this question is the same as to the previous one.
13 Do you agree that there should there be an exemption from MERs for mature students aged 25 or above?
Yes
Please explain your answer and give evidence where possible:
If MERs were to be introduced, such an exemption is desirable for the reasons given in the documentation accompanying this consultation. 14 Do you think there should be an exemption from MERs for part-time students?
Yes
Please explain your answer and give evidence where possible:
If MERs were to be introduced, such an exemption is desirable for the reasons given in the documentation accompanying this consultation.
15 Do you agree that there should be an exemption to the proposed MERs for students with existing level 4 and 5 qualifications?
Yes
Please explain your answer and give evidence where possible:
If MERs were to be introduced, such an exemption is desirable for the reasons given in the documentation accompanying this consultation.
16 Do you agree that there should be an exemption from any level 2 eligibility requirement to level 6 study for students with good results at level 3?
Yes
Please explain your answer and give evidence where possible:
If MERs were to be introduced, such an exemption is desirable for the reasons given in the documentation accompanying this consultation.
17 Do you agree that there should be an exemption to MERs for students who enter level 6 via an integrated foundation year, or who hold an Access to HE qualification?
Yes
Please explain your answer and give evidence where possible:
If MERs were to be introduced, such an exemption is desirable for the reasons given in the documentation accompanying this consultation.
18 Are there any other exemptions to the minimum eligibility requirement that you think we should consider?
No
Please explain your answer and give evidence where possible:
The documentation accompanying the consultation gives full coverage to a range of exemptions to be considered.
Part 2: Consultation on potential reform areas (Section B)
19 Do you agree with reducing the fee charged for foundation years in alignment with Access to HE fees?
Yes
Please explain your answer, providing evidence where possible:
We agree with the case put forward in the documentation accompanying the consultation.
20 What would the opportunities and challenges be of reducing the fee charged for most foundation years, and of alignment with Access to HE fees?
Please explain your answer, providing evidence where possible:
CDBU is not in a position to answer this question.
21 Do you agree there is a case for allowing some foundation year provision to charge a higher fee than the rest? Or is there another way for government to support certain foundation years which offer particular benefits?
Please explain your answer:
CDBU is not in a position to answer this question.
22 If some foundation year provision were eligible to attract a higher fee, then should this eligibility be on the basis of: Particular subjects? Some other basis (for example by reference to supporting disadvantaged students to access highly selective degree-level education)?
Please explain your answer:
CDBU is not in a position to answer this question.
23 What are your views on how the eligibility for a national scholarship scheme should be set?
Please explain your answer:
The proposal for a national scholarship scheme is welcome but seems at present very vague. It would be good to encourage applicants from schools which do not send many pupils to university, from low-income families. While one might expect academic criteria to feature in the eligibility requirements, these should not be the sole consideration.
Part 2: Consultation on potential reform areas (Section C)
24 How can Government better support providers to grow high-quality level 4 and 5 courses? You may want to consider how grant funding is allocated, including between different qualifications or subject areas, in your response.
Please explain your answer and give evidence where possible:
CDBU has no position on this.
25 What drives price differences at level 4 and 5, where average fees in FE providers are significantly lower than in HEIs? Please explain your answer and give evidence where possible. :
CDBU has no position on this.
26 To what extent do the drivers of fees at levels 4 and 5 differ from those for level 6 (including between universities, further education colleges and independent providers)?
Please explain your answer and give evidence where possible:
CDBU has no position on this.
27 How can we best promote value for money in the level 4 and 5 market to avoid an indiscriminate rise in fees? Please explain your answer and give evidence where possible:
CDBU has no position on this.
28 Which learner types are more or less price-sensitive and what drives this behaviour? As part of your response, you may want to specifically consider the learner cohorts described above and the equalities considerations set out in the level 4 and 5 section of the equality analysis document, published alongside this consultation.
Please explain your answer and give evidence where possible:
CDBU has no position on this.
29 What are your views on the current barriers, including non-financial barriers, that providers face in offering and marketing level 4 and 5 courses?
Please explain your answer and give evidence where possible:
CDBU has no position on this.
30 We want to ensure that under a flexible study model, learners studying HTQs still develop occupational competence. We also want the quality and labour market value of individual higher technical modules to be signalled. Which of the approaches below, which could be introduced separately or together, do you prefer for delivering these aims, and why?
Please explain your answer:
CDBU has no position on this.
31 How would these approaches align or conflict with OfS and/or university course approval requirements? Please explain your answer and give evidence where possible:
CDBU has no position on this.
32 Are there any other approaches we should consider?
Please explain your answer and give evidence where possible.:
CDBU has no position on this.
33 How should any of these approaches be applied to qualifications already approved as HTQs?
Please explain your answer and give evidence where possible.:
CDBU has no position on this.
Additional Comments
34 Do you have any other comments?
Free Text:
The documentation accompanying the consultation talks of ‘good outcomes’ but seems to assume that such outcomes are a matter of individual graduates securing high-earning (‘high-skilled’) employment. There is no consideration of what would count as a good outcome for society overall. We are disappointed that the Government appears not to recognise the valuable roles which graduates play in areas of civic life such as the public services and the arts and the less visible but well-attested social and public benefits of a UK higher education, including public citizenship, better health profiles, self-sufficiency, public spiritedness and the understanding and celebration of our heritage in all its diversity.
Join our mailing list to receive the latest blog posts by email.
