ࡱ> VXU ^5bjbj]q]q ,h??^-  m&'''''5V*'''*** ''****T*=0m***** :   Printable summary of your responses Name : Stephen Court Position : Senior Research Officer Institution/organisation : University and College Union Email : scourt@ucu.org.uk Responding as : Other - please specify in box below - University and College Union Address : Carlow Street Town : London Postcode : NW1 7LH 26/08/2011 11:38:00 Your responses 1 Following the changes to funding for higher education agreed by the Government, we need to phase out the mainstream teaching funding relating to old-regime students. Do you have any comments on our proposed approach? You may wish to suggest alternatives, with reference to the principles in paragraph 34 of our consultation. The University and College Union () is the largest trade union and professional association for academics, lecturers, trainers, researchers and academic-related staff working in further and higher education throughout the UK. We welcome the opportunity to respond to the consultation on teaching funding and student number controls but would like to express our concerns about the timetable. A consultation on a matter of significant importance to the sector over July and August is unacceptable and will not allow for the widespread debate within and outside the profession that is required. However, we acknowledge that this is the result of the delay in the publication of the HE White Paper and that ultimate responsibility for this lies with BIS rather than HEFCE. Paragraph 24 of the consultation document says: While these new-regime students are in the minority, we believe that the best approach to ensuring a smooth transition is to maintain considerable elements of the present teaching funding method, subject to adjustments that recognise the Governments new policy priorities. One aspect of the present teaching funding method is the use of moderation funding to cushion institutions from excessive turbulence in their income from the funding council. The consultation document also says: we want to minimise instability, disruption and uncertainty at a time of significant change in the sector (para 34). We consider that continuing moderation funding would play a key part in achieving the funding councils aim. In the 2010-11 recurrent funding allocation, moderation funding was approximately 19m or 0.3% of the recurrent grant. We recommend that a similar level of funding is set aside over the old regime to new regime transition period to help protect institutions from the impact of extreme change. Paragraph 42 proposes that the funding rates during the phasing out of the old regime students will depend on an institutions funding rates relating to its student population in 2011-12. We are concerned that basing rates on one year only may subject institutions to undue turbulence if the particular year in question was somehow unrepresentative of an institutions recent funding and student population patterns. We suggest that the funding council considers funding and student population patterns over the three most recent years in case 2011-12 was in some way an abnormal year, and considers contextual factors relating to individual institutions, before arriving at the final funding rates for individual institutions. 2 Given the reductions to HEFCE's teaching grant from 2012-13, do you have any comments on our proposal that certain non-mainstream allocations should be phased out, and others continued as an interim measure in 2012-13, as described in paragraphs 62 to 92 of our consultation? was firmly opposed to the previous governments policy of not providing funding to teach students studying for a qualification equivalent to, or lower than, one they already hold (ELQ). We also support maintaining capacity in strategically important and vulnerable subjects (SIVS). We therefore oppose phasing out funding for SIVS relating to ELQ funding. We oppose the proposal to phase out funding for research-informed teaching, which is part of funding for teaching enhancement and student success; we propose that funding for research into teaching should continue to be provided through HEFCE as it is in the interests of all HEIs to seek to enhance teaching, particularly in preparation for the introduction of tuition fees to a maximum of 9,000 in 2012. 3 Following government changes to funding for higher education, we need to change the way HEFCE provides teaching grant for new-regime students. Do you have any comments on our proposed approach for 2012-13, as outlined in paragraphs 31 to 108 of our consultation? The proposal in paragraph 98 that funding for subjects in price groups A and B should be sufficient so that HEIs do not to need to charge higher fees than for lower-cost subjects (C and D) is reasonable. Nevertheless, is strongly opposed to the policy being implemented by HEFCE of withdrawing recurrent funding for teaching for lower-cost subjects, and reducing funding for higher-cost subjects. 4 We have been asked by the Government to remove students achieving AAB+ equivalent from the student number controls. Do you have any comments on our proposed method of implementing this, as outlined in paragraphs 116 to 128 of our consultation? Please identify any possible negative or positive impacts from this proposal. There appears to be a contradiction between the proposal in para 117: All institutions will then be able to recruit freely from the AAB+ equivalent population, up to their student number control total and, separately, up to their medicine and dentistry control limits, and the aim, expressed in para 118 that institutions will be able to recruit without restraint from the AAB+ population. If HEIs will only be able to recruit AAB+ equivalent population up to the number control total, what happens if they recruit AAB+ students without restraint and exceed that number control total? Above all, we are very concerned about the access and equality implications of the new mini-market in AAB+ students. As a substantial proportion of the AAB+ A-Level students come from relatively affluent backgrounds, including independent or selective schools, the proposals could undermine widening access initiatives within research-led universities. In particular, the proposals will reduce the incentives for universities to use contextual admissions data and make offers that reflect the background and nature of students whose grades are below the AAB threshold. It is ironic that the White Paper celebrates the efforts of the Royal Veterinary College which has used contextual data to offer places on competitive courses when students have grades of CCC, and yet seeks to undermine such initiatives with the AAB+ mini-market. One potential consequence of the market in AAB+ students is that, in search of students with high academic potential, research-intensive HEIs in the Russell and 1994 groups which tend to have greater financial resources develop particularly attractive support packages for such students, which in turn draw them from less high-profile HEIs in the same city or region, creating a two-tier or polarised higher education system. It is worth noting that there were in 2009-10 several thousand students with AAB+ entry grades at approximately twenty large urban teaching-led post-92 HEIs. Such institutions could perhaps lose these students to research-intensive universities, which already recruit the majority of AAB+ entrants. Using a threshold based on A-level results may have unforeseen consequences on university departments if, as appears the case, students gain a higher proportion of AAB+ passes in some subjects, for example in the cheaper-to-teach arts and social sciences, rather than others, particularly some science and engineering subjects. In addition, the AAB+ policy may be inappropriate, or even destabilising, for higher education institutions which recruit on criteria additional to A-level results, particularly specialist institutions in the creative arts, which in their admissions process give considerable weight to a prospective students art portfolio or artistic performance. 5 The Government has asked us to consult on a core/margin approach to re-allocating places towards lower fee provision in order to increase choice, competition and fee diversity. Do you have any comments on our proposed method of implementation, as outlined in paragraphs 129 to 139 of our consultation? Please indicate any impacts you can identify, whether positive or negative. Competition for approximately 20,000 margin students open to providers with average full-time fees of 7,500 or less including institutions that do not currently have a funding agreement with HEFCE could see some or all of these students being recruited by Further Education Colleges or private providers. is opposed to the extension of private provision of higher education, and is extremely concerned about public funds being channelled into private, for-profit institutions, not least because we have serious concerns about the quality of provision that might be available in for-profit institutions that are competing on the basis of price. On the expansion of higher education within further education colleges will continue to demand that HE in FE staff have clear and comprehensive access to remitted time away from teaching to engage in necessary scholarly activity and research that will deepen and update both their subject knowledge and pedagogy to consistently underwrite a high quality learning experience for all HE in FE students. We are concerned at the potential for turbulence at HEIs with average fees after waivers of more than 7,500, particularly the teaching-led post-92s mentioned earlier in this submission, which might lose AAB+ students to institutions in the Russell or 1994 groups, and might lose margin students to FE colleges or private providers. This could have a significant impact on the finances of some institutions, particularly smaller ones operating on narrow financial margins. repeats its call expressed earlier in this submission for the continuation of moderation funding to limit destabilisation to HEIs due to these changes. We note HEFCEs comment in para 140 about taking mitigating action if needed in the case of negative impacts of the core and margin proposal, and urge that this might include moderation funding. 6 Do you have any comments on the impact(s), positive or negative, that the proposals in this consultation will have on equality and diversity? notes that the HEIs potentially most at risk from the AAB+ entry grade and core and margin proposals are the ones (see response to question four above) which have a high proportion of widening participation students, ie those from a disadvantaged background. Proposals which put at risk provision by such institutions cut across the funding councils desire as expressed in the proposal in para 68 to continue support for widening access for people from disadvantaged or minority backgrounds, and improving retention of such students. Potential students who might be more likely to want local provision of higher education because of their age (eg older students unable to move away to university because of existing commitments) or sex (eg female students who might be proportionately more unable to study beyond their locality because of caring commitments) could be disproportionately affected by the loss of educational provision if post-92 teaching-led HEIs specialising in widening participation are squeezed by the governments student number proposals. $(9A\t    ' / : M N ] ^ [\''9)00,1]5^5ٽh=cdh=cdB* CJaJphfh=cdB*CJaJphh=cd0JB*CJaJphh=cdB*CJOJQJaJphh=cdB*CJaJphh=cdB*CJaJphh=cd0JCJaJh\B*CJOJQJaJph'$N ] ['9)0,1]5^5dh]^gd=cddhgd=cddhgd=cddhgd=cd*&P 1h:p=cd. 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