ANNEX 2 (ii) – consultation on the proposed system for part time higher education funding – including student finance for 2012/13
Contents
Introduction and overview 1
The consultation process 1
Consultation feedback and Welsh Government comments 1
Annex A: Stakeholder responses to the consultation questions 5
Annex B: Full list of respondents 13
Introduction and overview
The Welsh Assembly Government issued a consultation paper on proposals to be made to the fee regime and student support system for part-time study in 2012/13 and were announced by the Minister for Education and Skills on 21 June 2011.
On 4 November 2011, having considered the consultation responses, the Minister announced his intention to postpone implementation of a revised system for part‑time higher education tuition fees and student support until academic year 2013/14.
The consultation process
The consultation on the proposed changes to higher education part-time fees and student support was launched on 5 September 2011 and was open for responses until 3 October 2011. The consultation was aimed specifically at stakeholders, but was also published on the Welsh Government consultation web page, making it available to the wider public. The consultation invited comment on some key questions (as listed in Annex A).
A total of 9 questions were set out in a proforma-style document within the consultation, and an online form was provided for ease of email return. The broad principles of the policy had already been agreed, meaning questions were specifically related to the finer details of the proposed changes and their implementation.
Consultation feedback and Welsh Government comments
Statistical analysis of consultation responses – summary
Total number of responses: 32
responses per cent
Higher education institutions (HEIs) and bodies 11 34
Further education institutions (FEIs) and bodies 8 25
Other organisations 7 22
Local authorities 2 6
NUS and student bodies 2 6
Members of the public 1 3
Third Sector organisations 1 3
Figures have been rounded to the nearest per cent, as such the sum of the constituent parts may not add to 100%.
A synopsis of the key issues identified by respondents is outlined below, grouped by all the stakeholder responses to the questions as laid out in the consultation document. Annex B provides a list of respondents for reference and excludes those who requested their response should remain confidential. Due to the delay in implementing the changes and the further ongoing analysis being done, the responses will not be published with this summary. On completion of the analysis, which is expected to be around Spring 2012, copies of non-confidential responses received in their original format and language will be available on request.
Some comments were outside the scope of the consultation, and although every effort was made to link these responses to the key themes of the consultation, this was not always possible. However, the essence of all such comments have already, or will be fully considered. The consultation document and response proforma adopted for this consultation can be found in the Education and Skills section (closed consultations) on the Welsh Government’s website at: www.wales.gov.uk/consultations. We would like to take this opportunity to thank everyone who responded to the consultation for their contribution.
Main themes arising out of the responses received
The overriding common theme was a request to delay the implementation of the changes until academic year (AY) 2013/14 instead of AY 2012/13 as originally proposed. However, there was also general agreement with the aims and objectives proposed in the consultation, especially with giving part- time study closer parity with full-time. Points for development and action were provided by many respondents. The delay to implementation of the changes was announced by the Minister for Education and Skills on 4 November 2011. The full statement can be found at:
http://wales.gov.uk/about/cabinet/cabinetstatements/2011/21juneparttime/?lang=en.
Below are the key themes arising from the responses to each of the consultation questions. More detail of the responses under each question can be found at Annex A. Although this document does not contain specific Welsh Government responses to the views provided at each of the consultation questions, the statement made by Minister for Education and Skills covers most of the major issues and concerns raised in the responses received. A list of the stakeholders providing responses (excluding those who expressed confidentiality) can be found at Annex B.
Key themes
· Importance of parity of part-time study with full-time.
· Timing of change.
· Retention of credit based funding system.
· Desire to maintain flexibility of study patterns.
· Recognition of need for fee plans to justify higher charges.
· Recognition of complex nature of part time study.
· Need for clear communication of changes.
· Need to reconsider approach for private providers.
Main points – summary of comments
Importance of parity of part-time study with full-time
· Respondents welcomed greater parity with full-time study and stated that the proposed part-time fee charging arrangements, including the setting of basic and higher amounts was to be commended and welcomed.
· Concerns were expressed about the proposal to link the part-time tuition fee grant with a requirement to take out a fee loan. Respondents suggested that this arrangement should be reconsidered and brought in line with the policy for full-time study.
· Part-time students will enter compulsory repayment after their third year of study if their income is above £21,000, even if they are still studying – respondents regarded this as a potential deterrent to applicants.
Timing of change
· The majority of respondents strongly advised delaying implementation until academic year 2013/14 to allow for further consideration of the changes and their impact.
Retention of credit-based funding system
· Respondents overwhelmingly wanted to retain a credit-based funding system, they viewed this as the fairest way to reflect a student’s changing pattern of study.
· The majority of respondents considered that a pro-rata basis of fee charging based on credits and intensity of study across all modes of part‑time study was the fairest way forward.
Desire to maintain flexibility of study patterns
· Several respondents indicated that they would like the Welsh Government or HEFCW to provide a clearer definition of part-time study.
· The majority of respondents considered that intensity of study over 75 per cent of full-time and below 120 credits should be treated as part‑time study for the purpose of student support and fee controls.
Recognition of need for fee plans to justify higher charges
· The majority of respondents agreed that all institutions providing higher education courses should be subject to the same fee planning requirements as for full-time provision when setting fees above the basic amount.
· There were differences of opinion between further and higher institutions on the level (basic fee) at which fee plans would be required. Further education institutions preferred institutional flexibility around the fee level whereas higher education institutions prefer to have basic and the maximum fees that can be charged aligned to the full-time fee arrangements.
· Respondents considered that linking part-time fee planning requirements to For Our Future1 priorities would help contribute to achieving its objectives.
Need for clear communication of changes
· Respondents indicated that there should be clearer communication of entitlement to part-time tuition fee loans and grants for those who have already undertaken higher education study.
· Respondents suggested that there should be a clear strategic communications plan in place to fully inform stakeholders and students of the part-time study changes in 2012/13 (or 2013/14 if implementation of the changes was to be delayed).
· Stakeholders requested that consideration be given to HEI and FEI representation on the Programme Delivery Board to help facilitate improved communication and understanding of implications for institutions.
Concern over possible changes in demand
· The majority of respondents envisaged the potential for a marked decrease in part-time study as a result of the introduction of higher fees combined with the current trend of the reduction in take up of provision.
· Respondents had mixed views on the question of capping student numbers, believing higher fees would themselves help to limit numbers.
· Respondents questioned whether any financial arrangements are to be put in place for those undertaking courses at an intensity of less than 25 per cent of full-time study and queried whether an increase in bursary awards may help to overcome this issue.
Need to reconsider approach for private providers
· Public money being used to finance tuition fee loans at private providers was seen almost universally as going in the wrong direction.
Stakeholder responses to the consultation questions
Key questions
The main proposals announced by the Minister for Education and Skills on the 21 June, both in relation to the part-time higher education fees and student support have been welcomed by the National Assembly for Wales. Therefore, the consultation paper did not invite comment on those broad principles. There remained, however, some key questions in relation to implementation of these proposals on which it was helpful to have views from stakeholders and delivery partners.
Part-time tuition fees
Q1. What should be the basic amount for part-time tuition fees, above which fee plans would be required from institutions wishing to charge a higher amount? Are there any advantages or disadvantages associated with establishing the basic fee amount at a fixed value for all part-time courses or varying the basic amount according to the course intensity?
Summary of responses
Most respondents welcomed the introduction of greater parity with full-time study and considered that the arrangements proposed for part-time fee charging and setting of the basic and higher amounts was to be commended. However some considered there may be risks associated with the proposals such as higher fees reducing demand for and take up of part-time courses, as well as administration costs to institutions, especially if a variable basic fee were to be introduced.
Some further education (FE) colleges considered that a variable basic fee instead of a fixed one would give them more flexibility. Higher education (HE) institutions considered that a fixed basic fee was fairer with some stating it should match the full‑time amount thereby allowing them to maximise income.
The majority of respondents considered that a pro-rata basis of fee charging based on credits and intensity of study across all modes of part-time study was the fairest way forward. This would allow institutional flexibility, take account of differences between part-time and full-time study modes and limit the cost to students.
Most respondents agreed that whatever the fee caps were, systems were needed to ensure that fees could not be charged above the cap (i.e. the higher amount). Some FE colleges considered that higher fees could have detrimental effects on their part‑time student intake and that flexibility on fee charging was crucial. The impact of higher fees on employer contributions was also a concern of several respondents.
Several institutions and other organisations provided differing pro-rata and fee setting options and indicated that some specific specialised provision might need to have fees set at higher levels to reflect the full cost of course delivery. Part-time fee plans (or combined with full-time fee plans) were seen as a crucial control measure and a way to direct institutional resources. Some FE colleges considered that their pricing of courses is already based on the real costs of delivery. Several institutions felt linking part-time fee planning to For Our Future[1] would help towards achieving its objectives.
Some concern was noted over the requirement for part-time students to take out a fee loan to access the tuition fee grant, which is not the case with full-time study.
Q2. Should institutions charging above the basic fee amount for part-time courses be subject to the same fee planning requirements as for full-time courses? Are there any specific issues which should be taken into account in respect of the fee planning guidance to be issued to HEFCW for part-time provision?
Summary of responses
The majority of respondents agreed that all institutions providing part-time higher education courses should be subject to the same fee planning requirements as for full-time provision when setting fees above the basic amount. Respondents suggested that fee plans needed to be adjusted to fully take account of the differing nature of part-time modes of study across the sector. This would address the “widening access” agenda, student support arrangements and strategic priorities such as For Our Future and the National Student Survey[2].
It was suggested that if fee plans were merged for all modes of study, more detail would be required to show how institutions are addressing or meeting government priorities/objectives. Several respondents indicated that institutions should strengthen pastoral and financial support provided to students, as this may increase retention rates. The provision of such support should, in their view recognise the differences between part-time and full-time study.
Several respondents raised concerns over potential employer reaction to higher part‑time fees and saw this as a significant risk to part-time vocational provision (an important part of the sector) that needs to be carefully considered.
Several respondents considered that the proposed timescales (2012/13) to introduce higher fees for part-time study were insufficient to allow the changes for full-time students to be properly assimilated and communicated to students. Most considered that implementation should be delayed for one full academic year to 2013/14. Early and specific communication to all students was seen as crucial.
Most respondents considered that account needs to be taken that similar services with similar costs are provided to both part-time and full-time students. However, to reduce administrative burdens and to allow flexibility to reflect the differing and complex needs of part-time students, fee plans should be written in a more targeted way for these students.
Q3. The Welsh Government proposes to make fee support available to eligible part-time students studying at an intensity of between 25 per cent and 75 per cent of the full-time equivalent. Should students studying between 75 per cent and 99 per cent intensity be treated as part-time students for the purposes of the student support (fee grant and loans) and fee capping legislation?
Summary of responses
The majority of respondents considered that intensity of study over 75 per cent of full-time and below 120 credits should be treated as part-time study as now. This was, however, not a universal view. Full-time study was seen by most respondents as 120+ credits per annum. The limited numbers of students studying over 75 per cent of full-time intensity should be subject to the same conditions as those studying between 25 and 75 per cent of full-time intensity, especially if in one academic year, they reduce or increase their intensity of study. Some respondents raised concerns about institutions not allowing students to study over 75 per cent of full-time intensity when fees are raised and reported that this currently happens at some HE institutions.
The credit based system equivalences (e.g. 90 credits = 75 per cent of full-time intensity, etc.) should be retained, with some respondents suggesting other calculations as alternatives, which could help reflect a student’s changing pattern of study. Some respondents pointed out the potential complications for the support system in trying to differentiate between modes of part-time and full-time study between 75 and up to 99 per cent of full-time intensity. Some respondents raised significant concerns about the lack of financial support to be provided to students undertaking less than 25 per cent intensity of full-time study and questioned the future funding arrangements for this intensity of study.
Q4. In view of the way in which the intensity of part-time study is negotiated between the student and their institution would the proposed method for determining pro-rata fee to be charged best work on:
a. a credit basis where the full-time equivalent study is defined as being 120 credits per year;
b. a banding basis where rates are set for 25 per cent, 50 per cent and 75 per cent study intensity; or
c. some other means of defining course intensity? e.g. on the basis of the number of years required to complete the course:
number of years of full-time course
x
100 = percentage course intensity
number of years of part-time course[3]
Summary of responses
The majority of respondents reported option (a) as their preferred choice as credits are currently used by institutions, would have less disruptive consequences to internal systems and would provide institutions with the greatest flexibility.
Several respondents provided advantages and disadvantages for each option.
Two respondents indicated that they would like to see a move to option (b) – that is banding.
Financial support
Q5. We intend to introduce support arrangements for part-time undergraduates which are similar to those for full-time undergraduates including access to a loan and a fee grant to cover the up-front costs of tuition fees for part-time courses between 25 per cent and 75 per cent intensity of a full-time course. Will these arrangements encourage applications for part-time study?
Summary of responses
Some respondents considered these proposals would assist the widening access agenda but many felt that charging higher fees would deter prospective part-time students from undertaking part-time HE with the potential effect being greatest on the least well off, most marginalised and socially excluded students. Many respondents felt those considering undertaking bite sized modules with an intensity of less than 25 per cent of full-time study would potentially be affected the most. Several respondents raised concerns about this issue, especially if the HEFCW teaching grant is, in future, no longer available.
Respondents noted that institutions have already experienced reductions in the number of students undertaking part-time study and even with no upfront fees and the availability of grants/loans, the price sensitive or debt adverse student might be put off. Again, the potential impact on employer contributions for part-time study was cited as a concern, as was the potential impact on both up-skilling and re-skilling opportunities. Concerns were also raised over current HEFCW funding for these types of courses and other short course provision. Respondents wanted reassurance or clarity over the levels of funding provided by HEFCW for this course provision when fee levels are raised.
Many respondents felt, some strongly, that the proposal to start loan repayments after thee years of part-time study would have a detrimental effect on students. Although this proposal is based on the conditions already established for full-time study where the student usually completes their studies after 3 years, respondents stated it seemed to them to be unfair to apply the same repayment timescales to part-time study. Several respondents suggested some other method of repayment would be preferential, such as loan repayments starting when a student’s course ends or when they have graduated and are earning over the £21,000 threshold. Several respondents were strongly opposed to the requirement to take out a fee loan to access the part-time tuition fee grant on the basis that this requirement would reduce the parity with full-time students.
Respondents considered that the communications strategy to publicise the changes to the part-time fees and support arrangements, needed to be carefully considered and managed. They stated that an appropriately targeted strategy should help correct any misconceptions students may have surrounding higher fees and the nature of the support package available.
In terms of whether the new arrangements would encourage applications for part‑time study, concerns were raised by, in the main, institutions providing courses to students who have had previous financial support. Under previous study rules such students would not be entitled to further support and consequently an impact of higher fees may be a reduction in the number of applications from students seeking to up-skill or change careers. Stakeholders considered that many such students currently benefit from fee waivers supported by HEFCW funding and if this funding were to be removed it would have a significant affect on them. Many respondents again suggested delaying the implementation of the part-time changes until 2013/14 to provide more time to consider the potential implications arising from the shift in funding to student support and also to take account of the experience in England in 2012.
Several respondents raised concerns over the lack of current financial support for students undertaking Equivalent or Lower Qualifications (ELQs) and that this may be exacerbated with the introduction of higher part-time fees.
Q6. We propose to make a tuition fee loan available for part-time students studying designated courses at private providers. The arrangements proposed for full-time students will provide for a maximum fee loan of £6,000. What do you consider should be the maximum loan available for part-time students?
Summary of responses
The majority of respondents had concerns about extending these support arrangements to private providers. Respondents considered that provision of increased loans could be seen as providing a subsidy to institutions which are not subject to the same requirements to meet For Our Future priorities as publicly‑funded institutions. If fee loans are provided to part-time students to attend private institutions, they should be required to provide a part-time fee plan to explicitly outline how they will target widening access, equality of opportunity and other stated Welsh Government priorities.
On the whole it was considered that this approach could be damaging for higher education, academia and the student experience in Wales, that it might lead to an influx of private HE provision and that it runs counter to the Welsh Government’s reconfiguration agenda. In summary, stakeholders put forward the view that the provision of public funding to enable students to study at private institutions represents a significant risk to the Welsh Government and to the higher education budget.
There was some support for matching the same pro rata levels of fee loans as for full-time study as is the case in England. However, if loans are to be made available to students studying at private institutions then stakeholders considered that they should be subject to the same regulatory and accountability requirements as publicly-funded institutions. Additionally, respondents considered that fee plans should be a requirement for private institutions charging fees above the pro-rata basic amount for part-time study.
Q7. In order to ensure that the policy is sustainable in the long term, we intend to control the number of under-graduate students eligible for part time support. What system and processes do you feel would be the most effective way of implementing a control on part-time student numbers in 2012/13?
Summary of responses
Many of the respondents considered that there is currently insufficient data available to assess whether part-time student numbers need to be capped in the future. Experience may demonstrate that there will be an overall reduction in student numbers if higher fees are introduced, creating a lower demand for part-time provision.
The introduction of penalties for over-recruitment and might help to limit numbers, although some priority courses would need to be exempted. Such provision could include employer sponsored courses, NHS bursary, work based learning or European Social Fund sponsored Foundation Degree courses.
Some respondents pointed out that one of the objectives of For Our Future is to increase the numbers of part-time students by 2012/13 and the opportunities to study part-time, which is at odds with capping numbers or provision.
If capping were to be introduced, as the consultation question suggests, respondents provided a range of possible flexible options. These included credits capping (favoured by most respondents), capping full-time equivalent (FTE) values, limiting Welsh domicile numbers at Welsh institutions or postponing implementation for one year (2013/14) along with ring-fenced funding in the interim. Concerns were raised that capping student numbers could result in reduced course or module provision.
Most respondents acknowledged the need for fiscal restraint in the current financial climate, but at the same time noted the need to increase take up of provision from its current level. Reducing the cost of part-time provision was seen by many colleges as a way forward.
Overall respondents considered that the changes to part-time fees and student support could lead to a much reduced take up of part-time HE provision. This could be exacerbated if employer contributions are significantly affected and the current trend towards lower demand continues. Some respondents indicated that some course provision could also be lost over time if a cap on numbers were to be introduced, unless careful consideration is given as to how this could be achieved.
Q8. Do you foresee any operational difficulties with student finance in relation to the changes we propose?
Summary of responses
Most respondents could foresee a number of operational difficulties with implementing these proposals. These included:
· the timescales are too tight and need to be delayed until 2013/14;
· the unpredictability of the part-time sector, the market and students;
· staff understanding the changes;
· implementation and operation of the proposals by the local authorities and the Student Loans Company systems;
· the interface with employer and bursary sponsorship;
· support arrangements for specific groups of students, for example, students with disabilities, carers and lone parents;
· transfers between modes of study;
· the arrangements for students with previous study or who are seeking to study equivalent or lower qualifications; and
· institutional planning assumptions.
It was suggested that these and other issues will require further and more detailed engagement with the sector in order for implementation to be successful. The communications strategy for prospective students needs to be sufficiently robust to dispel misconceptions about higher fees for part-time study. A multi-agency approach is needed to fully consider implementation of these proposals.
Respondents considered that the views of employers will also be important in respect of students taking vocational courses and those on continuing professional development courses. This was seen as a key component of the changes and potential impacts. Changes in circumstances are more prevalent to part-time students and systems need to be strengthened and made robust for the sector to capture them.
Respondents stated that more consideration should be given to the issue of fee loan repayments especially if implementation is delayed until 2013/14. Several respondents re-iterated their concerns about loan repayments being required 3 years after students commence their courses.
Q9. We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them.
Summary of responses
These comments were miscellaneous in nature, and some fell outside of the scope of this exercise, but are listed here for completeness.
· Should costs be related to the amount of teaching or contact the student has with the institution?
· Representation from higher education institutions on the Programme Delivery Board is desirable.
· Will there be any protection for high cost, Science, Technology, Engineering and Mathematics (STEM) or Welsh medium subjects?
· Consideration of the impact of the proposed changes across different communities within Wales needs to be further explored.
· The effect on cross border flows of students needs to be considered or researched.
· A quick response to respondent calls for a delay to implementation would be desirable.
· Consideration of unintended consequences as a result of these proposals.
· The effect of the proposed changes on the different types of part-time student should be considered.
· The sector seeks a clearer definition of part-time study.
· Clarification on the eligibility of those taking resits, part-time and full-time study mixed modes.
· The overall effect on teaching budgets once they are reduced to take into account new fee loans/grants – clarification on how this funding will be prioritised.
· Will the fee levels be subject to inflationary annual increases?
Full list of respondents
Respondents to the consultation (excepting those not consenting to publication):
Higher education institutions (HEIs) and bodies
Aberystwyth University
Cardiff University
Glyndwr University
National Association of Student Money Advisers (NASMA)
Open University in Wales
Swansea University
University of Wales, Newport
Further education institutions (FEIs) and bodies
Coleg Llandrillo
Colleges Wales/Colegau Cymru
Deeside College
Merthyr Tydfil College
Pembrokeshire College
Wales Evangelical School of Theology
Other organisations
Catholic Education Service for England and Wales (CESEW)
NIACE Dysgu Cymru
UALL Cymru
Local authorities
Cardiff Council (Cardiff/Newport Student Support Team)
Neath Port Talbot County Borough Council
NUS and student bodies
National Union of Students (NUS) Wales
Open University Students Association (OUSA) in Wales
Members of the public
Mrs Doyle, private individual