access to a more competitive student finance package for courses leading
to approved HTQs, than those who do not meet the technical conditions?
327. Ninety respondents provided qualitative comments to Question 22 and the views expressed were varied. Generally, respondents either agreed or disagreed outright with the policy proposal or agreed that whilst a competitive student finance package was required to incentivise take-up, they had serious reservations about linking this to OfS registration conditions.98
328. Those that were supportive of the proposal felt that it would help drive quality and build capacity. Those that were not were concerned that it could create a two-tier system and freeze certain providers out of the market, stifling student choice.
329. Several requests for further clarification were also made and it was felt that further consultation with students and stakeholders was required specifically on student finance in relation to HTQs.
Creation of a two-tier system (42 references)
330. For those that disagreed with linking student finance to ongoing registration conditions, key concerns related to introducing inequality into the system, reducing choice and penalising both providers and students. Whereas it was agreed that there should be a benchmark by which quality is assured, choice and access were perceived to be a priority. It was therefore felt important that there was still an opportunity for non-approved qualifications, or courses delivered by providers not meeting the OfS conditions, to be eligible for student finance if they met local need.
331. In addition, the proposed technical conditions also raised concerns. As outlined in responses to Question 14, questions were raised about the value and necessity of this
proposal. It was argued that many providers, ABs and professional bodies are already subject to rigorous regulation, meet professional standards and deliver high-quality qualifications and that they therefore should have access to student finance without needing to meet additional regulatory requirements.
332. Specific concerns raised were:
• The approach may lead to regional gaps in provision:
− Providers in rural or harder to reach areas, or those with funding or staffing challenges, may struggle to meet the OfS conditions.
− Where providers do not meet conditions, they should have access to support and development to help them reach them, especially where provision is necessary ensure student access or is in areas of strategic importance.
“This approach has the potential to lead to HTE provision cold spots
across England as it’s likely that institutions in metropolitan areas are more like to meet ongoing registration conditions (financial requirements) due to access to higher student numbers. It immediately creates a two-tier
system, which does not support the Industrial Strategy social mobility targets. Some form of support to enable institutions that are financially or regionally challenged by the conditions, due to rurality, or where previous funding cuts have affected potential to meet requirements, would be needed to ensure no disadvantage occurs.” Awarding body
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• Providers will have to go through a resource-intensive registration process to gain access to the market. Where a qualification is already recognised and meeting the needs of local markets this could be seen as unnecessary. It may be more prudent to keep provider costs low, resulting in lower fees for students.
• Students may be disadvantaged if their local provider does not meet the conditions. This could have a disproportionate impact on learners who are less able to travel, e.g. disabled or economically disadvantaged students or those with caring responsibilities. • Different student groups, e.g. those studying part-time, will have different financial
support needs and may benefit from varying packages.
• Funding may be challenging for many high-quality, market-relevant qualifications if they are not approved.
• Qualifications that do not map to occupational standards, or where there are no existing standards or Route Panels, will not have a standard against which they can be approved.
Driving quality and building capacity (20 references)
333. Those in support of the proposal felt that it would make HTE more attractive and would encourage providers to deliver high-quality courses that are responsive to local market needs.
“Offering a more competitive student finance package for approved HTQs would underpin their quality and sustainability, as well as the reputation and credibility of technical and vocational education. Creating parity between technical HE and academic HE in the student finance packages would send a clear message that there is also parity in the value of those technical HE qualifications.” Provider (HE)
334. Further, some respondents believed that those that did not meet the standard should not have access to the markets, particularly given the costs associated with registering.
“Agree – there is a cost of registering for HTQs and providers who achieve the standard should have greater access to the market than those that do not. Indeed, those that do not should be excluded from the market.” Professional/business organisation
Encouraging take-up amongst students (18 references)
335. For those that supported the proposals, in addition to encouraging a high-standard of provision, it was felt that it would make HTE more attractive for students. A competitive funding package was seen to be an appropriate incentive to encourage students and ensure that costs are not passed on to them. In addition, it was felt to demonstrate the quality of HTE, which would itself help engender positive perceptions of technical learning and encourage uptake.
100
More consultation or clarification required (39 references)
336. The consultation document set out that the detail regarding student finance packages was dependent on the conclusions of the Spending Review. As such, respondents felt that further consultation within the sector would be required once proposals were more clearly defined. In addition, because the proposal directly impacted students it was felt that they should also be consulted prior to decisions being made.
337. Respondents also asked for clarification in a number of areas:
• The definition and breadth of HTQs and the extent to which level 4/5 qualifications will be considered HTQs.
• How the “competitive funding package” would sit with existing funding arrangements, including Advanced Learner Loans, and the potential for simplifying the funding system. • How indicators of quality and the funding received by providers will be defined and
determined.
• The extent of providers’ responsibility to deliver skills required by local industry. “We would broadly agree with this statement, however this assumes that the definition of HTQs is sufficiently broad and accommodates local flexibilities necessary to support the development of a local workforce. A broad, national, definition that didn’t allow this local flexibility would force providers to decide between the financial incentive of the HTQs or delivering a qualification that met the needs of the local economy to the detriment of the providers financial health.” Provider (HE)