Sneaking out late on a Monday evening comes details of the first attempt to cap the number of students getting places at universities since 2012.
The policy is broadly following the lines set out by Universities UK’s proposed “gentlemen’s agreement” cap – last year’s recruitment of English domiciled undergraduate full-time students, plus the forecasted addition for this year, plus 5 per cent. But there numerous curious additions and tweaks to unpick.
In a nutshell
All English providers in the Approved (fee cap) registration category get their student numbers cap (SNC) as described above. There are a few exceptions – providers that don’t (FE colleges) or haven’t (new-ish providers) submitted their annual financial return to OfS get 1.5 per cent on last year’s numbers rather than their forecast. Brand new providers don’t get a cap at all, and neither do those in the Approved (no fee cap) registration category.
Each provider can merrily recruit up to their allocated cap – and if they already have more acceptances that’s fine too, they just can’t recruit any more students after that.
For providers in devolved nations, there’s a cap on the number on English domiciled students they can recruit (set as last year (from Student Loans Company data), plus 1.5 per cent as a forecast proxy, plus the 5 per cent). These are just the students that are funded from SLC.
What happens if a provider over recruits – well money is taken back. This is done in two hugely peculiar ways.
In England, if a provider goes over, there will be a reduction to the fee limit for that provider in 2021-22. That’s right – all full-time undergraduates would pay less than the £9,250 cap for that year, with penalties in three bands:
- For a provider going beyond their SNC by >0% to 6%, there’s a 3% reduction in the fee limit (this presumably might include going over by a single student)
- For a provider going beyond their SNC by >6% to 12%, there’s a 9% reduction in the fee limit
- And for a provider going beyond their SNC by >12%, a 15% reduction in the fee limit
So, 2021-22 students may well pay less in fees because of the bad behaviour of their provider in a previous year. Which is… odd.
In the devolved nations, there is a variation – instead, we get a reduction to the amount paid to the provider per new student in 2021-22 by the Student Loans Company. There’s draft secondary legislation – “The Higher Education (Fee Limits and Student Support) (England) (Coronavirus) Regulations 2020” – to follow, primarily to make the punishments work in 2021-22.
If a provider wants to recruit even more than their SNC, there are two additional student numbers competitions they could enter. The first allows them to bid for up to 250 places in an odd grab bag of subjects including the hard sciences, architecture, teaching, and social work – which at least gives us what might turn out to be a prescient sense of the courses that DfE ministers regard as “valuable”.
The second allows providers to bid for any number of courses in a selection of healthcare disciplines.
The bidding/eligibility process feels very TEF – to the extent it uses TEF data. You need a continuation rate greater than 90 per cent and a highly skilled employment rate greater than 75 per cent from last year’s TEF workbooks to qualify for the liquorice allsorts competition (other than for initial teacher training for some reason) – plus there’s a 500-word statement of assurance where you assure DfE that you have the capacity, kit, and commitment to teach those extra students.
For the health care competition, there are no metrics, but you have to prove that you’ve filled all your existing places up to the cap and that you have the capacity to teach and provide clinical placements for the extras. There’s no cap on the number of places you can apply for – even the total of 5,000 doesn’t appear to be a hard limit.
The bidding competition has a metrics element – the higher your percentages in the two indices of power, the more places you get. You can’t bid at all if you are subject to any conditions of registration that start with the letter B.
6 massive gaping holes in the overall idea
In devolved nations, the cap only applies to full-time undergraduate students who attract student loans company funding, in England it applies to all students. This may mean that the (roughly) 7.5 per cent of FT undergraduate students who pay their fees with a cheque would not be subject to these limits if they choose to study in Scotland, Wales, or Northern Ireland – providers there that recruit students from well-to-do backgrounds can, seemingly, fill their boots. For similar reasons, we anticipate a growth in part-time enrolments that later shift mode – the perfect antidote for those who don’t fancy year one online.
The clawbacks are staggeringly inept in design and execution. There is no reason at all not to cap the amount of loans available via SLC for English providers – it could, in fact, be argued that forcibly reducing fees for 2021-22 would make the cap-breakers more attractive to applicants. Why not pay less for year one, if you have the chance?
And while the principle of giving students a fee cut might be a good one, this feels like an odd way to do it – offering the lower prices to the first cohort to see their study not affected by Covid-19.
Those young people who chose to sit actual A level exams in the autumn are also not counted within the cap. You can see why this has been done – imagine delaying your university year to ensure that you get the right grades and then not having a place available? But this now becomes a perverse incentive not to enter clearing if you’ve missed your grades – why go to a less favoured provider if you can resit and then get a place pretty much anywhere you want in January?
Speaking of which, there isn’t any mechanism for students who might choose to apply to university for a January start for any other reason. So if you need to spend an extra few months taking care of your poorly Mum, you might want to resit an A level too. Otherwise, the cap will apply and you may not get a place.
What are these caps? I mean we know how they are calculated, but we don’t know how many students each provider can take this year, because neither OfS nor DfE deems it appropriate (commercial in confidence, apparently) to publish the student number forecasts. So we won’t know who has been naughty and who has been nice until, we suppose, DfE or OfS announces it in due course. Transparency is a basic component for a trustworthy system of student number allocation – HEFCE used to do it well.
6 massive gaping holes in the additional student numbers bidding process
The full details for the bidding element of the policy are not due until 17 June, so take these points in the spirit of formative assessment – in the hope some of these problems can be fixed.
First – why is there an arbitrary selection of subjects eligible under pot one (no, it isn’t “high cost” subjects assumed at a first glance). Architecture is seemingly a priority despite there being neither a shortage or a current immediate need. Business logistics is going to be a massive issue – pandemic resistant supply chains feel like an investment in the future, but there are no additional places made for it. Surely the sensible thing to do would be to allow these additional places to flow where needed – if more people than usual want to study sport at Loughborough then surely a case could be made.
Or do you even need that? There aren’t any mechanisms that would stop a provider bidding for 250 extra social workers and then enrolling 250 more fine arts students. Clearly you wouldn’t (or shouldn’t) get away with only recruiting 249 social workers from that allocation. But 251 would presumably be fine – you could say that 250 of them were the “extra” you’ve been given.
There are some odd omissions in the healthcare list. Who’s been running all these Covid-19 tests for us? Lab physiologists. Is there a huge shortage in the UK? Yes, there is. Are there more places on offer. No. Pharmacists have been doing a cracking job as the new frontline, advising people on health care and hygiene during the pandemic, but according to DfE, we don’t need any more of them. Spoiler – we do.
It’s an easy target, but we’ll shoot: what exactly is the relevance of the employment of 2013-14 graduates six months after graduation on the ability to manage additional places? Why should the number of students who started in 2012-13 and then dropped out hold any sway? We understand why you can’t use actual TEF (because you might accidentally look at which students actually reported getting something out of the course in the NSS metrics) but it is obvious to any data-literate observer that eight-year-old data will have no predictive utility in the After Times.
Maybe we could drop these banal, useless, pretence of data-driven regulation and just beef up the actual bids. You get more than 500 words about a course on the UCAS page – surely to make a nationally-informed strategic judgement on the investment of public funds we would need a few extra words and maybe some data tables or diagrams. We also note you reserve the right to prioritise applications by geography and subject – why not just do that? Decide what courses you want to beef up, and where in the UK you want them, and then run some tiny, localised competitions?
And meanwhile, if you have a condition of registration under category B you can’t bid. Just to be clear, if you have 14 pence in the bank and your campus is partially owned by your credit card supplier, then you can bid for as many places as you like. But if your rate of highly skilled employment was a little out of whack in 14-15, forget it.
We know this is difficult to believe from a government that has been marked from day one by an attention to detail and a commitment to transparency and consultation, but from what we can see of this proposal it is a bit of a dog’s breakfast. We’ve said before that only a handful of monster recruiters are likely to come anyway near last year plus forecast plus five per cent, especially with deferments widely forecast and a demographic low point for UK 18-year-olds. So expectations for this intervention were low.
But somehow it has managed to be worse even than expected. Needlessly complex – requiring a statutory instrument? – and using wildly inapplicable data in a bidding competition that has learned nothing from the clean and elegant way HEFCE used to allocate additional student number. We’ve not been this disappointed by something since the year-long delay in the publication of the TEF review.
Note: Some changes were made to this article during the course of 2 June as our understanding grew.