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 Applying Student Number Controls to Alternative Providers with Designated Courses. Response to BIS Consultation from Professor Geoffrey Alderman

Name of organisation (or name of person if the response is a personal response and is not submitted on behalf of an organisation)?

What type of organisation is it? (e.g. Alternative Provider, HEI, FEC, Regulatory Body etc.)

Professor Geoffrey Alderman [Personal Response]

Question 2

Do you have a preference for Method 1 (control based on eligible students) or Method 2 (control based on students accessing funding)? If so, why is this?


Question 3

What is your view on submission of data to HESA? Do you think designated courses at alternative providers should participate in the Key Information Set and therefore complete the National Student Survey and Destination of Leavers in Higher Education survey (if student numbers are large enough to permit this)?


Question 4

Are there any other methods for controlling student numbers on designated courses at alternative providers that you would recommend instead of Method 1 or Method 2?  
The consultation seems to conflate two separate issues. The first is the manifest duty of the Government to control public expenditure.  The second is the freedom of a higher education institution to choose those students to whom it wishes to offer places. If an institution wishes to offer – say – 200 places on a particular designated programme of study, but the government only wants to fund – say – 50, let the government choose which 50, and inform the remainder accordingly. Why shift the responsibility to the institution?

Question 5

Do you agree that there should be an exemption from student number controls for alternative providers with small numbers of students accessing student support? If so, do you have suggestions as to how the Department should define ‘very small’?
No exemptions.  The principle must apply to all.  [Otherwise there is a grave danger of abuse of the system – an alternative provider might be tempted to ‘parcel itself’ into smaller units to gain the exemption]


Question 6

Equality considerations: Do you think that the proposals for applying student number controls will have any equality implications (e.g. positive, negative, or neutral) for people with protected characteristics (as set out in the Equality Act 2010), or people from low income groups?  What impacts might there be and do you have any evidence of possible impacts?

Question 7

Do you have any other comments on the proposals within this consultation document?
1.      The consultation professes that it wishes to “create a more level playing field of regulation between similar providers,” but the policy outlined does not do that. For example, the document proposes that alternative providers must have each relevant course “designated,” and could have this course-specific designation revoked. Why is this draconian principle not being applied to taxpayer-funded providers? Why do taxpayer-funded providers enjoy a ‘blanket’ designation, but not alternative providers?

2.  The consultation document ignores completely those “mixed-economy” institutions that offer both FE and HE and which are currently inspected by the Independent Schools Inspectorate (ISI). There is not a single mention of the ISI in the entire document. Why? Is the intention of the Department to “squeeze out” the ISI from all designated provision? If so this is wholly wrong.


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