Scottish Government

A response to the proposal to set a higher fee for non-Scottish-domiciled medical students studying in Scotland

Preamble

The Coalition of Higher Education Students in Scotland (CHESS) represents the interests and views of its member institutions; the students' representative bodies of the universities of Dundee, Aberdeen, Glasgow, St Andrews, Strathclyde and the Open University in Scotland. CHESS represents around fifty percent of students studying in Higher Education institutions in Scotland, including four of Scotland's five medical schools. This submission can be seen as a joint submission by the bodies representing students at the member institutions.

Introduction

CHESS welcomes the chance to respond to the Executive's proposals and hopes that the Executive takes on board the comments made below . We do, however, have concerns about the manner of this consultation that limits the degree of stakeholder input. These concerns are outlined later in the paper and we would wish the Executive to reconsider its approach to consultation on this and other issues . In this response we seek to make our principled opinion known on how the Executive's proposal may affect students and also make suggestions as to what other areas may be more usefully examined as part of a more holistic approach to the issues raised . We believe a broader and more informed consultation should be considered to allow a more constructive input from all areas, which may negate the perceived need to consider fee increases .

Key principles

CHESS has consistently opposed the existence of tuition fees and the existence of variability within any tuition fees regime . CHESS reaffirms its belief that finance should not be a barrier to entry to Higher Education nor a determinant of a student's academic choices . Higher Education should not be a marketable commodity but a public good open to all and benefiting all regardless of finance or background. No student or graduate should have to suffer burdensome debt which provides both a deterrent to entry and a tax on ambition. The use of fees to deter English students from studying in Scotland shows that the Executive acknowledges that fees can deter students from entering higher education. Whilst we oppose the existence of fees, burdensome debt and variability, we wholeheartedly support the goal of widening participation in Higher Education as a key tool of social justice and equality. This is a valid consideration for any policy and improving access to the medical profession for under-represented groups is especially important.

CHESS is also sympathetic to the needs of Scotland's health service and NHS recruitment, but must primarily represent student needs and opinion . Again, fees and student hardship should not be used as mechanisms for the Executive to use to further their wider goals. CHESS believes that a wider discussion on ways in which to encourage students to stay in Scotland after graduation would be more valuable than the use of fees to deter students.

Section 2 , subsection 1 : the general fee level

The Draft Statutory order makes provision for a "general fee level" for all Scottish undergraduate degrees, excluding medical degrees, of £1700 per annum . This is an increase of £500 per annum compared to the current fee level of £1200 per annum. Students studying at a HEI in Scotland from September 2006 would graduate from afour-year degree £2000 more out of pocket than Students currently studying at Scottish HEIs. However, we welcome the Department for Education & Skill's decision that English domiciled students at Scottish HEIs will be able to defer payment of the fee . We also recognise that the Net Present Value of this debt is roughly similar to the pre-increase fee and that it is less of a deterrent than having to pay up-front.

The continual increase of tuition fees for students in non-medicine courses merely serve to increase further the cost and expense of attending university . Although it is true that Scottish Students would not pay this amount upfront they would still leave University with a higher level of debt than current Students, especially if they are studying a second degree or if SAAS in the future does not pay tuition fees . Several prospective students are already put off from studying at HEIs due to the current amount of debt they will incur, this rise in the general fee level will only further discourage individuals from studying at HEis. This move does not reflect the Scottish Executives commitment to widening participation.

The rise in the general fee level takes no account of additional costs incurred in the fourth year that would not be incurred through study elsewhere in the UK. Whilst CHESS accepts and respects the Scottish Executive's attempt to deal with the reality of a market-based system, our concern is the costs of studying in Scotland will be higher than the rest of the UK . The Scottish Executive will therefore see an increase in home students opting to study in the rest of the UK and not in Scotland, thus losing valuable members of the Scottish workforce and potentially creating a skills vacuum. CHESS believes that increasing student fees is not the solution to funding problems.

Principles in relation to the proposal to increase fees for medical students [Section 2 , sub section 2]

CHESS recognises that there are some difficulties in reconciling the above principles in a post-top-up fees context but rejects the proposal that fee variability be considered to pursue any aim. It is deeply regrettable that a situation exists where fee variability can be suggested as a way of protecting access to Higher Education, yet CHESS believes the Executive need not go down this route.

CHESS believes that to accept the logic of a differential fee in one instance is to open the door to similar appeals from other areas using the same rationale. We are concerned that `special pleading' in one area would lead to similar pleas from others. The development of a segmented and differentiated market for students in Scotland may not be the intention of this proposal but will undoubtedly be the unwelcome result. CHESS does not believe that medicine will universally be accepted as a `special case' but instead believes claims from other areas would quickly be forthcoming. With the potential squeeze on Higher Education funding and the uncertainty of the long-term effects on Scottish Universities of the introduction of top up fees in England and Wales, it does not take too much to imagine other subjects jealously eyeing the increased fees that medical schools are receiving per non Scottish Student. Will this then lead to pressure being brought to bear to allow dentistry, law or the sciences for example to start to claim their entitlement to charge differing fees for their course?

Once this order comes into fruition Section 2(l)(2) would set the fee for medical students to study medicine at a Scottish university to £2700. There has been no evidence from the Scottish Executive to allow the membership of CHESS to support a fee of this level. We have a number of concerns and they can be discussed here .

Firstly the level of debt this will put a student into . With the course of study to obtain a medical degree being 5 years, the cost of fees alone will be £13,500 . This is a massive amount of a debt for students to comprehend placing themselves in. This figure though is for tuition alone . On top of this there will be the quite considerablecosts for accommodation, books, living expenses etc that are a necessary part of being a student. The demands of studying medicine are such that in many cases if students wish to have some form of part time employment then this will be to the detriment of their studies . Such part time employment would be almost impossible in the latter years of their course when placements may require the student to work in a part of the country far from their place of learning. This would place Students who are struggling to support themselves financially in regards to fees and maintenance with a large amount of stress .

To afford the costs associated the student will have the choices of relying on parents or borrowing to fund their time at University. While many families would be able to afford such support for their offspring, many cannot. Is such a provision preventing families from lower social and economic backgrounds from attempting to enter the medical profession? It would be a failure of the Scottish Executive's if able students Were deterred from applying and commencing a medical degree on the basis of financial obligations. The risk of this should not be underestimated. Although it is currently true that Scottish Students would be protected from tuition fees specified in the Order because they are paid on the Students behalf by SAAS, this might not be the case in the future .

CHESS welcomes the expressed intentions of the Executive to maintain their opposition to up-front fees and fee variability for Scottish-domiciled students in Scotland, yet would not like to see the same disadvantages of England's top-up fee system extended to students in Scotland originally domiciled elsewhere in the UK. CHESS would further like the Executive to clarify its proposals with regards to Welsh and Northern Irish students, whose future tuition fee regimes are not clear . If either or both decide not to introduce top-up fees then the fears of much higher numbers of these students coming north would disappear and the logic of creating a higher fee for Welsh and Northern Irish students would be diminished .

CHESS would like the Executive to clarify their position in relation to Welsh and Northern Irish students in relation to their potentially different fee regimes .

At the moment the proposal is not to allow differential fees for Scottish students. There is the risk though that by the current Scottish Executive to put forward this Order, the precedent for future Executive's to amend the rules on who is eligible over a period of time, is set . Such a process may not happen, but the politicians of today cannot be sure of the decisions and choices that their successors will take.

CHESS does not believe a conflict between enhancing NHS recruitment, protecting access to medical places for Scottish-domiciled students and maintaining a fees system free of variability is necessary. CHESS urges the Executive to consider the issues more comprehensively and innovatively and propose other options and potential solutions for consultation that do not involve the use of variable tuition fees. In fact, CHESS welcomes many of the recommendations of the Caiman Report as positive ways that might be built on in order to avoid the perceived need for fees.

Consideration of premises and unknowns

A key problem with the proposition to increase fees for non-Scottish-domiciled medical students is that it is based on speculative premises and without serious consideration of potential alternatives. For example, whilst domicile may at present be an influencing factor in recruitment and retention, it can hardly provide a full picture, and CHESS believes a more holistic and imaginative approach must be taken . Other key factors affecting recruitment and retention may relate to living and working conditions, location of medical school in relation to the need for health workers, and any other factor that may make working in Scotland appear a less favourable alternative to working elsewhere in the UK.

The Caiman Report does highlight a number of these issues but does not give particular recommendations in this area, which would be helpful . It does, for example, highlight issues such as `the St Andrews Question' (s60-74) but lacks any major initiatives to incentivise domicile after graduation or improvements in working conditions.

CHESS would like the Executive to provide information and impact assessments on all other options, no matter how ambitious, to boost NHS recruitment and retention of all UK-domiciled graduates, and clarify the legal, financial and other implications of each.

Further, it is not clear what effect the introduction of top-up fees will have on crossborder applications and current thinking is speculative. It may be reasonable to plan for the eventuality of a higher demand for Scottish Higher Education, but it would also be prudent to avoid rushing in to implementing proposals detrimental to students when the problem may not be as severe as sometimes imagined .

Further still, whilst factors affecting recruitment and retention other than domicile need consideration, so do factors affecting application and admissions to medical courses. The Caiman Report does rightly highlight a number of these issues and CHESS believes the Executive should provide more concrete proposals as to how steps might be taken to improve transition from Highers to medicine, how school outreach may increase applications from Scottish-domiciled students, or how admissions procedures might be tailored to protect places for Scottish-domiciled students once applications are received. CHESS welcomes the recommendation that Scottish medical schools need to give more attention to the realities of secondary schools in Scotland (s46) and welcomes also the consideration of the `4 means of widening access' (s48).

The Calman report is one of a number of Higher Education documents that notes the major current challenge to widen participation in medicine is in fostering "aspiration, achievement and application" (HEFC 2003) in under-represented groups, implying a key role to ever more active recruitment and reform at school level . Yet if the fear is that greatly increased applications from well-qualified English applicants post-2006 will cancel out any gains made in this respect, ambitious reform of admissions procedures should be considered as an alternative to fee increases.

The Calman Report's recommendation to `ring-fence' the newly created medical places for schemes that increase the diversity of Scottish medical courses and for those most likely to be committed in the long-teen to NHS Scotland is welcomed. CHESS would be interested to know the extent to which mechanisms such as these could negate the perceived need for fee increases.

Schemes such as the `Pathways to the Professions', foundation year courses and ringfenced access places are positive schemes that, if expanded, might provide other ways of achieving the Executive's aims . Admissions procedures tailored to Scottishdomiciled applicants do exist (at Edinburgh the number of Scottish-domiciled applicants accepted is disproportionately high compared to application rates because of this) and might also be another avenue to be examined. If the executive could be bold and imaginative in providing alternatives for consideration, such as greater use of ring-fenced places, then this might negate the perceived need for fee increases and provide a more positive, constructive and ultimately more preferable approach .

CHESS would like the Executive to provide information and impact assessments on all other options, no matter how ambitious, could exist to boost recruitment and retention in University admissions and clarify the legal, financial and other implications for each .

CHESS is not at this stage advocating use of any of the above methods, merely that they must be deliberated over and consulted on. CHESS believes there is a wider picture to be considered and the Executive must deal with these areas before considering the use of tuition fees.

Aside from the recommendation to `take special account' of the position of medical funding (s8 1), the Colman Report has a number of very promising and constructive recommendations. CHESS believes some of the recommendations made, as well as many of those omitted, could be used to build an approach that negates the perceived need for a fee increase and would like to see these, and the assessment of their impact, progressed before consideration of funding changes .

CHESS reiterates that tuition fees cannot be used as `an easy option' in pursuit of the Executive's goals.

Other Options and poverty of consultation

CHESS appreciates this Consultation and the Scottish Executiverightly prides itself on its consultations with stakeholders, however we reiterate our belief that the introduction of differential fees into Scottish Education should require open public debate and primary legislation.

Given the importance of preserving the excellence of the Scottish National Health Service, CHESS believes that it is important that there is a full discussion on what can be done including

CHESS is not necessarily endorsing actions based on any of the above, but believe they would all be appropriate items for consideration in a wider and more informed consultation. Other appropriate bodies with far more expertise on these issues may have other suggestions also.

CHESS acknowledges that this consultation is limited to the issue of fees, but would like the Executive to reconsider the whole approach and launch a consultation with more information, options and impact assessments, including some of the suggestions above.

CHESS would like such a consultation to find a solution that negates the perceived need for increased medical fees.

Considerations if proposals were progressed

CHESS reaffirms its opposition to the introduction of increased medical fees for non-Scottish-domiciled students but believes it prudent to comment on the practicalities of any such increase and what the Executive must do if it were to implement such an increase.

Firstly, if the Executive were to ignore the views of the student body and impose such a fee increase, CHESS believes that a firm public commitment should be made stating that no other `special cases' would be considered and differential fees would go no further.

Secondly, if the Executive were to ignore the views of the student bodies and impose such a fee increase, CHESS believes it should set the fee at the minimum level possible. When deciding a fee level it should consider not just the relative price of tuition fees in England, but also the level of bursaries that accompany those fees. If the same fee level as England were set but without the accompanying benefit that students in England would receive, the real-terms cost of fees where would be significantly higher. The calculation set out in Annex C to the Order makes clear that the value of bursaries was considered. CHESS considers that the lack of bursaries available to those students further impinges on the Scottish Executive's stated desire for wider access to Medical Education.

Thirdly, if the Executive were to ignore the views of the student body and impose such a fee increase, CHESS believes that any revenue raised from the fee increase should be reinvested into widening participation . The revenue could provide access bursaries and other means of financial support for students from `non-traditional' backgrounds seeking to enter medicine, as well as ring-fenced places for Scottishdomiciled students . If extra revenue was to be raised, this would be one positive way of using it .

CHESS believes that ifstudent opinion was ignored and fees were imposed, the Executive should rule out further fee increases in other areas, should set the fee level at a minimal level with consideration of the bursary as well as fee levels in England, and should reinvest revenue into bursaries and places for Scottish-domiciled access students.

Whilst we welcome the Executive's expressed commitment to oppose top-up fees in Scotland, as well the claim that section 8 is to be used for medical fees only, the question must be asked why such legislative powers are necessary if there is no intention to use them . Even If the Executive has no intention of using such powers, they remain open to future governments to do so without proper scrutiny and should be removed.

Summary

Although CHESS is sympathetic to the needs of ensuring places for Scottishdomiciled medical students and to the need to improve recruitment for Scotland's health service, it does not believe that introducing a variable tuition fee for non-Scottish-domiciled medical students is an appropriate mechanism to achieve these ends. Increasing tuition fees should not be a mechanism by which government can further economic, political or social goals and other options must be explored and a more holistic approach taken. CHESS believes other measures must be considered and maintains its stance against fees and against variability .

CHESS is grateful of the chance to respond to this proposal but is disappointed that there has been little investigation into alternatives and would like to see a broader and more informed consultation that sought more imaginative responses to the Executive's twin aims of protecting places for Scottish-domiciled students and improving NHS recruitment and retention . The introduction of a differential fee into Scotland is too important an act to be taken as the `easy option' in pursuing these aims and all other measures from improving working conditions and incentive packages, to ring-fencing places and tailoring University recruitment and admissions procedures should be considered as factors more appropriate to influence .

CHESS has provided suggestions for the Executive in case they are to pursue the proposal discussed, including safeguards for the future and suggested use of revenue. Ultimately, however, CHESS believes Scotland must remain free of differential fees and opposes any move to threaten that. The development of a segmented and differentiated market for students in Scotland may not be the intention of this proposal but will undoubtedly be the unwelcome result, if not now then most probably in the future. CHESS does not believe that medicine will universally be accepted as a `special case' but instead believes claims from other areas would quickly be forthcoming .

In conclusion although CHESS is sympathetic to the needs of protecting places for Scottish-domiciled medical students and to the need to improve recruitment for Scotland's health service, it does not believe that introducing a variable tuition fee for non-Scottish-domiciled medical students is an appropriate mechanism to achieve these ends. CHESS believes other measures must be considered and maintains its stance against fees and against variability. Therefore we would urge the Scottish Executive to seriously reconsider the content of this Order, the rationale behind it and the impact that it will have on students for years to come.

Annex G

Respondent Information Form: Cons ultation On The Dra ft Stud ent Fees (Specification) (Scotland) Order 2005

Please complete the details below and return it with your response . This will help ensure we handle your response appropriately. Thank you for your help .

Name: Coalition of Higher Educartion Students in Scotland

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DD1 4HP

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