STUDENT AWARDS AGENCY FOR SCOTLAND (SAAS) RESPONSE TO THE DRAFT STUDENT FEES (SPECIFICATION) (SCOTLAND) ORDER 2005
1. OPERATIONAL IMPACT
If the new tuition fees were simply to apply to all students, the effects on our operations would be greatly reduced. However, by applying the new fees only to new students, amending the definition of who counts as a new student and introducing protection for self funding students, we are faced with a major IT development which will incur a substantial cost in terms of writing new software and higher, ongoing support costs due to the addition of a new layer of complexity to the system and the additional risk that poses.
To ensure our core business service delivery is not significantly impacted following the proposed changes to the fee rates, we need to develop what is effectively a new and separate stream of students This will accommodate the change to higher fee rates for students we already support , but will also be used to allow self funding students a route to fee support that has not been available before.
. If, as intended, this change is introduced for 2006/07, it will only be possible to identify new students i.e. those new to HE or gap year students. It will not be possible readily to identify those students who do not meet the criterion specified in Citation, commencement and interpretation 1 (2) (b) "existing student"…..and is continuing to study that course". Our understanding of this is that students who change course or institution in 2006 will come under the criteria specified in Citation, commencement and interpretation 1 (2) (e) a "new student". We have been in discussion with the Scottish Funding Council (SFC) to agree a route to deliver this, but it will require significant analysis of existing data to try to ensure the funding model is as accurate as possible.
This is a significant shift in a fundamental principle of student support policy, where a student retains the same eligibility criteria for the duration of a programme of study. It is not clear why there is a need for this change, but as highlighted above, it will have a significant impact on SAAS if it is to be carried forward for future years.
We will have to carry out a manual exercise to input the new fee rates and variables for all courses for the 2006/2007 session. This is a labour intensive task that we must achieve within a very tight timeframe
2. COST OF CHANGE
Our suppliers are reluctant to give any indication of cost until we can fully specify our requirement. However, from our experience of policy change over the years, and how it impacts our system, we can categorise this work as a major change. The costs will also be higher than we would normally expect because of the very short implementation window and the associated risks that go with such projects. If the change could be deferred for a year, we could achieve economies of scale by incorporating fees with other changes already in our development programme for 2007/08.
3. INFORMATION AND GUIDANCE COMPLEXITY
The complexity of the new legislation and the variables it contains makes it difficult for SAAS to present information and guidance in a clear and simple format for the start of the 2006/2007 session. It will inevitably result in increased calls and correspondence from interested parties seeking clarification on how the changes will impact on them and further complaints from those who already claim that our forms and guidance are difficult to understand and/or have concerns about student debt.
The 'Guide to Undergraduate Support' is a document that defines the broad policy contained in the Student Allowances (Scotland) Regulations 1999 (as amended). The guide defines the main student categories and gives details of the support packages available to each. We would not propose to add the proposed new fee structure to the guide. Instead, we would develop a summary leaflet for self funders (distribution method to be confirmed), which would highlight the additional support to be made available. This would also avoid the need to change our existing application form for a small cohort of students.
There is no need to change our application form to identify students liable for the higher rate of tuition fees, but we will need to add extra detail to our guidance notes, for completing the application, to ensure those students who will be treated under the 'gap year rule' can readily identify themselves and provide appropriate documentary evidence to support this.
The eligibility criteria for 'gap year status' means that a student must have deferred their entry to 2006/07 by 1st August 2005. There does not seem to have been any advance guidance put out by the SE on the need to meet this criterion before 1st August. This has the potential to create confusion amongst new applicants and lead to an increase in telephone calls and correspondence for SAAS.
As stated in section 1 of our response, the change to a fundamental principle of student support, "continuous programme of study", will be difficult to articulate both in our written literature and in dealings with the public whether by telephone or in person. This is because we are not clear about the justification for the change. It is appreciated that Scottish and EU students who will be liable for the new higher fee, due to a change in course/institution, will not themselves be required to make a payment for fees, but they will still need to be identifiable in our system so that the correct payments are made to the institutions concerned and so that we can inform the students of what is being paid on their behalf. This will require a change to the ways in which both SAAS and SFC collect Management Information. .
4. TIMING OF CHANGE
The timing of change does not sit well with the processing season for 2006/07 applicants. Students are required to make an annual application for student support. SAAS begin contacting certain groups of students in mid-March each year and issue the main application form around Easter. This means that the processing season actually starts in March with approximately over 1/3 of applications being received/processed by the end of June.
If the Student Fees Order is not implemented until June 2006 we have three options;
Option 1 - delay processing any 'new' students until June (this would have a high adverse impact on our operation)
Option 2 - process 'new' students for student support but not tuition fees (giving rise to additional work later in the year)
Option 3 - process 'new' students fully, including tuition fees (these would need re-assessed if the Fee Order is not implemented as it stands)
As this change impacts all 'new' applicants in 2006/07, we are talking about approximately 40,000 students. We can be confident that any significant delay in processing their applications will attract severe media criticism. We also know from past experience, that such a delay could have catastrophic knock on effects for processing applications from continuing students. . This means that option 1 cannot be considered. Option 2 would mean 'double handling' of student applications, leading to significantly increased mail being sent out to students who had already applied, which, in turn, will lead to increased correspondence and calls. That leaves option 3, which although not very palatable, is the only viable option to avoid unwanted media attention for SAAS in the short term.