Scottish Government

Consultation on the draft Student Fees (Specification) (Scotland) Order 2005

I am responding to the above consultation issued on 17 November 2005. This represents the views of the executive of the Scottish Funding Councils.

The Scottish Funding Council has participated in the Implementation Advisory Group (IAG) set up by the Scottish Executive to advise on this issue and, therefore, we have contributed at a detailed level to the discussions of that group which have informed the draft order. We have also responded to a previous consultation on this subject published on 4 April 2005 and our comments in that response still stand.

As we stated in our response to the previous consultation, we agree with the general principle of maintaining broadly the current levels of cross border flows and note the particularly acute pressure on cross-border flows in medicine. In this context we agree that setting the Scottish full-time degree fee at £1,700 and the full-time medical fee at £2,700 for academic year 2006-07 is appropriate in aiming to maintain stability in cross-border flows.

We agree that fees for sub degree level provision (eg HNC/HND) should stay at the lower level. There is little cross-border pressure on HNC/HND.

Although the basic concept of the changes is simple, there is significant complexity in the detail. We have stressed through IAG the importance of ensuring that clear information on the detail of the fee changes and who will be affected is publicly available and can be easily accessed by both students and institutions. The way the draft order is set out, for any courses not specified the fee remains at the lower level of £1,200. It is therefore essential that the categories of provision specified in the order are unambiguous, but broadly enough drawn to avoid any need for regular updating. It will be particularly important to bear this in mind if the categories of provision are to be added to following consideration of responses to this consultation.

In several parts of the draft order it states that full-time higher education fees are set by a letter from the Scottish Higher Education Funding Council and Scottish Further Education Funding Council. It would be helpful if the order set out in full the current arrangements which are that the Funding Council enforces, through a condition of grant, a fee level which is set by the Scottish Executive.

We note that the timescale for implementing these changes is tight and that the Scottish Parliament's decision on these proposed fee changes will come after we publish our 2006-07 main grant letter for HEIs. We urge the Scottish Executive to ensure that, in subsequent years, decisions on fee levels are taken in good time to feed appropriately into the annual funding round.

It is important that we make it clear that these changes apply to full-time fees only and do not affect part-time fees as they are not regulated. It may be useful to have a statement such as this upfront in the explanatory note of the order.

I hope these comments are useful.

Roger McClure

Chief Executive